Zentralverband des Deutschen Handwerks (ZDH)

The Packaging and Packaging Waste Regulation is a source of enormous costs and bureaucratic hurdles for German craft businesses. The attached opinion sets out our demands in order to make the Regulation manageable and reduce the burden on micro and small businesses in the craft sector.

Filed in German · English published by the European Commission

We welcome the European Commission's efforts to create legislative simplifications for companies as part of the planned Digital Omnibus. Only by harmonizing complex rules, reducing over-laps, and modernizing the regulatory framework can we succeed in strengthening Europe as a center for business and innovation.

The European Commission announces a Circular Economy Act (CEA) in Q4 2026, a regulatory framework to promote the circular economy in the EU single market and strengthen the EU’s resilience. The proposed Regulation aims to help create sufficient supply and demand for secondary raw materials and a genuine internal market for waste and secondary raw materials.

Filed in German · English published by the European Commission

In its 2023 report on public procurement in the EU, the European Court of Auditors found that the latest reform of European public procurement rules did not lead to increased competition and SME participation in public tenders. Therefore, the planned revision of the EU public procurement directives should not focus solely on a possible reduction in the burden on contracting entities.

Filed in German · English published by the European Commission

In its 2023 report on public procurement in the EU, the European Court of Auditors found that the latest reform of the European public procurement rules did not increase competition and the participation of SMEs in public tenders. Therefore, the planned revision of the EU public procurement directives should not in itself take into account the possibility of reducing the burden on procuring entities.

Filed in German · English published by the European Commission

The Central Association of German Crafts e.V. (ZDH) welcomes in principle the EU’s efforts to achieve climate neutrality by 2050. Against the background of greenhouse gas emissions from the building stock, this is becoming an important factor in the target spent.

Filed in German · English published by the European Commission

The German Confederation of Skilled Crafts and Small Businesses (Zentralverband des Deutschen Handwerks (ZDH, representing more than 1,000,000 crafts Enterprises from Germany) welcomes that the Commission asks for feedback upon the upcoming draft of the Climate Law as part of the Green Deal. However, we also express our concern that the Commission does not intend to initiate a comprehensive public consultation.

Stellungnahme Überarbeitung der EU-Abfallrahmenrichtlinie Konsultationsbeitrag der Arbeitsgemeinschaft der deutschen Lebensmittelhandwerke (AGLMHW) Brüssel, 22.11.2023 Zentralverband des Deutschen Handwerks Abteilung Europapolitik Ansprechpartnerin: [name removed] [phone removed] [email removed] Lobbyregister: R002265 EU Transparency Register: 5189667783-94 Einleitung: Der am 5.

Filed in German · English published by the European Commission

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

The ZDH has so far been critical of the European product and organisational eco-balances project. The reason for this was, firstly, the fear that the LCAs will entail significant costs and costs, thereby placing small-scale production at a structural disadvantage compared to industrial production.

Filed in German · English published by the European Commission

ZDH, the German Confederation of Skilled Crafts and Small Businesses, represents more than one million crafts enterprises. The majority of these are active in the construction sector. In short, we want to stress the following aspects. For a more detailed feedback, we kindly refer to the attached document.

Filed in German · English published by the European Commission

The German Confederation of Skilled Crafts (ZDH) represents more than 1 million skilled crafts enterprises from Germany, many of which are also active in the construction sector. The Construction Products Regulation (CPR) and its revision is therefore of particular importance for ZDH and should take at least the following aspects into account: No obligation for CE-marking in case of individual production: The…

The Central Association of German Crafts (ZDH), as the umbrella association for crafts, represents the interests of around 1 million craft businesses with more than 5.6 million employees and around 350.000 apprentices. As part of the first Omnibus package, the European Commission has proposed simplifications, including on CSRD and CSDDD.

Filed in German · English published by the European Commission

The German Confederation of Skilled Crafts and Small Businesses (ZDH) explicitly welcomes the proposal for a European data law (Data Act). Fair access to competition-relevant data and open interfaces are essential for crafts operating in downstream markets. Remote maintenance and diagnostics are becoming common practices.

ZDH welcomes the possibility to provide feedback on the inception impact assessment (IIA) regarding the planned Data Act. General observations: The IIA pinpoints the core challenges for SMEs in acquiring data access and using data in business-to- business situations (B2B) and rightly focuses on the GDPR which plays a key role in data portability. We believe that Art. 20(2) GDPR is not fit for purpose.

