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SGI Europe

SGI Europe

SGI Europe represents employers of public services across Europe as a cross-industry social partner in EU policy dialogue.

Lobbying Activity

Meeting with Cristina Guarda (Member of the European Parliament)

27 Jan 2026 · MFF

SGI Europe calls for modernized public service media funding rules

14 Jan 2026
Topic — The European Commission is evaluating State aid rules for public service broadcasting.
Message — SGI Europe requests a targeted update of the rules to reflect the modern digital landscape. They advocate for eliminating ex-ante evaluations that create administrative burdens and hinder the ability to innovate. The framework should maintain technological neutrality by recognizing digital services in all formats as core to the public service remit.123
Why — The organization would benefit from reduced administrative costs and greater flexibility to compete digitally.45
Impact — Large online platforms could lose their market dominance as public media regains competitive strength.67
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Meeting with Pierre Jouvet (Member of the European Parliament)

26 Nov 2025 · La future révision des marchés publics

Meeting with Christophe Grudler (Member of the European Parliament)

26 Nov 2025 · Politiques européennes

Meeting with Bruno Tobback (Member of the European Parliament)

26 Nov 2025 · Grids Package, planning and the Electrification action plan

Meeting with Nora Mebarek (Member of the European Parliament)

26 Nov 2025 · Politique du logement

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

18 Nov 2025 · Single Market

Meeting with Pierre Schellekens (Director Energy)

3 Nov 2025 · Energy governance, system planning and electrification

Meeting with Karlo Ressler (Member of the European Parliament)

28 Oct 2025 · Multiannual Financial Framework

SGI Europe calls for infrastructure investment to combat EU poverty

24 Oct 2025
Topic — EU strategy to reduce poverty and social exclusion affecting 20% of population.
Message — The organization requests that the Anti-Poverty Strategy prioritize access, affordability and quality of services of general interest. They call for closing investment gaps in infrastructure, promoting social investment over short-term fixes, and embedding structured involvement of social partners in policy design.123
Why — This would secure funding for essential service infrastructure and give their members a formal role in shaping policy.45
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SGI Europe urges digital regulation harmonisation for public service providers

14 Oct 2025
Topic — EU simplification of data, cybersecurity, AI and privacy rules across digital legislation.
Message — The organisation requests harmonised definitions across data laws, a single reporting platform for incidents, longer implementation deadlines of 18-24 months, and practical guidance for smaller public entities. They seek clarity on overlapping requirements and preservation of security exemptions for critical infrastructure data.1234
Why — This would reduce compliance costs and legal uncertainty for municipal utilities and public operators.567
Impact — Simplification could weaken cybersecurity protections if reporting requirements are reduced without maintaining oversight quality.8
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Meeting with Brigitte Fellahi-Brognaux (Head of Unit Employment, Social Affairs and Inclusion)

11 Sept 2025 · Exchange of views on social economy and SGI Europe

SGI Europe demands policy simplification over new social regulations

10 Sept 2025
Topic — The consultation concerns the future implementation of the European Pillar of Social Rights.
Message — The organization calls for prioritizing the implementation of existing social measures before introducing new ones. They emphasize the need to simplify rules and reduce administrative burdens for service providers.12
Why — Streamlined regulations would reduce compliance costs and prevent operational disruptions for public service providers.34
Impact — Proponents of new EU-wide social benchmarks lose influence as focus shifts to national flexibility.56
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Meeting with Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné), Valentina Schaumburger (Cabinet of Executive Vice-President Stéphane Séjourné)

10 Sept 2025 · Public procurement revision and Circular Economy Act

Response to Burden reduction and simplification for competitiveness of small mid-cap enterprises - Omnibus Directive

22 Aug 2025

SGI Europe welcomes the European Commissions initiative to revise key EU legislative acts to reduce administrative burden, improve clarity, and enhance proportionality under the Omnibus IV package. However, we would like to raise a horizontal issue that cuts across several of the targeted regulations: the way in which public and non-profit enterprises are excluded from simplified or proportionate regimes due to the ownership-based eligibility criteria used in both the SME (Commission Recommendation 2003/361/EC) and small mid-cap (Commission Recommendation 2025/3500/EC) definitions. In several legislative files covered by this review (including the General Data Protection Regulation, the Prospectus Regulation, and the Directive on Critical Entities Resilience), thresholds or obligations are tiered according to enterprise size, typically granting lighter regimes to SMEs or small mid-caps. Yet these definitions based on Commission Recommendation 2003/361/EC and related frameworks exclude enterprises with 25% or more public ownership, even when they fully meet staff and turnover thresholds. This automatic exclusion affects a wide range of Local Public Service Enterprises (LPSEs) and non-profit entities delivering services of general interest (SGIs). This exclusion: - Contradicts the spirit of simplification, as these entities often lack economies of scale and administrative capacity. - Undermines the proportionality principle, treating them as large enterprises for compliance purposes, despite their size. - Violates ownership neutrality under Article 345 TFEU, as it imposes regulatory burdens based solely on public participation. - Creates barriers to effective SGI provision, particularly where data protection, reporting obligations, or access to capital markets are concerned. We urge the Commission to consider introducing ownership-neutral criteria when referencing enterprise size thresholds in the revised legislation. This would ensure that publicly owned or non-profit SGI providers can benefit from simplified rules or proportionate obligations, where appropriate. We remain at your disposal to provide examples from our members or to support targeted adjustments in the legislative texts concerned.
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SGI Europe urges ownership neutrality in small business definitions

22 Aug 2025
Topic — The Commission aims to reduce administrative burdens and simplify rules for smaller businesses.
Message — SGI Europe proposes using ownership-neutral criteria for defining enterprise size thresholds. This would stop excluding small public entities from simplified regulatory requirements.12
Why — This change would reduce compliance costs for small public and non-profit enterprises.3
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Response to Gender Equality Strategy 2026-2030

6 Aug 2025

SGI Europe welcomes the opportunity to contribute to the shaping of the EU Gender Equality Strategy 20252030. As a cross-sectoral employer organisation representing public and private providers of services of general interest (SGIs), SGI Europe reaffirms its commitment to gender equality while calling for a strategic focus on implementation, capacity-building, and sector-sensitive approaches. SGI Europe and its members are committed to promoting gender equality both in their role as employers and as service providers. As such, SGI providers play a dual role: they are not only major employers in female-dominated sectors such as health, social care and education, but also enablers of womens labour market participation through the essential services they deliver. SGI Europe has recently published an opinion paper on Gender Equality post 2025. Drawing on examples from our members, the opinion outlines how services of general interest can contribute to gender equality through targeted measures in employment, care provision, and service access. The opinion also stresses the importance of supporting womens full-time work, addressing occupational segregation, and ensuring inclusive workplaces. To achieve meaningful progress, the document calls for a practical approach that links gender equality to economic performance, demographic resilience, and service quality across Europe. It emphasises the need to prioritise the implementation of existing directives over introducing new legislation, alongside stronger support for social dialogue and improved collection and use of gender-disaggregated data. Recognising the intersectional dimensions of gender inequality, SGI Europe stresses the importance of taking a broad and holistic approach. We support a dual approach to promoting gender equality through specific actions alongside gender mainstreaming. At this stage, the focus should be on practical and supportive measures that can effectively translate existing EU commitments into tangible improvements, particularly at local and organisational level.
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Response to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)

29 Jul 2025

Please find attached SGI Europe contribution to the call for evidence.
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Response to Proposal for an amendment to the InvestEU Regulation.

18 Jul 2025

Please find attached our contribution to the call for evidence.
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SGI Europe urges technology neutrality in industrial decarbonization act

8 Jul 2025
Topic — This initiative aims to accelerate industrial decarbonization while protecting European competitiveness and productivity.
Message — SGI Europe demands a technology-neutral approach and simplified funding for municipal companies. They also warn against adding new procurement rules to the legislation.123
Why — Local public providers would access easier funding while avoiding redundant administrative procurement requirements.45
Impact — Low-income households could suffer from higher prices if decarbonization costs are passed to consumers.6
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SGI Europe rejects including waste incineration in EU carbon market

1 Jul 2025
Topic — Review of the EU emissions trading system and market stability reserve rules.
Message — SGI Europe opposes including municipal waste incineration in the EU carbon market. They suggest targeting material producers rather than waste plant operators to reduce emissions.12
Why — Staying out of the system avoids higher operational costs for public service providers.3
Impact — Citizens and the recycling industry would face significantly higher costs for waste disposal.4
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Meeting with Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall)

3 Jun 2025 · Water Resilience Strategy and Circular Economy Act

SGI Europe urges alignment of Taxonomy with renewable energy rules

26 Mar 2025
Topic — A proposal to simplify EU sustainability reporting and reduce administrative burdens for companies.
Message — SGI Europe requests that the Commission reassess unfeasible emission thresholds for energy activities. They propose aligning the EU Taxonomy's bioenergy criteria with the Renewable Energy Directive.12
Why — Alignment would lower compliance costs and protect investments in transitioning energy technologies.3
Impact — Environmental advocates lose if lower thresholds result in slower carbon emission reductions.4
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Meeting with Elisabeth Werner (Deputy Secretary-General Secretariat-General)

20 Mar 2025 · competitiveness

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné), Valentina Schaumburger (Cabinet of Executive Vice-President Stéphane Séjourné)

18 Mar 2025 · Revision of European public procurement rules

Meeting with Aurore Lalucq (Member of the European Parliament) and Fédération des élus des Entreprises Publiques Locales

12 Mar 2025 · Renouveau industriel et relance économique

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

12 Mar 2025 · Competitive and sustainable European economy

Meeting with Valérie Hayer (Member of the European Parliament) and ELECTRICITE DE FRANCE and RTE Réseau de transport d'électricité

12 Mar 2025 · Economie sociale et solidaire et Services d'intérêt général

Meeting with Pierre Jouvet (Member of the European Parliament, Shadow rapporteur)

12 Mar 2025 · marchés publics

Meeting with Roxana Mînzatu (Executive Vice-President) and

20 Feb 2025 · Exchange on priorities in the area of employment and social policy

Meeting with Andrea Wechsler (Member of the European Parliament) and Forward Global and Avanci, LLC

20 Feb 2025 · EU Energy and industry policy

Meeting with Luca De Carli (Head of Unit Climate Action)

11 Feb 2025 · Designing a resilient climate architecture beyond 2030

SGI Europe: Public services are foundation of single market competitiveness

30 Jan 2025
Topic — The EU is developing a strategy to improve single market resilience and global competitiveness.
Message — SGI Europe calls for public services to be considered an essential part of economic strength. They propose removing SME definition references to reduce reporting requirements for local public enterprises. They also suggest introducing recycled content criteria via tradeable quotas.123
Why — Local public enterprises would face lower costs by escaping reporting rules intended for larger corporations.4
Impact — Suppliers of raw materials could lose market share as new quotas mandate recycled alternatives.5
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Meeting with Valdis Dombrovskis (Commissioner) and

16 Jan 2025 · Exchange of views on the engagement of social partners in the European Semester and on future implementation dialogues

Meeting with Benedetta Scuderi (Member of the European Parliament)

