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SMEunited

SMEunited represents over 12 million European small and medium enterprises and crafts businesses at EU level.

Lobbying Activity

Response to Revision of EU rules on the eInvoicing

17 Dec 2025

Electronic invoicing can contribute to burden reduction and reduce payment delays. The phase-in of new digital tools such as electronic invoicing across the EU can not only contribute to reduce payment terms but also to better payment controls and ultimately, improve the regulatory oversight of payment terms. However, its introduction needs to be within the reach of all businesses. SMEunited recommends a voluntary and phased introduction, ensuring SMEs have time to gain knowledge and financially access this tool. Financial literacy trainings will also participate in changing the payment culture in the EU , and should involve SME organisations.
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Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

10 Dec 2025 · Attendance to SME United's Vision 2040 event

Meeting with Elisabeth Grossmann (Member of the European Parliament, Shadow rapporteur for opinion)

3 Dec 2025 · Small mid caps

Meeting with Thomas Bajada (Member of the European Parliament, Shadow rapporteur)

3 Dec 2025 · Omnibus 4

Meeting with Karen Vandekerckhove (Head of Unit Justice and Consumers)

21 Nov 2025 · Presentation of Pay transparency directive and discussion on the implementation, especially of provisions relevant to SMEs

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall) and Wirtschaftskammer Österreich

5 Nov 2025 · Simplification

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

5 Nov 2025 · Participation to SME United sustainability WG

SMEunited Calls for Stronger E-commerce Rules to Shield Small Businesses

24 Oct 2025
Topic — EU proposal to strengthen consumer protection against dark patterns and unfair online practices.
Message — The organization requests the DFA focus on protecting SMEs from unfair e-commerce competition, streamline consumer law for small companies, and strengthen enforcement of existing rules. They urge updating guidelines to tackle digital threats rather than creating new legislation.123
Why — This would reduce regulatory burden on small companies while protecting them from platform competition.456
Impact — Consumers may receive weaker protections if new legislation is replaced with guideline updates.7
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Meeting with Xavier Coget (Cabinet of Executive Vice-President Henna Virkkunen)

21 Oct 2025 · SMEunited General Assembly

Meeting with Jana Toom (Member of the European Parliament, Rapporteur)

15 Oct 2025 · Just Transition in the World of Work

Meeting with Michele Piergiovanni (Cabinet of President Ursula von der Leyen)

14 Oct 2025 · Proposal for a late payment Regulation 45th Anniversary Conference – “Vision 2040 by Crafts & SMEs”

SME Association Seeks Biocidal Products Regulation Relief for Small Firms

13 Oct 2025
Topic — EU proposal to simplify food safety regulations including biocidal product requirements.
Message — The organization requests fairer data-sharing arrangements similar to REACH, a regulatory freeze on new data requirements during evaluation, fee reimbursement for regulatory delays, and exemption of micro and small enterprises from all fees. They also seek better guidance document accessibility and translations.1234
Why — This would reduce authorization costs and delays that make it difficult to maintain products on the market.56
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SMEunited urges comprehensive support for heating decarbonisation

9 Oct 2025
Topic — EU strategy to accelerate decarbonisation of heating and cooling sectors.
Message — The organization requests a coherent regulatory framework with measurable national and local targets, streamlined digital permitting with short deadlines, and affordability measures including lower VAT and accelerated depreciation for clean technologies. They call for coordinated infrastructure upgrades, investment in skills training and recognition across the EU, and pragmatic implementation of the F-gas Regulation.123
Why — This would reduce their compliance costs and administrative burden from overlapping regulations.45
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Meeting with Anna Banczyk (Head of Unit Employment, Social Affairs and Inclusion), Steven Engels (Head of Unit Employment, Social Affairs and Inclusion)

9 Oct 2025 · SMEUnited position paper on the future Skills Portability Initiative

SMEunited urges EU to make electrification affordable for small businesses

7 Oct 2025
Topic — EU plan to accelerate electrification and shift energy demand from fossil fuels to renewables.
Message — The organization requests prioritized grid upgrades, simplified access to flexibility markets, accessible financing schemes, and sector-specific support. They emphasize the need for measures tailored to SMEs' limited administrative capacity.123
Why — This would reduce upfront costs and enable smaller firms to compete in electrification markets.45
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Meeting with Valentina Schaumburger (Cabinet of Executive Vice-President Stéphane Séjourné)

7 Oct 2025 · Implementation of the Single Market Strategy

SMEunited Backs 28th Regime to Ease Cross-Border Growth for SMEs

30 Sept 2025
Topic — EU corporate legal framework to help innovative companies operate across borders.
Message — The organization supports a 28th Regime that provides a harmonized, optional legal framework accessible to all companies at any stage. They emphasize it should follow the Think Small First principle and guarantee a level playing field.123
Why — This would substantially reduce compliance burdens and lower legal and administrative barriers for cross-border expansion.45
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SME Organization Calls for Fair Energy Transition with Targeted Support

24 Sept 2025
Topic — EU revision of energy security framework for decarbonized, electrified energy system.
Message — The organization requests targeted support for SMEs to afford decarbonization and efficiency improvements. They want the EU to assess alternatives to marginal pricing and implement a mechanism to temporarily decouple electricity and gas prices during crises. They seek resilient infrastructure investments benefiting SMEs equally with large players.1234
Why — This would reduce energy costs and protect SMEs from price volatility and crisis impacts.56
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Meeting with Ana Carla Pereira (Director Justice and Consumers)

23 Sept 2025 · The discussion focused on three points: 1) The event organized by the COM on the Roadmap for Women’s Rights 2) A study visit of SMEunited members on the Pay Transparency Directive 3) SMEunited input on the next Gender Equality Strategy

Meeting with Annukka Ojala (Cabinet of Executive Vice-President Roxana Mînzatu), Max Uebe (Cabinet of Executive Vice-President Roxana Mînzatu)

23 Sept 2025 · Quality Jobs Roadmap and Act

Meeting with Rosalinde Van Der Vlies (Director Energy)

18 Sept 2025 · Discussion on the energy efficiency support measures for the SMEs, including those enshrined in the Affordable Energy Action Plan

Meeting with Mary Veronica Tovsak Pleterski (Director Internal Market, Industry, Entrepreneurship and SMEs) and EuroCommerce and DIGITALEUROPE

18 Sept 2025 · Meeting with business associations on the way forward of the implementation of the Single Market Strategy/”Terrible Ten”

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur)

9 Sept 2025 · Omnibus I

SMEunited urges flexible incentives instead of rigid ZEV mandates

8 Sept 2025
Topic — This consultation explores setting mandatory zero-emission targets for European corporate vehicle fleets.
Message — SMEunited calls for flexible, incentive-based pathways instead of rigid mandates for corporate fleets. They emphasize the need for robust infrastructure investment and technology neutrality to reflect diverse SME operational realities. Additionally, they advocate for a regulatory framework ensuring affordable EV repairability and exemptions for essential services.123
Why — This approach prevents financial strain from high upfront costs and preserves operational flexibility.45
Impact — Climate goals might suffer as slower transition pathways delay vehicle fleet decarbonization.6
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Meeting with Daniele Calisti (Head of Unit Competition)

8 Sept 2025 · Review of the Merger Guidelines

SME association urges integrated climate resilience framework to close protection gap

3 Sept 2025
Topic — EU regulation establishing framework for climate preparedness, resilience and harmonised climate risk management rules.
Message — The organization requests establishing a common European climate resilience reference scenario, harmonising comprehensive national climate risk assessments, and implementing measures to close the climate insurance protection gap. They call for regional climate risk information hubs and mainstreaming climate resilience in all EU funding programmes.1234
Why — This would reduce their uninsured losses and provide affordable access to climate risk information and insurance coverage.567
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SMEunited urges merger guidelines to protect innovative small businesses

2 Sept 2025
Topic — The European Commission is revising merger guidelines to address modern economic trends and competition.
Message — The organization calls for guidelines to address bargaining power imbalances and prevent killer acquisitions. They propose allowing European champions only when sufficient competition from non-EU players remains.123
Why — Stricter rules would prevent large firms from eliminating innovative small competitors through acquisitions.45
Impact — Large multinational corporations would face more regulatory intervention and restrictions on market consolidation.6
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SMEunited calls for small businesses to be recognised as key energy transition actors

2 Sept 2025
Topic — EU framework for consumer protection and citizen participation in clean energy transition.
Message — The organization requests removal of bureaucratic barriers to self-generation and peer-to-peer energy sharing for SMEs. They want financial incentives for SMEs to join energy cooperatives, improved grid access, and tailored advisory services. They emphasize that small businesses face energy price volatility like vulnerable households.123
Why — This would reduce energy costs and enable their 25.8 million member SMEs to participate in local energy markets.45
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SMEunited Urges Gradual CBAM Expansion with Specific SME Support

25 Aug 2025
Topic — Extending the Carbon Border Adjustment Mechanism to downstream products and preventing circumvention.
Message — SMEunited supports preventing unfair competition but demands any expansion happens gradually. They call for careful impact assessments and simplified reporting requirements. They also request specific support measures to help small businesses adapt.123
Why — Simplified reporting and dedicated support would reduce the heavy administrative burden on SMEs.45
Impact — Local manufacturers face deindustrialisation if carbon rules are not properly adjusted.67
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SMEunited urges simplified rules for the EU Consumer Agenda

11 Aug 2025
Topic — The EU is developing a strategic consumer protection framework for 2025-2030.
Message — The group requests streamlining consumer laws to reduce administrative burdens on small businesses. They advocate for maintaining voluntary dispute resolution systems and simplifying complex product withdrawal requirements.123
Why — This approach would lower compliance costs and prevent disproportionate penalties for minor technical mistakes.45
Impact — Consumers may see a reduction in the mandatory information they receive during purchases.67
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Response to Revision of the Standardisation Regulation

18 Jul 2025

As part of the evaluation of the Standardisation Regulation, SMEunited flagged that the focus should be laid on effective implementation. With adequate financial support and representation of interests, especially of SMEs, the existing legal framework is adequate and proved to be efficient in delivering standards and technical specifications to support EU policy and legislative needs. The current text of the Regulation 1025/2012 is still timely and fit for purpose and very targeted technical amendments for articles 5 and 6 will be sufficient, as previously done for certain articles with the Regulation 2480/2022. Small Business Standards contributes to the vital role of standardisation in support of European competitiveness, particularly in digitalisation and sustainability. However, SMEs, startups, civil society and academia still face financial and capacity constraints to participate in standardisation both at national and European level SMEs, as well as severe challenges in terms of access and balanced participation in system. Additionally, SMEunited insists that to ensure that standardisation can effectively support legislation in a timely manner, it is important to consider the potential need for standards as early as possible, from the moment a legislative proposal is issued.
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Meeting with Ana Maria Blass Rico (Acting Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

17 Jul 2025 · Exchange of views on the REACH Revision, proposal for the European Chemicals Agency (‘ECHA’) Basic Regulation and expected timelines for the PFAS restriction proposal.

Meeting with Lucia Yar (Member of the European Parliament, Shadow rapporteur)

17 Jul 2025 · Gender Equality Strategy

Meeting with Maroš Šefčovič (Commissioner) and

11 Jul 2025 · Implementation dialogue on customs legislation - Rules of origin

Meeting with Henning Ehrenstein (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

9 Jul 2025 · Revision Public Procurement directive 2014

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

4 Jul 2025 · Simplification

Meeting with Stéphane Séjourné (Executive Vice-President) and

2 Jul 2025 · EU Clean Industrial Dialogue on Circularity

Meeting with Maria Velentza (Director Competition) and

22 May 2025 · Exchange of views on EU payment markets

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

20 May 2025 · Discussion of the up-coming Single Market Strategy and SMC omnibus.

Meeting with Enikő Győri (Member of the European Parliament, Shadow rapporteur for opinion)

13 May 2025 · Omnibus I

Meeting with Jorge Martín Frías (Member of the European Parliament, Rapporteur)

8 May 2025 · INI SMEs and scale-ups financing

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

23 Apr 2025 · State of play of the simplification initiatives; upcoming Midcaps initiative

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

23 Apr 2025 · Circular economy

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

8 Apr 2025 · Simplification

Meeting with Evelyn Regner (Member of the European Parliament)

8 Apr 2025 · General Exchange of Views

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur)

8 Apr 2025 · Sustainability omnibus

Meeting with Stéphane Séjourné (Executive Vice-President) and

3 Apr 2025 · - Competitiveness Compass and the Clean Industrial Deal - SME Passport - SMCs - Late Payment Directive - Single Market Strategy - business transfers

Meeting with Jessika Roswall (Commissioner) and

27 Mar 2025 · Roundtable “Water, Agriculture, and the Food Supply Chain”

Meeting with Sanna Laaksonen (Cabinet of Executive Vice-President Henna Virkkunen)

26 Mar 2025 · Improving the position of the SMEs in Europe

Meeting with Henrik Dahl (Member of the European Parliament, Shadow rapporteur) and Amazon Europe Core SARL and EUROCHAMBRES – Association of European Chambers of Commerce and Industry

26 Mar 2025 · Simplification

Meeting with Ana Carla Pereira (Director Justice and Consumers)

24 Mar 2025 · Exchange of views on the Roadmap for Women’s Rights and the gender equality policies

Meeting with Anna Banczyk (Head of Unit Employment, Social Affairs and Inclusion)

20 Mar 2025 · Exchange of views on Vocational Education and Training (VET)

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and BUSINESSEUROPE and

19 Mar 2025 · SME intergroup breakfast

Meeting with Regina Doherty (Member of the European Parliament, Shadow rapporteur for opinion) and EUROPEAN TRADE UNION CONFEDERATION and

18 Mar 2025 · Public Procurement

Response to EU Start-up and Scale-up Strategy

17 Mar 2025

SMEunited supports the European Commission's goal to foster innovation and the development of businesses within the Single Market. In addition to start-ups and scale-ups, it is important that the proposed measures also benefit SMEs, which face challenges in their innovation capacities. For example, hurdles startups and scaleups face, such as access to finance, regulatory burdens, fragmentation, access to talent and infrastructure, resonate within the SME community. Additionally, a strategy to foster innovation should include access to data. To support SMEs innovation, the strategy should ensure they have access to investment and institutional support. SMEunited will share additional feedback soon.
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Meeting with Paul Speight (Head of Unit Environment)

17 Mar 2025 · REACH revision, chemicals regulation

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur)

14 Mar 2025 · Omnibus I

Meeting with Michael Wimmer (Director Secretariat-General) and BUSINESSEUROPE and EUROCHAMBRES – Association of European Chambers of Commerce and Industry

10 Mar 2025 · To discuss the Commission’s Better Regulation agenda with a specific focus on the SME test.

Response to Approvals of unilateral extensions of ETS2 scope and corresponding additional allowances

28 Feb 2025

A strong and competitive manufacturing base is a precondition for a competitive European economy able to grow and create jobs. SMEs play a key role in all the industrial ecosystems: in supply chains, as service provider and customer for sustainable products. If the ETS2 was extended to other sectors than road transport and buildings, SMEs could be significantly impacted. The price development is volatile and difficult to predict, which has negative effects on planning security. Instead of incentivising investments in clean technology, companies might hesitate to invest instead. Therefore, an extension of scope should only be allowed, if a comprehensive impact assessment involving concerned SME organisations was conducted. However, what remains is that different scopes in member states are contrary to a level playing field.
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SMEunited demands business water rights in EU resilience strategy

28 Feb 2025
Topic — A multi-annual plan to ensure European water security and long-term aquatic ecosystem management.
Message — SMEunited calls for the strategy to guarantee the right of economic activities to consume water. They propose focusing on enforcing existing rules instead of introducing new reporting obligations or usage restrictions. The organization also requests financial incentives and subsidized insurance to help small businesses manage climate-related water risks.123
Why — This approach protects small businesses from operational shutdowns and high administrative compliance costs.4
Impact — Environmental groups lose if prioritizing business water rights weakens strict conservation and restoration efforts.5
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Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

25 Feb 2025 · Omnibus

Meeting with Piotr Müller (Member of the European Parliament, Rapporteur)

20 Feb 2025 · Evaluation of the Public Procurement Directives

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

20 Feb 2025 · marchés publics

Meeting with Pär Holmgren (Member of the European Parliament)

19 Feb 2025 · Climate Risks

Meeting with Hana Genorio (Cabinet of Commissioner Jozef Síkela)

