UNION EUROPEENNE DE L ARTISANAT ET DES PETITES ET MOYENNES ENTREPRISES EUROPÄISCHE UNION DES HANDWERKS UND DER KLEIN- UND MITTELBETRIEBE

Transcription

1 Position Paper UEAPME 1 position on the Proposal for a Regulation of the European Parliament and of the Council on the Programme for single market, competitiveness of enterprises, including small and medium-sized enterprises, and European statistics and repealing Regulations (EU) No 99/2013, (EU) No 1287/2013, (EU) No 254/2014, (EU) No 258/2014, (EU) No 652/2014 and (EU) 2017/826. (COM(2018) 441 final) Executive Summary UEAPME welcomes the aims of the Proposal, such as improving the functioning of the internal market, improving the competitiveness of businesses with a focus on SMEs and increasing the level of standardisation by streamlining and finding better synergies between different funding mechanisms for SMEs. However, UEAPME also points out that since the Proposal is at its current stage very general in nature, the activities carried out under the Programme and the distribution of finances need to be further elaborated involving the relevant stakeholders. The Programme encompasses a wide variety of arrays also including consumer protection interests. Measures taken under the aim of ensuring a high level of consumer protection need to prove that they also improve the working of the internal market and do not increase the bureaucratic burden for enterprises. Introduction First, UEAPME refers to its Position Paper Priorities of SMEs for the next Multiannual Financial Framework from 26th of April 2018 in which the priorities for SMEs for the upcoming financial period were underlined. UEAPME stands by its position recommending a MFF with a focus on increasing competitiveness giving priority to the following challenges: 1 UEAPME subscribes to the European Commission s Register of Interest Representatives and to the related code of conduct as requested by the European Transparency Initiative. Our ID number is UNION EUROPEENNE DE L ARTISANAT ET DES PETITES ET MOYENNES ENTREPRISES EUROPÄISCHE UNION DES HANDWERKS UND DER KLEIN- UND MITTELBETRIEBE EUROPEAN ASSOCIATION OF CRAFT, SMALL AND MEDIUM-SIZED ENTERPRISES UNIONE EUROPEA DELL ARTIGIANATO E DELLE PICCOLE E MEDIE IMPRESE 1

2 improving access to expertise and assistance services and finance for SMEs; promoting entrepreneurship; strengthening the industrial base and developing knowledge-intensive services in Europe to ensure that Europe s economy is able to provide jobs, growth and a high living standard; contributing to a stable and inclusive society in order to ensure social and political stability; mastering the change to a sustainable economy and society; supporting a knowledge-based economy and society by improving Europe s innovation system; supporting and pushing needed reforms to improve productivity and competitiveness; helping SMEs to keep pace with technological and societal challenges, especially as regards the shift towards a sustainable economy, digitalisation and globalisation; reducing the skills gap on labour markets. In the context of the Proposal, UEAPME welcomes the streamlining of financing instruments under the InvestEU Fund and hopes that the new organisation will ensure a more simple and efficient operating of these funds to better benefit SMEs. The proposal lacks an explanation, however, as to how exactly this increased coherence should be achieved, considering that most measures of the current COSME Programme should be maintained. UEAPME also underlines that despite the change in the management of the financing system, the continuity of financial assistance for SMEs needs to be guaranteed in the transitional period. Further, UEAPME wishes to underline that the Proposal, in its current stage, is of a very broad nature and does not foresee specific measures on how financing will be carried out. Moreover, the proposed scenarios for the various measures (e.g. the new Scale-up instrument as described in the Staff Working Document on pp. 295/296) do not define the amounts of the financial resources located for the different measures. It is true that while certain flexibility as regards the Programme is welcome, it makes it difficult to give constructive feedback on the composition of the Programme at this stage. In this view, UEAPME underlines the need to build on the Proposal an ambitious work programme listing the specific measures that will be implemented in order to respond to the needs of all types of SMEs. Additionally, future legislative instruments building on this Proposal should be developed together with the representative business organisations in order to best adapt the Proposal to the realities of European SMEs. In addition, the Programme which aims to improve the functioning of the Single Market, includes various activities that have so far been financed from different headings and that relate to the Single Market and the competitiveness of SMEs to a different extent and importance. For example, a significant share of the budget of the future Single Market Programme is allocated to health-related dossiers, such as food safety as well as to safeguarding of consumer protection interests. Since the Proposal is first and foremost meant to bring added value to the competitiveness in the Single Market, the actions under these objectives need to be thoroughly analysed in order to avoid launching clashing initiatives under the Proposal. When the Programme will be promoted in the business community, doubts to the efficiency of the Programme may be raised, as more funds in absolute and relative terms are devoted to health-related dossiers than actual enterprise supporting measures. 2