4 Oct 2024 · SGI Intergroup

Response to Interim evaluation of the Connecting Europe Facility 2021-2027

24 Sept 2024

SGI Europe is the European representation of employers of services of general interest in the energy, transport, water, waste management, telecommunication, education and health sector and welcomes the public consultation on the mid-term evaluation of the Connecting Europe Facility (CEF) Fund for the Transport, Energy and Digital sector. One of the key public funding schemes has been serving as a vital support instrument for Europes critical infrastructures and will continue to play an important role in addressing to cover the budget of the three named sectors. For SGI Europe, it will be an important priority to keep the CEF tools designated to the different sector as they have different yet important elements that will drive the planned Clean Industrial Plan of the new European Commission ahead. We find it therefore as elementary to keep the CEF budget separate for the three sectors and dedicate the funding to the specific needs of the energy, transport and digital sector. With the aim to create a seamless and more sustainable mobility sector in Europe, SGI Europe deems it as important to ensure that first and foremost the CEF fund for energy should focus on investing heavily in innovative technology with a more technology neutral lenses to ensure that the clean technology approach can take up the goals that will be set in the new Commission Net Zero approach and the Clean Industrial Decarbonisation approach pioneered by the team of Commissioner Wopke Hoekstra. At the same time, the digitalisation sector will have a new dimension of challenges coming ahead and Europe will need for its critical infrastructures a progressive and modern digitalisation programme with a wise use of Artificial intelligence tools. The significant funding gap that SGI Europe sees impedes progress in decarbonising public transportation and hinders efforts to achieve the EUs climate goals. By strengthening the CEF and its alignment with EU climate goals, Europe will be better positioned to accelerate the transition to greener, more efficient critical infrastructure systems. For this reason, SGI Europe would like to point out the following evaluations on the CEF: More recommendations can be read in the attched file. - The CEF program should be maintained in the next programming period 2028-2034. It is and will continue to be essential for the completion of the TEN-T network. The program proved to be key for fostering and accelerating the construction of new lines and cross-border projects. -The centralised management of the CEF has demonstrated its significant leverage effect and should be maintained. - Considering investment requirements, SGI Europe believes that the current CEF budget should be increased fivefold. The upgraded ambitions of the revised TEN-T regulation, the upcoming digitalisation programmes also under the Digital Service Act, the increase in new innovative technologies for the energy sector to lower energy prices will make it necessary to increase the program's budget for the next MFF period. -To meet the revised TEN-T requirements, the next CEFs core priorities should be infrastructure modernisation, ERTMS deployment, the construction of new lines / TEN-T missing links and ensuring climate resilience of the railway system. In addition to the funding requirements for infrastructure, CEF should also support ERTMS on-board equipment of freight and passenger rolling stock, help modernise and develop stations and contribute to the expansion and construction of rolling stock maintenance facilities.
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Meeting with Nicolas Schmit (Commissioner) and

9 Jul 2024 · Social dialogue at European level

Meeting with Aleksandra Baranska (Cabinet of Vice-President Maroš Šefčovič)

26 Apr 2024 · Competitiveness

Meeting with Maroš Šefčovič (Executive Vice-President) and

8 Apr 2024 · Dialogue on Clean Mobility

Meeting with Ditte Juul-Joergensen (Director-General Energy) and EPIA SolarPower Europe and

26 Feb 2024 · Clean Transition Dialogue on EGD Infrastructures

Meeting with Maroš Šefčovič (Executive Vice-President) and

26 Feb 2024 · Clean Transition Dialogue on EGD Infrastructures

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Transport and Environment (European Federation for Transport and Environment) and

23 Feb 2024 · Energy market

Meeting with Maroš Šefčovič (Executive Vice-President) and

5 Feb 2024 · Meeting with social partners on the European Green Deal

Meeting with Nicolas Schmit (Commissioner) and

5 Feb 2024 · European Green Deal

Meeting with Nicolas Schmit (Commissioner) and

29 Jan 2024 · Affordable and social housing

Meeting with Nicolas Schmit (Commissioner) and

9 Jan 2024 · Exchange on the challenges faced by the inclusive (affordable and social) housing

Meeting with Maroš Šefčovič (Executive Vice-President) and

17 Nov 2023 · Involvement of social partners in the green transition

Meeting with Maria Luisa Cabral (Cabinet of President Ursula von der Leyen)

23 Oct 2023 · Tripartite Social Summit preparatory meeting

Meeting with Nicolas Schmit (Commissioner) and

10 Oct 2023 · The policy priorities for the 2024 Commission Work Programme

SGI Europe Urges 80% Emissions Reduction by 2040

23 Jun 2023
Topic — EU consultation on setting a 2040 target for climate neutrality.
Message — SGI Europe recommends a minimum 80% emissions reduction by 2040. They demand technology neutrality and the inclusion of social partners in planning green skills.123
Why — This provides public service providers with investment stability and long-term regulatory visibility.4
Impact — Large polluters would face higher costs through expanded producer responsibility and water regulations.5
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SGI Europe Urges Inclusion of Waste Incineration in EU Taxonomy

3 May 2023
Topic — Defining technical standards for sustainable economic activities under the EU Taxonomy regulation.
Message — SGI Europe requests that waste incineration be recognized as a sustainable activity. They also want postal and courier services included as enabling activities for the circular economy.1234
Why — Including these activities would secure easier access to green financing for public service providers.56
Impact — Environmental advocates lose as recognizing incineration may reduce pressure to improve recycling rates.7
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Meeting with Ursula von der Leyen (President)

27 Mar 2023 · Meeting with President SGI

Meeting with Margrete Auken (Member of the European Parliament, Shadow rapporteur) and IDEXX laboratories

21 Mar 2023 · Recast of the UWWTD

Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion) and BUSINESSEUROPE and

16 Mar 2023 · CMRD6

Response to 2023 Strategic Foresight Report

13 Mar 2023

SGI Europe welcomes the process of preparing the Strategic Foresight Report 2023, particularly the opportunity to contribute to identifying and addressing mega-trends to achieve a balanced and sustainable Europe. Services of general interest (SGIs) are vital to keeping everyday infrastructures and daily supply chains functioning, ensuring the preservation of the EU model relying on its social, economic, green, digital and geopolitical standing. The ongoing work on developing a systemic EU foresight approach, as well as its strategic implementation, will play a significant role in identifying these mega-trends and connecting EU policies to anticipate future developments. With this contribution, SGI Europe intends to contribute to the long-term development of the EU, and the need to ensure its growth on the social, economic and ecological dimensions. 1. Achieving a social, economic and environmental sustainability transition The COVID-19 pandemic, as well as the spillover effects of the Russian war against Ukraine, also reignited the debate on the kind of economic growth we pursue, what actually matters for human well-being in a world of limited resources. The gas price crisis highlighted some emerging challenges linked with the transition and the need for a genuinely inclusive and fair digital and green transformation. To that aim, beyond decisive policy choices to ensure the long-term prosperity of EU citizens and enterprises, it will be crucial to develop new, more accurate metrics to measure prosperity and well-being beyond GDP growth. To support that reflection, SGI Europe, together with the other EU social partners developed a list of indicators for Supplementing GDP as welfare measure: proposed joint list by the European Social Partners. (more: https://bit.ly/42ag9r2) 2. The contribution of Services of General Interest (SGIs) Through their activities in sectors such as central & local administrations, healthcare, social services, education, housing, waste management, energy, transport, water or communications, SGIs have a stabilizing function for the European labour and internal markets during the crises. SGIs are vital for the EU social market economy, the well-being of citizens and the competitiveness of enterprises. By ensuring to keep everyday infrastructures and daily supply chains function, they are indispensable to supporting economic, social and green development while preserving the comfort and quality of life and the resilience of the EU. In order to ensure a harmonious growth and future for EU citizens and enterprises, SGI Europe calls for integrating and renewing our common understanding of services of general interest and reflect on the need for better assessing the provision of those services to all EU citizens. (more: https://bit.ly/42aCggM) 3. Foresight as a key instrument for EU long-term planning Since the creation of a portfolio dedicated to Strategic Foresight within the European Commission, SGI Europe has been committed to further raising foresight awareness amongst our members and network. Developing a long-term vision for the EU, including a prominent place for SGIs, should be at the heart of the decision-making process. To that aim, we call for better embedding the conclusions of the Foresight Report (and its Strategic component) into the long-term agenda of the European Commission, with other tools such as the EU Multiannual Financial Framework, the Better Regulation agenda (and the Fit-for-Future platform) and the Commission Work Programmes. (more: http://bit.ly/3Fl9Y9T)
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Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur)

1 Mar 2023 · Urban wastewater treatment

Meeting with Nicolas Schmit (Commissioner) and

19 Dec 2022 · The European Partnership for Integration to support the labour market integration of third-country nationals and people fleeing Russia's war of aggression against Ukraine.

Meeting with Nicolas Schmit (Commissioner) and

9 Dec 2022 · Social Dialogue initiative.

Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur)

16 Nov 2022 · pesticide reduction, water pollution and provision of clean drinking water, sensitive areas

Meeting with Nicolas Schmit (Commissioner) and

8 Nov 2022 · Social Dialogue Initiative.

Meeting with Nicolas Schmit (Commissioner) and

8 Jul 2022 · European Care Strategy.

Meeting with Valdis Dombrovskis (Executive Vice-President) and

28 Jun 2022 · EU Social Partners Conference "Strengthening Europe through Social Dialogue" -European Social Dialogue Work Programme 2022-2024

Meeting with Nicolas Schmit (Commissioner) and

24 Jun 2022 · The promotion of social dialogue and collective bargaining in EU.

Meeting with Ismail Ertug (Member of the European Parliament, Rapporteur)

15 Jun 2022 · How to decarbonise urban and peri-urban mobility?

Response to Revision of the Intelligent Transport Systems Directive

18 Mar 2022

SGI Europe strongly supports the Commission’s aim at building a strong legal framework regulating data by imposing high ethical and regulatory standards. Furthermore, SGI Europe generally welcomes the Commission’s aim to make transport more sustainable and its efforts to deliver effective and seamless multimodality. We understand that data-driven innovation will play a crucial role in achieving these goals. Nevertheless, we call for careful assessment of the already existing legislation and its enforcement before introducing additional rules. SGI Europe would like to point out that the Open Data Directive already imposes strict sharing obligations on the public bodies. Therefore, the upcoming legislation should, in particular, prevent further imbalances in market power and ensure fair competition. The coherent data framework is highly desirable, showing clear delienation of the scope of last Commission’s initiatives such as the Data Act and other more sector tailored rules. Also, the Intelligent Transport System Directive (ITS) is introducing new provisions on data availability enshrined in Article 6a and Article 7 paragraph 1a). Whilst SGI Europe generally welcomes Commissions’ aims to create a data economy, benefitting consumers and enterprises with less market power, we are concerned about the clearness of the envisaged obligations. Namely, we are worried about the legal certainty of these provisions since Article 6a refers to the type of data listed in Annex III. In particular unclear to us are which data will have to be created and at which cost. Furthermore, Article 7 para 1a) empowers the Commission to adopt delegated acts in accordance with Article 12 to amend the list of data types in Annex III, including the date of implementation and the geographical coverage for each data type. Our primary concern lies in the uncertainty that such undetermined provision could bring. Whilst we understand that in a fast-developing world, quick responses are crucial, this should not open the door for not involving relevant stakeholders in the legislative process. We believe that reasonable solutions that benefit society at large should be found in dialogue.
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Response to 2022 Strategic Foresight Report

