SMEunited

SMEunited supports the aim to effectively address barriers to the EU Single Market for secondary raw materials and circular business models, such as regulatory fragmentation, lack of economic incentives and limited funding for small and medium enterprises (SMEs).

SMEunited has supported and welcomed the 2024 Directives as important step to improve participation of SMEs. However, delays and insufficient implementation of the Directive in national law did not lead to the expected improvements.

A simple, accessible, and proportionate EU Inc. is essential for SMEs, through low administrative burdens and digital-by-default procedures. A fully digital company lifecycle and seamless cross-border activity require interoperable EU systems such as BRIS and eIDAS, as well as improved access to finance and recognition of modern business models.

Recent developments highlighted how the fragmentation of the Single Market hampers companies growth in the EU. It negatively impacts entrepreneurs ambitions, investors willingness to finance European companies and ultimately EU productivity. The initiative of a 28th Regime, building on former initiative such as the European Company Statute, could bring solutions and ease companies growth cross-border.

For European SMEs, the Public Procurement Act should focus on defining and simplifying the procurement process rather than prescribing what has to be procured. Additionally, the division of contracts into lots is essential to facilitate SME participation. Therefore, the current provision should be strengthened by establishing a mandatory 'divide or explain' mechanism.

From the SME perspective, the EU freedom to Stay is about economic resilience and social cohesion. By empowering local businesses and investing in people, the EU can ensure that staying is as viable and attractive as leaving.

SMEunited supports addressing a feasible substantiation of green claims and creating a harmonised legal framework. SMEunited calls for simple, workable and proportionate substantiation criteria in the Directive on Green Claims. The Directive must not result in the use of green claims being reserved for financially strong market players. Therefore, SMEunited calls for changing the Directive in several ways.

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.

SMEs are a driving force in Europe's mobility and transport economy. They play a key role in greening fleet operations, often adopting new technologies early on through leasing, rental, and shared mobility solutions. However, the European Commission's accelerated path towards a legislative proposal on zero-emission vehicle (ZEV) targets for corporate fleets risks undermining these efforts.

SMEs are a driving force in Europe's mobility and transport economy. They play a key role in greening fleet operations, often adopting new technologies early on through leasing, rental, and shared mobility solutions. However, the European Commission's accelerated path towards a legislative proposal on zero-emission vehicle (ZEV) targets for corporate fleets risks undermining these efforts.

SMEunited supports addressing the risk of circumvention and resulting unfair competition for small and medium enterprises in Europe with regards to the Carbon Border Adjustment Mechanism (CBAM), for example in the iron/iron/steel and aluminium processing industry.

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.

SMEs are disproportionately vulnerable to escalating climate risks. Floods, droughts, wildfires, storms and extreme heatwaves lead to asset damage, operational and supply chains breakdowns, growing financial risk, and threats to workers health and business productivity.

SMEunited supports the European Commissions ongoing efforts to effectively address barriers to accelerating a gradual, cost-efficient and SME-friendly electrification, that keeps system costs and consumer bills down.

Dear Madam, dear Sir, On behalf of SMEunited, I would like to inform you that we are not able to provide feedback on this consultation within the deadline of today (5 May). Due to the huge number of consultations, we are still discussing our position paper with our member organisations and we would be glad if you could accept our feedback that will be finalised in the upcoming days.

Proving of DNSH is especially for SMEs and other small entities extremely burdensome as the cost benefit analysis commissioned by DG GROW on taxonomy for SMEs has proved. Therefore, the 2nd Platform on Sustainable Finance rightly recommended in its streamline approach of sustainable finance for SMEs that SMEs which work in Europe and fulfil all legal requirements are not doing significant harm as long as they are…

To decarbonise the heating and cooling sector, the forthcoming Heating and Cooling Strategy must comprehensively must address SMEs key challenges from complex regulation and high costs to skills gaps and limited financial incentives.

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.

SMEunited, the European SME organisation, emphasises that the Digital Fitness Check must guarantee that EU digital legislation supports the competitiveness of SMEs by being proportionate, coherent, and easy to implement.

The Regulation's complex requirements make it difficult for SMEs to keep existing products on the market while also investing in biocidal innovation. Responsible employer practices must include the highest standards of care and caution regarding occupational safety and health requirements, and environmental protection when biocides are used.

Energy security is essential for the competitiveness of small and medium enterprises (SMEs) in Europe. A future energy security framework must ensure a fair, well-integrated and resilient energy market that is free of fossil fuels, while expanding the supply of cost-competitive renewable energy.

SMEs form the foundation of the European economy. In the EU, 25.8 million out of 25.85 million enterprises are SMEs, providing almost two-thirds of total employment. The European Commissions review of Directive (EU) 2019/633, which addresses unfair trading practices in business-to-business relationships within the agricultural and food supply chain, is an important step towards better protecting smaller suppliers in…

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.

The bureaucratic burden on EU´s companies is significant. This is especially true for SMEs, which are struggling with the costs and complexity to implement the EU-legislation, which also includes the EU chemicals legislation.

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.

For SMEs, a level playing field is of great importance. All economic operators must comply with the same safety and conformity rules, regardless of their origin. However, the current situation shows that enforcement is falling short, especially regarding products entering the single market directly from third countries via e-commerce.

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.

The upcoming revision of the EU merger guidelines should take into account the specific characteristics of SMEs in European markets. Unlike large multinational corporations, SMEs often lack the financial and legal resources and therefore might face aggressive consolidation trends that reduce market. In particular, some acquisitions can remove innovative SMEs from the market.

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.