• There is an urgent need to create fair competitive conditions in the platform economy. • On the one hand, it is important to have fair contractual terms and conditions between online platforms and the companies offering their services and products on the platforms.

Filed in German · English published by the European Commission

ZDH Basically supporting measures to promote the free movement of workers. The EU should support the recognition of qualifications but not impose additional legal regulations. The requirements for professional qualifications set by the destination countries must continue to be decisive. The recognition of foreign professional qualifications acquired in EU countries play a subordinate role in Germany.

Filed in German · English published by the European Commission

ZDH Basically supporting measures to promote the free movement of workers. The EU should support the recognition of qualifications but not impose additional legal regulations. The requirements for professional qualifications set by the destination countries must continue to be decisive. The recognition of foreign professional qualifications acquired in EU countries play a subordinate role in Germany.

Filed in German · English published by the European Commission

Then German Confederation of Skilled Craftsa and Small Businesses (ZDH) Basically supports measures to promote the free movement of workers. The EU should support the recognition of qualifications but not impose additional legal regulations. The requirements for professional qualifications set by the destination countries must continue to be decisive.

Filed in German · English published by the European Commission

With the operationalisation of the taxonomy and the expansion of the NFRD/CSRD, the demand for business data is once again significantly increasing in terms of the ‘green’ value added. For example, the taxonomy will impose a specific obligation on large companies to disclose sustainability information under the CSRD.

Filed in German · English published by the European Commission

Key requirements: • No extension of the scope of the NFRD to SMEs • Create fair voluntary disclosure frameworks for SMEs @-@ Explanation: SMEs take their collective responsibility seriously and are strongly committed to sustainability on a traditi-on-line basis. Craft businesses are an essential pillar of sustainability, as they strengthen regional economic cycles, repair, advise, maintain, plan and develop.

Filed in German · English published by the European Commission

The ZDH considers the proposal to introduce common specifications as an alternative to harmonised standards to be very problematic. Such a measure would create a parallel system, which could result in fragmentation of the internal market, higher costs for businesses and less involvement of relevant stakeholders.

ZDH-feedback on the draft implementing act on the DPP Registry: ZDH supports the establishment of a well-functioning registry. From a think small first-perspective, it considers amendments of several provisions essential to avoid SMEs will being disproportionately burdened. The skilled crafts sector in Germany counts around one million enterprises employing around 5,6 million staff.

The ZDH welcomes the SME relief package presented on 12 September 2023, as well as the previous proposals to achieve a 25 % reduction in reporting requirements, which were presented on 17 October together with the work programme for 2024. It is an important and long-awaited signal that the European Commission is focusing more on cutting red tape.

Filed in German · English published by the European Commission

The Central Association of German Crafts represents one million craft businesses employing around six million people. Many of the businesses are micro and small enterprises, which rely mainly on regional banks and savings banks for financing. In the attached opinion, you will find the ZDH’s proposals on how this type of funding can continue to be secured and facilitated.

Filed in German · English published by the European Commission

The Central Association of German Crafts (ZDH) represents the interests of 1 million craft businesses employing around 5.6 million people. These businesses would also benefit from the simplification of banking regulation, which could facilitate lending. In particular, proportionate requirements are needed for small banks as well as for lending to small businesses.

Filed in German · English published by the European Commission

ZDH explicitly supports the proposal’s underlying objective of a sustainable circular economy. However, when achieving this objective, various factors must be considered. WE welcome the proposal to amend Directive 2005/29/EC (“Unfair Commercial Practices Directive”) as the right approach to protect against unfair commercial practices related to greenwashing and misleading environmental claims in general.

Filed in German · English published by the European Commission

For ZDH (German Confederation of Skilled Crafts and Small Businesses) the Quality Jobs Act will be one of the central initiatives of this legislative term in the area of social and employment policy. It will reach everyday practice in the more than one million skilled crafts businesses and have a direct impact on the day-to-day working lives of the roughly six million people employed in the skilled crafts.

Filed in German · English published by the European Commission

Setting EU-wide limit values for air pollutants under Directive 2008/50/EC is, in the view of the ZDH, a necessary and meaningful task of EU policy. A successful pollution reduction policy requires, in addition to setting limit values, a consistent and uniform approach to ambient air measurement across Europe. In the view of the ZDH, there is considerable room for improvement.