17 Feb 2025 · Introductory meeting

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

17 Feb 2025 · CID priorities

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

5 Feb 2025 · Omnibus

Response to Savings and Investments Union

3 Feb 2025

Europe needs more efforts to make progress with the creation of a European Capital Market Union (now savings and investment union), which allows SMEs to scale-up while keeping their business in Europe, and secure the necessary investments needed for the twin transition. Moreover, diversifying the financing landscape will further improve economic stability, and further mobilising private capital within the EU will increase our strategic autonomy. To allow this shift, the EU should motivate Member States to modernise their tax regimes in order to provide tax incentives for private investors to finance companies and to eliminate tax disincentives for equity finance within SMEs. Additionally, facilitating the process of public listing of SMEs and improving the participation of retail investors will mobilise the capital of all European citizens to further strengthen Europe. Finally, exploring the reintroduction of investment protection agreements, harmonising certain parts of insolvency regimes (especially in case of cross-border insolvencies), and expanding the role of ESMA will create consistency in enforcement and improve (legal) certainty for cross-border investments.
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Meeting with Hubert Gambs (Deputy Director-General Internal Market, Industry, Entrepreneurship and SMEs)

3 Feb 2025 · SME policy

SMEunited demands concrete roadmaps to remove single market barriers

31 Jan 2025
Topic — The Single Market Strategy 2025 aims to further develop the EU's internal market.
Message — SMEunited requests concrete roadmaps with clear timelines to remove barriers to the movement of goods and services. They advocate for a horizontal approach to simplify the regulatory landscape and reduce administrative burdens. They also seek improved access to alternative funding and fairer digital infrastructure.123
Why — Streamlined rules and better enforcement would lower costs and boost productivity for smaller firms.45
Impact — Large platforms and third-country importers lose their competitive edge from unfair practices and non-compliance.67
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Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

31 Jan 2025 · Simplification agenda of the Commission

Meeting with Julien Mousnier (Director Justice and Consumers) and

30 Jan 2025 · Annual Rule of Law Cycle – single market dimension

Meeting with Pascal Canfin (Member of the European Parliament)

30 Jan 2025 · EU policies and SME

Meeting with Alicia Homs Ginel (Member of the European Parliament, Rapporteur)

29 Jan 2025 · Effects of the Traineeships Directive for SMEs

Meeting with Svenja Hahn (Member of the European Parliament) and BUSINESSEUROPE and

29 Jan 2025 · Renew Europe Stakeholder Roundtable: “Elevator Pitch for Better Single Market Rules”

Meeting with Riikka Torppa (Cabinet of Commissioner Maria Luís Albuquerque)

27 Jan 2025 · Introductory meeting

Meeting with Jessika Roswall (Commissioner) and

24 Jan 2025 · Regulation regarding SMEs

Meeting with Terhi Lehtonen (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and Suomen Yrittäjät ry

23 Jan 2025 · To hear interest representatives’ view on SME issues in relation to the just transition.

Meeting with Christian Ehler (Member of the European Parliament) and Salzgitter AG

21 Jan 2025 · European Industrial Policy

Meeting with Henrik Dahl (Member of the European Parliament, Shadow rapporteur for opinion) and DIGITALEUROPE

15 Jan 2025 · AI Liability

Meeting with Grégory Allione (Member of the European Parliament)

15 Jan 2025 · Réunion SMEunited

Meeting with Pascal Arimont (Member of the European Parliament)

14 Jan 2025 · Framework conditions for SMEs when implementing the Green Deal

Meeting with Marie-Hélène Pradines (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

13 Jan 2025 · SME policy

SMEunited urges fairer public procurement rules for small businesses

6 Jan 2025
Topic — The European Commission is evaluating three directives governing public procurement and concession contracts.
Message — Member States should divide contracts into lots and stop ignoring the apply or explain principle. SMEunited also seeks reduced financial guarantees and an end to prioritizing the lowest price.123
Why — This would improve participation of SMEs and help innovative firms win more public contracts.45
Impact — Suppliers of traditional goods may lose market share to more innovative small competitors.6
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Meeting with Brigitte Van Den Berg (Member of the European Parliament)

9 Dec 2024 · Social policy and skills

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur)

5 Dec 2024 · discussions on Green Claims Directive

Meeting with Delara Burkhardt (Member of the European Parliament, Rapporteur) and L'Oréal and Procter & Gamble

2 Dec 2024 · Green Claims

Meeting with Nikola Minchev (Member of the European Parliament)

14 Nov 2024 · Meeting

Meeting with Susana Solís Pérez (Member of the European Parliament)

17 Oct 2024 · SME development

Meeting with Angelika Winzig (Member of the European Parliament)

4 Oct 2024 · Meeting with a representative of SMEunited

Meeting with Christian Ehler (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

4 Oct 2024 · Clean Industrial Deal

Meeting with Alessandra Moretti (Member of the European Parliament)

1 Oct 2024 · SMEs

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis), Nicolo Brignoli (Cabinet of Executive Vice-President Valdis Dombrovskis) and European Builders Confederation

24 Sept 2024 · Sustainable Finance

Response to Application of the ‘do no significant harm’ principle to the Social Climate Fund and its possible future extension

16 May 2024

SMEunited agrees that European Funds should not go to activities, which do significant harm to environmental objectives. However, when formulating guidelines to apply this principle, the related regulatory and reporting burdens have to be taken into account. A recent study from DG GROW (https://op.europa.eu/publication/manifestation_identifier/PUB_ET0524277ENN) shows that proving taxonomy alignment can create costs around 22.500 EUR for micro-enterprises and up to 125.000 EUR for SMEs, mainly for the do-no-significant-harm (DNSH) proofing. This is why the Commission in the context of sustainable finance is working on a radical simplification of requirements for SMEs. This work done by DG GROW and DG FISMA together with the Platform for Sustainable Finance should be taken into account, when formulating requirements for DNSH proofing to ensure that SMEs and especially micro-enterprises are able to access European Funds. Otherwise, the proposed measures undermine mitigating additional costs for micro-enterprises from the ETS2, in particular given the effects of the inclusion of small installations.
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Meeting with Maroš Šefčovič (Executive Vice-President) and

15 Mar 2024 · Clean Transition Dialogue for Cities

Meeting with Antoine Kasel (Cabinet of Commissioner Nicolas Schmit), Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit)

27 Feb 2024 · Action Plan for labour and skills shortages

Meeting with Mirzha De Manuel (Cabinet of Executive Vice-President Valdis Dombrovskis)

26 Feb 2024 · Upcoming Action Plan for labour and skills shortages

Meeting with Maroš Šefčovič (Executive Vice-President) and

22 Feb 2024 · Clean Transition Dialogue on Clean Technologies

Meeting with Svenja Hahn (Member of the European Parliament) and BUSINESSEUROPE and

21 Feb 2024 · Stakeholder Roundtable on Late Payment Regulation

Meeting with Martina Dlabajová (Member of the European Parliament) and BUSINESSEUROPE and

13 Feb 2024 · SME Intergroup event

Meeting with Nicolas Schmit (Commissioner) and

5 Feb 2024 · European Green Deal

Meeting with Maroš Šefčovič (Executive Vice-President) and

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

Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra)

30 Jan 2024 · SMEs and climate action

Meeting with Wopke Hoekstra (Commissioner)

30 Jan 2024 · Exchange of views on an EU climate policy fit for SMEs

Meeting with Philippe Lamberts (Member of the European Parliament)

24 Jan 2024 · European SME's

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

24 Jan 2024 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Response to Advanced alternative dispute resolution for consumers

22 Dec 2023

A simpler, faster and more accessible process would facilitate the settlement of disputes between businesses and consumers. However, it must not lead to further obligations for SMEs by becoming compulsory and extending significantly the scope. The objective set by the European Commission to reduce by 25% the administrative burden for SMEs paves the way and must be followed in every field, including ADR. If obligations are not lightened for SMEs, appropriate measures should be implemented to properly support and guide SMEs in this new framework. First, this system needs to be workable for SMEs. SMEunited stresses the necessity of implementing a voluntary system, free of charge for companies and a fast processing time to foster the use of this scheme. Indeed, the cost that this mediation scheme represents is a significant burden for European SMEs as the process falls entirely on the company responsibility. The appropriate support for SMEs should therefore be discussed to help them face these additional obligations. Secondly, SMEunited is against extending the scope to all goods and services as it automatically enlarges the process for SMEs. In addition, changes in the workload or regulatory ADR bodies would require additional resources (staff, administrative and financial resources) in order to properly tackle an increase of requests. Other difficulties such as procedural languages would appear and must be taken into account. The obligation of the company to respond to the ADR request within 20 working days under art. 5 § (8), is a burdensome proposal. The participation in the ADR system should remain voluntary, and give the company a reasonable response deadline. An unfair inequity would be created between parties as the consumer has one year to make a request while the company has only 20 days to provide an answer. Finally, SMEunited is in favour of removing the obligation of the trader to send a notification to ADR bodies when an agreement between the parties cannot be found. This proposal is a first step towards alleviating the obligations of SMEs, but will not be sufficient to compensate new ones imposed.
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Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton)

23 Nov 2023 · Late payment rules

Meeting with Izaskun Bilbao Barandica (Member of the European Parliament) and EuroCommerce

14 Nov 2023 · EC SME Assembly

Meeting with Martina Dlabajová (Member of the European Parliament) and BUSINESSEUROPE and EuroCommerce

14 Nov 2023 · Ad hoc delegation to the SME Assembly

Meeting with Pascal Canfin (Member of the European Parliament) and Novonesis A/S and Association of European Automotive and Industrial Battery Manufacturers

8 Nov 2023 · Green Deal

Meeting with Róża Thun Und Hohenstein (Member of the European Parliament, Rapporteur)

24 Oct 2023 · Combating Late Payments Regulation

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

18 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

Response to Adjusting size criteria for inflation in the Accounting Directive to define micro, small and medium-sized enterprises

6 Oct 2023

SMEunited believes the adjustment of the size criteria for micro, small, medium-sized undertakings in the scope of the Directive 2013/34/EU (Accounting Directive) is fair. Businesses are already struggling with the consequences of high and unstable inflation pressures. Additional bureaucratic struggles from falling outside the SME classification merely due to inflation are not justified. Thus, we welcome the revision of the thresholds within the Accounting Directive. However, specific rules for SMEs only exist where SMEs would otherwise face disproportionally high compliance cost due to size-related limits to their economic and organisational resources. Extending the definition of SMEs beyond the point where these specificities exist would go against its purpose. Consequently, we are observing the discussion started by the European Commission in the SME Relief Package on potentially including mid-caps in the SME definition with scepticism. The definition of midcaps must be taken up separately, and with separate measures. Therefore, SMEunited demands that changes of SME criteria remain limited to the alignment with inflation and are done cautiously.
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Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

29 Sept 2023

As a joint evaluation, SBS, EBC and SMEunited welcome the evaluation of Regulation 1025/2012 on European standardisation and is looking forward to fully engaging in the process, starting with this reply to the initial call for evidence. SBS, EBC and SMEunited support the current text of Regulation 1025/2012 and believes that the Regulation is still fit for purpose and that at this time it is not necessary to amend its main provisions. The focus should rather be put on their full and effective implementation. SBS, EBC and SMEunited believe that the main emphasis for a more complete and effective implementation should be put on articles 5 and 6 of the Regulation, concerning stakeholder participation in European standardisation and access of SMEs to standards both at European and national level. Please find more details attached.
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Response to Establishing the digital euro

7 Sept 2023

SMEunited - Craft and SMEs in Europe is in general supportive to the introduction of a digital euro. It has the potential to offer new payment services to small merchants, which is cheaper than the current dependence on international card schemes. However, these advantages can only be realised, if the pricing of the service does not exaggerate the real cost of the system, given that the Euro System is providing the infrastructure. Therefore, we welcome the provision to cap the fees, which is especially important for any interchange fee for banks providing the digital euro to costumers. In addition, SMEs are concerned about the fact that they have to accept digital euros, if they accept any other electronic payment. Such a provision makes a strict cost limitation for merchant even more important. SMEunited is currently working on a more detail position paper for the discussions during the legislative procedure and will provide additional comments as soon as a common position is agreed.
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Response to Compulsory licensing of patents

31 Jul 2023

In principle, a lean, uniform, efficient system in the internal market is welcomed instead of a patchwork of 27 different procedures across Member States. If supply chains cannot offer the provision of necessary services and goods in case of crisis, regulatory instruments that can ensure this functioning are supported. However, given the diversity and heterogeneity of crises (health crises, cyberattacks, energy crises, natural disasters, etc.), the question is whether a "one size fits all" initiative can actually apply here. It is essential that such an instrument be limited to the scope of what is absolutely necessary; its measures must be exceptional in nature. As soon as the crisis has ended or is declared to have ended by the responsible authorities, such an order must be revoked, as it is no longer lawful. Therefore, we insist on the following: Voluntary licensing must be given unconditional priority. Efforts to prevent compulsory licenses are welcome. It is of utmost importance that the rights and interests of the rights-holder and the licensee are assessed in the most diligent manner. We therefore welcome consultations of both parties upon which the most workable solution shall be found. Advisory boards must consult SME representatives, particularly in delicate matters like compulsory licensing. Compulsory licences should always be limited in time and more communication on the anticipated timeline is therefore necessary also in times of crisis. A procedure for identifying potential licensees needs to be established. You will find attached our more detailed position.
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SMEunited warns of reporting trickle-down burden on small businesses

7 Jul 2023
Topic — This consultation covers the first set of new European sustainability reporting standards for companies.
Message — They strongly encourage the development of a voluntary standard to reduce the burden on SMEs. They recommend narrowing the value chain definition to only include direct suppliers. They insist on a complete rewriting of the standard in an understandable language.123
Why — A voluntary standard would shield small firms from heavy administrative costs and bureaucratic jargon.4
Impact — Consumer groups lose transparency if reporting requirements regarding consumer impacts are entirely suspended.5
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Meeting with Andrus Ansip (Member of the European Parliament, Rapporteur) and TIC Council

4 Jul 2023 · Meeting on Green Claims

Response to European Critical Raw Materials Act

29 Jun 2023

SMEunited welcomes the initiative to increase the supply of raw materials that are too often scarce and furthermore needed for future-oriented technologies. Creating an assisting environment for raw materials projects, and binding procedural deadlines for Member States are a necessary start to make raw materials projects deliverable for SMEs. However, the proposal has a number of weaknesses, namely: 1. A European Critical Raw Materials Board is set up for coordinating and exchanging Member States performance. The Board may then report to the Commission without consulting stakeholders. This is not acceptable. SMEs must be represented in all meetings and discussions that concern them or their possible involvement in the raw materials value chains. 2. The proposed regulation has interlinkages with a large range of EU legislation (Net-Zero Industry Act, Single Market Emergency Instrument, Ecodesign Regulation, Chips Act), but also with currently implemented procedures such as Environmental Impact Assessments. Yet, it is unclear, whether the Regulation would take precedence over the existing rules, due to which the procedures are currently held up, and if not, how the time limits can be achieved. 3. The separation of critical and strategic raw materials appears sensible to account for both current and anticipated developments. However, there is no clarity on the relationship between the two categories and the methodologies for both need to be closely and continuously evaluated for transparency and effectiveness. To conclude, SMEunited believes that the currently outlined administrative support does not represent significant assistance for SMEs to deliver strategic projects. Ultimately, diversifying the supply of raw materials can only be achieved through diversifying our trading partners using tailored agreements.
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SMEunited calls for feasible 2040 climate targets and SME support

20 Jun 2023
Topic — This consultation seeks input on setting a 2040 climate target for the EU.
Message — SMEunited requests that the 2040 target follows a steady trajectory between 2030 and 2050. They demand feasible goals supported by technical guidance and separate carbon removal targets.123
Why — Realistic targets and market-based solutions would provide businesses with stability and competitive advantages.4
Impact — Foreign manufacturers in the paper and ceramics sectors would face higher costs via expanded taxes.5
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Response to Upgrading digital company law

9 Jun 2023

Already in its position paper during the call for evidence, SMEunited stressed that a European harmonisation of digital company law should not reduce what already exists in Member States, should ensure trust-worthy information and lead to a reduction of the administrative burdens. We welcome the principle of one-time registration of companies when establishing branches or a company in another Member State. SMEunited advocates for the better implementation of the once-only principle and this proposal goes in the right direction. Disclosure of information being sometimes a sensitive issue, we welcome the fact that the proposal only includes data strictly necessary. Together with the abolition of certified translations of company documents which is a relief in terms of time and costs, we also welcome the multilingual certificate which overcomes language issues entrepreneurs often face.
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Response to Promoting sustainability in consumer after-sales

