Confederazione Italiana della Piccola e Media Industria Privata
CONFAPI
CONFAPI, Confederazione Italiana della Piccola e Media Industria Privata, represents and protects Italian industrial SMEs, promoting their development and internationalisation.
ID: 409218395037-03
Lobbying Activity
Response to Circular Economy Act
6 Nov 2025
Confapi, the Italian Confederation of Small and Medium Private Industry, represents and supports Italys industrial SMEs the backbone of the national productive system. Confapi welcomes the initiative for a Circolar Economy Act (CEA), recognizing circularity as essential for the EUs strategic autonomy and competitiveness. However, the transition must not undermine competitiveness and must place industrial SMEs at its core. The primary objective of the CEA should be to eliminate fragmentation in the single market for waste and secondary raw materials. Confapi stresses the need for a coherent and proportionate regulatory approach, especially for SMEs. Legislative measures should be based on thorough impact assessments, accounting for cumulative effects along the value chain and SME organizational capacity. Obligations arising from Extended Producer Responsibility (EPR) systems and the Digital Product Passport (DPP) must fully respect the Think Small First principle and the EU target to reduce administrative burdens by 35%. Key Priorities for Industrial SMEs: 1) Simplification & Single Market Harmonization Introduce a binding mutual recognition obligation in the Waste Framework Directive (WFD): an End-of-Waste (EoW) or by-product decision issued by one Member State must be automatically recognized by all others, transforming materials into tradable commodities and preventing unjustified border restrictions. 2) Harmonization of Producer Responsibility (EPR) Fully harmonize EPR requirements (registers, fees, reporting) for key product streams such as packaging, WEEE, and batteries. Establish a Single Entry Point, a unified European digital platform where producers register and report once, in line with the once only principle. 3) Financial & Technical Support Ensure substantial investment in high-tech infrastructure for WEEE and Critical Raw Materials (CRM) collection and recycling. Revenues from the WEEE tax should be ring-fenced exclusively for this purpose at both national and EU level. Confapi recommends that the Commission promote: - Binding harmonization of EoW criteria to enable the free movement of secondary raw materials. - Creation of a Single Entry Point for EPR compliance and interoperable national registers with standardized data formats. - EPR fee modulation to reward products with high recycled content. - Development of standardized and free compliance tools for SMEs to reduce reliance on costly consultants. - Simplification is fundamental to the competitiveness of Italian industrial SMEs. It is the precondition for investing in the green transition, adopting innovative technologies, and strengthening the EUs strategic autonomy. The full contribution is atthached to this comment
Read full responseResponse to Carbon price paid in a third country under the carbon border adjustment mechanism (CBAM)
24 Sept 2025
The recognition of the carbon price already paid in third countries can be a useful tool to avoid double taxation, but it requires very strict criteria. It represents a critical and potentially dangerous aspect of the CBAM, which Confapi rejects in its current design. This mechanism is turning into a tool of unfair competition against European companies, particularly Italian ones, which are already heavily burdened by significant energy transition costs. Article 9 of Regulation (EU) 2023/956 assigns the Commission the task of defining uniform rules, and it is essential that these ensure comparability with the EU ETS. Regulation (EU) 2023/956 provides that EU importers may deduct from the number of CBAM certificates to be surrendered the carbon price already paid in a third country, pursuant to Article 9. In principle, this mechanism is useful to avoid double taxation and to acknowledge the efforts genuinely undertaken by other countries. However, Confapi insists that deductions should only be granted to carbon pricing regimes that meet minimum requirements of transparency, monitoring and independent verification. Offsetting credits of dubious quality or unregulated voluntary markets must not be accepted. It is crucial that any recognition of carbon credits be based exclusively on solid and verifiable certifications, in line with EU standards on substances and production processes. For instance, alignment with systems already adopted at EU level such as the ECHA lists of Substances of Very High Concern (SVHC) or the REACH Regulation would ensure greater legal coherence and transparency for operators. Only an explicit link to recognised certifications and ISO/IEC standards, such as ISO/IEC 17065, can guarantee that carbon credits genuinely contribute to sustainability and do not become instruments of environmental or social dumping. It would also be useful to introduce a European list of recognised regimes, subject to periodic review, together with an ex-post audit system to prevent abuse. In line with the spirit of the Commission proposal COM (2025) 87 final under Omnibus I, the deduction of the carbon price must be regulated with clear and uniform rules that simplify procedures for importers while avoiding abuse or unjustified reductions. In light of the evolving ETS and the forthcoming ETS II, Confapi stresses that the recognition of foreign carbon prices must not result in a competitive disadvantage for European companies already facing high energy transition costs. Italian