17 Mar 2022

SGI Europe Feedback on the 2022 Strategic Foresight Report The focus of the 2022 Strategic Foresight Report (SFR) on understanding the twinning between the green and digital transitions is a timely opportunity to provide Member States and stakeholders with a forward-looking guide on concrete and evidence-based policy options aimed at achieving the EU green and digital objectives. Committed to this relatively new tool, SGI Europe welcomes the direction taken by the European Commission and hereby provides its input and feedback to make the SFR an influential and accessible policymaking tool. The ongoing war of aggression from the Russian Federation in Ukraine clearly demonstrates the strategic importance of rapidly embedding foresight in the EU policymaking cycle and toolbox. Despite an unprecedented reaction from the EU and its Member States, the excessive dependency of our energy supply on Russian gas and oil is severely limiting our policy options and political leverage in the context of a conflict with dire consequences in our neighborhood. With the emergence of a new geopolitical and economic order, the SFR should have a greater prominence in shaping policy choices which aimed ultimately at reducing our common liabilities and anticipate external risks. In other words, the SFR should become one of the main compass whereby strengthening our strategic autonomy and resilience. In our view, the SFR should have among its key objectives the prevention of similar future scenarios in which disjointed, uncoordinated and shortsighted policy choices hinder the collective capacity of the EU to act and operate effectively and autonomously. Together with the consequences of the pandemic, the long-term consequences of the war in Ukraine should not be overlooked and dismissed as temporary. In particular, among the key downside risks, the war is likely to accelerate upwards the pressure of energy and food prices, further aggravate supply chains bottlenecks and disruptions and also increase poverty rates among disadvantaged households. Against this background, the objective of the 2022 SFR should be that of providing concrete pathways on twinning the green and digital transitions whereby EU and Member States can inform their long-term policy choices. Furthermore, another objective of the SFR should be to support policymakers and stakeholders to maximise the potentials of the tool by gathering and therefore relying on better and more comprehensive data on twinning the two transitions. In the complete document attached you can find the five dimensions we mapped where SGIs have a key role to play: 1 - Key role of SGIs in twinning the transitions; 2 - Twinning the transitions as a strategic geopolitical objective; 3 - New emerging threats require new focus and orientation; 4 - Role of SGIs in the digital dimension; 5 - Role of SGIs in the green and sustainable dimension.
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Meeting with Nicolas Schmit (Commissioner) and

17 Mar 2022 · Skills and Talent Package, help for Ukrainian refugees.

Meeting with Ana Carla Pereira (Cabinet of Commissioner Nicolas Schmit), Fabien Dell (Cabinet of Commissioner Nicolas Schmit)

9 Mar 2022 · Social Taxonomy

Meeting with Valdis Dombrovskis (Executive Vice-President) and BUSINESSEUROPE and

10 Feb 2022 · Videoconference with social partners on RRF implementation and the economic governance review

Meeting with Nicolas Schmit (Commissioner) and

19 Nov 2021 · The social dialogue initiative

Response to Social and labour aspects of the climate transition

10 Nov 2021

SGI Europe fully endorses the ambition of the European Commission to make the European Green Deal the "new growth strategy" and its ultimate aim to turn the EU into a fair society with a modern, resource-efficient and competitive economy decoupled from resource use. Services of general interest (SGIs) will play a central role in bringing to life this intention and need the right framework to ensure that the transition is just for the workers they employ and the citizens they serve. • SGI Europe welcomes the upcoming proposal for a Council recommendation to proactively tackle all dimensions of a fair and just green transition whilst supporting the implementation of the European Pillar of Social Rights. It is crucial for the proposal to: o include a dedicated approach putting access to SGIs and essential services (as defined in the EPSR) at the heart of the transition; o address a broad scope of essential services, covering all the services of Principle 20, supported by an operational definition of accessibility, affordability, availability; o contribute to more effective and sustainable support mechanisms to guarantee access to all essential services, to mitigate the adverse impact of the green transition, including through European funds and the sharing of best practices and mutual learning activities; o recommend monitoring and evaluating whether the reforms and investments undertaken in the National Recovery and Resilience Plans improve access to essential services. • In the context of the upcoming proposal for a Council recommendation, SGI Europe calls on Member States to: o involve social partners in creating just transition strategies dealing with socio-economic challenges, optimise employment and competitiveness opportunities for workers and enterprises, and contribute to inclusive and fair transitions. o increase awareness and understanding of the employment opportunities and challenges of the green transition, facilitate knowledge and experience exchange across institutions and sectors, and promote the principles and values of sustainability across sectors and at all levels; o increase the attractiveness of specific occupations in essential sectors of the green transition through raising the image and visibility of VET education and through communication campaigns about occupational opportunities and career prospects in essential services; o improve skills and employment intelligence, especially at local and regional levels, through better cooperation between public authorities, employers, education and training providers, and public employment services; o continue efforts of making VET become the first choice by raising its profile and visibility in other policy areas and integrating VET in the EU agendas on regional development, innovation and industry; o intensify technical assistance offered to the Member States to address the lack of awareness and understanding opportunities on EU funding; o improve the training offer to inactive, unemployed, and NEETs, and provide quality and inclusive guidance and counselling services; o involve social partners in modernising education and training curricula, reforming skills and employment strategies, and strengthening job creation within the greening transition.
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Response to Revision of the Broadband Guidelines

16 Sept 2021

SGI Europe, as an employers’ organisation and a recognised European social partner, welcomes the initiative to revise the current Broadband Guidelines. Please find attached SGI Europe’s feedback on the Roadmap on the Revision of the Broadband Guidelines.
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Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion) and BUSINESSEUROPE and SMEunited aisbl

25 Jun 2021 · right to disconnect Business Europe

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

24 Jun 2021 · Fit for 55 package

Meeting with Mattia De' Grassi (Cabinet of Vice-President Dubravka Šuica)

16 Jun 2021 · Discussion on the Conference on the Future of Europe.

Meeting with Nicolas Schmit (Commissioner) and

1 Jun 2021 · Exchanges on the Fit for 55 package.

Meeting with Frans Timmermans (Executive Vice-President) and BUSINESSEUROPE and

1 Jun 2021 · Fit for 55 Package

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

1 Apr 2021

SGI Europe welcomes overall the Digital Markets Act (DMA) of the European Commission and the opportunity to reflect again on the proposal for a regulation in the public feedback consultation. The DMA is an important starting point to ensure fair competition in the digital world and increase consumer choice. The set-up of a swift and flexible intervention mechanism is essential to tackle structural competition concerns raised by large digital platforms acting as gatekeepers which are not fully addressed under current competition law framework. An ambitious DMA has the potential to lead the way, globally, in defining better market dynamics in the field of core platform services as defined in the proposal, including cloud, operating systems, app stores, search and many other crucial tools. Please find below the SGI Europe’s position on the DMA and our further recommendations to reach for a true and fair European Digital Age.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

31 Mar 2021

SGI Europe welcomes the Digital Services Act (DSA) by the European Commission and the opportunity to reflect on the proposal for a regulation again in the public feedback consultation. Service providers of general interest serve to the public good and protect European fundamental rights. We are taking Europe forward in serving and acting in the general interest and in being key players in the digital environment. At SGI Europe, we are optimistic that Europe can set and lead the global standard for a more competitive, non-discriminatory, responsible, and fairer online environment with the DSA. The EU has a unique opportunity to show digital leadership, highlighting the positive aspects of a modern digital single market that makes societies more inclusive, benefits European citizens and companies of all sizes and establishes a level playing field. At the same time, this will also be the time to address challenges that might hamper the development of a functional and fair competitive digital market. Global online players benefit significantly from the public infrastructures operated and provided by service providers of general interest across Europe, as well as from the content they provide. Their behavior and the regulatory framework on digital players have an impact on SGI Europe members. For this reason, SGI Europe will outline its position on the DSA and present further recommendations to reach for a true and fair European Digital Age. The document can be found below.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

SGI Europe welcomed in general the European Commission’s initiative for “A Renovation Wave for Europe”. Buildings in Europe consume around 40% of energy, therefore, to achieve the ambitious climate neutrality target and to successfully decarbonise the economy, as set in the EU Green Deal, the building and housing sector has to play a greater role. In the context of the current corona crisis and the Commission’s decision to step up the greenhouse gas emission reduction from up to 55% net by 2030, SGI Europe sees it as important that the Energy Performance in Buildings Directive (EPBD) will be accordingly and fairly revised. Therefore, SGI Europe welcomes the opportunity to contribute to the development of climate policies at the EU level, through the open feedback on the “Inception Impact Assessment for the Revision of the EPBD”. SGI Europe is convinced that the Energy Efficiency First principle (EE1 principle) is a useful guideline across many sectors. At the same time, it must be subordinate to the decarbonisation and reduction of climate impacts. In fact, the EE1 principle is not cost effective and does not lead to prioritising the most important actions for climate. The EPBD as well as the EED revision should both focus on “climate-efficiency centric approach”, with the need to reduce at the same time GHG emissions and energy consumption, with more ambitious targets on carbon than on energy efficiency. A “Carbon reduction efficiency first” principle could be more powerful to reach the main 2050 Green Deal target. It is simply not beneficiary for Europe to base the EE1 principle on the meaning to implement the maximum efficiency standards to apply cost-optimality on the basis of energy efficiency rather than GHG-reductions. This clarification would significantly improve the image of energy efficiency measures. SGI Europe would like for the purpose of the impact assessment highlight the following recommendations, which you can read in the attached file below.
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Response to Revision of the NIS Directive

18 Mar 2021

SGI Europe generally welcomes the opportunity to provide feedback to the recently adopted Directive on security of network and information systems (NIS 2 Directive) by the European Commission that introduces in our point of view significant and problematic changes compared with the first version of the Directive. SGI Europe wishes to take this opportunity to comment on the proposal since it has identified that the new draft could have a negative impact on many of its members that are providers of services of general interest and subject to the Directive under the provisions of Annex I of the proposed draft. The main issue lies in the fact that the entitlement to define the threshold for the application of the mandatory technical and organisational measures that weigh in on these operators has been withdrawn from Member States (MSs.) The Commission now includes all public and private entities in the relevant sectors in the scope of the proposal. The only exception from the scope is for Micro- and Small Enterprise as defined by the Commission Recommendation 2003/361/EC . SGI Europe is once again forced to point out the unsuitability of the European SME definition, which continues to be a burden for many SGI members all across Europe. Please find SGI Europe's full response attached.
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Meeting with Laure Chapuis (Cabinet of Commissioner Kadri Simson), Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

4 Mar 2021 · To present their position papers on the recent consultation of the European Commission on the Renewable Energy Directive II and the Energy Efficiency Directive.