24 May 2023

The Directive will have positive effects on repairers, a sector mostly composed of SMEs. Independent repairers have the right expertise, experience, and the necessary tools to offer high-quality repair services. The Directive rightly proposes that repairers should have access to spare parts and technical documentation. However, the Directive will certainly have an impact on retailers and manufacturers. SMEunited therefore demands to create a uniform European right of redress for the final seller who is often a SME. While SMEunited supports promoting repair as primary remedy, we have strong reservations to whether the Directive proposes a proportionate and targeted means of how to get to that end. Instead, we suggest a product-specific over a horizontal one-size-fits-all approach. Moreover, we object to another change in the legal guarantee law by amending the Sale of Goods Directive, which has only become applicable in early 2022. Legal guarantee law is an essential legal institution for all companies. It must be designed in a way that is practicable for consumers and businesses alike and provide legal clarity and planning stability to SMEs. In our view, a sound analysis of the transposition of this Directive and a fitness-check would be the better option. Regarding the objective of strengthening repair, it should be noted that the behaviour of consumers is shaped by a wide variety of aspects. When choosing between repair and new purchase, decision criteria such as economic efficiency, durability and the time required play an important role. A "right to repair" therefore only has the potential to significantly influence consumer behaviour if all other criteria are considered and accompanying measures are also created in these areas. We consider awareness-raising measures for a culture of repair, improving consumers knowledge about the existing rights in terms of legal guarantee, and financial incentives such as a VAT reduction for repair services to be preferable over further regulatory measures considering the cumulative effects of current Green Deal legislation.
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SMEunited demands simplified green claim rules for European SMEs

24 May 2023
Topic — The EU proposal requires companies to substantiate environmental claims using standardized footprint calculation methods.
Message — The association requests simplified substantiation criteria and an alternative verification scheme for smaller businesses. They advocate for EU-level tools to facilitate lifecycle analysis and help businesses comply. Additionally, they propose an assumption of conformity for small-scale marketing and local advertising.12
Why — Smaller companies would avoid excessive administrative costs and maintain a level playing field.3
Impact — Third-party verification providers would lose business if SMEs use alternative national schemes.4
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SMEunited urges slower f-gas phase-out and financial support

23 May 2023
Topic — The European Commission seeks strategies to accelerate heat pump market deployment across Europe.
Message — They request a longer phase-out of f-gases and simplified financial access. They propose a compensation mechanism for SMEs that train the specialized workforce. Access to blueprints and spare parts for repairs should also be improved.123
Why — Extending the transition period would lower immediate compliance costs and operational risks.45
Impact — Larger competitors would face higher costs if required to compensate SMEs for staff.6
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SMEunited demands fix-price energy contracts and easier energy sharing

16 May 2023
Topic — The EU is updating electricity market rules to lower prices and increase stability.
Message — Small businesses should be allowed to form cooperatives to access better power deals. The group also demands mandatory fix-price contracts and easier ways to share excess energy.12
Why — Small firms would benefit from lower electricity costs and protection against price spikes.34
Impact — Energy suppliers would lose market freedom due to mandatory fix-price contract requirements.5
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Meeting with Raphaël Glucksmann (Member of the European Parliament, Shadow rapporteur)

11 May 2023 · APA level - Forced labour

Response to Ecodesign for Sustainable Products - Product priorities

9 May 2023

The revised Ecodesign Regulation will have positive repercussions on the world of repairers, a sector mostly composed of SMEs. However, it will certainly have an impact on SMEs manufacturing these products but also supplying components to bigger manufacturers. Many SMEs manufacturing products or supplying components to bigger manufacturers will be effected by the extension of the ESPR to the broadest possible range of products. SMEunited believes that predictability and stable investment conditions should always be a priority when regulating products on the EU market. Taking into account the complexity of the product prioritisation, SMEunited supports the Commissions idea to regulate these details through delegated acts. However, given that the European Parliament is currently negotiating its position, including on the topic of product priorities, the European Commission must ensure that the results of this consultation must be presented to the committees involved as soon as possible. Furthermore, the methodology to clarify the prioritisation of these new product groups as proposed by the Commissions Joint Research Centre (JCR), needs to be updated in the light of the results of this consultation and the changes need to be highlighted. SMEunited proposes that the first Ecodesign working plan should take into consideration: a) Following a step-by-step approach to be able to evaluate the economic impacts; b) Prioritising those intermediate products that would make it significantly easier for SMEs involved in assembly or manufacturing of more complex products to define the digital passport for their products; c) Prioritising those products not covered by other regulations (including upcoming proposals); d) Paying attention to coherence with existing legislation (e.g. the Construction Products Regulation). The proposed amount of performance and information requirements for product categories overburden small and medium enterprises, considering their limited financial and human resources. Individual and tailor-made products, typically manufactured by SMEs, should be exempted from the Ecodesign requirements. For smaller batches, a presumption of conformity should be considered. The framework legislation requires the working plan to evaluate whether the implementation of the main potential measures identified in the assessment of environmental relevance would entail disproportionate costs (article 16(1)(a)). The original impact assessment states that the overall costs are hard to estimate before the detailed measures are proposed. Unfortunately, the JCRs draft technical report does not shed more light on this crucial point. SMEunited believes that the costs involved deserve a more thorough examination that involves the SME perspective and takes financial expenditure as well as human resources into account.
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Meeting with Anouk Faber (Cabinet of Commissioner Nicolas Schmit), Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit)

8 May 2023 · Meeting on youth policies

Response to Virtual worlds, such as metaverse

3 May 2023

SMEunited warmly welcomes the initiative by the European Commission to formulate EU ambitions based on developments in different kinds of immersive technology. Developments in the field of virtual worlds technologies will doubtlessly influence the possibilities to provide and gather information and with it whole business and customer relations. The combination of our current strong value based regulatory framework and an open environment for investments will be fundamental to strengthen the EU position in the development and standard-setting of virtual worlds worldwide. Balanced guidelines and standards that ensure a level playing field in the EU and globally are necessary for an inclusive and competitive future of the European economy. Investing in and (responsible) development of different kinds of deployment of technologies in which a digital space and a physical space complement each other, can enhance the competitiveness of the EU for the benefit of its citizens and businesses. It is of utmost importance to start working early on a strong regulatory framework that is aligned with existing trends and initiatives like the Digital Decade and that incorporates European values. It is in the nature of new digital technologies that their impact and further development cannot be fully foreseen and require agility in governance to timely adapt to such impacts and developments. Moreover, comprehensive conception is needed to stimulate innovation and competitiveness. Regulations must be complementary, not overlapping. Mismatches, contradictions or unnecessary burdens must be avoided. SMEunited is a proponent of a risk-based and learning approach because it is balanced and not discouraging SMEs. Any initiatives from the EU should include feasible options for small and medium sized companies to participate. Needless to stay, an attractive environment for investments in the field of immersive technologies is one of the most important aspects in this regard. We believe it is important for EU Member States to strengthen collaboration, research cooperation, and develop market-driven standards in emerging technologies such as immersive technologies. In this regard, SMEunited welcomes that this initiative is not only about virtual worlds in a narrow sense, but covers virtual worlds technologies including Virtual Reality (VR) and Augmented Reality (AR) on a broader scale. The EU should investigate how to stimulate or facilitate these processes without unnecessary or detrimental protective measures.
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Meeting with Philippe Lamberts (Member of the European Parliament)

2 May 2023 · Beyond Growth

Meeting with Tom Vandenkendelaere (Member of the European Parliament)

2 May 2023 · ongoing IMCO files

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and Potsdam-Institut für Klimafolgenforschung

27 Apr 2023 · ETS

Meeting with Marcel Kolaja (Member of the European Parliament, Shadow rapporteur)

27 Apr 2023 · discussions about the potential impact of the Product Liability Directive on SMEs

Meeting with Martin Hojsík (Member of the European Parliament, Shadow rapporteur)

24 Apr 2023 · Classification, labelling and packaging Regulation, chemicals

Meeting with Mirzha De Manuel (Cabinet of Executive Vice-President Valdis Dombrovskis)

20 Apr 2023 · Economic Governance review, SME relief package, Corporate Sustainability reporting, Retail Investment package, competitiveness, traineeships.

Meeting with Margrethe Vestager (Executive Vice-President) and

20 Apr 2023 · Platform to Business regulation, data act, SME package

Meeting with Kadri Simson (Commissioner) and

20 Apr 2023 · Exchange on SME challenges in greening the economy and in particular the Sustainable Product Initiative and energy transition, also exchange on electricity market design and EPBD.

Meeting with Sándor Rónai (Member of the European Parliament)

18 Apr 2023 · PPWR Regulation

Meeting with Stelios Kympouropoulos (Member of the European Parliament, Shadow rapporteur)

18 Apr 2023 · Meeting on Strengthening Social Dialogue

Response to Interim Evaluation of the InvestEU Programme

14 Apr 2023

Reinforce the SME window and other funding / financing tools for SMEs SMEunited supports Commissioner Bretons proposal to reinforce the SME window and other funding / financing tools for SMEs. Many SMEs have either invested their savings or taken up additional loans to stay afloat during the pandemic. Now they lack the investment capacity to ensure upfront financing for investments in energy transition, digitalisation and so on. At the same time, SME financial instruments available via the SME Window of InvestEU are not sufficient. The first calls are already heavily over-subscribed and most of the budget comes from Next Generation EU, which means it is only available for the next two years. Therefore, the review of the Multiannual Financial Framework should increase the budget available for the SME finance from InvestEU.
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Meeting with Krzysztof Hetman (Member of the European Parliament, Shadow rapporteur)

29 Mar 2023 · Exchange of views on Forced Labour Regulation (meeting delegated to parliamentary assistant)

Meeting with Ursula von der Leyen (President)

27 Mar 2023 · Meeting with President SMEunited

Meeting with René Repasi (Member of the European Parliament, Shadow rapporteur) and Affordable Medicines Europe and Independent Retail Europe (formerly UGAL - Union of Groups of Independent Retailers of Europe)

20 Mar 2023 · Binnenmarktnotfallinstrument/ Single Market Emergency Instrument (SMEI) - Staff Level

Response to Enhancing the convergence of insolvency laws

17 Mar 2023

Key messages The proposal delivers on two of its core objectives: o Reducing information and learning costs for cross-border creditors and consequently increasing legal certainty as regards the outcomes of insolvency proceedings through the provisions on Creditors committees Tracing assets Enhancing transparency of national insolvency laws o Raising the average recovery value in liquidation cases through minimum provisions on Avoidance actions Directors duty to request the opening of insolvency proceedings SMEunited welcomes simplified administrative proceedings with lower procedural costs for insolvent microenterprises and increased efficiency of quick and simple winding-up procedures. o However, close attention needs to be paid to minimising the complexity and to ensuring the practicability of an insolvency procedure resting solely on the shoulders of entrepreneurs. o Proceedings without an insolvency administrator can be quite challenging for micro-enterprises. Precise rules are necessary to ensure the protection of creditors and to prevent both intentional and unintentional misuse of the freedoms gained by the Directive. The proposal, in some parts, lacks clarity and transparency on the ways and means of enhancing insolvency proceedings. This is problematic for the transposition phasein which the degree of harmonisation will be ultimately decided, but also for creditors whose protection should be ensured. o This is most striking in the case of the pre-pack proceedings. While a quick and efficient sale of a business in a functioning state is desired by all parties involved, it does not become clear how pre-pack proceedings can achieve that. Finally, the limitation of the number of creditors in the creditors' committee to a maximum of 7, does not ensure that the interests of all categories of creditors are sufficiently represented. See our full position paper attached
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Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion) and BUSINESSEUROPE and

16 Mar 2023 · CMRD6

Response to Key performance indicators for the Digital Decade policy programme 2030

13 Mar 2023

Position paper on the draft key performance indicators for the Digital Decade policy programme 2030 SMEunited supports the introduction of indicators that identify areas in which digitalisation is still lacking or progressing slowly. These indicators should therefore focus on essential competences and capacities that are necessary for the vast majority of business to remain competitive in the future and facilitate innovation. SMEunited is sceptical that the proposed indicators really allow a representative interpretation of digitalisation. Among SMEs digitalisation is not carried out for the sake of digitalisation, but when concrete opportunities to improve the business model arise. We can certainly not agree with the statement in recital 2 that The KPIs set out in this Decision reflect the best possible measurements of the progress towards the digital targets. On the contrary, in our opinion they are certainly not smart, not attainable and not measurable. Some of the indicators are even completely irrelevant for measuring the so-called digitalisation of SMEs/enterprises. This is the case for example with Article 2, 1 (10) Artificial intelligence, measured as the percentage of enterprises using at least one artificial intelligence technology. WAZE for example, a community-based traffic and navigation app using AI, is already used by millions of individuals and companies. Using this indicator is consequently irrelevant and cannot be seen as an indicator for the deliberate use of AI by a company. The question is also how the surveyed persons are aware that AI is used in a technology. Also the KPI mentioned under (11): SMEs with at least a basic level of digital intensity, measured as the percentage of SMEs using at least 4 of 12 selected digital technologies is unclear, not measurable. What means basic level of digital intensity? What is the relevance of 4 of 12 selected digital technologies? There are also still some remaining open questions: O Will there be adaptations during the period of application (till 2030) (e.g. 6G could perhaps become relevant within this time period)? O How will KPIs be measured in individual Member States (eg Quantum Computing, which is more relevant on European level).
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Meeting with Thierry Breton (Commissioner) and

10 Mar 2023 · European SME policy

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Frans Timmermans (Executive Vice-President)

27 Feb 2023 · SME dimension in the implementation of the European Green Deal, in particular in relation to the Green Deal Industrial Plan and circular economy proposals

Meeting with Jan Huitema (Member of the European Parliament, Shadow rapporteur)

24 Feb 2023 · Ecodesign for Sustainable Products Regulation

Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton)

13 Feb 2023 · EU SME policy and SME relief

Response to New Agenda for Latin America and the Caribbean

9 Feb 2023

Europe is deeply connected with Latin America and the Caribbean (LAC) by common languages, history, culture and commerce. Faced with an unprecedented multitude of crises, it is crucial to deepen our economic and diplomatic ties with the LAC region. War on the European continent and clogged supply chains originating from closed harbours in China showed the urgent need to diversify trading partners and reduce dependencies. At the same time, it is important to also focus on strengthening political cooperation with the LAC region. The economic and political pillars are interrelated and economic ties will not grow until regular political dialogue is reinforced. Attached our more complete comments on the matter.
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Meeting with Morella Siemers (Cabinet of Commissioner Ylva Johansson)

2 Feb 2023 · the European Year of Skills 2023

Response to Review of the Designs Directive

31 Jan 2023

SMEunited welcomes the initiative by the European Commission to update EU design protection rules. For SMEunited, the updated rules bring breakthroughs in 3 particular areas: 1. Clarifying that designs developed as part of employment relationships belong to the employer, 2. Outlining administrative invalidity proceedings as a more cost-effective and easier alternative to court procedures and 3. Establishing a permanent repair clause that still leaves room for improvement. See attached our more detailed position.
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Response to Review of the Community Designs Regulation

31 Jan 2023

SMEunited welcomes the initiative by the European Commission to update EU design protection rules. However, not all revisions and additions contribute to clearer and simpler rules for SMEs, e.g. limiting design strictly to visible components or delegating power in delicate matters such as appeal proceedings. Also, reducing the fees of the European Union Intellectual Property Office is one of the most important aspects for SMEs. The potential was however not fully exploited. See attached our more detailed position.
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Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur) and Anti-Slavery International and Responsible Business Alliance

26 Jan 2023 · Forced Labour ban

Meeting with Nicola Danti (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

25 Jan 2023 · Stakeholder consultation on the CRA

Meeting with Maria Luisa Llano Cardenal (Cabinet of Vice-President Margaritis Schinas)

11 Jan 2023 · European Year of Skills (with Cabinet Commissioner Schmit)

Meeting with Anouk Faber (Cabinet of Commissioner Nicolas Schmit), Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit)

11 Jan 2023 · Meeting on the European Year of Skills

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.