companies along the value chain, in particular, risk being doubly penalised: on the one hand by the increase in indirect costs generated by ETS II in the transport and heating sectors, and on the other hand by the possibility that non-EU goods may benefit from excessive reductions through unjustified deductions. Finally, Confapi calls on the Commission to look beyond CO alone. The overall environmental impact of production also includes hazardous substances and working conditions, as highlighted by the REACH Regulation and the ECHA lists of SVHC. From an integrated sustainability perspective, priority should be given to producers that have adopted international standards for environmental and occupational safety management, such as ISO 14001 and ISO 45001. This would ensure greater policy coherence and protect European supply chains from competition based on environmental and social dumping.
Read full responseResponse to Carbon border adjustment mechanism (CBAM) methodology for the definitive period
24 Sept 2025
Confapi, representing Italian private industrial SMEs, acknowledges the importance of the CBAM in preventing carbon leakage but considers its current design disproportionate and burdensome for Industrial SMEs. The calculation methodology must ensure environmental integrity, legal certainty and proportionality of obligations, avoiding duplication with existing rules under Regulation (EU) 2023/956, the EU ETS Directive and Delegated Regulation (EU) 2019/331. Confapi calls for simplification, in line with Omnibus I, through digital reporting models, standardised templates and technical support. Verified actual data should be prioritised, while default values must remain residual. The recognition of carbon credits should be linked to robust EU-recognised certifications (e.g. REACH, ECHA, ISO), turning CBAM into an incentive for decarbonisation rather than a bureaucratic burden. Attention must also be given to electricity-related and indirect emissions, ensuring credibility without disproportionate costs. Selective application of CBAM risks creating fragmented value chains and incentivising relocation; any extension to downstream products should therefore be preceded by proper impact assessments and supported by anti-circumvention measures. We attach a detailed position paper for further reference.
Read full responseResponse to Adjustment of the obligation to surrender CBAM certificates to take account of ETS free allowances phase-out
24 Sept 2025
The gradual phase-out of free allowances under the EU ETS system, scheduled between 2026 and 2034, represents a crucial transition that coincides with the full entry into force of the CBAM. The implementing act under Article 31 of Regulation (EU) 2023/956 must clearly define how free allocation will be translated into a discount on CBAM certificates, ensuring equal treatment between goods produced in the EU and imported goods. The reference must remain Delegated Regulation (EU) 2019/331, which sets the benchmarks for free allocation. The concern is that without a clear and accessible methodology, much of the industrial SME fabric may face an impracticable mechanism. It is essential that the implementing act guarantee neutrality between EU-produced and imported goods, avoiding unjustified advantages for non-EU operators. The ETS context is rapidly evolving, with the inclusion of maritime transport, new aviation rules and the forthcoming launch of ETS II (expected in 2027), all of which will affect energy and logistics costs. Confapi is concerned that a poorly calibrated CBAM certificate adjustment mechanism could create cumulative effects that further damage the competitiveness of industrial SMEs. It is also essential to provide official calculation tools and harmonised guidelines to ensure legal certainty and transparency. For industrial SMEs, which lack the same administrative resources as large companies, free digital tools, dedicated support services and a single EU-level platform would be highly beneficial. The Commission proposal COM (2025) 87 final, as part of Omnibus I, clearly set the objective of simplifying the CBAM regime: the future implementing act must translate this principle into rules that are understandable and workable also for industrial SMEs, while ensuring consistency with the free allocation system under the ETS. Finally, Confapi draws attention to the risk that an inaccurate calculation of the CBAM discount could penalise European processing industries, favouring imports from third countries with lower costs. The implementing act should therefore be accompanied by structured dialogue with sectoral associations and by an updated impact assessment that also takes into account parallel developments linked to ETS II and their effects on energy and transport costs. Since 1947, Confapi the Italian Confederation of Small and Medium Private Industry represents and promotes Italian small and medium private industries, the backbone of the production system. Today Confapi represents a broad network: more than 116,000 companies, up to 1.2 million employees, 63 local and regional associations, 13 sectoral federations and 2 interest groups. Confapi is a member of the EESC, where it actively participates in the committee tasked with issuing opinions and proposals for the European Commission. Confapi is also a member of European Entrepreneurs CEA-PME, the largest European confederation of voluntarily associated SMEs. Its objective is to represent SMEs interests before EU institutions. Confapi also takes part in EU-funded projects within international partnerships across various sectors, to support innovation, competitiveness and the development of our enterprises.
