Lobbying by Federation of Small Businesses

Federation of Small Businesses

FSB

The FSB represents the interests of small businesses in all sectors in the whole of the UK.

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ID: 64802948320-88

Lobbying Activity

Meeting with Luiza Bara (Head of Unit Secretariat-General) and Confederation of British Industry and

2 Dec 2025 · EU-UK Withdrawal Agreement – Regular engagement of the co-chairs of the Specialised Committee on the implementation of the Windsor Framework with Northern Ireland business stakeholders

Meeting with Luiza Bara (Head of Unit Secretariat-General)

5 Nov 2025 · EU-UK Withdrawal Agreement – Implementation of the Windsor Framework and engagement with stakeholders in Northern Ireland

Meeting with Luiza Bara (Head of Unit Secretariat-General) and Confederation of British Industry and

5 Jun 2025 · EU-UK Withdrawal Agreement – Regular engagement of the co-chairs of the Specialised Committee on the implementation of the Windsor Framework. with Northern Ireland business stakeholders

Meeting with Luiza Bara (Head of Unit Secretariat-General) and Confederation of British Industry and

5 Mar 2025 · EU-UK Withdrawal Agreement – Regular engagement of the co-chairs of the Specialised Committee on the implementation of the Windsor Framework. with Northern Ireland business stakeholders

Response to Revision of the Union Customs Code

7 Nov 2023

The Federation of Small Businesses (FSB) is a non-profit making, grassroots and non-party political business organisation that represents members in every community across the UK. Set up in 1974, we are the authoritative voice on policy issues affecting the UKs 5.5 million small businesses, micro businesses and the self-employed. We welcome the opportunity to provide feedback to the European Commission proposal on the revision of the Union Customs Code, limiting our comments to the proposed removal of the 150 de minimis threshold. FSB acknowledges the importance of tackling the issue of undervaluation for customs purposes; however we have serious concerns that removing the de minimis threshold may have a significant impact on small firms' ability to trade internationally, and their viability in the EU market. FSB data shows that small businesses often deal with low value consignments: 16 per cent of businesses say that the goods they import or export on average fall below the current UK customs threshold of £135 (https://www.fsb.org.uk/resource-report/customs-clearance.html). The payment of customs duties on low value goods already has a significant impact on the margins of the smallest businesses; scrapping the threshold would increase the financial burdens of trade for those businesses least able to absorb new costs. Indeed FSB has long called for a global increase of the customs de minimis threshold to £1,000 or equivalent. This would not only bring huge savings to many businesses, but incentivise more to begin exporting or importing by reducing the complexity of international trade. Removing the EU threshold, by contrast, may disincentivise small businesses from entering the EU market - ultimately impacting end consumers. Furthermore, it should be considered whether this could lead to non-EU markets introducing similar measures in response, affecting EU exports. FSB would encourage the Commission to explore further the potential impacts of removing the de minimis threshold on small businesses and the wider economy.

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Meeting with Gwendoline Delbos-Corfield (Member of the European Parliament) and KPMG and Logistics UK

13 Apr 2023 · EU-UK relations & Northern Ireland

Response to Sustainable Products Initiative

22 Jun 2022

FSB supports the objective of the proposed Regulation to foster greater product sustainability and circularity, and agrees that a Regulation is the most effective means of ensuring greater harmonisation and levelling the playing field for businesses operating within the Single Market. We are however concerned that the proposed Regulation will significantly increase burdens on Small and Medium Size Enterprises (SMEs). Many small businesses are already actively working towards greater sustainability, but due to their relative lack of financial and human resources, may need more time or support on their journeys to greater sustainability than their larger peers. Although Article 19 acknowledges the need for further measures, including guidance and financial support, to help small businesses integrate sustainability into their value chains and comply with the new requirements, it is unavoidable that the provisions set out in the proposed Regulation will create significant costs for small businesses that cannot easily be absorbed. Given the nature and scope of the Regulation, the bulk of the requirements that will apply to particular sectors or product categories will be regulated by delegated acts, meaning that many of the requirements will be developed outside the standard legislative process. It is even more important than ever therefore that the voice of SMEs is included in all relevant fora or expert groups the Commission intends to consult when designing the delegated acts to be adopted under the Regulation. It is also essential that an SME test is applied to all delegated acts on product or sector categories falling into the scope of the Regulation. It would be helpful if the Regulation would include indicative dates of when delegated acts for particular sectors or product categories may be expected - this would create greater certainty and predictability for small businesses that may have to adapt their processes or supply chains. Similarly, small businesses must be consulted in the design of the new Digital Product Passport. While there are potential benefits to a digital product passport, the EU should be mindful of the challenges that overly burdensome requirements could create for the smallest businesses. For instance, the cost of establishing a digital product placement is likely to represent a significant outlay for a small business and many SMEs may not have the technological capabilities to administer or support a digital product passport. Finally, we would also urge the Commission to ensure that this proposed Regulation aligns and is compatible with other proposed or forthcoming legislation in this area, such as the expected proposal on the right to repair. The proposed Regulation should improve integration and coordination between all the elements contributing to sustainability in the market, and should avoid the duplication of disproportionately burdensome requirements.