3 Comments on the Programme With the aim to guarantee that the objective of the Proposal to ensure the competitiveness of SMEs is achieved and that the funds distributed under this Programme are managed and used in the most optimal way, UEAPME highlights the following aspects: Since SMEs are not a homogenous group of enterprises, their needs for assistance vary widely, which is why the financing for SMEs should cover a broad range of areas from support of a more general nature, i.e. provision of relevant information and assistance services, cutting red tape and simplifying the activities of SMEs to granting more specific financial contributions in different sectors, including facilitating the digital transformation of SMEs. UEAPME emphasizes that the financing given under the Programme objective of improving the competitiveness of SMEs should be limited to SMEs and not include the so-called mid-caps (of which so far not even an agreed definition exists) who differ vastly from SMEs having more capabilities to expand and better access to financing. The funds under the Programme should first and foremost be directed to enterprises who are currently lacking the support to better participate on the Single Market and who can gain from the Programme the most. Middle capitalisation companies that vastly exceed the capabilities of SMEs do not fall under that category. Therefore particular attention should be turned to microenterprises and enterprises engaged in craft activities. The Proposal does not include any references to the Small Business Act, however, with the aim to achieve most beneficial results for European SMEs, the principles of the SBA should be echoed in this Proposal and its implementation, including the only once and think small first principles. In order for SMEs to practically benefit from the Programme, the financing measures provided for under the Programme need to be accessible for all companies throughout their life cycle. Therefore, UEAPME advocates to ensure that information activities are set in place in order for these measures to reach a wide range of SMEs. Furthermore, administrative formalities should be kept to a necessary minimum in order not to discourage SMEs from applying. The current European SME policy and especially the supporting measures and tools, such as the SME tests, the country fact sheets, SME conferences, SME envoys network, are nearly exclusively financed by the current COSME programme. Other important initiatives, which are supported under the COSME programme, are in particular the Enterprise Europe Network (EEN), the exchange programme Erasmus for Young Entrepreneurs, the Intellectual Property Rights SME Helpdesk as well as support measures in the area of chemical legislation. UEAPME underlines that these measures should receive a sufficient amount of funding also under the Proposal to continue delivering assistance for SMEs. Regulation (EU) No 1287/2013 of the European Parliament and of the Council of 11 December 2013 establishing a Programme for the Competitiveness of Enterprises and small and medium-sized enterprises (COSME) ( ) and repealing Decision No 1639/2006/EC Article 21 foresees a committee to assist the Commission in the implementation of the COSME programme. In the new Proposal the establishment of such a committee is not foreseen. UEAPME finds, however, that in order to ensure the effective use of the funds under the Proposal, a committee consisting of national and 3