Read full responseResponse to Evaluation of the Good Laboratory Practice (GLP) Directives
27 Jun 2025
Confapi, Confederazione Italiana della Piccola e Media Industria Privata, accoglie con favore l'iniziativa della Commissione europea di avviare una valutazione approfondita delle Direttive 2004/9/CE e 2004/10/CE in materia di Buone Pratiche di Laboratorio (BPL). Riteniamo fondamentale garantire un quadro normativo armonizzato, efficace e proporzionato, in grado di assicurare la tutela della salute pubblica e dell'ambiente senza introdurre oneri sproporzionati per le piccole e medie imprese. A tal fine, alleghiamo alla presente consultazione la nostra posizione, che riassume le principali osservazioni delle PMI industriali italiane attive nei settori chimico, ambientale e di laboratorio. Il contributo evidenzia in particolare alcune criticità legate all'eccessiva discrezionalità degli Stati membri nel recepimento delle direttive, che rischia di compromettere il principio del mutuo riconoscimento e la competitività delle imprese a livello europeo. Confapi propone, tra le raccomandazioni principali, la trasformazione delle attuali direttive in un Regolamento europeo direttamente applicabile, al fine di superare l'eterogeneità normativa tra Stati membri che, come sottolineato anche nel rapporto The Future of European Competitiveness di Mario Draghi, ostacola il buon funzionamento del mercato unico e la piena operatività transfrontaliera delle imprese europee; l'integrazione di strumenti digitali per facilitare l'interoperabilità e lo scambio di dati; e la necessità di valutazioni d'impatto specificamente orientate alle PMI. Restiamo a disposizione per fornire ulteriori approfondimenti.
Read full responseResponse to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)
13 May 2025
Confapi welcomes the opportunity to contribute to the public consultation on the Commissions draft Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EUDR), and appreciates the efforts made to improve legal clarity and reduce compliance burdens, particularly for SMEs. The proposed amendments represent a step in the right direction by clarifying the scope of the regulation and addressing certain interpretative issues which, in their current form, risk generating disproportionate obligations, especially for small and medium-sized enterprises. Confapi strongly emphasizes the need to ensure that the EUDR is implemented in a way that is feasible for SMEs, in line with the differentiated and proportionate approach already adopted in other recent EU sustainability instruments (Omnibus I). In this regard, the simplifications and clarifications introduced in Annex I meet some of Confapis expectations, but should be further reinforced through tools specifically designed to support SMEs. Confapi particularly supports the following clarifications contained in the draft Delegated Regulation: The exclusion of product samples and items intended for testing and analysis, which are not placed on the market, are often destroyed in the process, and are essential for innovation and quality control activities, especially in the agri-food sector; The clarification that only products that are composed of, contain, or have been fed with relevant commodities fall within the scope, through the introduction of the ex prefix in Annex I. This clarification is essential to avoid an overly broad interpretation and to facilitate the work of customs authorities; The exclusion of reusable transport packaging, which serves a logistical rather than commercial function and is widely used in sustainable value chains, particularly in the agri-food sector; The exclusion of accessory or supplementary items, such as manuals, labels, or informational documentation, which have a negligible environmental impact but may create unnecessary administrative complexity. In addition to supporting these elements, Confapi proposes further measures to make EUDR compliance more manageable for SMEs, including: The introduction of a minimum threshold (e.g. EUR 10,000 or 1 tonne/year), below which micro-operators would be exempt from due diligence obligations; The creation of a simplified digital form, with pre-filled fields and integration into the EUDR IT system, specifically tailored to the needs of SMEs; The recognition of collective compliance schemes, such as consortia or cooperatives, that allow SMEs to share documentation and reduce