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Response to Sustainable corporate governance

23 May 2022

FSB supports the European Commission’s objectives of achieving economic, social and environmental sustainability in corporate governance. However small businesses, many of which do not have shareholders or boards of directors, must not be overburdened with regulatory requirements. Placing disproportionate or costly administrative burdens on SMEs could disincentivise or exclude European businesses from participating in cross-border trade, and consequently FSB supports the exclusion of SMEs from the scope of the proposal. Due diligence requirements should remain risk-based, proportionate and context specific and should be limited to a company's own operations and its immediate suppliers. Although many small businesses are taking active steps towards greater sustainability, they often lack the resources or capacity necessary to fulfil complex technical or reporting requirements. SMEs cannot easily absorb the costs of such requirements in comparison to larger companies with greater resources. SMEs have less capacity, knowledge, information, and resources to build diversified supply chains and to effectively implement the proposed obligations in their operations. Reporting obligations imposed on larger entities should not therefore trickle down to SMEs. Furthermore SMEs need support to identify and mitigate the risk of their supply chains and reduce adverse human rights and environmental impacts. The Commission could consider introducing a toolbox for companies to translate due diligence criteria into business practices. Finally, FSB reminds that the EU is currently working on several parallel initiatives related to due diligence and sustainability in business practices. It stresses the importance of ensuring coherence between these initiatives as well as with existing initiatives at global level such as OECD work in this field.

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Response to VAT in the Digital Age

3 May 2022

FSB supports the Commission’s objective of ensuring the EU’s tax framework is fit for purpose in the digital age. Our comments relate particularly to the issue of VAT registration in the EU. Under the terms of the new UK-EU trading relationship overcoming issues relating to VAT – and in particular requirements to register for VAT purposes in multiple EU Member States - are one of the biggest challenges facing UK small business exporters. FSB supported the establishment of the Import One-Stop Shop (IOSS) in 2021 as a means of streamlining VAT declarations and payments for goods from non-EU businesses to customers based in the EU. In principle, the introduction of the IOSS is a positive step that has the potential to have a significant impact on the administrative and financial costs of trade for small businesses. In particular FSB welcomed the possibility of an exemption from the requirement to appoint an intermediary for third countries that have concluded a mutual assistance agreement that is similar in scope to the Recovery Directive (2010/24/EU) and VAT Administrative Cooperative Regulation (904/2010). However, as the UK is not considered as falling within this category, UK businesses that register to use the IOSS are required to appoint an intermediary, the cost of which will be prohibitively expensive for many smaller firms. FSB members are diligent businesses keen to meet their legal and fiscal obligations but are effectively unable to access the IOSS as it currently operates. While we acknowledge that the resolution of this issue is not within the scope of this call for evidence, FSB is nonetheless concerned that extending the application or making use of the IOSS mandatory without first resolving the issues that make it difficult for third country SMEs to make best use of it will ultimately prevent the IOSS from achieving its objectives.