Meeting with Nicolas Schmit (Commissioner) and

12 Feb 2021 · Preparatory meeting for the organization of the Porto Social Summit.

Meeting with Nicolas Schmit (Commissioner) and

3 Feb 2021 · Presentation of the report on strengthening European social dialogue to the Social Dialogue Committee (SDC).

Meeting with Nicolas Schmit (Commissioner) and

2 Feb 2021 · Meeting on the Action Plan to implement the European Pillar of Social Rights.

Response to Initiative on adequate minimum wages

18 Dec 2020

SGI Europe – response to open consultation on minimum wage directive proposal December 2020 SGI Europe agrees with the overall objectives of achieving adequate wages across the EU, making work pay, fighting poverty, and strengthening the role of social partners and social dialogue, in line with national industrial relations systems. A lot of work is done, in particular in the European semester. SGI Europe responded to the first and second stage social partners’ consultation and clearly expressed a preference for a social partner negotiated solution to be implemented via a council recommendation, instead of the now presented proposal for a directive. SGI Europe members also had initial discussions and assessment of the proposal. There are some different views and assessments on the content in the directive proposal itself, but our members agree overall that the directive will likely influence wage setting and the wage level. Foremost we have some questions around the proposal, presented below and SGI Europe’s members would appreciate if the Commission could clarify these issues...
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Response to Green Paper on Ageing

14 Dec 2020

SGI Europe, representing the services and enterprises of general interest which underpin Europe’s economic and social performance, agrees with the Commission that demography is one of the mega-trends that is transforming European societies. Besides, active ageing, care and pensions belong to the long-term impacts of this trend. SGI Europe, representing the services and enterprises of general interest which underpin Europe’s economic and social performance, agrees with the Commission that demography is one of the mega-trends that is transforming European societies. Besides, active ageing, care and pensions belong to the long-term impacts of this trend. SGI Europe shares the Commission’s point of view that aspects of demographic change as healthcare, long-term care and adequate pensions will have an impact on the sustainability of public budgets. Pensions aim to protect retired people from old-age poverty and the risk of outliving their resources. They are the primary source of income for about a quarter of the EU population. In some Member States, occupational schemes provide up to half of the pension income. Principle 15 of the European pillar of social rights states that ‘Workers and self-employed have the right to a pension commensurate to their contribution and ensuring adequate income. Everyone in old age has the right to resources that ensure living in dignity.’ Concerning the need for adequate pensions, SGI Europe likes to underline that concerning the pressure of public budgets, multi-pillar pension systems show their advantages, and it is clear that supplementary pensions are needed. Especially occupational pension provision is in a lot of Member States often designed and cared for by the social partners. Medium to high supplementary pension coverage is mostly found in countries characterised by an active role of social partners and collective bargaining. Keeping this in mind, we like to state some basic points which can be found as well in the final report of the High-Level Group of Experts on Pensions, December 2019: • Member States should provide financial and regulatory incentives encouraging social partners to set up collective pension plans that ensure risk-sharing between members while respecting the autonomous competences of the social partners and the sponsoring companies. • Member States should reserve tax and/or financial incentives in both the saving and pay-out phase for supplementary pensions meeting minimum quality requirements. These incentives should reflect the diversity in characteristics of types of pensions and the related social policy of a Member State. • Considering the topic of information, there are two aspects to be taken into account. First, regarding the individual, it means that a good and proper understanding of the relevant pension systems is a suitable goal. However, it is essential not to overestimate the impact of information. There is a trade-off between the precision of pension information and its clarity. • Regarding supervision, the supervisors request more and more information from pension institutions. Even if that aims at a worthy target, we have to realise that 100% of security or control is a myth and high costs minimise the benefits. • Regarding the legal environment, we like to state that pension policies can influence people’s behaviour toward pension savings for better or worse. The legal and prudential environment should not prevent employers and employees from making contributions to occupational pension plans. Therefore, it is essential to create or keep a pension-friendly legal environment (social and labour law, tax law, prudential law). • Last but not least, the primary target of pension institutions might not be forgotten: provide retired people with a decent pension in order that he or she can maintain his or her standard of living.
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Meeting with Celine Gauer (Head of Task Force Secretariat-General)

3 Dec 2020 · Recovery and Resilience Facility

Meeting with Nicolas Schmit (Commissioner) and

16 Nov 2020 · Meeting on the Recovery Strategy.

Response to Union of Equality: European Disability Rights Strategy

12 Nov 2020

CEEP is committed to empowering people with disabilities so that they can enjoy their rights and participate fully in the economy and society. CEEP therefore welcomes the EC Roadmap for the Post-2020 European Disability Strategy, whose approach represents a further step towards the social integration and recognition of social and economic rights of people with disabilities. During the past 10 years, European Institutions and Member States have shown substantial commitment in this field, but further action is needed to ensure that the priorities and targets are achieved, especially in the current challenging context caused by the COVID-19 health crisis and its economic and social consequences. People with disabilities (e.g. work and leisure-time accidents, chronic illnesses, temporary chronic illnesses, mental illnesses) will indeed be strongly affected by the current crisis. The Disability Rights Strategy for 2021-2030 should therefore be designed to help acquire and improve factual understanding in order to assess the effectiveness of inclusion of people with disabilities in EU Member States, raise awareness of the issue and produce knowledge about what helps people with disabilities to cope with disadvantage and marginalisation. CEEP wants to underline several key elements that will contribute to the definition of the next Strategy and ensure its implementation and delivery over the next 10 years. The rest of CEEP Position can be found in the attached document. https://www.ceep.eu/
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Meeting with Stella Kyriakides (Commissioner) and

11 Nov 2020 · Meeting with EU Social Partners on the Pharmaceutical Strategy and Europe’s Beating Cancer Plan

Meeting with Carole Mancel-Blanchard (Cabinet of Commissioner Elisa Ferreira)

10 Nov 2020 · Long-term vision for rural areas

Response to Evaluation of the Sewage Sludge Directive 86/278/EEC

24 Aug 2020

CEEP, the European Centre of Employers and Enterprises providing Public Services and Services of General Interest (SGI), welcomes the opportunity to submit its input to the evaluation of the Sewage Sludge Directive (Directive 86/278). Since the environmental circumstances and the consumption behaviour of society and the industry have substantially changed over the last three decades, CEEP sees it as highly necessary to re-evaluate the Sludge Directive and align it to the current challenges of climate change and EU policies. Increased and improved treatment of water on one end will de facto produce more sludge as well as higher pollutant concentrations on the other end. These resources represent a great potential in a circular economy –with material or energy recovery. However, there is also a risk that this opportunity remains insufficiently addressed and unexploited. In fact, the revision of the Sludge Directive should be carried out in coordination with the revision of the Urban Waste-Water Treatment Directive, since both address the issues for more efficient waste-water management treatment across Europe and the issues of energy and resource efficiency that play a central role in its modernisation progress towards the objective of the EU Green Deal. For that reason, CEEP outlines in the following its policy recommendation for the evaluation of the Sewage Sludge Directive to become a sustainable and effective EU policy framework: In accordance with the precautionary principle and the control at source principle, measures need to be taken to prevent pollution at the source across the value chain through a consideration of sectoral, market and trade policies, to improve the framework for a sustainable and circular economy. Avoidance of one-sided end-of-pipe solutions: Relying merely on end-of-pipe solutions is not a holistic nor a sustainable solution for this environmental challenge and the burden of costs should not rely on citizens. Create an EU wide framework and collective responsibility for all actors in the value chain: It is critical to acknowledge that sludge is a collective responsibility and calls for cooperation amongst all actors to find common solutions and overcome divergences in an informed manner. CEEP calls here for a strong EU sludge policy that is coherent with other EU policies and EU law to ensure that municipal companies can rely on a legal framework that also gives them investment and planning security. The re-evaluated Sewage Sludge Directive and municipal waste-water guidelines should support municipal water companies in investing in energy projects: The generation of heat and electricity from sewage sludge plays a special role on the path to climate neutrality and if this is not effectively managed, valuable energy potential remains unused and counter acts towards the circular economy ambitions. Support and harmonising the local sewage sludge management: National and local authorities have moved away from EU minimum rules creating a patchwork of different rules. Additionally, to avoid to further dispose sludge, local municipalities need EU and national support for incentives and help creating improved utilisation and recycling possibilities. High quality sludge can be safely spread onto land and agricultural fields: Locally, this can be facilitated with quality assurance schemes and agreements between water operators and farmers to ensure high quality, safety and mutual trust. At EU level, coordination with the Fertilisers Regulation would provide the opportunity for high quality sludge to obtain a science-based quality certification for fertilising purposes, hence ensuring the consideration as a resource throughout the EU.
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Response to Legislative framework for the governance of common European data spaces

28 Jul 2020

CEEP, the organization representing employers and enterprises providing public services and services of general interest in Europe since 1961, welcomes the opportunity to reply to the Inception Impact Assessment on the legislative framework for the governance of common European data spaces. In the enclosed opinion, we would like to emphasise some aspects of the legislative framework and highlight our position. This concerns the acknowledgement of the heterogeneity of the public sector, the definition of data, the problems of the term “data altruism”, the need of a European effort of standardisation and competition problems. In general, CEEP welcomes the initiative to create common European data spaces provided that a governance framework for fair data access and use. The initiative presented by the European Commission in the Inception Impact Assessment seems to be about how to increase the amount of available data in the EU than about the governance of the European data spaces itself. It should also raise specific questions about the underlying infrastructure that will support this initiative. At this point, we wonder whether the focus of the initiative is appropriate to the intention and will suggest further topics to explore. For the “Legislative framework for the governance of common European data spaces”, we strongly recommend: - a clear distinction between public sector bodies and public undertakings. - that based on this distinction, all public undertakings operating in a competitive environment should be excluded from any further data-sharing obligations. In case additional data-sharing obligations are imposed on public undertakings, they should reciprocally address private sector counterparts. They hold equally valuable data which can benefit society and re-level the playing field. - that the role data plays in concentrating market power is taken into account in competition assessments, including antitrust and merger decisions. - that fair competition conditions are ensured, which grant public service providers access to data on the use of their content and services when offered on third-party platforms, without prejudice to data protection regulation.
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Response to New competition tool

26 Jun 2020

CEEP, the organization representing employers and enterprises providing public services and services of general interest in Europe, welcomes the opportunity to reply to the Commission’s Evaluation and Fitness Roadmap concerning the new tool to combat emerging risks to fair competition. This topic is also of great relevance to the public sector. The role of public policy values in competition analysis has been discussed extensively in antitrust circles for several years. However, we believe that this issue remains unsettled and invite the Commission to take account of the following in reviewing the new tool to combat emerging risks to fair competition. In this sense, we believe that it is important to adapt and extend the competition law toolbox regarding digital markets that pose numerous challenges to antitrust and merger control. In general, we welcome the initiative to overcome strong market concentrations in the digital sector and to pay more attention to them in the future. Nevertheless, it is important for us to highlight in the following the need to include and protect the rights and special role of the public sector in this process. Please find enclosed our comments on the Commission’s Evaluation and Fitness Roadmap concerning the new tool to combat emerging risks to fair competition.
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Meeting with Nicolas Schmit (Commissioner) and

11 Jun 2020 · Meeting with Vice-President Schinas and Social Partners on Skills.

Meeting with Margaritis Schinas (Vice-President) and

11 Jun 2020 · Skills Agenda

Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion)

10 Jun 2020 · impact of Corona virus

Meeting with Helena Dalli (Commissioner)

9 Jun 2020 · Exchange of views on impact of Coronavirus on women’s economic situation; the importance of Gender Equality Strategy and Pay Transparency measures.

Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

CEEP, the European association representing public services and services of general interest (SGIs), welcomes the Commission’s “A Renovation Wave initiative for public and private buildings”. Buildings in Europe consume around 40% of energy, therefore, to achieve the ambitious climate neutrality target and to successfully decarbonize the economy, as set in the EU Green Deal, the building and housing sector has to play a greater role. In the context of the current corona crisis and the ongoing challenges of climate change, CEEP sees it as an important message to keep the climate and energy policies in the center of the recovery plan. We believe that when achieving our climate goals and rebuild our economy from this shock we must stick to our climate and energy objectives across the value chains. It is therefore of vital importance to acknowledge, that investments in sustainable solutions have an incredible impact on economic growth and have job-creating effects. The initiative seems therefore a great opportunity to make the case for countercyclical investment in the context of a dawning recession across Europe. However, by drafting the Communication on “Renovation wave”, the Commission should take these four key aspects of building and housing renovation into account: Fairness: Improving the renovation efforts for social and public housing Sustainability: Promote recycling and circular economy schemes Decarbonization: Include sustainable heating/cooling technologies and decentralized renewable energy production Finance: Support diverse means of finance schemes and add multiple implementing partners These aspects are closely intertwined and only through a comprehensive approach to renovation, the objectives will be met. The « renovation wave » initiative announced by the European Commission as part of the EU Green Deal can help social and public housing providers pursue the climate neutrality trend and support more sustainable heating and cooling technologies. For this reason, CEEP would like to highlight the following recommendations, which you can find in the attachment.
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Meeting with Nicolas Schmit (Commissioner) and

8 Jun 2020 · High-level hearing with Executive Vice-President Dombrovskis and the Social Partners on the Action plan to implement the European Pillar of Social Rights.

Response to Strategy for smart sector integration

29 May 2020

In the context of the current corona crisis and the discussions of EU Ministers for a recovery plan, CEEP continues to support the agreed EU climate neutrality targets in 2050 and sees it as an important message to keep the European Green Deal and its climate policies in the center of the recovery plan. We believe that when achieving our climate goals and rebuild our economy from this shock we must stick to our climate and energy objectives across the value chains. While the industry has proven to be resilient and ensured secure supply of energy during this virus pandemic. Climate change has not stopped, and it continues to be a threat to our environment and our economy. CEEP underlines the importance to continue having climate policies as a top priority on the EU Agenda and they must be developed as part of a sustainable approach based on three dimensions: economy, environment and the social policy. These dimensions are at the core of the CEEP members activities as actors of public services and of services of general interest in Europe. In this context, CEEP sees the coming Smart Sector Integration Strategy as at the center of the Green Deal and welcomes this consultation. In the next pages, CEEP develops its detailed answers but would call attention on the following high-level messages: As a general principle, for CEEP, it is needed to develop holistic concepts in which electrification as well as decarbonised and renewable gases and innovative heating/cooling, industry and transport solutions with their respective infrastructures will have a role to play. There is not one technology or application that is going to solve all our problems, but we will need to increase the cross-sectoral cooperation to unleash the true potential in all sectors/applications. Cost-effective and energy-efficient principles give a key role to decarbonized and renewable gases to achieve a carbon neutral transition. As there are many ways to produce decarbonized and renewable gases, it is key for an efficient market to have simple and clear definitions, for instance between renewable character and GHG footprint. -Existing gas network operators have a clear expertise that must be used to for the introduction of hydrogen in present networks and for the construction and operation of hydrogen networks. This is a key element for the introduction of an EU-wide framework for decarbonized and renewable gases in the gas directive that can accelerate the establishment of a European market for these gases. -Flexibility of energy systems is key to accommodate the growing intermittency of renewables and what is really lacking is the possibility for all sources of flexibility of all energies to compete on a level playing field. -To enable decarbonized and renewable gases to make their contribution to achieving climate neutrality by 2050, the course must now be set at EU level. First and foremost, it is essential to have a clear commitment and strategic view from the EU on gas and the integration and use of renewable and decarbonized gases in the internal market and the grids taking into account their potential and constraints. -Finally, CEEP would like to underline that the Smart Sector Integration Strategy must also give large room to district heating and cooling which is a sector integration technology; it allows thermal storage and recycling waste, a good example of circular economy.
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Meeting with Nicolas Schmit (Commissioner) and

13 May 2020 · Videoconference on the Recovery Plan.

Meeting with Ylva Johansson (Commissioner) and

5 May 2020 · Migrants’ challenges in the current COVID-19 crisis and their contribution to economic recovery

Response to European Year of Rail (2021)

4 May 2020

On the 4th of March 2020, the European Commission proposed the decision to make the year 2021 “the European year of rail” [2020/0035 (COD)]. CEEP, the European Centre of Employers and Enterprises providing Public Services and Services of General Interest (SGIs), appreciates this proposal and welcomes the recognition of rail as sustainable mode of transport that needs more (European) support. Despite CEEP’s general advocacy of this idea, CEEP believes that the proposal is not yet complete since it neglects to address the benefits of public transport as a whole that is similarly important as rail for a successful modal shift. Transport emissions and Cities (indirect role of public transport): The transport sector is responsible for almost ¼ of all Green House Gas emissions (GHG) in Europe. Urban transport is responsible for about 23% of these total CO2 emissions from transport and this number is still rising. About 70% of CO2 emissions in urban transport come from passenger cars and 27% from goods transport vehicles. Traffic accidents on urban roads cause about 40% of all traffic accident fatalities in the EU. Currently, more than 70% of European Citizens are living in cities with an upward trend. Already in its 2016 European Strategy on low-emission mobility the EC admitted that “the delivery of this [low-emission mobility] Strategy will very much depend on cities and local authorities and cities are already at the forefront in the shift to low-emission mobility.” [(COM(2016) 501 final]. Public transport already is a good alternative with low or less CO2 emissions. This shows the importance of Cities in fighting the increase in emissions in transport and the need to include public transport in a successful modal shift campaign which comprises rail services but goes beyond by including trams, metros and (E-/H2)-Buses. A modal shift awareness strategy must comprise public transport: It is widely recognised that increasing the share of public transport is the best decarbonisation and e-mobility strategy for Cities.1 Public transport is not only sustainable and clean but also reliable. This became obvious in the current COVID-19 crisis in which public transport operators maintained their service and were, therefore, vital for transporting medical staff to hospitals and other system-relevant actors. In the aftermath of Covid-19 infrastructure projects of public transport operators will require a considerable financial input. These investments will be vital as the public transport sector is a key location factor and a driver for employment. Further, public transport serves as basic requirement for successful economic structures. To safeguard the development and the decarbonised transition of this sector (a) a continued and strong political environment and long-term legal security and (b) better access to European funding for urban transport is necessary. Therefore, CEEP argues that the year 2021 should not only be dedicated to rail but also to public transport (in Cities). Metros, Trams and buses as collective forms of transport actively contributing towards the EU’s emission abatement targets and an improvement of the air quality and health of citizens. CEEP proposes the following concrete amendments to the EC’s proposal. (Please find our recommendations for amendments attached)
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Response to Climate Law

30 Apr 2020

CEEP, the European Centre of Employers and Enterprises providing Public Services and Services of General Interest (SGIs) is supporting the European Commission’s goals of making Europe the first climate-neutral continent by 2050. During this corona crisis, which is having a devastating socioeconomic effect, CEEP is more than ever convinced that a true recovery can only be achieve when developing a balanced and sustainable strategy relying not only on the economic elements, but also on the social and environmental dimensions. SGIs and public services understand that the rules of our economy and our society will have to be re-defined. Finding solutions that will protect the public wellbeing, our environment and the socioeconomic aspects will become more important than ever. At the same time, the climate crisis is an ongoing challenge and will continue to be if we do not act now. The European Commission has the means to develop a carbon neutral and a resilient Europe. In a dynamic and transformative process, cities and rural areas may become places of solutions for future crisis. CEEP emphasises that climate neutrality will only be truly achieved if all three dimensions are included in a holistic approach that takes into account all climate challenges in the energy, water, transport, building and waste management sectors and effectively coordinates new and existing legislations. This applies in particular to the planned increasing climate targets by 2030. It is in the general interest to act quickly to avoid lock-in technologies and to reach the target in a cost-effective way. CEEP underlines that each sector must achieve its goals to make an appropriately and effective contribution to the overall achievement of the EU Green Deal and each Member States must achieve their European Commitments and targets for the Greenhouse Gas (GHG) reduction, renewable energy and the increase of energy efficiency. CEEP also wants to reaffirm the importance of an all-inclusive approach, in which all sectors work closely together, is necessary in order to reach the net zero CO2-emission-target in 2050. Developing a sustainable gas and electricity market will be key to this goal. CEEP supports that the decarbonisation process in the energy sector must be cost-efficient for all sustainable technology types. Therefore, the new Climate Law Regulation should promote a technology neutral based approach. Therefore, sector integration and sector coupling must play a greater role in European policies. It will be essential to lay out an appropriate framework to enable the sustainable electricity and gas sector to contribute to achieving the high ambition of a climate neutrality in the energy supply sector by 2050. Overall, CEEP recommends when achieving the climate neutrality goals by 2050, it will require clear political guidelines that ensures a competitive economic development, social acceptance of the climate transitions and sufficient environmental protection. CEEP therefore welcomes the European Commission's proposal for a regulation to create the framework for achieving climate neutrality and to amend Regulation (EU) 2018/1999 (European Climate Law). In addition, the GHG reduction target for 2030 should be adjusted to the goal of climate neutrality in 2050. Lastly, the EU Emission Trading System (ETS) will continue to place an important tool in the mitigation measurements. Then even once the corona crisis is over, it is certain that climate change will continue. For this reason, to significantly reduce emissions and boost the investments in new and clean energy technologies, ETS must be included in the climate neutrality objective.
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Meeting with Stella Kyriakides (Commissioner) and European Disability Forum and