compliance-related costs. In the attached document, Confapi also provides technical comments on specific products, such as bovine hides, used and second-hand goods, and semi-finished products containing relevant commodities, highlighting the technical challenges, economic impacts, and risks of competitive distortions stemming from disproportionate application. Lastly, Confapi stresses the need to clarify certain textual inconsistencies, particularly regarding the treatment of bamboo and rattan, and calls on the Commission to ensure harmonised implementation across the EU through practical guidance for businesses and competent authorities. Future updates to Annex I should be based on a careful risk assessment, technical feasibility, and a transparent dialogue with stakeholders. The full technical contribution is attached to this submission.
Read full responseResponse to Single Market Strategy 2025
31 Jan 2025
Confapi, the Italian Confederation of Small and Medium-Sized Industries, has been representing and supporting SMEs since 1947, advocating for their central role in the Italian and European economy. With 116,000 enterprises and 1.2 million employees, Confapi embodies a strong and structured network that spans across 63 regional and provincial offices and 13 national sectoral unions, covering industries from manufacturing to services, chemicals, energy, and digital technologies. Since its foundation, Confapi has worked to give a clear and unified voice to Italian industrial SMEs, ensuring their interests are well represented at the national and European levels. As member of the National Council for Economy and Labour (CNEL) representing small and medium-sized industries, member of the European Economic and Social Committee (EESC), and as an active member of European Entrepreneurs CEA-PME, Confapi is deeply committed to shaping policies that foster innovation, competitiveness, and sustainable economic growth. Despite the progress made over the decades, persistent barriers continue to fragment the Single Market and hinder further economic integration, posing a significant challenge to European competitiveness on a global scale. In this regard, the Single Market Strategy 2025 represents a crucial opportunity to strengthen the productivity of industrial SMEs, in line with the priorities set by the European Commission for 2024-2029. In our attached document, we outline our views on the Single Market and highlight key challenges that must be addressed to fully unlock its potential. These include: Energy and Raw Materials: High energy costs are a major burden on European SMEs where prices are higher than for global competitors. It is essential to establish a European Energy Union to harmonise energy markets and stabilise prices, ensuring SMEs have access to affordable and sustainable energy. Regulatory Barriers and Administrative Burden: The complexity of EU regulations disproportionately affects SMEs. Confapi strongly supports the reduction of regulatory burdens, the simplification of reporting obligations, and the application of the "Think Small First" principle to ensure SMEs are considered at every stage of the legislative process. Access to Finance and Innovation: European SMEs face increasing difficulties in accessing capital, especially for green and digital transitions. A European Competitiveness Fund is needed to support strategic industrial projects, alongside enhanced financial instruments tailored to SMEs, similar to the former SME Instrument under Horizon 2020. Strategic Autonomy and Industrial Policy: The EU must promote supply chain resilience and reduce dependence on external markets, particularly for critical raw materials. This should be supported by reshoring incentives and targeted partnerships with strategic regions such as Africa. Confapi also endorses the recommendations from the Much More Than a Market report by Enrico Letta and the Draghi Report on Competitiveness, which emphasise the urgent need to strengthen the Single Market as a driver of innovation, green and digital transition, and strategic autonomy. We ask the EU Commission to take decisive action to remove existing obstacles, modernise governance, and ensure a pragmatic and balanced approach to sustainability and competitiveness. The Single Market should become a true enabler for industrial SMEs, fostering a level playing field and securing Europes global industrial leadership.
Read full response