Filed in German · English published by the European Commission

Setting EU-wide limit values for air pollutants under Directive 2008/50/EC is, in the view of the ZDH, a necessary and meaningful task of EU policy. A successful pollution reduction policy requires, in addition to setting limit values, a consistent and uniform approach to ambient air measurement across Europe. In the view of the ZDH, there is considerable room for improvement.

Filed in German · English published by the European Commission

Common specifications The ZDH is convinced that in any case common specifications should only be consid-ered as a last resort measure. The primacy of stakeholder driven harmonised stand-ards must be preserved as the main way to facilitate compliance and provide presump-tion of conformity.

The German Confederation of Skilled Crafts and Small Businesses (ZDH) welcomes that the scope of the Just Transition Fund (JTF) includes the support of SMEs to create new opportunities for growth and employment in the regions most impacted by the green transition.

The Central Association of German Crafts (ZDH) represents the interests of around 1 million craft businesses in Germany, employing around 5.6 million people. The attached opinion sets out practical approaches on how to significantly reduce the burden on craft businesses by making the necessary adjustments. The proposals go beyond simplifying EU rules in the area of direct taxation.

Filed in German · English published by the European Commission

The ZDH supports strengthening market surveillance, particularly in online trade and imports from third countries. The EU should focus on enforcing existing regulations more effectively and ensure that platforms are held fully accountable for the products they sell, which often do not meet European safety, labour or environmental standards.

As the European Commission prepares its next European VET-strategy, we must set the course for VET systems across the EU that empower learners and businesses alike. VET is not only a powerful launchpad into work its a cornerstone of competitiveness, social inclusion, and democratic resilience.

Common specifications The ZDH is convinced that in any case common specifications should only be consid-ered as a last resort measure. The primacy of stakeholder driven harmonised stand-ards must be preserved as the main way to facilitate compliance and provide presump-tion of conformity.

From the point of view of employers in the German craft sector, there is no need for a directive to strengthen the application of the principle of equal pay for men and women through pay transparency and enforcement mechanisms.

ZDH, the German Confederation of Skilled Crafts and Small Businesses, is one of the leading associations of the German economy. ZDH is the roof association of 53 Chambers of Crafts, 49 craft trade associations and other institutions of the craft sector in Germany. ZDH represents the interests of 1 million companies, 5,5 million employees and around 360 000 apprentices.

ZDH is of the opinion that the current EU legal framework is sufficient, both in terms of REACH Annex XVII restrictions as well as in terms of occupational safety and health legislation. The EU Commission's impact assessment correctly recognises that the main risk from asbestos is in the HANDLING of asbestos, i.e.

The ZDH welcomes the Commission’s initiative to draw lessons from the pandemic and to create a European emergency instrument also in the context of new crises. The strength of EU countries lies in their cooperation and cohesion in the EU — only together can the protection of the European people and the economy from global crises be ensured.

Filed in German · English published by the European Commission

The Central Association of German Crafts represents the interests of around one million mainly small craft businesses with more than 5.6 million employees in Germany. As funding opportunities for our members are closely linked to the smooth functioning of the financial system, we are participating in this consultation.

Filed in German · English published by the European Commission

The Central Association of German Skilled Crafts (ZDH) supports the plan to revise EU rules on electronic invoicing. However, from a ZDH point of view, the use of so-called extensions, i.e. extensions of the e-invoice beyond the core CEN EN 16931 standard, must still be allowed in both B2G and B2B cases if the issuer of the invoice and the recipient of the invoice agree on the use.

Filed in German · English published by the European Commission

The Central Association of German Crafts represents the interests of around one million mainly small craft businesses with more than 5.6 million employees in Germany. Craft businesses depend not only on smooth lending, but also on the security of their deposits with the main bank in order to be able to pay salaries, materials or other items.

Filed in German · English published by the European Commission

The Commission is considering a partnership to help SMEs innovate, collaborate and grow and to support their integration into global value chains and new markets in order to contribute to the EU’s long-term competitiveness and economic growth - building on the existing Eurostars2 programme but significantly revising its scope and expanding its partners.

The Central Association of German Crafts represents the interests of around one million mainly small craft businesses with more than 5.6 million employees in Germany. As funding opportunities for our members are closely linked to the smooth functioning of the financial system, we are participating in this consultation.

Filed in German · English published by the European Commission