29 Apr 2020 · VC meeting on the Impact of COVID-19 on Social Services and the risks for persons in vulnerable situations

Meeting with Nicolas Schmit (Commissioner) and

29 Apr 2020 · Videoconference meeting on social support care service and COVID-19

Meeting with Nicolas Schmit (Commissioner) and

23 Apr 2020 · Exchange of views on the effects of the COVID-19 crisis.

Response to Carbon Border Adjustment Mechanism

31 Mar 2020

CEEP, the European Centre of Employers and Enterprises providing Public Services and Services of General Interest (SGIs), welcomes the initiative to respond to the improvement of the carbon border adjustment mechanisms by the European Commission. When achieving our climate goals and to realise the ambition to reach climate neutrality by 2050, it is vital that all Member States take the necessary responsibility and actions in reducing their carbon emissions. For CEEP, the principle of a carbon border adjustment between EU and its partners is seductive as a climate tool promoting decarbonised products inside Europe and avoiding carbon leakage of industries out of Europe preventing competition with imported products that would be less expensive but heavily carbonised. Nevertheless, the practical implementation of such a tool implies a long path of difficulties: Which industrial sectors? How to define the carbon content of products at the border? Which compliance with the WTO rules? How would react EU trading partners? How to ensure a coherency between a carbon border adjustment mechanism and the EU-ETS, keeping in mind that this example is a fragile construction as the sudden decrease of its price during the present corona virus crisis shows it. CBA is a solution to explore especially for simple products, yet CEEP would like to recall that if the idea is to create a European decarbonised industry, the CBA could be combined with other solutions to build a decarbonised internal market in which the industry would find buyers for their products. CEEP invites the Commission to propose and explore these solutions as they have been developed in the recent Agora Energiewende report “Climate-Neutral Industry ». Finally, CEEP underlines that decarbonisation will require huge investments in many industrial sectors. There is a major role for the EU to accompany this transition to support R&I and by reducing risk of investors in a climate friendly framework for the industry.
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Response to Revision of the Energy Tax Directive

31 Mar 2020

CEEP, the European Centre of Employers and Enterprises providing Public Services and Services of General Interest (SGIs), welcomes the revision of the Energy Taxation Directive proposed by the European Commission. In fact, the energy taxation is an important tool to facilitate a sustainable energy and mobility transition, boosting investments to achieve effectively the Energy Union objectives whilst continuing to respect the principle of subsidiarity. The present version of the Energy Taxation Directive (ETD) dates back to 2003, since then the energy markets, energy and fuel solutions and technologies, the greater awareness of Climate Change have largely changed the political landscape. With the publication of the European Green Deal that reflects exactly this political change a revision of the ETD is necessary. It is time to prepare an evolution of energy prices including taxes to deliver to customers a clear climate friendly signal on top of the costs of the value chains of each type of energy. The carbon content of the different energies should be taken into account for having a real CO2 component, CEEP believes it is key to encourage customers to switch toward decarbonised and renewables solutions. The ETD is the opportunity for better heating solutions using biomethane and heat pumps and it is also a chance to uptake electro mobility of light vehicles by adapting taxes on electricity. This revision is also a vital development for the public transport sector. Both railways and local public transports are the most environmentally friendly modes of transportation for European citizens, and the ETD can set an important framework to support this low CO2 emission transportation and help to increase the usage of it across Europe. CEEP suggests that the tax exemption possibility in Art. 15(1)(e) for energy products and electricity used for goods and passenger transport by rail, metro, tram and trolley bus should include all local public passenger transport (by road and rail), instead of treating public transport separately in Art.5 and applying minimum tax rates. Member States should be encouraged to make use of these exemption possibilities. The revision of the ETD is also an opportunity to remove all the taxes and levies from the energy bills that have nothing to do with electricity, gas or heat. It is presently a burden for the final consumer. It would clarify the economic and climatic signal sent to the final consumer by having all energies on a level playing field. A side effect of the present high level of taxes and levies on energy bills is that suppliers have been given a role of tax collector before Member States and often have to assume the payment of taxes to them on unpaid invoices. Suppliers should not support any more this risk. ETS should be taken into account when introducing a CO2 component on the energy bill, at least for electricity. It is necessary to ensure a common approach between all Member States as carbon should have the same value in all Member States. CEEP supports the end of unanimity between Member States for energy taxation and a quick transition to Qualified Majority.
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Meeting with Nicolas Schmit (Commissioner) and

18 Mar 2020 · Videoconference meeting on the impacts of the Covid-19 crisis

Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

11 Mar 2020

Please find our response to the consultation in the attached file.
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Meeting with Ylva Johansson (Commissioner) and

3 Mar 2020 · Consultations on the New Pact on Migrations

Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion)

20 Feb 2020 · Minimum wage

Response to Climate Law

5 Feb 2020

CEEP welcomes the ambition of the European Commission to propose the first-ever EU Climate Law to ensure all EU policies contribute to the European Green Deal objectives to become the first climate-neutral continent by 2050. However, at CEEP we do not share the opinion of the Commissions statement that an impact assessment is not required because a full analysis on the implications of the 2050 climate-neutrality objective has already been provided in support of the “Clean Planet For All” communication. Based on the assumption that the EC will respond positively to our call for a proper impact assessment, we would like to indicate a set of recommendations in view of the finalisation of the draft: 1.To deliver on this neutrality target, CEEP advocates for decarbonising our economy to a net-zero emission target by 2050. It is in the general interest to act quickly to avoid lock-in technologies and to reach the target in a cost-effective way. Making the fight against climate change is top priority, the implementation of the Green Deal should also ensure a level-playing field and a technology neutral approach. At the same time, holistic approaches are essential to overcome the effect of climate change in our environment and we hope to see in the upcoming EU Climate Law a framework that includes all climate challenges in the energy, water, transport, building and waste management sectors and effectively coordinates new and existing legislations.2.CEEP believes that carbon price signals should be meaningful and predictable to spur sustainable investments. In a context of increased emission reductions, all sectors will have to tackle their emissions, especially in the heating and transport sectors.3.The future burden sharing between Emission Trading System (ETS) and non ETS sectors will be decisive in achieving the targets and the most efficient and cost-effective measures must be chosen. Therefore, the relevance of a scope extension of the EU ETS to the building and transport sector is generally welcomed by CEEP. The impacts of this development must still be very carefully analysed. 4.Additionally, CEEP is convinced that an all-inclusive approach, in which all sectors work closely together, is necessary in order to reach the net zero CO2-emission-target in 2050. Developing a sustainable gas and electricity market will be key to this goal. It will be essential to lay out in the new EU Climate Law an appropriate framework to enable the sustainable gas sector to contribute to achieving the high ambition of a climate neutrality in the energy supply sector by 2050. This includes a clear commitment and a strategic perspective of the EU on sustainable gas as an energy source to reduce our emissions.5.As a general principle, CEEP supports that the decarbonisation process in the energy sector must be cost-efficient for all sustainable technology types. Therefore, sector integration and sector coupling must play a greater role in European policies. 6.Furthermore, in the mitigation process CEEP highlights the need to take further actions in other areas of climate protection such as enhancing biodiversity, limit local air pollution, ensure quality water supply and land use and include them in the process to reduce our emissions and environmental impacts. A holistic approach is crucial on these issues and, together, with the Commission’s approach to develop a second Circular Economy Plan, we call for a framework that includes these climate challenges.7.Despite the efforts made, CEEP pleads for concrete measures for an adaptation strategy. Maintaining communication systems, ensuring the production and distribution of energy and water, and maintaining buildings and transport networks is increasingly difficult and costly with the consequences of climate change. The need to improve resilience of our infrastructure to environmental damage needs to be taken into account when drafting the new EU Climate Law.
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Meeting with Nicolas Schmit (Commissioner) and

3 Dec 2019 · Minimum wage and Social economy

Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion)

17 Jul 2019 · Skills

Response to More efficient law-making in social policy: identification of areas for an enhanced move to qualified majority voting

24 Jan 2019

CEEP is highly skeptical about the opportunity to use, in the present political context, the passerelle clause of the Lisbonne treaty in the social sphere. CEEP is an organisation which, together with its employers and trade-union counterparts, contributed to the very definition and constitution of Europe’s social dimension and its legislative and non-legislative tools, through constant negotiations, debates and cooperation with the EU institutions. CEEP agrees on the importance of upward social convergence in Europe. CEEP believes that a stronger potential lies in the EU bringing support to Member States in developing further initiatives and actions which would ensure a stronger refocus of EU instruments for Social Policy purposes. Instruments like the European Semester were built to ensure progressive convergence between the Member States through debates, mutual-learning and peer pressure on issues often exclusively in the remit of Member States such as social protection and Education and training policies. CEEP supported the inclusion of the Pillar of social rights in the EU semester as an effort to make it more balanced with the Economic dimension while respecting the strict repartition of competence in the European Union. CEEP is surprised by this proposal as in the Commission’s reflection paper no reference was made to the use of the passerelle clause in the scenario “deepen the social dimension of Europe together”. Also, CEEP stands by the Rome declaration of March 2017 of the leaders of 27 member states and of the European Council, the European Parliament and the European Commission which recognized “a Union taking into account the diversity of national systems and the key role of social partners”. CEEP asserted that its members are extremely attached to the strict respect of the repartition of competences between the EU and the Member States. Respecting the principle of subsidiarity and proportionality is a condition sine qua non to the success and widespread acceptance of further development of the EU Social Dimension. It is critical to recall that a unique model that would work for every country does not exist and that only Member States can anticipate the implications of policy initiatives at national, regional and local level. Full harmonization of EU social rights is presently neither desirable nor politically feasible in the present state of the EU as divergences between Member States are too important in terms of social and industrial relation systems. There are strong political risks within the Commission exploring the use of the passerelle clause. Before the European elections and the risk of seeing the rise of euroskepticism in Europe and in the European Parliament, the use of the passerelle clause may send the wrong signal that Member states are being overruled. The progressive integration of national policies, by which Member States are asked to give up part of their sovereignty, is a long term and far-reaching process, which requires long-term and consistent support from EU governments and citizens. Unanimous decision-making may take longer and require more patience from all involved in the process, but it offers better guarantees for a broad support for integration. Any decision-making system has to be geared to the depth and scope of the decisions to be taken, and should not cater to short-term interests and gains, which make for quick results without serving the real cause of more united Europe. For CEEP the passerelle clause constitutes a strong political risk as gives the impression that the EU has failed to promote convergence without using instruments to overrule the Member states.
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Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

9 Jan 2019 · PSI Directive

Response to Strategy for long-term EU greenhouse gas emissions reductions

9 Aug 2018

CEEP gathers members from the whole economy, including sectors such as health, transport, communications, environment, waste, water, education, housing, local administration and, of course, energy. This last one is on the front line when addressing greenhouse gas (GHG) emissions reduction. But as the EU action is impacting the whole economy, and seen the broad actions required to reduce substantially greenhouse gas emissions, all CEEP members are concerned and can bring their expertise in that debate. Reducing the EU GHG emissions is more than a goal: it is an obligation. This pledge to reduce GHG in Europe materialized by the commitment undertaken in Paris in 2015 and the adoption of the Clean Energy Package. CEEP members, including both large companies and local public services enterprises, are daily actors of the energy transition. We would like to share 5 main messages: 1. As one of the EU cross-industry social partner, CEEP underlines that, together with digitalization, the energy transition is a revolution for companies and employees, and must be just. ‘Just transition’ means, among others, that any compulsory closure of industrial installations before the end of their economic life implies accompanying companies, workers and territories. For instance, specific training for adults would benefit to workers, employers and the whole society. European regional policy should facilitate the transition of strongly impacted territories. 2. Competitiveness is included in the 5th dimension of the Energy Union. For this reason, CEEP pleads for a long-term strategy where all decarbonization technologies compete on an equal level-playing field. Public financing must be deployed in line with that principle. 3. The recent Clean Energy Package and the revision of the ETS directive happened at different moments, leading to overlaps between the EU climate and the energy policies. CEEP calls for a realignment of those two policies within the Strategy for long-term EU greenhouse gas emissions reductions, especially by giving to carbon an efficient and predictable market price. 4. Electricity covers about 22% of the EU energy needs, with a maximum of 35 % in Sweden who is a leader in low-carbon electricity in Europe. These figures show that there is a lot of room in Europe to increase decarbonized energy based on decarbonized electricity. Going higher than 35 % is likely in the long-term with, among others, the electrification of (light) vehicles. Combining a significant step forward in electrification with deep decarbonisation of electricity must be an objective, and can be achieved in a cost-effectively way, especially with the recent decrease of costs of renewables and batteries. 5. Finally, with the growing share of dispersed low-cost generation, CEEP insists on the roles of local actors, especially towns and local authorities, in the energy transition. They are in the best place to combine advantageously district heating, gas and electricity systems and take advantage of all new decarbonization technologies.
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Response to Multiannual Financial Framework - CAP Strategic Plans

