Feedback on the Evaluation of the Transfers Directive (Directive 2009/43/EC) and Possible Synergies with the European Trade Indexes Registry (EUTIR)

This document, prepared by DigitalTrade4.EU in September 2025, provides feedback to the European Commission on its evaluation of the Transfers Directive (2009/43/EC). It argues that the evaluation must consider the drastically changed geopolitical and technological landscape since 2009, including the war in Ukraine and the push for digital trade infrastructures. The core proposal is to explore synergies between reforming the defence transfers framework and the European Trade Indexes Registry (EUTIR), a proposed cross-sectoral, digital trust infrastructure designed to ensure harmonisation, efficiency, security, and legal certainty through features like machine-readability and cryptographic audit trails.