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).

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.

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.

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 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.

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.

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 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.

The consultation process with our member organisations is still going on. We will finalise our position paper in the coming days. However we can already provide the following preliminary remarks. In general the Due Diligence Directive leaves too much freedom to the Member States to legislate further, so it won’t be possible to create a level playing field and a harmonised due diligence framework within the Internal…

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 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.

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).

SMEunited supports the overall objectives of the Digital Fairness Act (DFA) to protect vulnerable people online and ensure a level playing field for all. The European Union must play its protective role, particularly with regard to SMEs, which are suffering from fierce unfair competition linked to the development of e-commerce platforms. European consumers benefit some of the strongest protections in the world.

Please find SMEunited complete feedbacks attached. Overall, we very much welcome the initiative to take a horizontal approach to lay down common basic rules for all sectors regarding data access. The Data Act is a significant step towards a more competitive and innovative data economy, and it is crucial for SMEs to have better and fairer access to data.

POLICY PAPER Ref. Ares(2021)4159816 - 25/06/2021 SMEunited input to the EC Roadmap on the Data Act SMEunited welcomes the opportunity to comment on the European Commission’s Roadmap on Data Act (including the review of the Directive 96/9/EC on the legal protection of databases), published on 28 May 2021. SMEunited agrees with the objectives of the initiative.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

POLICY PAPER Ref. Ares(2021)2238312 - 31/03/2021 SMEunited position paper on Digital Services Act (DSA) - COM(2020) 825 final Introduction SMEunited welcomes the opportunity to comment on the European Commission’s proposal on the Digital Services Act (COM(2020) 825 final), published on 15 December 2020.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

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.

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.

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, [name removed]

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.

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.

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.

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 welcome the proposal on horizontal cybersecurity requirements as it includes several of SMEuniteds preliminary requests. Indeed, a patchwork of rules would hamper the ability of manufacturers of digital products, especially of small and medium size, to operate and scale up across European markets. To ensure legal certainty, we insist that the requirements must be defined precisely.

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.

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 European Union needs more than two million additional homes a year, and the vast majority of the building, renovation and installation work needed to deliver them is carried out by small and micro construction enterprises. In construction, 99.9% of enterprises are SMEs and 94% are micro-enterprises.

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.

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.

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.

We would like to highlight the following points: 1. Non-financial reporting outside the scope of CSRD The Omnibus directive (Directive (EU) 2026/470 of the European Parliament and of the Council of 24 February 2026), and the delegated act establishing sustainability reporting standards for voluntary use by undertakings protected by the value chain cap, ensure that enterprises subject to the CSRD cannot require…

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.

POSITION PAPER Ref. Ares(2022)3937446 - 25/05/2022 Position paper on “Empowering consumers for the green transition Substantiating Green claims (COM(2022)143) Introduction SMEunited explicitly supports the proposal's underlying objective of a sustainable circular economy. However, when achieving this goal, various factors must be considered.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

SMEunited welcomes the initiative to review the electricity market design with the aim to reduce the volatility of the market. Next to new market rules, investments to increase supply like renewable energy production, networks, interconnectors and storage capacities are necessary.

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.

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.

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.

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.

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.

SMEunited welcomes the proposal as updated liability rules are necessary to account for the necessities of a digitalised world and a circular economy. Below our main take aways: - The proposal must take into account that an increased liability comes together with higher prices for European products. - Entrepreneurs require clear rules in order to make their business decisions.

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.

POLICY PAPER Ref. Ares(2021)5693238 - 17/09/2021 SMEunited input to the EC Roadmap on the Revision of the Package Travel Directive (PTD) SMEunited welcomes the opportunity to comment on the European Commission’s Roadmap on the Revision of the Directive (EU) 2015/2302 on package travel and linked travel arrangements, published on 6 August 2021. SMEunited agrees with the objectives of the initiative.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

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.

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.

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.

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.

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.

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.

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.

SMEunited believes that harmonised implementation of the existing OEL in the relevant sectors is the right approach and should be the first step before considering to further tighten limits, which, in addition, may not be feasible to be implemented in practice by Crafts and SMEs. Additional costs for the sectors more at risk of dealing with asbestos and consumers should be taken into account.

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…

SMEunited welcomes the aim to provide more clarity and legal security for businesses engaging with AI in EU Member States and especially for businesses trading across borders. Bringing minimum levels of protection is appropriate but must take into account the size and resources of the different economic actors.

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.

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.

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.

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 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.

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.

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.

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 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.