Response to Single Market Emergency Instrument (SMEI)

13 Dec 2022

Although SMEunited supports the basic idea of moving away from ad-hoc measures by individual governments in crisis situationsthe draft of the Single Market Emergency Instrument (SMEI) still leaves many questions open and contains obligations for companies that require further discussion and change. First of all, SME representatives participation to the Advisory Group should not be limited to only gathering information. The SMEI will have a significant impact on SMEs and SME representatives must be consulted in the decision making process. Also, the criteria according to which the various crisis modes can be activated are formulated far too vaguely. Instead of providing much-needed legal certainty, this could have exactly the opposite effect. Furthermore, The necessity and proportionality of certain obligations are insufficiently substantiated to restrict the freedom of enterprise to this extent. The monitoring obligations, the strategic reserves, the priority rated orders are obligations that will lead to breach of fair competition, of contractual trust and can lead to severe bankruptcies and the SMEI does not take the downside effect of these measures into account. The instrument should not only be about sanctions, but bring forward incentives for companies. For instance, the strategic reserves measure could be complemented with a mention of fiscal or financial incentives. It is also deceiving that the SMEI do not focus more on joint EU public procurement of crisis-relevant goods and services as the way out of any crisis Lastly, we insist that the mechanism of the SMEI must remain of temporary application and cannot become the rule.
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SMEunited urges proportionate cybersecurity rules to protect small businesses

12 Dec 2022
Topic — This initiative sets cybersecurity requirements for manufacturers and vendors of digital products.
Message — SMEunited requests precise definitions and proportionate requirements to protect small operators. They propose use-case-based risk classification and simplified verification procedures for distributors. Finally, they insist that sanctions must not threaten the survival of smaller firms.123
Why — Standardized rules and increased transparency would provide small businesses with a competitive edge.4
Impact — Consumers may face increased risks if retailers have limited responsibilities for verifying product safety.56
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SMEunited urges EU to keep 500 Euro liability threshold

9 Dec 2022
Topic — The EU is updating product liability rules for digital products and software.
Message — SMEunited insists on keeping a 500 Euro limit for claims and requests a 24-month implementation period. They demand clearer definitions for product defects to provide certainty for small firms.123
Why — Maintaining thresholds and clearer rules would protect small businesses from potential insolvency.45
Impact — Consumers would lose the ability to claim compensation for low-value product damages.6
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Meeting with Nicolas Schmit (Commissioner) and

9 Dec 2022 · Social Dialogue initiative.

SMEunited warns forced labour ban threatens small business survival

30 Nov 2022
Topic — The European Commission proposed a ban on all products made using forced labour.
Message — SMEunited demands a mandatory impact assessment and an SME test before adopting the regulation. They insist public authorities should prove violations rather than burdening small business owners. Supporting tools must also be operational before any enforcement begins.123
Why — This would shield small businesses from facing disproportionate sanctions for unknown supply chain violations.45
Impact — National authorities would bear the full administrative burden and cost of investigating complex supply chains.67
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SMEunited seeks legal clarity on European AI liability rules

28 Nov 2022
Topic — The European Commission is proposing new liability rules for AI-enabled products.
Message — SMEunited wants rules to consider the resources of smaller economic actors. They argue the definition of AI remains unclear and demand consistency with other digital laws.123
Why — This approach would lower cross-border trade risks for small enterprises.45
Impact — Tech developers face uncertainty regarding overlapping liability for connected devices.67
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Meeting with Nicolas Schmit (Commissioner) and

22 Nov 2022 · The European Year of Skills policies, the Vocational Education and Training (VET).

Meeting with Agnieszka Skonieczna (Cabinet of Commissioner Thierry Breton)

17 Nov 2022 · Energy crisis and SMEs; SME relief package

Meeting with Anouk Faber (Cabinet of Commissioner Nicolas Schmit), Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit)

16 Nov 2022 · Meeting on the Year of Skills

Meeting with Nicolas Schmit (Commissioner) and

8 Nov 2022 · Social Dialogue Initiative.

Meeting with Karolina Herbout-Borczak (Cabinet of Commissioner Stella Kyriakides), Ralf Kuhne (Cabinet of Commissioner Stella Kyriakides)

13 Oct 2022 · VTC meeting on Food Waste and Food Labelling

SMEunited urges ECHA efficiency to limit SME bureaucratic burden

10 Oct 2022
Topic — A legislative initiative to modernize European Chemicals Agency governance and financing.
Message — SMEunited wants ECHA to gain resources by optimizing administrative procedures. They also advocate for transferring resources saved by Member States to the agency.12
Why — Avoiding new costs helps SMEs manage the complexity of chemicals legislation.3
Impact — Member States would see their budget resources shifted to the central agency.45
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Response to Strengthening social dialogue

30 Sept 2022

In view of the technological evolution, the significance of vehicle-generated data increase and the shift towards environmentally-friendly fuels and power trains, SMEunited welcomes the proposal of the European Commission for a revision of the EU Regulation 461/2010, which provides for a five-year extension of the exemption of the Regulation for the motor vehicle category (MVBER) and the simultaneous review of complementary guidelines on vertical restraints in the agreements for sale, repair and distribution of spare parts for vehicles. The initiative aims to extend the Motor Vehicle Block Exemption Regulation and it constitutes an important step towards strengthening the current legislation, facilitating overcoming restrictions and criticalities in access to technical information of manufacturers persistent to the detriment of independent operators, thus limiting repair and further maintenance of vehicles. SMEunited believes that free access to technical information is a priority objective to be achieved in compliance with the principle of fair competition and a level playing field for all market participants. For a better effectiveness and coherence, the needs of the automotive repair industry have to be taken into account in regulation. To this end, it is necessary to establish proper conditions for an effective balance in the single market between authorized and independent operators with regard to access to technical information. Consequently, this will positively affect all stakeholders. Auto repair and maintenance is regularly carried out by micro, small and medium-sized companies, being in close proximity to consumers and thus contributing to the development of local markets. Independent operators offer professional premium service that meets the needs for proper, safe and environmentally-friendly use of vehicles in a timely manner, enhancing overall mobility of citizens and the entire transport sector. In addition, a free access to technical information of manufacturers will boost innovation in the automotive sector and in mobility, improving quality, choice and prices of services provided to consumers, while taking into account cybersecurity and protection of personal data concerns. SMEunited points out the relevance of the above mentioned pending issues for the motorcycle after sale market, and therefore suggests to extend the scope by also including this market, or, otherwise, to consider addressing these issues in a dedicated regulation.
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Meeting with Catharina Rinzema (Member of the European Parliament)

1 Sept 2022 · SMEs

Response to Review of the de minimis aid Regulation

19 Jul 2022

SMEunited welcomes the possibility to give feedback and comments for the up-coming review of the de-minimis regulation. Even if we agree that the current regulation is in principle fit for purpose as the result of the fitness check in 2019 has shown, SMEunited and its members want to restate some suggestions to improve the current regulation further, when reviewed for 2023: SMEunited welcomes the intention to increase of the de-minimis threshold in line with the inflation rate to ensure that the real amount of aid provided under the de-minimis regulation is stable. However, when increasing the threshold the European Commission should also reflect on the impact of higher thresholds on competition between SMEs at local and regional level. SMEunited supports the introduction of a mandatory register, which would provide more transparency about who receives such aid and – even more important – it will reduce the administrative burden for companies who currently use a self-declaration system. However, such a register - especially if it is a public one - has to ensure that competitors and other companies will not have access to business secrets of other companies via such a register. Therefore, such are register should only be accessible for provider of State aid or the public available information may only cover the amount but not the purpose of a specific aid provided. Some national members complain about the high burden related to very small amounts of aid (i.e. seminars, advisory services, etc.), which often are below € 1000 and create fully unproportionate administrative burdens for both the SMEs and the provider of aid (i.e. craft chambers) without risking to come even close to the overall threshold for deminimis. If the introduction of a mandatory register fails again, the European Commission should provide a less burdensome solution for this very small amounts of aid. Furthermore, SMEunited insists that the new regulation should again include safe harbour measures for loans and guarantees (method to calculate the gross grant equivalent). Finally, SMEunited asks for a proper public consultation on the draft review for the regulation.
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Response to Geographical indication protection at EU level for non-agricultural products

13 Jul 2022

SMEunited warmly welcomes the proposal for a Regulation on geographical indications for non-agricultural products as we have been advocating for it for decades. Therefore it has to be ensured that it will be adopted still during this Commission mandate. - The proposal proves its worth in establishing a strong protection system at European level for the GIs of craft and industrial products. - We support the initiative as it can enhance possible growth of local businesses represented in terms of economy, employment and the development of tourism and culture. - The text must clearly define in a specific article the objectives of the regulation. - We believe the regulation must include a clear control on possible irregularities by Member States. - A new procedure must ensure it does not create a burden on SMEs with a complex process to obtain an EU-wide protection. You will find our detailed position attached.
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Meeting with Alexandra Geese (Member of the European Parliament) and Deutscher Gewerkschaftsbund and

29 Jun 2022 · Event: Repowering the Recovery - RRF one year on

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 Nicolas Schmit (Commissioner) and

21 Jun 2022 · The situation in Ukraine, Minimum Wage, Labour and skills, Social reforms, platform work, Individual Learning accounts.

Meeting with Nicolas Schmit (Commissioner) and

21 Jun 2022 · EU response to the conflict with Ukraine, Labour & skills shortages, social reforms, platform work, Individual Learning Accounts.

SMEunited demands realistic forced labour rules for small businesses

20 Jun 2022
Topic — This consultation addresses a ban on products made with forced labour.
Message — Legislation must include public authorities as fighting forced labour exceeds the power of entrepreneurs. Existing guidelines are not adapted for small businesses and lack a reality check.12
Why — SMEs would avoid being tasked with complex site inspections they cannot perform.3
Impact — Public authorities would bear more responsibility if enforcement duties are not privatised.4
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Response to Open finance framework

30 May 2022

SMEunited supports all initiatives, which facilitate access to finance of SMEs. Improving access to data can improve access to finance from third parties. However, for SMEs it is important to control access to their data. This means, even if SME data are stored at a platform or similar locations, the SMEs must have control over who can access them.
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Response to Cyber Resilience Act

25 May 2022

SMEunited welcomes the initiative for harmonised rules regarding cyber resilience. Manufacturers and developers must be liable to ensure cybersecurity, not sellers. The Cyber Resilience Act must be precise regarding when cybersecurity must be ensured: assessments during the whole lifetime of a product would be costly. We recommend a mixed approach, combining both soft and hard rules. Considering the pace at which cyber threats evolve, the Commission should pay close attention to the ways in which these policies can be swiftly yet reliably amended or supplemented. Attached our detailed position.
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Response to Empowering the consumer for the green transition

25 May 2022

See attached SMEunited position paper.
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SMEunited warns Due Diligence Directive risks overburdening small businesses

23 May 2022
Topic — This consultation concerns new sustainability due diligence requirements for companies and their supply chains.
Message — SMEunited demands safeguards to prevent large corporations from shifting compliance burdens to small suppliers. They request simplified guidance tools developed in collaboration with small business organizations.123
Why — Avoiding direct regulation helps small firms bypass expensive costs and complex legal requirements.45
Impact — Large corporations lose the ability to offload expensive compliance tasks onto smaller supply chain partners.67
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Response to Streamlining EU scientific and technical work on chemicals through the EU agencies

7 Apr 2022

We support the streamlining and optimisation of the EU’s public administration in general, but also in the area of chemicals legislation. Existing resources should be used more efficiently. Cooperation between EU and national agencies is crucial for a better usage of resources. So are identifying synergies and overlaps in their line of work. Furthermore, the role, tasks and expertise of each agency should be clearly defined and exploited in a targeted manner. Agencies should stay within their assigned areas of duty and abstain for example from political interventions. Since the administration of chemicals legislation especially for SME became heavier and is expected to become even more burdensome, some of the freed resources should be also used to better support these companies.
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Meeting with Nicolas Schmit (Commissioner) and

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

Meeting with Mirzha De Manuel (Cabinet of Executive Vice-President Valdis Dombrovskis)

16 Mar 2022 · SME policies and participation in standard setting.

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

9 Mar 2022 · Sustainable product policy and consumer empowerment for the green transition

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

9 Mar 2022 · Sustainable product policy and consumer empowerment for the green transition

Meeting with Margrethe Vestager (Executive Vice-President) and

4 Mar 2022 · Single Market Emergency Instrument and Data Act

Meeting with Valdis Dombrovskis (Executive Vice-President) and

3 Mar 2022 · Social Dialogue, implementation of national recovery and resilience plans and decent work

Meeting with Nicolas Schmit (Commissioner) and

2 Mar 2022 · Social dialogues initiatives.

Response to Evaluation and revision of the Weights and Dimensions Directive

21 Feb 2022

SMEunited welcomes the planned increase in the maximum permissible weights and dimensions. The increase of the maximum permissible gross weights of HGVs with heavy superstructures (crane, grab, tipper) should be made possible. The EU directive concerning the maximum permissible dimensions for certain road vehicles in national and national and international traffic within the Union and the maximum permissible weights for maximum permissible weights in cross-border traffic does not allow such a provision, which is why, within the framework of the revision of the EU Directive in question, the maximum permissible gross weights of the vehicles listed in Annex 1, point 2, should be increased by should be increased by 10%. Increasing the maximum permissible gross weights has numerous advantages: - Reduction of lorry mileage, which cushions the steadily growing volume of traffic. - Reduction of CO2 emissions - Reduction of fuel consumption - Reduction of noise and dust - More efficient loading through higher payloads With regard to the transition to electric mobility, the weight adjustment to compensate for the higher weights is sensible and necessary because new drive technologies increase the weights. This also applies in particular to commercial vehicles of class N 3. However, the use of alternative drive technologies also leads to an increase in the tare weight of vehicles of classes M1 and N1. This reduces the payload, which could only be solved by increasing the limit for M1 and N1 (3.5 t hzG), which in turn would require changes in trade, traffic and driving licence law at national, EU and international level. Under no circumstances should the maximum permissible gross weight of trucks be limited to 40 tonnes. This would directly affect the transport of mineral building materials and timber. Restricting the maximum permissible weight to 40 tonnes only leads to an increase in the number of lorries on the roads in order to be able to transport the same quantities and thus to higher CO2 emissions and congestion potential. Such a restriction leads to additional costs, inefficiency, increased fuel consumption and thus, in sum, to higher environmental pollution. Regarding the proposal concerning the alignment of the maximum permitted dimensions, it should be noted that it would be favorable to introduce the possibility of having a longer semi-trailer, rather than favoring the coupling of trailer and semi-trailer, increasing their lengths. In fact, the introduction of an extended semi-trailer allows the load volume to be increased without making changes to the wheelbase and can be applied to any location, regardless of morphological and road configuration. For example, it is increasingly common to introduce roundabouts which, in effect, restrict the access of excessively long vehicles.
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Response to EU standards for safe and secure parkings

10 Feb 2022

SMEunited welcomes the initiative of the European Commission to make parking areas in the EU safer and more suitable for the function they have to perform. In particular, the draft delegated act integrating Reg. n. 561/2006 of the European Parliament and of the Council contains important elements to guarantee operators ideal conditions to carry out their work, thus protecting the main resource of road transport. First and foremost, it is considered essential to increase the safety standards to which each rest area must adhere. In fact, it is not acceptable that operators should have to worry about their own safety and of the load they are transporting when they make a stop, as ensuring that there are conditions to be able to rest properly is fundamental to reduce the risk of accidents due to fatigue and stress. SMEunited agrees on the urgency of providing transparency and certainty to operators passing through the above-mentioned areas, also thanks to controls carried out by independent bodies. However, the insufficient availability of save and secure parking areas is still a big issue. It forces operators to park in unsecured locations, often leading to cargo thefts that put the drivers at risk and cause losses for companies. A 2019 study (https://sstpa.eu-study.eu/results/) shows that often there is insufficient parking capacity or inadequate facilities, as well as a lack of information on such facilities. So even when the standards are good, this does not help operators if there is no place to park. It is therefore necessary to address these issues, such as the amount and the geographical spread of the SSTPAs. This includes information on where these parking areas are located, which facilities they have, and what their capacity is, preferably updated in real-time so drivers can see where they can go for the night. Finally, it is necessary to ensure that all service areas have toilets, the possibility to buy and consume food and drinks, and emergency hot spots.
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Meeting with Maria Luisa Cabral (Cabinet of President Ursula von der Leyen)

10 Feb 2022 · the European Year of Youth

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 Alexandra Cupsan-Catalin (Cabinet of Commissioner Ylva Johansson), Asa Webber (Cabinet of Commissioner Ylva Johansson)

15 Dec 2021 · Pact for Asylum and Migration

Meeting with Mirzha De Manuel (Cabinet of Executive Vice-President Valdis Dombrovskis)

26 Nov 2021 · Exchange of views on the forthcoming legislative proposal on platform work

Meeting with Nicolas Schmit (Commissioner) and

19 Nov 2021 · The social dialogue initiative

Meeting with Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit)

16 Nov 2021 · Participation at the Training Committee of SME United.

Meeting with Renate Nikolay (Cabinet of Vice-President Věra Jourová)

10 Nov 2021 · Data flow

Response to Revision of the specifications for EU-wide real-time traffic information services (Delegated Regulation 2015/962)