4 European-level representatives should be convened to provide the Commission with valuable practical advice on how to best benefit from the Programme. Therefore UEAPME proposes to establish a committee with the focus on fulfilling the objective of improving the competitiveness of enterprises with a special emphasis on SMEs. The committee should include representatives of Member States as well as business organisations and could meet in different formations depending on the specific topic. Similarly, when evaluating the success of the Programme, UEAPME believes that the engagement of local authorities and business organisations helps to give a better overview of the effectiveness of the measures under the Programme. It will ensure that the financing under the Programme is directed towards the right beneficiaries and actions which need the help of the Programme the most. Regarding standardisation, the new Proposal should particularly support measures that help ensure the participation of SMEs and microenterprises in the European standardisation process of formulating and adapting European standards and requirements as well as the implementation of these standards in the enterprises. Stable funding for the Small Business Standards organisation (SBS) should be guaranteed on a long-term basis as the number of standards is constantly increasing. In order to ensure the effectiveness of the projects undertaken under the Single Market Programme and make changes when needed, statistical offices should be equipped with the necessary means to collect relevant data from enterprises. This needs to be done in a proportionate and reasonable way without creating unnecessary burdens for businesses. Existing data sources should first be tapped into, before additional data is requested of enterprises. UEAPME reiterates that it does not support the introduction of the "IFRS for SMEs" in the European accounting framework. Indeed IFRS are based on a top-down-approach. This is completely incompatible with the important "think small first"-principle of European legislation and IFRS are not suitable for SME needs. Furthermore, since the implementation of the principles as foreseen in the Proposal is subject to more detailed implementing actions, UEAPME hereby declares its readiness and willingness to provide input to develop the Programme further in order to best benefit European SMEs under the Proposal. Proposed amendments Text proposed by the Commission Amendment Recital 22 Strengthening the competitiveness of European enterprises while reassuring an effective level playing field and an open and competitive internal market is of outmost importance. SMEs are the engine of the European economy making Strengthening the competitiveness of European enterprises while reassuring an effective level playing field and an open and competitive internal market is of outmost importance. SMEs are the engine of the European economy making up 99% 4

5 up 99% of all businesses in Europe, providing two thirds of jobs, and contributing substantially to the creation of new jobs with a regional and local dimension. of all businesses in Europe, providing two thirds of jobs, and contributing substantially to the creation of new jobs with a national, regional and local dimension. Recital 29 Creativity and innovation are crucial for the competitiveness of the Union's industrial value chains. They represent catalysts for industrial modernisation and contribute to smart, inclusive sustainable growth. However, uptake by SMEs is still lagging behind. The Programme should therefore support targeted actions, networks and partnerships for creativity-driven innovation throughout the industrial value chain. Creativity and innovation are crucial for the competitiveness of the Union's industrial entrepreneurial value chains. They represent catalysts for industrial enterprises modernisation and contribute to smart, inclusive sustainable growth. However, uptake by SMEs is still lagging behind. The Programme should therefore support targeted actions, networks and partnerships for creativity-driven innovation throughout the industrial entrepreneurial value chain. Article 21 Committee procedure Committee procedure 1. The Commission shall be assisted by the Standing Committee on the Food Chain and Animal Health established by Article 58 of Regulation (EC) No 178/2002 of the European Parliament and of the Council99. That committee shall be a committee within the meaning of Regulation (EU) No 182/ Where reference is made to this paragraph, Article 5 of Regulation (EU) No 182/2011 shall apply. Where the opinion of the committee is to be obtained by written procedure, that procedure shall be terminated without result when, within the timelimit for delivery of the opinion, the chair of the committee so decides or a simple majority of committee members so requests. 1a.(New) To ensure the achievement of the objective referred to in Article 3(2)(b), the Commission shall be assisted by a committee. That committee shall be a committee within the meaning of Regulation (EU) No 182/ The Commission shall be assisted by the Standing Committee on the Food Chain and Animal Health established by Article 58 of Regulation (EC) No 178/2002 of the European Parliament and of the Council99. That committee shall be a committee within the meaning of Regulation (EU) No 182/ Where reference is made to this paragraph, Article 5 of Regulation (EU) No 182/2011 shall apply. Where the opinion of the committee is to be obtained by written procedure, that procedure shall be terminated without result when, within the time- 5

6 limit for delivery of the opinion, the chair of the committee so decides or a simple majority of committee members so requests. Brussels, October 2018 For further information on this position paper, please contact: Luc Hendrickx Director Enterprise Policy and External Relations l.hendrickx@ueapme.com 6