31 Jul 2018

CEEP welcomes the proposals for modernising and simplifying the Common Agricultural Policy (CAP). CEEP has a clear vision of a future sustainable agricultural policy, which is equally environmental-friendly and economically viable. We invite the European Commission to establish the balance between production of food and protection of our valuable water resources. The emissions from the agricultural sector are causing serious challenges for water utilities. Agricultural residues such as pesticides cause great difficulties for the production of drinking water and the operation of urban waste water treatment plants. The implementation of the EU water acquis (incl. the Water Framework Directive and the Drinking Water Directive) is continuously hampered by agricultural activities. CEEP believes that funding from the CAP should contribute to the goals of the EU water acquis and establish better coherence and coordination with other policies. The right quality and quantity of water resources are of crucial importance for a profitable and sustainable agricultural sector. The current proposal is unfortunately not taking this sufficiently into account. In view of this, the European Commission should play a key role in supervising and guiding the implementation of the CAP to address the existing deficits within Member States. The following elements, which are contributing to the protection of our water resources, should be better taken into account in relation to the Commission proposal: National strategic plans: The national annual strategic CAP plans, which play a central role in the legislative proposal, should take the pressures on the water system into account and measures to lower the impact of agriculture should be proposed. Water utilities possess a great knowledge to assess which measures are effective and needed for this. They should always be one of the key stakeholders that can give input when designing and setting up the national CAP plans. ECO-schemes: The proposed voluntary eco-scheme needs to be attractive for the farmers to be successful, effective and frequently used. The eco-schemes should also deliver substantial advantages for the environmental protection to contribute substantially towards the “greening” of the current CAP. Measures from the eco-scheme should strike the right balance between gains for the farmers and the environment. Member States need to investigate as soon as possible which measures they could introduce to tackle this issue. We believe that the protection of water resources and a sustainable use of the soil should play a central role in the national eco-schemes. Rural Development Fund: Many water utilities cooperate with farmers in projects to protect and/or improve water quality. These projects contribute substantially to the liveability and resilience of the rural regions, while being in the interest of the cooperating farmers. These projects are very often paid for and initiated by water utilities and are co-financed by the EU rural development fund. Over the last years, great successes have been achieved, and water utilities would like to continue these types of projects under the future CAP. However, the co-financing percentages for these types of projects are substantially lowered in the Commission proposal. Even though there are exceptions possible for the co-financing percentages of non-productive investments, they do not cover all the necessary measures and still require a farmer to make an initial investment. We strongly like to make a plea on the Council and European Parliament to change this. Conditionality Mechanism: The newly introduced system of "conditionality" which should link the income support (and other area- and animal-based payments) to the application of environment- friendly farming practices – is in our view not ambitious enough. It is high time to address qualitative and quantitative water aspects through concrete legislative measures.
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Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion)

17 Jul 2018 · Introductory meeting to reinforce the fruitful cooperation

Meeting with Andrus Ansip (Vice-President) and

9 Jul 2018 · Public sector information proposal, ePrivacy, eGovernment

Meeting with Valdis Dombrovskis (Vice-President) and

15 May 2018 · Exchange of views on the next Multi-Annual Financial Framework

Meeting with Maroš Šefčovič (Vice-President) and

10 Apr 2018 · 3rd Mobility package

Response to Revision of the Drinking Water Directive (RECAST 2017)

26 Mar 2018

CEEP would like to seize the opportunity and share the message of providers of public services and SGIs on the recently published Commission proposal for the revision of the Drinking Water Directive (DWD). CEEP very much supports the creation of the long-awaited link between the DWD and the WFD (and its Daughter Directives) which clarifies the Member States’ responsibility to protect drinking water resources. This is a crucial step in achieving policy coherence and coordination within EU water legislation. CEEP welcomes the further introduction of the risk-based approach (RBA) adding to what has already been laid down in Annex II in 2015. It is very positive that both the hazard assessment of water bodies (including the catchment area) and the risk assessment of the domestic distribution system now complements the supply risk assessment. However, where the Commission proposal aims for an integrated source to tap RBA, there should be a general obligation for Member States to ensure that there is a clear and balanced distribution of responsibilities in place, tailored to the national institutional and legal framework, bearing in mind the principle of subsidiarity. Furthermore, CEEP notes that in the proposal the supply risk assessment focuses on adjusting monitoring frequency only, where a risk-based approach in water supply is an integral management tool for assessing and managing risks. CEEP welcomes the position taken by the Commission to hold on to the high level of protection provided for by the Directive regarding drinking water standards, including the continuation of the precautionary principle as a leading principle for setting drinking water quality standards. The new legislative proposal foresees measures that go beyond the existing Directive’s scope. Those measures should always be proportional and avoid unnecessary requirements for water operators. CEEP has some concerns regarding the proposed definition of water suppliers and the use of the term in the proposal. In some provisions it reads as if water suppliers are directly addressed, where the Directive should clearly be directed at Member States only. CEEP believes legal obligations, which are addressed to Member States should not leave any legal uncertainty for possible liabilities towards water suppliers. Moreover, the proposed definition might need some amendment, as in its current wording it might include other entities than drinking water companies. The status quo is not good enough regarding the current Article 10 on products and materials in contact with drinking water. CEEP therefore calls upon the Council and European Parliament to provide a legal baseline in the Directive for health requirements for products and materials in contact with drinking water. CEEP notes that the former Article 9 on derogations is deleted. Although CEEP would welcome a simplification of the process of granting 3 derogations of maximum 3 years, the complete deletion of the legal instrument of derogations leaves Member States and water suppliers with the situation that temporary exceedances can no longer be embedded in a legal framework. In addition, CEEP expresses its concern about the deletion of Article 6, paragraph 2 (‘shall be deemed clause’ in relation to domestic distribution systems in non-public supplies) and the deletion of the exception for notification to consumers in case of trivial non-compliances (Article 12 of proposal). CEEP believes the proposed changes constitute a too rigid system leading to legal and practical problems. CEEP stresses that Article 14 (and Annex IV) and the requirements on information to the public with aspects such as tariffs, investment decisions, waste water collection and treatment, and leakage rates are going beyond the scope and the objectives of the DWD, which should focus on water quality and the protection of human health as determined by Article 1. The principle of subsidiarity should be respected.
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Meeting with Raquel Lucas (Cabinet of Vice-President Valdis Dombrovskis)

12 Feb 2018 · Exchange of views on Social Fairness Package

Response to Fitness Check of the Water Framework Directive and the Floods Directive

16 Nov 2017

In general, CEEP is convinced that the Water Framework Directive (WFD) has been an effective key instrument of European water policy. The objectives of the WFD should essentially be retained before 2027, taking into account the polluter pays principle and the precautionary principle. The Commission should support the Member States in the implementation of the WFD. Therefore, CEEP would like to propose the following measures: - to continue to use the WFD as a framework directive which provides the necessary scope for action in order to achieve a sustainable balance between protection and use of water. In this context the Commission should support the Member States for better implementation of art.7.3 in order to avoid deterioration in water quality to reduce the level of purification treatment required in the production of drinking water. With regard to an effective and efficient protection of drinking water resources the implementation of the WHO WSP approach should be envisaged to involve all relevant stakeholders in water catchment areas, - to ensure coherence with and within other EU policy areas (for example Nitrates Directive, PPP Directive, REACH, Renewable Energy Directive), in order to avoid contradictory rules and allow dynamic developments, - to insert a usage clause for water supply and wastewater disposal and for energy generation as a means to implement the "non-deterioration" principle, thus allowing certain new or extended uses of water which are conducive to services of general interest or the implementation of other EU directives and which have been recognised as being predominantly in the public interest, - to define water supply and wastewater disposal as preferred desired uses of water, in order to secure the supply and disposal for the population, - to develop European strategies and assessment methods for the problems of pharmaceutical drugs, microplastics and general "trace substances" also in respect to the Priority Substances Directive, - when setting environmental quality standards (EQS) for water, to take into account the technical and practical feasibility and also to assess the proportionality of costs and/or the cost-benefit analysis of the EQS in that respect, - to tackle the existing challenges of the current time limits regime to achieve the targets with a system based on management cycles, which could stipulate more closely defined improvements. This is closely linked with the existing use of a water body (e.g. for services of general interest), the technical availability and feasibility of measures as well as the associated socioeconomic costs, - as far as the quality of water is concerned, to present not only the shortfalls towards the realistic targets set but also the "improvements"/ “successes” made in water qualities and thus to measure results in time perspectives, - in place of an aggregated overall status, to introduce a separate assessment of the chemical status and the ecological status of a body of water also in relation to the use of drinking water purposes, - as far as the chemical status is concerned, to replace the "one-out all-out" approach with an assessment of the achievement of objectives in respect of specific pressure indicators notwithstanding the existing goals on water quality, - when assessing the ecological status, to replace the worst-case principle with an overall view of the uses, times of year, neobiota and f.e. the resulting ecological substitute fauna and flora, - to retain Recital 1 and to secure the position of public water supply as a service of general interest within the internal market, - to make clearer that the WFD serves the protection of water as well as a sustainable management of waters with the objective of taking into account people's need to utilise the waters in the form of many various types of use such as drinking water abstraction and waste water discharge, industrial use and energy generation.
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Meeting with Marianne Thyssen (Commissioner)

15 Nov 2017 · European Pillar of Social Rights

Response to Evaluation of the Urban Waste Water Treatment Directive 91/271/EEC (UWWTD)