7 Nov 2021

Feedback of SMEunited SMEunited in coordination with its members welcomes the inclusion of infringements against cabotage rules and does not object to the inclusion of other infringements based on legislative changes introduced by the Mobility Package I. SMEunited does not support the categorisation of infringements according to the level of seriousness. The proposed classification is completely intransparent as no criteria are listed that justify the categorisation of serious (SI) and very serious (VSI) infringements. Thus, to us it appears as if this categorisation is executed on the basis of subjective viewpoints rather than objective criteria. We also object to the automatic classification of newly added infringements of regulation 561/2006 as serious infringements. In addition, a clear distinction should be made between intentional fraudulent falsification of documents and obvious mistakes. The latter should be categorised as minor infringements. Furthermore, SMEunited suggests a re-evaluation of the present classification of serious and very serious infringements according to objective and transparent criteria. Last but not least point 13 “Infringements against Regulation (EC) No 593/2008 (Rome I)” definitely must be concretised as it is unclear which provisions of Rome I are concerned. Otherwise the rule of law cannot be guaranteed.
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Response to Food waste reduction targets

29 Oct 2021

SMEunited shares the Commission's objective of working to reduce food waste. A reduction in food waste and surpluses is of primary importance both for reasons related to the improvement of environmental sustainability and for what concerns the reduction of production costs faced by Crafts and SMEs. However, as almost 50% of food waste is produced in EU households, reduction targets cannot be reached by addressing small food businesses alone. Small businesses often lack information as well as staff and resources to integrate food waste prevention practices and introduce measurement tools. SMEs require support as well as financial incentives (e.g. tax incentives on donation, reduction of waste management fees) to facilitate this transition. SMEunited recommends targeted information campaigns and guidelines for small food businesses on how to manage food waste (developed by European and national institutions), food surpluses and food donation. Particularly the latter, however, urgently requires the revision of product liability, to be truly feasible. To facilitate the contribution by SMEs, it is important to harmonise across the EU several administrative procedures that might hinder food or feed donations. Whenever it is safe to re-use food products or donate them, this should be incentivised. For this purpose, the EU should encourage member states to closely review certain administrative policies such as difficult taxation of donation or bureaucratic burden. SMEunited while agreeing with the objective of the overall reduction, stresses the importance of not burdening SMEs with additional compliance burdens, such as the possible keeping of records, regarding protocols drawn up for measuring and reporting the same waste, which should, among other things, be shared among the EU countries themselves, to spread practices aimed at reducing food waste as much as possible. Finally, about food waste reduction targets, it is preferable for the European Commission to set differentiated targets for each Member State, thus considering their specific characteristics. We would like to highlight the important distinction between avoidable and unavoidable food waste: many figures include the unavoidable part, such as fruit peels, bones or products that have become inedible due to mould. All efforts related to food waste reduction should only refer to the avoidable food waste. SMEunited views on a food waste reduction target are preliminary. We will provide more detailed input to the upcoming public consultation, after the consultation of our members. Furthermore, we would like to be part of the upcoming targeted consultations and events on the matter.
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Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion)

29 Oct 2021 · social affairs

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

28 Oct 2021 · Upcoming legislative initiative on platform work and other initiatives in social affairs.

Response to Sustainable food system – setting up an EU framework

26 Oct 2021

SMEunited welcomes the opportunity to comment on the Commission’s Inception Impact Assessment on EU sustainable food system. We agree that a holistic approach in the EU food systems is crucial to improve its sustainability and resilience across the whole European Union. Cooperation between different actors in the food chain should be encouraged and facilitated. We also agree that the EU has achieved high levels of food security, food safety and a varied choice of food products for the consumer. There are, of course, challenges in the food system that need to be addressed, and we are willing to do our part in contributing to a more sustainable future for both businesses and consumers. However, we believe that sustainable food production must necessarily pass through the identification and development of new business models, in which the necessary conditions must be present to allow Crafts and SMEs to be able to take advantage of the new opportunities offered. The adoption of sustainable business practices may become particularly difficult due to the lack of specific information, specific technical skills, organisational skills, and adequate financial resources. In this regard, the European Commission is urged to support Crafts and SMEs no matter the policy options it has identified and intends to achieve. When designing a horizontal regulatory instrument at EU level, meant to coordinate and drive change across the food systems, SMEunited insists that the better regulation principle as well as the SME test have to guide the Commission’s policy-making. It is considered of fundamental importance that the introduction of requirements relating to the food sustainability of a given product are introduced progressively, to allow Crafts and SMEs to adapt to the new rules without running the risk of having their production capacity damaged. SMEunited views on a EU sustainable food system framework are preliminary. We will provide more detailed input to the upcoming public consultation, after the consultation of our members. Furthermore, we would like to be part of the upcoming targeted consultations and workshops.
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Response to Short-term rental initiative

14 Oct 2021

SMEunited agrees that Short Term Accommodation Rental services are indeed a fast-growing sector that can create opportunities for businesses, in particular SMEs. We also believe that ensuring a level playing field is essential so that unfair competition between the various providers is avoided. It should be stressed however that whatever rules are introduced, they need to be simple and easy to be applied and enforced. Undue administrative burdens for SMEs, who constitute the majority of providers in the sector, has to be avoided. This approach should also be applied to the collection of data by public authorities, by fully implementing the “once only” principle (OOP) while at the same time full compliance with GDPR should be ensured. Guaranteeing effective market access and removing unnecessary market access barriers is also vital as is the principle of proportionality. However we do not completely agree with the statement in the IIA that STR services on a purely occasional basis should not be faced with the same regulatory requirements that apply to professional hosts. Indeed also occasional STR services should respect some minimum quality standards and guarantees (fire insurance , fire safety certificate,…). The issue remains in any case how to differentiate between occasional and professional. One issue that we also consider important is that measures should be introduced to fight tax evasion as this is not only illegal but can lead to unfair competition with all negative consequences. Taken into account also the possible negative impact on the local housing market and the sustainable development of cities, local authorities should be allowed to take the necessary measures in the field of urban planning.
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Response to Review of the general product safety directive

4 Oct 2021

Key messages According to SMEunited the proposal contains several provisions and approaches which are very positive, such as: - the need for uniform market surveillance in the EU, - the general approach to AI, - the formal recognition of the imbalance between the rules for physical stores and those for digital platforms. However SMEunited evaluates negatively the approach to penalties, their amount and the possible publication of the identity of the economic operators in case of infringement. In the case of unsafe products and of products not complying with labelling obligations, distributors should be deemed responsible solely of informing the manufacturer or importer, and the competent authorities. For more details, see our attached position paper.
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Response to Revision of Regulation (EC) 648/2004 on Detergents

30 Sept 2021

SMEunited believes that: The Detergents regulation is a well established, sector-specific regulation for detergents and cleaning agents. It is well implemented by companies and accepted by the authorities. Therefore, it should remain as a separate regulation. Improvements of the interface to the CLP regulation concerning the medical data sheet and CLP, Annex VIII are necessary. Improvements of the interface to the biocidal product legislation in relation to the labelling of preservatives are necessary. Digitization and simplification of the labelling are necessary. SMEunited prefers an amendment or minor changes to the detergent regulation and not a merger with other pieces of legislation. Moreover, SMEunited thinks that any necessary elements of the Chemicals Strategy for Sustainability should be integrated as part of an amendment of the detergents regulation.
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Response to Package travel – review of EU rules

17 Sept 2021

Please find attached the feedback of SMEunited.
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Response to Revision of Combined Transport Directive

16 Sept 2021

Key messages SMEunited supports a shift to rail (or other means of transport) but a call for a massive shift to rail is a noble but unattainable goal as the rail network in rural areas is not well developed. A shift to rail can only take place if there is sufficient rail capacity. If combined transport is to be promoted from public funds, this must not be done to the detriment of SMEs. The framework conditions for combined transport are to be designed in such a way that they are encouraged by the stakeholders. Financial support from the member states must be increased significantly, especially in the areas of expansion and relocation of terminals. The EU must ensure that the member states actually expand the TEN network. Please further in the attached file.
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Response to Simplification and digitalisation of labels on chemicals (CLP, Detergents, Fertilising Products)

15 Sept 2021

The European Commission is considering how to improve communication on chemicals. The focus is currently on detergents and fertilizers. In this context, the labelling requirements for these categories of chemical products could be streamlined and digital labelling could be used. Although the current focus are detergents and fertilizers, we assume that in future other sectors could be regulated in a similar manner and on the basis of experience from these two areas. In this context SMEunited would like to highlight the following corner-stones: • Simplification is urgently necessary. The current regulatory labelling framework for chemicals is not fit for purpose. Labels are simply overpacked with information; • The information on the label should be limited to the most essential elements (e.g. some CLP elements) and the rest (e.g. further labelling elements due to specific regulations) could be made available digitally; • The information on the label should basically serve as a kind of entrance gate to safety information and not go into details; • Details on the label are not necessary, since consumers are either overwhelmed or, those who want more detailed information, do not get enough (e.g. allergy sufferers); • We do not support mandatory digitalization at the present time, as not all companies have sufficient options and experience in adding or using digital information. In any case, a sufficiently long transition is necessary in which certain elements can either be indicated digitally or, alternatively, continue to be indicated directly on the packaging; • Ultimately, the goal would be to design the label in such a way that it is clear, concise and leads to further information. This would make the label more legible and at the same time enable users to access more detailed information easily. In the commercial supply chain, a digital link to the safety data sheet also offers a useful way of passing on additional safety information; • However, it is important to underline that digitalization is not per se easing administrative burdens. Less so, if national legislation foresees supplementary of diverging information requirements. It also very much depends on how a digital tool is conceived. The more "only once" principle you have, where data is automatically or easily transferred, the fewer burdens arise for enterprises (while data protection obviously has to be secured).
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Meeting with Maria Elena Scoppio (Cabinet of Commissioner Paolo Gentiloni)

8 Sept 2021 · National recovery and resilience plans Corporate Social responsibility Taxation: Business Taxation for 21st century and fair taxation

Response to Upgrading digital company law

29 Jul 2021

SMEunited welcomes the publication of the Inception Impact Assessment on “Upgrading digital company law”. However we regret once again that this consultation has been published during the holiday period. Our feedback on the IIA can be found in the attached policy paper.
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Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

The attached document contains feedback of the SMEunited secretariat on the proposal on corporate sustainability reporting adopted by the European Commission. The main comments were already made during several conferences in the last months and on our website. A final position paper of SMEunited will follow after the summer break. The main remarks on the proposal are: • CSRD will neither benefit SMEs nor their direct stakeholders • Uncertainty about the ‘SME standard’: a Listed SME one or real SME (micro) standard? • In absence of timely ‘SME-standard’ the market will impose big industry one • SMEs will have in practice no transposition period (contrary to Listed SMEs – 3 years) • No guarantee that the ‘SME standard’ will be accepted by non-SME clients • Risk of gold-plating by Member States • No ‘one in/one’ out compensation • Estimated costs for SMEs: between 10 and 200 billion euro. • Lack of budget for needed SME support.
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Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion) and BUSINESSEUROPE and SGI Europe

25 Jun 2021 · right to disconnect Business Europe

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

16 Jun 2021 · Article 8 Disclosures Delegated Act Taxonomy Regulation

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 New EU urban mobility framework

25 May 2021

SMEunited is the association of crafts and SMEs in Europe with 65 members from over 30 European countries; a recognised employers’ organisation and European Social Partner. The main prerequisites for enterprises are: flexible mobility structures, unhindered accessibility of their own locations, construction sites and suppliers as well as good accessibility to customers. Stricter access bans for certain diesel vehicles as part of the air pollution control policy have recently created additional restrictions for companies. Against this background, further burdens must be avoided and traffic connections improved again. Special transport needs of SMEs: companies, employees and customers - Inner cities are the living and working space of entrepreneurs, their employees and families as well as their customers - businesses need parking spaces and loading areas close to the customer to provide their services at the place of order, as direct access to sometimes heavy materials and heavy tools is necessary for structural measures - The vehicle is in most cases not just a means of transportation, but rather a work tool with multifunctional equipment (mobile work bench). - businesses will therefore need their own vehicles that can be used efficiently and flexibly in the future so that they can drive to construction sites and customers directly - Stricter access bans for certain diesel vehicles as part of the air pollution control policy have in the past led to additional restrictions for the companies; further burdens must be avoided against this background - In the context of a sustainable transport policy, the forced improvement of offers for low-emission mobility must have clear priority over restrictions and bans. - The goal is not the "car-free city", but the "livable and environmentally friendly city" - Commercial mobility within the cities must be embedded in an overall transport concept, including the surrounding area - Ensure accessibility and permanent vitality of the inner cities, taking into account all necessary services and supply needs - Massive expansion of local public transport in the city as well as in rural areas also serves to make it easier for commercial transport that continues to rely on vehicles, as this reduces private motorized transport - Use the opportunities of intelligent traffic control - Advance digitisation - Avoiding traffic through mixed-use “cities with short distances”: The more commercial locations there are close to customers, the more traffic is avoided, and development must also be considered - Strengthening cycling and other modern mobility offers (sharing, on-call buses, etc.). In the trade, cargo bikes are increasingly being tested. - Improve internal goods logistics: To the extent that common delivery strategies, interim storage facilities or goods logistics systems can be used for certain areas of goods transport, especially for parts of trade and parcel services, SMEs expressly support these efforts by the cities and the sectors concerned. - SMEs as mobility providers: vehicle mechatronics technicians, bodybuilders, two-wheel mechanics, electrical craftsmen and numerous suppliers for the car and rail industry - Employee mobility with low-emission means of transport should be supported by by job and trainee tickets or with e-bikes - Modernization of the vehicle fleet: The trade has been committed to low-emission or locally emission-free drives for years (through retrofitting or new vehicles) - SMEs also support other transport policy approaches such as gas, hydrogen fuel cells, e-fuels, which contribute to the reduction of pollutant, greenhouse gas and noise emissions and create more traffic safety - SMEs are partner for a modern transport policy, without which a sustainable and functional city of short distances is not possible. - SMEs are an ideal partner for the public sector in creating modern, sustainable transport structures in cities.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

20 May 2021

The EU needs a general simplification of its chemicals legislation and a chemicals policy, which is more inclusive for SMEs. The Commission should give high priority to this aspect during the evaluation of the REACH Regulation. In more detail SMEunited suggests: It should be explored, how to further exploit the obligatory data/cost sharing to reduce burden. We see potential with sharing of data between different substances (e.g. read across data). There is the need to reduce the discrimination of lower tonnage bands. A fundamental problem of the registration process is that it is highly discriminating low tonnage substances between 1 and 100 t/a. This inherent property of the current information requirements design makes the extension of production capacities in this tonnage band less profitable than in other tonnage bands. This effect has a high potential to hamper growth and to keep small enterprises small. This effect could, however, be moderated by a hybrid approach between a process orientated research and development (PPORD) notification and the current registration regime. Based on this, the testing costs should be distributed over several years and also market response to a substance could be taken into account. The authorisation process is a considerable challenge for SMEs and it is becoming more important every day. While an authorisation is already highly challenging for large industry, it can be existence threatening for an SME. An important simplification would be the option for an authorisation scheme that takes into account that most activities performed by SMEs – also those with annex XIV substances - are usually geographically very limited. Consequently, the full potential of an EU wide valid authorisation is significantly flawed. Many small users usually stay within their Member State or a specific region, which is finally not only due to limited language skills. An optional regionally limited authorisation, which should be simpler and more cost efficient, could balance this situation. Furthermore, SMEunited considers that the data sharing rules as known from registration could be a useful element also for the authorisation application process. These rules have proven to be a major element to relieve SMEs from prohibitively high testing costs and to reduce testing intensity in the EU. As far as we can see, the awareness of the role of safety data sheets (SDS) has increased significantly over the past years. The same goes for their quality. The extended SDS, however, is still not easy to handle. The main problem is the amount of information that is often of limited use for a specific downstream user. This makes it difficult to recognize and identify the important bits. In particular, SMEs struggle with the time consuming regular review of the voluminous documents. To a certain extent, this is also true for the “normal” SDS, which became much more voluminous due to the formal requirement to include all chapters and subchapters. Disentangling of the current SDS and eSDS by introducing a “basic SDS” (bSDS): this SDS of 2 pages should include the most essential information and hyperlinks to more detailed information. The most essential information could be for example an emergency number, emergency measures, allowed uses as well as classification and labelling. We think that the formalisation and harmonization of the existing regulatory management option analysis (RMOA) process would make regulatory decisions more transparent and more efficient. It would also contribute to a better understanding of the impact of regulatory actions. It would support choosing the most appropriate RMO and avoiding regulatory overlaps and/or contradictions, as well as unnecessary double regulation.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

