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Safety isn't an add-on – it's the entry ticket

Without safety:

• no green transition

• no trust in innovation

• no secure supply

Why Europe must invest in open, neutral safety infrastructures 

Europe’s next growth wave depends on the safe deployment of green and digital technologies. This is the mission of the new European Strategy on Research and Technology Infrastructures. 

From hydrogen and methanol to batteries and electrification, Europe is embracing transformative technologies, each bringing new risks that must be managed before they can be trusted and scaled. 

Without independent testing, training, and neutral infrastructures, neither citizens, regulators, nor markets can fully embrace the technologies that Europe needs to succeed.  

The challenge: Gaps in safety evidence 

Today, Europe’s test facilities remain too limited in scale. Most laboratories can only run small, controlled experiments that fail to capture the real risks of complex systems: tunnels, ferries, underground parking garages, and refuelling hubs. 

This gap – the lack of large-scale testing facilities – has serious consequences: 

  • For the green transition: Without robust data, deployment of hydrogen, batteries and e-fuels will slow down or stall. Clean technologies can only scale when their risks are understood, tested, and proven safe 
  • For competitiveness: Companies cannot scale-up, certify, insure or export technologies without trusted test results. Neutral, large-scale facilities accelerate certification and standardization, giving European innovators a first-mover advantage. 
  • For trust: Regulators withhold approval, and the market will not adopt new technologies when safety evidence is incomplete. Transparent, full-scale testing facilities provide the needed assurance. 
  • For secure supply: A single failure in a battery depot, port terminal, or hydrogen hub could disrupt energy resilience. Safety failures undermine both public confidence and Europe’s resilience. 


DBI’s suggested way forward 

DBI - The Danish Institute of Fire and Security Technology is an independent, non-profit Research & Technology Organisation with a public mission. DBI operates several testing facilities, although most lack the scale required to demonstrate safety under realistic conditions. 

DBI proposes that the EU co-fund a network of open, large-scale test and training infrastructures under the new Research and Technology Infrastructure strategy—using GBER Art. 26/26a and SGEI frameworks to allow up to 100 % public funding of non-economic activities.  These infrastructures should: 

  • Replicate real-world, full-scale scenarios. 
  • Provide independent evidence for regulators, insurers, and markets. 
  • Train both specialists and non-specialists, including first responders. 
  • Generate standards and operational procedures ahead of market needs and regulations. 


Safety is the entry ticket 

Europe must treat safety as strategic infrastructure. By investing in world-class, open safety facilities, the EU can accelerate its green transition, strengthen competitiveness, and safeguard supply security. DBI stands ready to contribute evidence, facilities, and expertise.  

  • Without safety, the green transition cannot scale. 
  • Without safety, technology will not earn trust. 
  • Without safety, no guarantees of secure supply. 

Safety is not optional. It is the foundation of Europe’s future. 

Download DBI's policy paper "Safety is the entry ticket" 

Download

DBI's response to the European Commission’s Call for Evidence on the General Revision of GBER (Regulation (EU) No 651/2014) 

DBI's response supports the GBER review to simplify compatibility conditions and reduce administrative burdens while preserving competition. DBI proposes eight changes, ordered by DG COMP priorities: 

  1. Safe harbour for clearly non-economic RD&I activities. Instrument: Recital + annexed checklist + Commission guidance.  
  2. Standardised accounting-separation template to avoid cross-subsidy. Instrument: Commission Staff Working Document / guidance note.  
  3. Clear paths for national co-funding of EU projects. Instrument: DG COMP FAQ with model scenarios + optional dedicated GBER category.  
  4. Recital confirming the activity-based concept of “undertaking”. Instrument: Recital aligned with the Notice on the notion of State aid and the RDI Framework.  
  5. Clarify that only economic parts of mixed projects are subject to GBER. Instrument: Recital + guidance encouraging work-package-level structuring and accounting.  
  6. Positive and negative examples distinguishing non-economic from economic RD&I. Instrument: Annex or guidance list incorporated by reference in recitals.  
  7. Enhanced transparency via a curated public e-State aid Wiki and aligned national FAQs. Instrument: Commission-hosted portal with anonymised Q&A; Member State FAQ alignment.  
  8. Recognition of open, non-profit technology infrastructures, including test and demonstration facilities, as primarily non-economic. Instrument: Recital referencing the 2025 EU Strategy on Research and Technology Infrastructures.  

Download REVISION OF THE GENERAL BLOCK EXEMPTION REGULATION (GBER)  - DBI's Response to the European Commission’s Call for Evidence on the General Revision of GBER (Regulation (EU) No 651/2014) 

Download

Contact

Carsten Damgaard R&D Director
Morten K. Thomsen PR Manager
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