9 Nov 2017

CEEP welcomes the opportunity to comment on the Evaluation Roadmap and would like to provide the feedback of providers of public services and of services of general interest (SGIs) in the EU. Overall, due to the high compliance ratio that could be achieved (95% for connection, 89% for secondary treatment and 85% for more stringent treatment in 2014), CEEP does not see the need for big amendments to the existing Directive. However, CEEP would like to stress that the evaluation should consider the need for better policy coordination. The UWWTD is clearly linked to other EU legislation such as for example the Water Framework Directive but also the Priority Substances Directive. Moreover, the Commission is currently working on a strategy to decrease the impact of pharmaceuticals into the environment and on a plastics strategy. Both strategies may also be of relevance for the UWWTD evaluation. Indeed, the evaluation should also consider the issue of emerging pollutants, the management of by-products, issues related to the circular economy, such as criteria for reclaimed water and for plants which produce their own energy, major engagement with flood and drought Directives and, finally, the refitting or renewal of ageing sewer systems. It needs to be ensured that the tap water consumer is not charged with the treatment costs of emerging pollutants. The polluter pays principle must be included in the global “water bill” to ensure clean and wholesome tap water. In this sense, it needs to be emphasized that control at source is the most sustainable way to avoid the release of certain pollutants in waterbodies: end-of-pipe treatment must be the last option. Moreover, the integration of several issues that have been discussed during the last meetings of the Commission’s UWWTD Expert Group should be considered, including the debate on water reuse from the treatment plants to act against water scarcity as well as the issue of COD replacement due to the ban of the Potassium Dichromate used in the reference method. However, it needs to be clarified which other parameter should be used (TOC?). A study of the transposition of the Directive in the Member States’ regulations at national and regional level – with respect to the subsidiarity principle – is of primary importance in order to identify potentially inconsistent legislation that could harm the free exchange between different Member States (as it occurs in the field of the regulation on agricultural sludge that could cause alteration on the European Market). In this context, river basin management is of particular importance. In addition, regarding how well the Directive promotes a sustainable approach, the evaluation should also address the inclusion or exclusion of recovered nutrients from waste legislation in order to foster market opportunities and free trade of recovered products. Moreover, it is crucial that a sustainable approach includes the cost recovery principle, including amortization of cost of restoration. Furthermore, the evaluation should include the idea that the water resilience of cities must first be integrated in the urban town planning and projects. In this context, it should be considered that management of water and waste water is often happening at the local level and should therefore require local and ad-hoc solutions. Green infrastructure development activities inside the cities should be stimulated by European and national funds. Incentives may determine and stimulate water reuse from the treatment plants (also by Sanitation Safety Plan Implementation), ensuring that there is no danger for agricultural products. Additionally, current monitoring requirements should be more frequent, effective and flexible and on-line monitoring should be considered. Finally, the option of obtaining more information about the presence of microplastics in the treated water released should be debated.
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Meeting with Maroš Šefčovič (Vice-President) and

6 Nov 2017 · 2nd Mobility Package

Meeting with Luc Tholoniat (Cabinet of President Jean-Claude Juncker)

30 Oct 2017 · Social dialogue

Meeting with Michel Barnier (Head of Task Force Task Force for Relations with the United Kingdom)

27 Oct 2017 · Meeting with the Task Force for the Preparation and Conduct of the Negotiations with the United Kingdom under Article 50 TEU

Meeting with Michel Servoz (Director-General Employment, Social Affairs and Inclusion)

13 Oct 2017 · social services

Meeting with Marianne Thyssen (Commissioner)

17 Jul 2017 · EU-social dialogue

Response to Revision of the EU SME Definition

6 Jul 2017

Welcoming the European Commission’s Inception Impact Assessment, CEEP would like to provide the feedback of providers of public services and of services of general interest (SGIs) in the EU. CEEP shares the point of view that 14 years after the current EU SME Definition’s publication, there is a clear need to review and adjust it. SMEs are the backbone of the European economy and, therefore, they should indeed benefit from specific support schemes. Amongst these SMEs in need of targeted measures, there are many providers of public services and SGIs at local level. They fulfil all criteria of the current SME Definition, including their number of employees and turnover, except for the last one, specified in Article 3, Paragraph 4 of the Definition’s Annex which states that SMEs with a public ownership of more than 25% are to be excluded from the Definition’s scope. This creates important burdens for these SMEs linked both to regulatory and financial aspects. Whilst having to increasingly cope with limited resources, local public services’ enterprises that are excluded from the Definition’s scope suffer from undue regulatory burden, which is contrary to the Definition’s objective to reduce the burden from SMEs that would otherwise be disadvantaged. This concerns both European legislation and its implementation at national level (e.g. the Energy Efficiency Directive’s obligation to carry out energy audits whose costs in some cases even exceed the actual annual energy costs of these SMEs) as well as a wide range of national acts referring to the EU SME Definition (e.g. the German IT Security Act in 2015 or the Italian Stability Law in 2016). These SMEs must also cope with increasing challenges in accessing financing. Local public services’ providers in several Member States that are SMEs have reported difficulties in accessing bank loans despite their public ownership and are increasingly engaged in “risky investments”. SMEs that are local public enterprises are not “hidden big companies” with “hidden subsidies and additional personnel”. They meet the same challenges as private SMEs of the same size. However, their development is hampered by the exclusion from support schemes e.g. of national investment banks referring to the EU SME Definition. Moreover, local public SMEs are “SMEs at the disposal of other SMEs”. They are deeply rooted in their local business environment and lead to direct, indirect and induced growth and employment in privately-owned SMEs. They open up public markets to private SMEs. Furthermore, they provide the infrastructure based on which other SMEs can develop. Therefore, strengthening local public services enterprises means strengthening all SMEs. In addition to that, the EU SME Definition is contrary to Article 345 TFEU which states that “The Treaties shall in no way prejudice the rules in Member States governing the system of property ownership”. As there are approx. 13.000 SMEs with public participation, out of a total of 23 million SMEs in Europe, there are 13.000 reasons to address the negative impact of the current Definition. However, their number is too small to expect that a possible extension of the Definition would hamper the benefits provided to privately-owned SMEs, or lead to an inclusion of “all companies”. Therefore, CEEP calls for an amendment to the European SME Definition, guaranteeing equal treatment of all SMEs who fulfil the criteria regarding their number of employees and turnover, irrespectively of their ownership. Until a possible revision of the Definition, further references to it in EU legislation should be avoided and its Article 3, Paragraph 4 of the Annex should no longer be used. In this context, CEEP very much welcomes the upcoming public consultation that will allow to provide additional elements for an effective, targeted and sensible revision of the EU SME Definition.
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Meeting with Maroš Šefčovič (Vice-President) and

15 May 2017 · Transport and mobility policy

Meeting with Michel Servoz (Director-General Employment, Social Affairs and Inclusion)

20 Apr 2017 · Update on EC position vis-à-vis setting up a sectoral social dialogue for social services

Response to Revision of the Drinking Water Directive

27 Mar 2017

CEEP, the European Centre of Employers and Enterprises providing Public services and Services of general interest, appreciates the opportunity to express its views on this roadmap/inception impact assessment on the revision of the Drinking Water Directive. Regarding the revision of the Drinking Water Directive (the ‘Directive’), CEEP holds the view that the Directive has been and still is a well-functioning European legal instrument contributing to the supply of wholesome and clean drinking water throughout the EU. The Directive should be kept in place and further improved, as was also concluded by the recently finalised evaluation of the Directive. Regarding the 4 key topics the Commission addresses in the section on ‘objectives and policy options’, CEEP would like to stress that: 1) The precautionary principle should be kept as a leading principle in setting drinking water quality standards of Annex I of the Directive and for environmental quality standards for source water. This could be made more explicit in the inception impact assessment document. 2) CEEP welcomes the elaboration of policy options for the introduction of integrated source-to-tap Risk-Based Approaches in the Directive. This elaboration should include considerations of subsidiarity and flexibility at Member States’ level to leave room for approaches tailored to the legal and institutional framework in Member States. 3) The revision of the Directive should include a sound legal basis (health and hygienic requirements) for the harmonised acceptance of materials and chemicals in contact with drinking water, taking full account of the work on the so-called ‘four Member States Common Approach’. In addition, CEEP would like to stress the need for better integration of the protection of drinking water resources in the administrative arrangements, Programmes of Measures and the River Basin Management Plans under the Water Framework Directive (WFD). The revision of the Directive should include the introduction of a cross-reference to the WFD, in particular its Article 7, the Groundwater Directive, the Priority Substances Directive as well as the Nitrates Directive, the Plant Protection Products Regulation and the Directive on the Sustainable Use of Pesticides. Precautionary and preventative measures to safeguard drinking water resources from diffuse pollution, such as from agriculture, should also focus on reaching the Drinking Water Directive’s objectives. This could be made more clear in the inception impact assessment. Furthermore, CEEP advocates keeping the objective and the scope of the Directive unchanged. Issues such as benchmarking, water as a human right and costs should be addressed separately from the revision of the Directive. Regarding the consultation strategy, CEEP stresses that it is important that stakeholders from the drinking water sector will be again meaningfully consulted after the publication of the impact assessment and the policy options, thereby assisting the Commission in achieving the objectives set out by the Commission in this inception impact assessment.
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Meeting with Marianne Thyssen (Commissioner)

20 Mar 2017 · Pillar of Social Rights, Work-Life Balance, Working Time Directive

Meeting with Matthias Ruete (Director-General Migration and Home Affairs)

16 Mar 2017 · Prep. Discussion with Social Partners (2nd European Dialogue on Skills and Migration)

Meeting with Maroš Šefčovič (Vice-President) and BUSINESSEUROPE and

21 Nov 2016 · Consultation of Social Partners on Energy Union

Meeting with Raquel Lucas (Cabinet of Vice-President Valdis Dombrovskis)

23 Sept 2016 · Exchange of views on Social Dialogue

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

21 Apr 2016 · Digitalisation

Meeting with Andrus Ansip (Vice-President) and

18 Feb 2016 · Digital Single Market and it's impact on jobs

Meeting with Henrik Hololei (Director-General Mobility and Transport)

19 Jan 2016 · Public Transport, White Paper, 4th Railway Package, Aviation Package

Meeting with Johannes Laitenberger (Director-General Competition)

1 Dec 2015 · To make acquaintance and to review competition policy trends

Meeting with Valdis Dombrovskis (Vice-President) and

27 Nov 2015 · Discussion focused on the European Semester, namely the implementation of structural reforms; Five Presidents' report, in particular Competitiveness Boards and organisation/timings of the Tripartite Social Summit

Meeting with Lowri Evans (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

22 Oct 2015 · Single market, industry modernisation, SME policy

Meeting with Michel Servoz (Director-General Employment, Social Affairs and Inclusion)

18 Sept 2015 · State of play

Meeting with Marianne Thyssen (Commissioner) and

13 Jul 2015 · Presentation of European Social Partners' autonomous Work Programme 2015-2017 and In-depth employment analysis

Meeting with Maroš Šefčovič (Vice-President)

24 Feb 2015 · Energy Union

Meeting with Michel Servoz (Director-General Employment, Social Affairs and Inclusion)

23 Feb 2015 · la question du dialogue sectoriel des administrations centrales

Meeting with Michel Servoz (Director-General Employment, Social Affairs and Inclusion) and BUSINESSEUROPE and

12 Feb 2015 · Meeting with Social Partners

Meeting with Michel Servoz (Director-General Employment, Social Affairs and Inclusion) and BUSINESSEUROPE and

26 Jan 2015 · Meeting with social partners

Meeting with Markus Schulte (Digital Economy)

22 Jan 2015 · Telecommunication policy

Meeting with Michel Servoz (Director-General Employment, Social Affairs and Inclusion) and BUSINESSEUROPE and

14 Jan 2015 · Meeting with Social Partners

Meeting with Cecilia Malmström (Commissioner)

19 Dec 2014 · Services of economic general services