19 May 2021

The EU needs a general simplification of its chemicals legislation and a chemicals policy, which is more inclusive for SMEs. The Commission should give high priority to this aspect during the evaluation of the CLP Regulation. In more detail SMEunited suggests: The introduction of a mechanism to remove CLI entries, which have been inactive for a longer period of time (e.g. 3 years). Furthermore, there is the need to foster the joint agreement on different C&L entries for a specific substances. The CLI could be a very valuable source of information, which, unfortunately and due to many misleading/erroneous entries, it is not right now. Individual companies or a group of companies should be able to directly trigger a CLH process. This means concretely that they should be able to prepare a CLH dossier, submit it and start a RAC discussion, without the need to involve a Member State. This way economic operators would have the possibility to put their scientific findings to an official review. In justified cases the classification should then be adopted according to the current process. SMEunited does not support the planned unilateral deviations from the UN GHS and the introduction of additional hazard classes. In our view, the sequence should be different and an implementation should first happen at UN level. The EU was already a frontrunner in implementing the GHS criteria. Now that we have implemented them, our economy should also get the opportunity to gain some of the benefits of this global harmonisation exercise and with this receive some compensation for the previous investments.
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Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

5 May 2021 · Implementation of the chemicals strategy for sustainability

Meeting with Thierry Breton (Commissioner) and EUROCHAMBRES – Association of European Chambers of Commerce and Industry and

4 May 2021 · Exchange on the upcoming update of the Industrial Strategy and its SMEs dimension

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

30 Apr 2021 · SMEs long term vision for the future of rural areas

Meeting with Deša Srsen (Cabinet of Vice-President Dubravka Šuica)

23 Apr 2021 · Long-Term Vision for Rural Areas

Response to Proposal for a Regulation - Regional and urban Policy

20 Apr 2021

SMEunited, the Association of Crafts and SMEs in Europe, welcomes the creation of the Brexit Adjustment Reserve. Small and medium-sized enterprises require assistance to adapt to the new realities caused by Brexit, on top of the impact of the COVID-19 pandemic. Members of SMEunited made and are still making substantial efforts to prepare and support companies in the best possible way to deal with the effects of Brexit. The feedback gathered demonstrates that smaller businesses have already incurred some considerable adjustment costs in the form of legal and tax advice and will probably continue to do so in the future for the establishment of sales branches or the fulfilment of labelling and certification requirements, once all control devices will be set up in the United Kingdom. Therefore, SMEunited recommends several guidelines for the Brexit Adjustment Reserve to meet the expectations of companies adversely affected by the withdrawal of the United Kingdom from the European Union. For the recommendations, see the position paper enclosed.
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Meeting with Margrethe Vestager (Executive Vice-President) and

19 Apr 2021 · Industrial Strategy

Meeting with Didier Reynders (Commissioner) and

19 Apr 2021 · Substainable Corporate Governance

Meeting with Mairead McGuinness (Commissioner)

15 Apr 2021 · Capital Markets Union Non-Financial Reporting.

Response to Technical specifications for the construction and type-approval of the second version of the smart tachograph

25 Mar 2021

We would make the following remark concerning 3.6.4 on the registration of loading and unloading operations: 3.6.4 provides that a loading or unloading operation must be initiated at the latest immediately after the loading or unloading operation. What if the loading or unloading operation takes place in the absence of the driver? For example, during the driver's daily rest period, the vehicle is loaded by someone of the warehouse. How should the loading or unloading operation be recorded then? Should the driver enter the loading or unloading operation in the morning when he returns from his place of residence? The driver will have no idea of the exact time his vehicle was loaded or unloaded by the warehousemen during the night. How to handle this, as it often happens that vehicles are loaded or unloaded during the driver's daily or weekly rest period.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

SMEunited welcomes the initiative to revise the Energy Performance of Buildings Directive (EPBD) and believes that the third option presented by the Inception Impact Assessment can guarantee the achievement of the desired objectives; SMEs represent more than 90% of the businesses in the EU building sector. Therefore, it is essential that the adapted directive is SMEs-fit in order to maximize the results in the interest of the climate, the employment and the economy; A mandatory, general European renovation rate is not advisable, due to geographical, meteorological, and cultural differences in Europe, as well as to the different levels of renovation; Building targets, including those for renovation, should be applied in a construction material-neutral manner; Incentives and a framework to promote the renovation of buildings are welcome. These incentives must be designed in a technology-neutral way. In addition to funding instruments, tax measures that provide an incentive for households and businesses could be a powerful instrument; Raising awareness and better communication of the broader benefits of sustainable buildings (especially in terms of cost savings) are also necessary in terms of decarbonisation, sustainability for generations and society; The aim must be to preserve the building substance and bring it closer to the state of the art, as well as to integrate it into the energy and energy networks and thus use the buildings as energy hubs and storage facilities. A holistic approach is crucial in this sense.
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Response to Europe’s digital decade: 2030 digital targets

9 Mar 2021

SMEunited welcomes the intention of the Commission for a Communication to prepare Europe’s digital decade towards 2030. Digital transformation is a key enabling factor for SMEs in order to overcome the current crisis and to grow in the Single Market and beyond. SMEunited supports the idea of setting digital targets (1. Digital infrastructures, 2. Digital education and skills, 3. Digital transformation, and 4. Digital government) and a system to monitor the progress towards the objectives of the Digital Decade as long as a stronger emphasis on the digital transformation of SMEs is provided. SMEunited also welcomes the proposal of a Charter of Digital principles at the service of people. However we miss at least some concrete end objectives to be achieved defined in a SMART way. The targets put forward by the Commission are too fluid especially taken into account the short timeframe and impact. The Roadmap for the Communication needs some further clarification and raises some remarks and additional comments which can be found be in the attached position paper.
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Response to Legislative framework for the governance of common European data spaces

8 Feb 2021

Dear Madam, dear Sir, I am pleased to submit the contribution of SMEunited to the consultation on DGA under the form of a position paper that you will find attached. If you have questions, please do not hesitate to contact me. Kind regards, Erisa Taraj
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Meeting with Nicolas Schmit (Commissioner) and

4 Feb 2021 · Preparatory meeting for the Porto Social Summit.

Response to Setting of nutrient profiles

3 Feb 2021

SMEunited, the association of Crafts and SMEs in Europe, welcomes the possibility to express its views about the roadmap on the revision of Regulation (EU) No 1169/2011 on the provision of food information to consumers. The EU food sector is characterised by a very high presence of SMEs, while around 80% of the food products are produced in SMEs. The roadmap rightly points out that the variety of food labelling schemes creates costs for businesses and results in the fragmentation of the internal market. Hence, the revision should lead to simplify the existing frameworks and ensure clearer and applicable rules for SMEs in the food sector. SMEunited asks for a cohesive and coordinated approach to assess the impact of setting out new provisions in food labelling, in particular on small businesses. It is of utmost importance for us to get the right balance between facilitating informed and healthy choice of consumers and placing additional burdens on small businesses. Any future initiative should be accompanied by robust information campaigns and professional guidance to help SMEs and consumers to apply and interpret food labels.
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Meeting with Nicolas Schmit (Commissioner) and

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

Response to Collective bargaining agreements for self-employed – scope of application EU competition rules

2 Feb 2021

SMEunited has not finalised its position yet. We will publish it in the coming days. However we can already mention that according to SMEunited improving the “precarious situation of self-employed”, will not be reached through this initiative. The policy options of the IIA are not a suitable way to tackle the issue described. The European competition law is also not an obstacle to improve the situation of some platform workers. The proposed restriction of the term "undertaking” seems also problematic, as it would lead to unequal treatment between entrepreneurs within a sector who offer their services on the same market. Irrespective of the problem of with whom such "collective agreements" are to be negotiated, such exemptions could lead to competitive disadvantages and legal uncertainties on the part of those enterprises that do not fall under the exemption, if they are small or micro enterprises but act as employers. The Commission should consider other measures, such as for example an improved P2B-regulation, the late Payment directive,... to enhance the position of all SMEs.
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Meeting with Thierry Breton (Commissioner) and

2 Feb 2021 · Exchange on SME strategy and impact of DSA/DMA on SMEs

Meeting with Nicolas Schmit (Commissioner) and

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

Response to EU strategy for sustainable textiles

1 Feb 2021

Please see position paper enclosed.
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Response to Revision of EU rules on food contact materials

29 Jan 2021

SMEunited, the association of Crafts and SMEs in Europe, welcomes the revision of EU rules on food contact materials (FCMs) and calls for harmonised rules at EU level that are practical and manageable for Crafts and SMEs. As set out in the various reports supporting the ongoing evaluation of the FCM legislation, the current regulatory framework is complex and challenging for small businesses. It does not take into account their specificities and hinders to provide clear guidance on how to operate safely and in compliance. More harmonisation at European level could help to achieve a greater harmonisation of national legislations and reinforce the mutual recognition across Member States. The list of priorities for SMEs includes the prevention of unnecessary burden and bureaucracy, the simplification of compliance work, and making sure that barriers do not impede the circulation of products in the EU internal market. Moreover, in view of its relevance to health, safety, quality and hygiene requirements have to remain the main considerations to all materials intended to come into contact with food.
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Response to Digital Levy

15 Jan 2021

As regards the introduction of a digtial levy, SMEunited supports the activities taken at international level (OECD) and supports own initiatives at EU level only, if the efforts of the OECD fails. In such a case, action at EU level is necessary to avoid different solutions at national level and distortion of the single market. Here the last statement of SMEunited at this topic: SMEs are less able to exploit the different regimes for tax planning and are confronted with high compliance costs and higher effective tax rates SMEunited requests that tax rules ensure that all economic operators, independently from their size, sector and location, pay their fair share of taxes. This is especially necessary for the digital sector. The European Union should actively support the action undertaken by the OECD and G20. However, if there is a lack of progress, initiatives at European level may become necessary, to avoid a patchwork of different digital taxation solutions at national level since it will make cross-border selling for SMEs even more complicated.
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Response to EU single access point for financial and non-financial information publicly disclosed by companies

14 Jan 2021

We regret that the consultation has been launched at the beginning of the Christmas break and that only 4 weeks have been attributed for sending comments, while the Commission offices were closed during 10 days. We are not able to send our comments by tomorrow 15th. We will send our comments with some delay. Many thanks for your understanding.
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Meeting with Eszter Batta (Cabinet of Commissioner Thierry Breton) and Small Business Standards

11 Dec 2020 · Standardisation strategy

Meeting with Frans Timmermans (Executive Vice-President)

3 Dec 2020 · COVID-19 crisis and recovery, climate targets; circular economy

Meeting with Nicolas Schmit (Commissioner) and

1 Dec 2020 · Exchange of views on minimum wages and the Recovery and Resilience Facility.

Meeting with Virginijus Sinkevičius (Commissioner) and

1 Dec 2020 · To discuss Circular Economy Action Plan, especially from the angle of small and medium enterprises.

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

30 Nov 2020 · COVID-19 impact on SMEs, National Recovery and resilience plans, Ecosystems.

Response to EU Strategic Framework on Health and Safety at Work [2021-2027]

26 Nov 2020

SMEunited strongly supports health and safety at work. Crafts and SMEs employers recognise that investments in OSH measures help to prevent accidents and increase productivity. A good health and safety environment for all, depends amongst others on the right conditions such as a legislative framework that is fit for purpose, and support for compliance. SMEunited welcomes the EC Roadmap for the EU Strategic Framework on Health and Safety at Work. SMEunited believes that the current EU legislative framework on OSH is largely adequate and sufficient. We support in principle updating EU legislation where it is proven to be outdated on the condition that it concerns a strictly targeted initiative and is supported by strong scientific evidence and impact assessments. Moreover, SMEunited recommends to conduct such revisions in consultation of social partners and involvement of SMEs representative organisations. Crafts and SMEs employers’ organisations should be consulted on policy initiatives to ensure that new provisions and/or policy developments can be implemented effectively. However, rather than creating new burdens for them, we recommend strengthening the role of intermediate bodies or SME organisations to advise/guide companies to implement OSH measures. Moreover, better cooperation, partnerships and integrated policies to support small businesses especially at regional and local level need to be strengthened. This concerns all stakeholders involved, notably social partners, public authorities, but also professional organisations, such as SME organisations. Concerning the identified necessity to address new risks in the new EU Strategic Framework, such as those resulting from new ways of working, new technologies, digitalisation and COVID-19 pandemic, SMEunited underlines that the OSH Framework Directive already covers the legal obligation to protect workers from all workplace risks. Specific new legislative action is hence not necessary. SMEunited would like to recall some fundamental principles from the perspective of Crafts and SMEs for the successful implementation of the new Strategy: 1. Avoid excessive burdens for Crafts and SMEs The main challenges for SMEs to comply with the rules are a lack of awareness and too excessive burdens. A ‘Think Small First’ approach is essential with regard to all legislation in the field of health and safety. Taking into account that SMEs employ more than 60% of the workforce in Europe, it is of utmost importance that legislation truly respects the ‘Think Small First’ principle, avoiding disproportionate burdens for implementation in SMEs and micro-companies, and facilitating higher compliance levels. Moreover, transposed legislation at national level should ensure that compliance costs in small businesses are reduced to a minimum. 2. Support SMEs comply with implementation of OSH measures Actions should be targeted to ensure that SMEs have knowledge and practical tools for execution of OSH requirements, especially obligation to carry out risk assessment. At local level, dedicated actions and outreach should take place to support micro-enterprises, including through SME business organisations. SMEunited points to the need of building capacity of SME organisations to provide guidance and support. 3. Strengthen the role of national and sectoral social partners SMEunited invites the European Commission to integrate in the new Strategic Framework the lessons learned from the COVID-19 crisis, in particular the essential role played by national and sectoral social partners. COVID-19 pandemic should not create further legal obligations as the existing ones already create the adequate basis for the prevention of health risks at the workplace. On the contrary, strong social partners are able to jointly deliver realistic solutions for enterprises and workers to tackle emerging challenges such the safe return to work during the COVID-19 pandemic.
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Meeting with Nicolas Schmit (Commissioner) and

16 Nov 2020 · Meeting on the Recovery Strategy.

Meeting with Stella Kyriakides (Commissioner) and

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

Response to Evaluation of the impact of LEADER on balanced territorial development

13 Oct 2020

SMEunited, the association of crafts and SMEs in Europe, has repeatedly stressed the importance and effectiveness of cooperation programmes managed by local level actors in local action groups (LAG). SMEunited believes that LEADER/CLLD actions have an essential impact on the activities of SMEs in rural areas and on the economic and social development of regions. The general view is that LEADER/CLLD actions have proved to be a very efficient tool allowing for a good cooperation between local actors, in particular farmers and SMEs. However, the real economic, social and environmental impact of LEADER/CLLD actions is still unknown. SMEunited requests to assess the socio-economic impact of actions, analyse the partnership methods between local actors and conduct specific analysis of the impacts on SMEs and microenterprises, benefiting from LEADER/CLLD actions. Beyond the actions themselves, the LAG principle has become a method of cooperation and partnership between local actors and demonstrated its effectiveness. Therefore, we call for strengthening existing LEADER/CLLD actions and developing a large number of local initiatives. This can be achieved by greatly increasing the allocation of funds for this method under cohesion and rural development policy. We also ask for a comprehensive approach to simplify administrative procedures and give way to more simplified cost options. SMEunited acknowledges the information activities of the LEADER-networks towards local stakeholders. However, national, regional and local SME organisations should be also entrusted with communication and dissemination activities addressing local businesses and decision-makers. In this regard, we ask for the involvement of SME organisations at all levels in programming, projecting and implementing of LEADER/CLLD actions. For the full feedback please see the document enclosed.
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Meeting with Maroš Šefčovič (Executive Vice-President) and BUSINESSEUROPE and EUROPEAN TRADE UNION CONFEDERATION

7 Oct 2020 · Maroš Šefčovič participates in an informal meeting with social partners on CWP 2021/Better Regulation/Strategic Foresight.