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Response to Promoting sustainability in consumer after-sales

4 Apr 2022

FSB supports the objective of tackling the unsustainable consumption of goods and promoting greater repair and reuse. Small businesses are keenly aware of the need to act on climate change and are eager to contribute. Many are taking active steps towards greater sustainability, whether within their own business practices or in terms of the products and services they provide. Small businesses are often also important actors in the repair market, and as such already play an important role in promoting the longevity of products. FSB would support initiatives that will play a role in encouraging changes in consumer behaviour and attitudes towards product longevity. However, many smaller firms are resource-poor in terms of time, expertise and finance – FSB research shows that while over half (56 per cent) of UK small firms believe there is a climate crisis only a third (36 per cent) have a plan to combat climate change. We would therefore urge the Commission to apply a ‘think small first’ approach to any new proposals to ensure that they take into account the responsibilities of all players along the value chain and do not result in disproportionate burdens or costs for small businesses. The Commission should carry out as part of its consultation process a dedicated small business impact assessment to thoroughly examine the potential impact of its proposals on SMEs and the support they may need to fulfil any new obligations. FSB would point out that while a ‘right’ to repair is to be welcomed, this should not automatically translate to an obligation on a small business – whether manufacturer or seller – to carry out repairs on defects caused by consumers or outside the legal guarantee period when such repairs would be disproportionately burdensome or expensive. Likewise, small businesses should not be made liable for defects in or damage caused by products that have been remanufactured, refurbished, restored or repaired under the right to repair. Product longevity and reparability must be balanced against liability and safety, and responsibility should be fairly distributed throughout the value chain. Practical considerations must also be taken into account when considering the scope of any new proposal that will impact on small businesses – for instance, increased legal guarantee periods would have a direct impact on stock and space availability, requirements which would be more easily absorbed by larger businesses. FSB would therefore not support the proposed sub-options 2A or 3B which envisage extending the legal guarantee period of goods. Any proposal for a right to repair must be compatible with other legislative proposals, in particular the Sustainable Products Initiative and the evaluation of the Product Liability Directive. Likewise, any new proposal should not impose a blanket right to repair on all consumer product categories. It should focus on well-targeted incentives and the removal of barriers rather than imposing a one-size-fits all obligation. Existing and future voluntary commitments by businesses or sectors should be taken into account. Notwithstanding, in order to minimise fragmentation and increase legal certainty, FSB would welcome EU-level rather than national initiatives. FSB would support option 1 as proposed in the impact assessment as an important means of encouraging changing consumer behaviour. Further, FSB would support making repair the preferred remedy when it is less expensive than replacement as proposed in sub-option 2B; however we would urge caution around imposing an obligation to repair – responsibilities must be fairly distributed along the supply chain and must be balanced against the creation of disproportionate costs for small firms. We would support a sector-by-sector and risk-based approach. Of the high intervention options, FSB would support sub-option 3C, enabling the seller to replace defective products with refurbished goods when such an option is feasible and cost-effective.

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Response to Application of EU health and environmental standards to imported agricultural and agri-food products

15 Mar 2022

The Federation of Small Businesses (FSB) supports the Commission’s objective of exploring ways to increase the sustainability of food systems and to lead global efforts in this area. Well-designed rules have the potential to promote greater sustainability in global food systems, but the design and functioning of any EU proposal raises complex questions and must be based on detailed research and a robust evidence base. The EU legislative framework ensures that food imported into the EU is safe while providing legal certainty for non-EU producers and EU consumers. The possibility of extending EU rules to include production processes, going beyond current rules around safety and sanitary standards, must be carefully considered in order to minimise the risks of disproportionate administrative burdens and costs for businesses. As with other due diligence proposals currently under consideration in the EU, consideration must be given to how, for example, due diligence or reporting requirements will be applied across value chains and particularly their potential impact on small businesses. Small businesses must be given sufficient time and support to phase in any new requirements. Any proposal in this space must be aligned with WTO rules, particularly the WTO Agreement on the Application of Sanitary and Phytosanitary Measures (SPS Agreement). Furthermore, FSB would support an approach from the EU that takes into account the conditions and standards in place in third countries exporting to the EU. The Commission could consider incorporating the principle of equivalence into potential proposals that it makes in this space as a way of reducing disproportionate administrative burdens and costs for small businesses.

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Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

5 May 2021

Please find attached FSB's position paper on the proposed Digital Services Act.

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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

31 Mar 2021

Please find attached FSB's position paper on the proposed Digital Services Act.

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Meeting with Andrea Almeida Cordero (Cabinet of Commissioner Mariya Gabriel)

17 May 2019 · women in enterprise, digital skills, female entrepreneurs

Meeting with Věra Jourová (Commissioner) and