Meeting with Thierry Breton (Commissioner)

2 Oct 2020 · Exchange on SME strategy and COVID-19 impact

Response to Long term vision for rural areas

9 Sept 2020

SMEunited, the association of crafts and SMEs in Europe, welcomes the Commission's ambition to engage in a comprehensive reflection of the long-term vision for rural areas. On many occasions, we regretted the restrictive and too sectoral conclusions of the European Conferences on Rural Development and the lack of a truly holistic and inclusive approach to rural development. It is estimated that more than 7 million SMEs, craft and micro enterprises are located in rural areas. They ensure economic and social cohesion by providing vital services and local products, in particular in the agriculture, food, forestry and tourism sectors. Moreover, they contribute to social and economic stability with creating and maintaining jobs, particularly in areas where they are the only ones to generate employment. Rural areas need a supportive ecosystem for all enterprises. In practice, like urban development, rural development should be based on a territorial approach and not on a pure sectored vision. For SMEunited, the notion of territorial cohesion does not apply only between Member States and between regions, but also at the local level, ensuring coherence amongst all economic, social and public actors. The new rural development policy must provide the right tools for all players in rural areas, as agricultural and non-agricultural. SMEunited requests to strictly apply the partnership principle and to ensure the participation of rural development actors in line with the European Code of Conduct on Partnership. Please find the feedback of SMEunited in the document attached.
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Response to Review of EU rules on fluorinated greenhouse gases

4 Sept 2020

Already in 2017 it was obvious that the availability of crucial f-gases in the internal market would become limited. Prices were exploding, supply could not be guaranteed for many applications. Only between March and October 2017 prices in central Europe increased to ~750% for common cooling agents. This trend continued into 2018 and stabilised then. In 2018 we started to observe first cases of theft and smuggling of cooling agents. In 2019 we could see a clear proportion of illegal refrigerants on the market. As a result, there is currently an oversupply of refrigerants on the market (legal & illegal ones). Therefore refrigerant prices are slowly declining and there is no supply shortage of refrigerants. At the moment you can buy everything either legal or illegal and, depending on the supplier, there is significant price distinction between those different channels. This unlawful situation is caused by the quota system and needs urgent attention. The consequences for companies can be severe: • it is usually impossible to distinguish the illegal f-gases from the legal ones, especially for a small company; • the illegal f-gases can be contaminated and of low quality, causing damages to the equipment and threating safety; • compliant companies are not able to compete with the illegal goods, which usually cost a trickle of the legal ones. Moreover, we need to question the current approach of the F-gas-Regulation, which in SMEunited’s view does not work as it should by favouring large industry and causing the development of mono / oligopolies. SMEunited is of the opinion that a successful substitution of refrigerants can only happen cautiously and by considering a larger context. In this sense, our experts developed a 4-pillar model. This model takes into account various equally important factors for a concrete system. Those are: • eco-efficiency, • energy efficiency, • safety and • manageability. According to SMEunited, the step by step phase down of HFC refrigerants introduced by the F-Gas Regulation is in principle a sensible and realistic way to achieve a continuous reduction of HFC refrigerants by 1 January 2030. An acceleration of the current deadlines and / or further decrease of the teq CO2 put on the market in the upcoming years could jeopardize the capacity of SMEs in this sector of maintaining an efficient cold chain due to lack of refrigerants. An anticipation of investment plans is also economically not feasible. Indeed, a stricter regulation concerning the use of HFC refrigerants or a fixed phase out date would not improve the situation where we are faced with a decreasing amount of available HFC refrigerants while at the same time prices are increasing. The current boost in prices and availability limitations as described above actually show that the system in principle works, although some adjustments are needed to cushion the most disproportional effects. On the contrary, many end-users would be faced with the pressure to abruptly implement alternative solutions, which would completely overwhelm not only the end-users but also equipment installers in terms of personnel, technical knowledge, organisational capabilities and economic means. Investments were planned according to the provisions and the deadlines of the F-Gas Regulation and companies are counting on the legal certainty as provided in the Regulation. Furthermore, we observe a lack of qualified technicians of the refrigeration and air conditioning contractor sector as well as of equipment installers. In the next future it is also important that the review of EU rules on fluorinated greenhouse gases provides the exclusion of combustible gases from refrigerant gases as alternatives FGAs (for safety reasons). Moreover, the review should improve the traceability of f-gases in pre-filled equipment. Those actors, who place such equipment on the market for the first time and have most information about it, should be the main addresses of such obligation.
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Response to Environmental claims based on environmental footprint methods

27 Aug 2020

Putting some order in the world of green claims is definitely useful and important. However, there is a big risk that the use of certain methodologies, such as PEF / OEF, could make life much more difficult for craft and SMEs in terms of higher costs and administrative work. This is due to the fact that SMEs, and particularly micro and small businesses, are not used to working with these methodologies and do not have the infrastructures and the resources to perform in-depth environmental analysis. Therefore, SMEunited believes that the Commission should first of all propose a voluntary legal framework to substantiate green claims in the EU. Because of the considerations above, SMEs should be granted support measures to ensure that they are able to implement these procedures. As a matter of fact, it has to be avoided at all cost that, as a result of the PEF /OEF, SMEs refrain from putting forward environmental claims or are obliged to implement a procedure that is disproportionate for their structure and the impact of their products. The following support measures are essential and become a precondition if substantiating green claims should ever take the form of a mandatory EU legal framework:  An SME-tool to facilitate the application of PEF / OEF as well as a general simplification of these procedures from the earliest stages of their development;  Freely accessible on-line databases in all the EU languages with life cycle analysis (LCAs) for different product groups, since SMEs, and particularly craft and micro businesses, cannot perform these LCAs directly;  Capacity building for SME organisation, particularly at local level, in the area of PEF / OEF. This is due to the fact that SMEs turn first to their associations for advice and technical assistance. Therefore, training the SME associations at local level on PEF / OEF methods could facilitate their uptake by SMEs. Moreover, this would avoid that lots of SMEs invest resources in consultants to help them advertising their green claims. The certification and verification of environmental profiles are also elements which can easily increase costs and red tape for small businesses. Therefore, SMEunited proposes that SMEs should be granted the possibility of using self-certifications. As for the verification, this should be performed by applying simplified and shorter procedures for SMEs avoiding the lengthy processes applied to big businesses. As a last point, it would be useful to keep the call for applicants continuously open for new PEFCRs developments in order to facilitate these processes.
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Response to Review of the Construction Products Regulation

18 Aug 2020

SMEunited called for a consultation on the Review of the Construction Products Regulation among their members. As result SMEunited has concerns over the radical changes proposed by the European Commission in the Refined Indicative Options for the Review of the Construction Products Regulation of 8 April 2020, especially with regard to the possible discontinuation of the ETA route. While a targeted improvement of the Construction Products Regulation (CPR) would benefit all stakeholders, some of the Commission’s current suggestions risk affecting the construction sector very negatively in terms of adaption costs, timeliness and the practicability of implementation as well as international competitiveness. The discontinuation of the ETA (European Technical Assessment) route, for instance, would remove considerable flexibility from the system and create major hurdles for manufacturers of non-standard products, such as innovative, complex, unique/niche or green products. Some non-standard products might even be blocked from the internal market and CE marking altogether. This situation risks harming the European Union's competitiveness, distorting the competition among upcoming product technologies, and increasing the uncertainty that manufacturers would have to accept in order to enter the European market. All in all, this would create an innovation-adverse climate.
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Meeting with Elisa Ferreira (Commissioner) and

18 Jun 2020 · The future of Cohesion Policy

Response to Chemicals strategy for sustainability

17 Jun 2020

In principle, according to SMEunited, the approach of evaluating a chemical substance only once makes sense. The use of REACH data for other legislation is, therefore, a viable option that could bring more coherence to EU chemicals legislation. However, it will be essential that there is a clear division of responsibilities, work and resources between the various EU agencies, the various scientific committees, the Commission services and the authorities in the Member States. The current situation in the EU´s chemicals legislation shows weaknesses, which are precisely due to such a lack of coordination between various actors. For example, problems relating to worker protection legislation are solved by less suitable instruments of the REACH Regulation. In this sense, the existing Risk Management Option Analysis (RMOA) process should better structured as a first step to make the regulatory system more efficient and targeted. Also a clear financing without placing an additional burden on companies will be essential. In particular, fee increases are rejected. Financing should come from the global EU budget or from the Member States. The EU`s enterprises are already contributing enormously to the costs of EU chemicals legislation as data suppliers. When drawing up and implementing a chemicals strategy for sustainability, it is also essential that all three pillars of sustainability (economic, social and environmental) are treated equally. In our view, this requires at least joint leadership by the Commission services in DG Grow and DG Environment. DG Research, DG Employment and DG Sante should also be substantially involved. In particular, all the objectives of REACH (Article 1) should be considered equally. SMEs deserve special attention. Therefore there should be specific impact assessments taking into consideration micro and small enterprises, small scale production and niche markets in order to find adequate solutions to reduce administrative burdens and to better promote innovation potential and business opportunities for these companies. The interface between waste and chemicals regulation needs to be approached more systematically. In particular, there is a need for a transparent mechanism to define substances, which are relevant to the circular economy. For this purpose hazardous properties alone are unsuitable. While such properties can play a role, there are also other parameters, which may be important. For example, on the one hand certain non-hazardous raw materials are valuable for recycling (e.g. platinum), on the other hand they can prevent efficient recycling (e.g. unpleasant fragrances).
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Meeting with Nicolas Schmit (Commissioner) and

17 Jun 2020 · Meeting on Vocational Education and Training as well as apprenticeships.

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

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

8 Jun 2020

SMEunited welcomes the European Commission’s “Renovation Wave Initiative for public and private buildings” as an important building block of the European Green Deal and step to accelerate building renovations, which is indispensable to reach the EU’s carbon neutrality, energy efficiency and renewable energy objectives as well as to improve the well-being of European citizens, which on average spend over 90% of their time indoors. The renovation wave should become a central part of the recovery strategy of the EU. Not only should more resources be directed to working towards the double goal of sustainability and digitalisation, the renovation wave could also contribute significantly to the economic restart of the EU. General focus areas: • High volumes of investments are necessary. Housing providers already committed to large investments for renovating houses before COVID-19. However, in order to adapt the entire social, cooperative and public housing stock, more investments are needed. Public funding from well-designed investment programmes should complement the already committed private investments. • It is very important that the renovation wave is strongly connected to other relevant policy initiatives that are interlinked with it, such as the Circular Economy Action Plan, the SME strategy and EU Industrial Strategy. This is e.g. due to the strong links with energy production and infrastructure, re-use of materials and secondary raw materials, and facilitating SME’s to make the transition to becoming more sustainable. • The focus within the European Green Deal should be about incentivising and seducing business to invest in sustainability. This also applies to the renovation wave, in which companies and citizens are incentivised to direct investments into low carbon solutions. • The renovation wave policy has to result in long-term investment certainty. Business should be presented with clear long term policies. Ultimately, policy certainty determines the successfulness of the transition and avoids stranded assets. • Due to the COVID-19 crisis, special attention should be given to address potential liquidity problems for the ecosystem involved in renovating the built environment.
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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 Amending requirements for information for poison centers

1 Jun 2020

The introduction of the ICG and the possibility to refer to standard formulations can significantly improve the practicability of annex VIII. With regard to paints that are mixed on site, it is also positive that these "bespoke paints" are exempted from the reporting obligation. However, we are questioning the alternative labelling obligation. Bespoken paints usually contain five pigments in an individual colour mix. This means that a container would have to be labelled with five UFIs. We have doubts that in a case of emergency this approach is workable. Furthermore, the concentration labelling > 5 % in addition to the UFI is practically without function and should therefore be omitted. Adequate transitional provisions or provisions on entry into force are in any case necessary. It will certainly take time before the amending provisions are finally adopted. Companies must have sufficient time - especially in the current situation - to take the necessary steps and take action. Even if the changes are decided quickly and ECHA is working in parallel on implementing the necessary IT changes, it must not be forgotten that the internal software solutions within the company must also be adapted and tested in order to carry out the notifications with a reasonable amount of effort. We doubt whether all this will be possible before 1 January 2021, even without taking account of the current exceptional situation.
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Meeting with Valdis Dombrovskis (Executive Vice-President) and

28 May 2020 · COVID-19 relief measures

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

Meeting with Nicolas Schmit (Commissioner) and

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

Response to Farm to Fork Strategy

18 Mar 2020

SMEunited, the association of crafts and SMEs in Europe, welcomes the Farm to Fork Strategy striving for a transition towards more sustainable food systems in line with the Green Deal and asks for a balanced approach that takes into account the SME perspective. The Farm to Fork Strategy needs to allow SMEs operating in the food sector to take a major role in realising the transition towards more sustainable food systems. SMEs and their EU representative organisation, SMEunited, are the logical partners in the design and implementation of the strategy. SMEunited stresses the importance of dialogue and involvement of SME organisations at national and European level to achieve sustainable regulatory and non-regulatory measures. The Farm to Fork Strategy should strive for greater coherence and consistency of EU policies, lead to a fairer and more resource-efficient food supply chain and result in a solid regulatory framework ensuring that the transition to greener business models is a real opportunity and less burdensome for SMEs. SMEunited is ready to engage in future actions and is committed to provide its knowledge and expertise for the implementation by counting on the most extensive European network of SME organisations and SMEs. Please find SMEunited's full feedback in the document attached.
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Meeting with Nicolas Schmit (Commissioner) and

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

Meeting with Valdis Dombrovskis (Executive Vice-President) and

6 Mar 2020 · Industrial Strategy, SMEs strategy, Social Dialogue and Pillar of Social Rights, European Semester

Meeting with Nicolas Schmit (Commissioner) and

5 Mar 2020 · Skills

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

3 Mar 2020 · SME Strategy, Capital Markets Union

Meeting with Ylva Johansson (Commissioner) and

3 Mar 2020 · Consultations on the New Pact on Migrations

Response to Revision of Non-Financial Reporting Directive

27 Feb 2020

SMEunited contribution to the Inception Impact Assessment on the Revision of the Non-Financial Reporting Directive This position paper is a first reaction as a reply to the Inception Impact Assessment. SMEunited will reply more in detail on the public consultation launched on the 20th February 2020. In its analysis of the current problems regarding the NFRD, the Commission states that the reporting requirements in the NFRD are not detailed and leave a lot of discretion to the reporting companies. In must be highlighted that SMEunited welcomed in the time this approach. However, the experience of the Commission is that the current approach makes enforcement difficult. There is also complexity and uncertainty regarding the reporting requirements among companies. The IIA points out that the information reported under this directive is not comparable nor reliable and it is not often relevant to the public. At the same time the Commission relevantly identifies that companies incur unnecessary and avoidable costs related to reporting non-financial information. SMEunited strongly advocates that the EC should in the first place correct the perceived shortcomings of the current directive before considering of enlarging the scope of application. As the directive’s requirements are already complex and burdensome to large companies applying them, they would be even more burdensome and complicated for SMEs to comply with. They would once more create additional costs to SMEs who most often do not have the expertise to fulfill these types of reporting obligations within the company itself, but would have to pay for external consultants. If the directive at its current state is not delivering the desirable results, it would be unreasonable to enlarge the group of companies having to comply with a directive that does not work well. It would also be completely against EC’s goal to “Think Small First” and reduce administrative burdens of SMEs. Until the current directive will be functioning well for large companies, the Commission should continue the current approach of non-binding guidelines to ensure proper application and effectiveness of the directive and at the same time avoiding the risk of ‘trickle down’ and / or supply chain effects. As a secondary option, drafting voluntary standards could be envisaged. Possible standards should however be affordable and easy to apply in small businesses as well and accepted in the whole supply chain. However, too many overlapping sustainability reporting frameworks should be avoided to provide companies more clarity. It has to be taken into account that SME information systems are ill-equipped to collate data. In summary, SMEunited is of the opinion that: - Non-Financial Disclosure should remain a voluntary engagement of entrepreneurs. Therefore, the scope of the Directive should not be enlarged; The amount of administrative obligations has reached already an unproportionable level for small enterprises; - Entrepreneurs should be able to choose the appropriate way for their specific situation and the needs of their stakeholders; in particular SMEs need indicators simple and oriented to their specific characteristics; - Non-Financial Information can be useful for the decision-making process as strategic decisions are also based on the values of an enterprise; - SMEs need support, accompanying measures, and adapted proportional tools in order to be able to comply with the taxonomy if they want or need to. Due to the fact that no support was given in the past, SMEs suffer from a relative lack of knowledge on how to report if they had to report. There is a lack of suitable scalable standard and / or guidance; - SMEunited and its members are willing to work with the European Commission on defining reporting standards and procedures that are affordable for SMEs and comparable across the EU.
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Meeting with Maria Luisa Cabral (Cabinet of President Ursula von der Leyen)

26 Feb 2020 · Tripartite Social Summit Commission Work Programme

Meeting with Agnieszka Skonieczna (Cabinet of Commissioner Thierry Breton)

10 Feb 2020 · SME strategy

Response to Climate Law

5 Feb 2020

The adoption of a European ‘Climate law’ will confirm the EU’s commitment to comply with the Paris Agreement and to provide a long-term framework ensuring stability and consistency of policies, which are essential for the economic system, including SMEs, to plan the necessary investments. SMEunited considers the new ‘Climate Law’ should include the following elements:  For SMEs which are already frontrunners in sustainability: initiatives spurring innovation and the development of new sustainable technologies as well as supporting measures to export and to explore new markets to give the EU a competitive edge worldwide;  For SMEs which are catching up: an enabling political and legislative framework providing information, technical assistance at local level, easier access to different forms of financing for the upfront investments linked to new business models, upskilling and reskilling of the workforce as well as capacity building for SME associations at all levels to turn them into one-stop-shops orienting SMEs towards circularity and sustainability;  Equal targets, rules, and instruments for all actors at EU level combined with equal implementation and enforcement of these targets, rules, and instruments. In practice, the EU’s approach should integrate SME policy in the sustainability agenda and prevent any fragmentation of the internal market rules. Consequently, harmonised European instruments, such as the EU Emissions Trading Scheme (ETS), will be more effective to facilitate the green transition than national initiatives;  If an increase of the 2030 GHG reduction target is necessary, then one single, new long-term increase should be adopted. Continuous increases in a short time create uncertainty and delay investments because SMEs need a stable and predictable policy, legislative and investment framework;  A balanced approach which strives to fighting climate change and equally considers the social dimension and the economic impacts of the possible alternatives in order to guarantee social cohesion and a sustainable growth in the EU. In-depth impact assessments in these latter two areas are, therefore, a prerequisite for action;  Measures boosting research & development, technological innovation and natural based solutions covering all possible alternative ecological fuels, all methods to reduce, capture and reuse greenhouse gas emissions as well as fostering new disruptive technologies able to make the EU leapfrog towards a carbon-neutral society;  Cooperation agreements for energy partnerships with third countries as well as a highly connected and integrated energy network inside the EU, for which additional investments are required. Modernisation and stepping up of existing national networks should also be carried out urgently. This is due to the fact that security of supply deserves a special focus as well, since most of today’s energy mix will have to be replaced by other forms of energy;  The setting up of a European decarbonisation fund also financed through the existing ETS revenues, that supports businesses, and particularly SMEs, in their transition to a zero-carbon production;  Last but not least, a commitment from the EU to keep leading international negotiations on the implementation of the Paris Agreement both with diplomacy and with concrete measures aimed at pushing the other major emitting areas to similar commitments as the EU. Important first steps should be the setting up of a carbon border carbon adjustment mechanism compatible with the World Trade Organisation (WTO)’s rules and the implementation of a global carbon price for the power sector and the sectors with the highest emissions.
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Response to Strengthening the principle of equal pay between men and women through pay transparency

3 Feb 2020

Closing the gender pay gap is an important challenge linked to many underlying factors. SMEunited is committed to promote the equal pay principle and to combat all forms of discrimination at the workplace. However, the gender pay gap is broader than the concept of equal pay for equal work or work of equal value, making it a complex issue to tackle. Therefore, it is crucial that the gender pay gap debate is based on evidence and facts, and avoids equating the gender pay gap with pay discrimination. In reality, the gap measures a concept that is much broader than the concept of pay discrimination alone. The gender pay gap is the result of multiple factors, notably gender stereotypes, horizontal and vertical segregation on the labour market, the different educational and professional choices between men and women, cultural norms, behavioural factors, career breaks, a lack of affordable and quality child- and elderly care services, as well as the disproportionate number of women in part-time jobs. The overemphasis on pay transparency shows only a fragmented picture of the proper way to address the gender pay gap. Instead, a more holistic approach is needed in order to address the root causes. Experience shows the importance of awareness-raising and the involvement of social partners in the design and implementation of measures. Collective bargaining plays an important role in ensuring wage transparency and reducing the gender pay gap. Accordingly, there is a need for a more hands-on approach through social dialogue, moving away from a punitive approach focused on sanctions. SMEunited considers the following measures essential to reduce the gender pay gap: improving female labour market participation, fighting gender stereotypes, tackling gender segregation in education and the labour market, and investing in the provision of affordable, accessible and quality child- and elderly care services and infrastructure. Furthermore, there is a need to adapt tax-benefit systems and correct the fiscal disincentives to work for second-wage earners. Promoting women entrepreneurship should also be part of the solution. SMEunited supports the principle of a new Gender Equality Strategy to mainstream gender equality in all policy measures including labour market policy. However, regarding binding pay transparency measures, SMEunited asks that the specificities of SMEs, particularly micro and small enterprises, are fully taken into account, thus avoiding any unnecessary additional red tape and administrative burden. Possible costs of such measures for employers include the investment in software or consultants, the risk of poaching of staff, risk of reduced motivation if pay structure is perceived as unequal, etc. Furthermore, micro and small enterprises might simply not have large enough comparison groups among employees in order to draft detailed pay reports or audits. If conclusions have to be drawn based on the data of a limited number of employees, anonymity could no longer be ensured, resulting in a breach of data privacy and protection. Therefore, in the vast majority of Member States which have already introduced binding pay transparency measures, small enterprises have justifiably been exempted of such an obligation. Experience at national level shows that binding measures on pay transparency have proven extremely complex to put in place in practice. In addition, given the relatively recent introduction of pay transparency measures in many Member States, it is not yet possible to fully assess their effectiveness in reducing the gender pay gap. What has been shown so far is that simpler versions of pay reporting requirements did not pose major obstacles for larger companies. However, reports and auditing requirements only became meaningful and effective when they added more complex and detailed data, including various components of pay beyond basic salaries and extra information.
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Meeting with Ana Carla Pereira (Cabinet of Commissioner Nicolas Schmit)

20 Jan 2020 · Exchange on “ A strong social Europe for jus transitions” and on the initiative on fair minimum wages

Response to A new Circular Economy Action Plan

8 Jan 2020

It is good for the new action plan to support SMEs' participation since they are the key to the successful implementation of the circular economy in the EU. To this end a complex of measures is necessary including information, technical assistance, better access to finance, upskilling and reskilling of workers and capacity building for SME organisations, which could become one-stop-shops promoting more circularity and more sustainability in SMEs. It is positive to foster the internal market for secondary raw materials, but at the same time circularity should also be promoted in supply chains where SMEs could be supported in this effort. Moreover, it would also be important for public authorities to work with SME organisations at local level to stimulate circularity through SMEs (which traditionally operate in areas such as repairing, refurbishing and maintenance) and by increasing the number of industrial symbiosis where SMEs can be integrated. The sustainable product policy mentioned in the roadmap will definitely result in a reduction of products put on the market by SMEs and in an increase of costs and red tape to manufacture new products based on minimum requirements. The same can be said for the information to be provided on products' sustainability features. In order to cut costs and bureaucracy for SMEs, they should at least be provided with freely accessible databases with LCA analysis for different product groups, which SMEs cannot perform directly. Moreover, SME-friendly tools should be developed to simplify procedures and reduce costs particularly in the framework of mandatory product footprint declarations. As for actions to address high-impact sectors, new legislation should be science-based and not only ideologically driven, should be developed in cooperation with industry's and SMEs' representatives and should start from a balanced approach by which manufactures are not considered as the scapegoats of the system, but responsibility is equally shared among the all the actors involved in a product life cycle. Therefore EPR with an excessively large scope like in the Single Use Plastic Directive should be avoided.
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

17 Dec 2019 · Green Deal and the transition to a climate neutral economy

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

20 Nov 2019 · Digital transformation – SME United views on digitalising of SMEs

Meeting with Anne Bucher (Director-General Health and Food Safety)

4 Nov 2019 · SME policy for the new legislative term

Meeting with Margrethe Vestager (Commissioner)

18 Oct 2019 · Meeting to discuss SME policy

Meeting with Sabine Weyand (Director-General Trade)

9 Oct 2019 · EU Trade Policy & enforcement of trade agreements

Meeting with Jyrki Katainen (Vice-President)

24 Sept 2019 · EU policy framework for SMEs

Meeting with Timo Pesonen (Acting Director-General Internal Market, Industry, Entrepreneurship and SMEs)

18 Sept 2019 · Introduce themselves and discuss SME policy in general

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

15 Jul 2019 · Skills

Meeting with Valdis Dombrovskis (Vice-President)

21 May 2019 · Social Dialogue at the EU and national level

Response to Evaluation of the Motor Vehicle Block Exemption Regulation

19 Mar 2019

SMEunited would like to thank the European Commission for possibility of providing comments to the Evaluation Roadmap. With this contribution, SMEunited representing through members more than 12 million enterprises with around 55 million employees across Europe, would like to bring the SMEs perspective to the review. We are convinced about the need to maintain the MVBER, but with modernisation given the changes and new developments in the sector. The upcoming evaluation process should pay particular attention to the role SMEs play in the sector, digitalisation and new trends in the automotive market that should be further examine for their impact on the competition. SMEunited, together with members look forward to be further engaged and share knowledge in the next steps of this evaluation process. Please see attached our contribution.
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Meeting with Karmenu Vella (Commissioner) and

6 Feb 2019 · Environment issues

Response to Evaluation of the Vertical Block Exemption Regulation

6 Dec 2018

See the attached document with our comments. The request to give the organisation size has no sense in the case of a business organisation...I have put small as it corresponds with the number of employees at the secretariat.
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Response to Establishing a legal limit for the industrial trans fats content in foods

31 Oct 2018

In a nutshell (please confer to UEAPME full position paper): This draft Regulation bears several problems for small craft producers: • The responsibility for the use of TFA lies only with the SME who is producing and selling the final product to the consumer on the market. • The craft process does not allow to measure the TFA content. • Certain transformation processes, in particular the frying process can add and produce TFA. This would raise the amount of TFA in a given product. When measuring the content of TFA the small and craft enterprises are at the end of the chain, thus a small entrepreneur is additionally disadvantaged. He does not have the financial resources to perform an analysis on each delivered batch of fat. The entrepreneur is dependent on his supplier when he wants to calculate the values of TFA. The suppliers often do not provide all the data. This means that a small baker cannot calculate the value of TFA in his biscuits. Therefore, it is necessary that there is a maximum level of TFA in the delivered raw materials. The oil and grease industry can adjust its production method easily and produce a consistent fat which will allow craft producers to comply with the regulation. This has already happened at an earlier stage in many Member States. The current legal text does not encourage the industry to adjust their production methods. This could mean that the levels on TFA in the raw materials might even increase again and this is not the purpose of this law.
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Meeting with Věra Jourová (Commissioner) and

27 Sept 2018 · New Deal proposal

Meeting with Andrus Ansip (Vice-President) and

26 Sept 2018 · SME policy, digital transformation, data, eCommerce, skills

Meeting with Andrus Ansip (Vice-President) and

20 Sept 2018 · GDPR, privacy shield, e-privacy

Meeting with Günther Oettinger (Commissioner) and Wirtschaftskammer Österreich

4 Sept 2018 · Single Market, InvestEU, Industrial Policy

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

19 Jun 2018 · Introductory meeting

Response to Initiative to improve the Food Supply Chain

14 Jun 2018

The current position on the draft directive by the European Association of Craft, Small and Medium Sized enterprises UEAPME, is addressed to the current legislator. We welcome the document with some smaller changes and hope that it can be adopted fast. SMEs need a tangible solution to UTPs in the food sector.
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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

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and

9 Mar 2018 · Connected Car

Meeting with Elżbieta Bieńkowska (Commissioner) and

27 Feb 2018 · Exchange of views on current topics

Meeting with Marianne Thyssen (Commissioner) and

27 Feb 2018 · Social dialogue and Social Fairness Package

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

6 Feb 2018 · Exchange of views on the Pillar to improve access to social protection

Meeting with Andrus Ansip (Vice-President) and

30 Jan 2018 · GDPR, e-privacy

Meeting with Marc Lemaitre (Director-General Regional and Urban Policy)

15 Jan 2018 · Nouveau programme politique régionale et implication des PME

Response to Evaluation of Food Contact Materials (FCM)

21 Dec 2017

UEAPME, the European Association of Craft, Small and Medium sized enterprises, agrees with the request to clarify the scope and the definitions of the Reg. 1935/2004 on Food Contact Material.
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Response to Amendments of the Annexes to REACH for registration of nanomaterials

6 Nov 2017

The suggested draft-regulation should address the perceived lack of information in relation to nanoforms of substances and the hazards and risks that they may pose. This suggested “upgrade” of the REACH-regulation certainly will mean an additional and significant burden for companies, which have intentionally or unintentionally nanomaterials in their portfolio. They will have to provide additional analytical data and studies. This will involve considerable expenses and it would be only fair to forsee a special SME-fund to compensate the disproportional burden for SME that is caused by REACH and in particular by such additional requirements. Like the EC, we also consider a nanoform of a substance to be in principle equivalent to its bulk form. This approach can contribute that the overall costs are not as high as they could be. However, a more pressuring problem we see due to the fact that there is still no final definition of a “nanomaterial”. That causes a significant uncertainty and may lead companies to take wrong decisions and waste resources for something that is not needed to fulfill legal requirements, something that may be fatal for a SME.
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Meeting with Maroš Šefčovič (Vice-President) and

6 Nov 2017 · 2nd Mobility Package

Meeting with Jan Mikolaj Dzieciolowski (Cabinet of Commissioner Corina Crețu)

25 Sept 2017 · Future of Cohesion Policy

Response to Initiative to improve the Food Supply Chain

22 Aug 2017

UEAPME, the European Association of Craft, Small and Medium Sized Enterprises, thanks the European Commission for the consultation on the initiative to improve the food supply chain in the framework of the inception impact assessment. At the same time, UEAPME regrets the fact that the inception impact assessment is initiated by DG AGRI solely as we believe the food supply chain concerns all actors of the chain alike and therefore, UEAPME is of the opinion that all actors need to be addressed equally. This should be reflected from the start of the process of any impact assessment.
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Meeting with Monika Ladmanova (Cabinet of Commissioner Věra Jourová)

29 Jun 2017 · Work-Life Balance

Meeting with Andrus Ansip (Vice-President) and

24 May 2017 · GDPR Implementation and Privacy Shield

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)

8 May 2017 · new appointed secretary general

Meeting with Dominique Ristori (Director-General Energy)

27 Mar 2017 · Energy policy

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and European Chemical Industry Council and

21 Mar 2017 · Reach evaluation

Meeting with Daniel Calleja Crespo (Director-General Environment)

23 Feb 2017 · Circular Economy, REACH for SMES

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

15 Feb 2017 · Meeting to introduce the new Secretary General of UEAPME, Ms Véronique Willems

Meeting with Brian Synnott (Cabinet of Vice-President Karmenu Vella)

1 Feb 2017 · Green Week

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

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

Meeting with Marianne Thyssen (Commissioner)

13 Jan 2017 · Pillar of Social Rights

Meeting with Dominique Ristori (Director-General Energy)

21 Dec 2016 · Energy policy

Meeting with Andrus Ansip (Vice-President) and

19 Dec 2016 · Discussion with industry on general data protection regulation implementation

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

21 Nov 2016 · Consultation of Social Partners on Energy Union

Meeting with Dominique Ristori (Director-General Energy)

2 Sept 2016 · Internal energy market

Meeting with Jyrki Katainen (Vice-President)

21 Apr 2016 · SMEs and EFSI

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

16 Mar 2016 · Startups, Geoblocking, Collaborative economy, Late payment Directive, SME event, Capacity-building

Meeting with Stephen Quest (Director-General Taxation and Customs Union)

24 Feb 2016 · Introductory meeting

Meeting with Andrus Ansip (Vice-President) and

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

Meeting with Valdis Dombrovskis (Vice-President) and

10 Feb 2016 · Introductory meeting with the new President of UEAPME. Vice-President and Ms Ulrike Rabmer-Koller discussed ways to strengthen institutional cooperation and reinforce social dialogue involving SMEs

Meeting with Jyrki Katainen (Vice-President)

26 Jan 2016 · SMEs, Investment plan

Meeting with Stefaan Hermans (Cabinet of Commissioner Marianne Thyssen)

26 Jan 2016 · Courtesy meeting by new President of the UEAPME

Meeting with Jasmin Battista (Cabinet of Vice-President Andrus Ansip), Juhan Lepassaar (Cabinet of Vice-President Andrus Ansip) and

24 Nov 2015 · Digital contracts

Meeting with Daniel Calleja Crespo (Director-General Environment)

27 Oct 2015 · Circular Economy Package and SMEs

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

23 Sept 2015 · SME policy, Internal market strategy, Better regulation

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 Elżbieta Bieńkowska (Commissioner)

26 Jun 2015 · Small Business Act and SME Policy

Meeting with Frans Timmermans (First Vice-President) and

13 Apr 2015 · Better regulation / Small Business Act

Meeting with Jonathan Hill (Commissioner)

6 Mar 2015 · Capital Markets Union + SMEs

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

12 Feb 2015 · Meeting with Social Partners

Meeting with Aura Salla (Cabinet of Vice-President Jyrki Katainen)

26 Jan 2015 · Investment Initiative

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

26 Jan 2015 · Meeting with social partners

Meeting with Aura Salla (Cabinet of Vice-President Jyrki Katainen), Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

26 Jan 2015 · Investment plan

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

14 Jan 2015 · Meeting with Social Partners

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

10 Dec 2014 · Investment initiative