��ࡱ�>�� ������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������!` ��H�bjbj\�\� .�>�>��sa �������$$$8� � � 8� tH!L8g8��!�j"j"j"j"E#.s# #�7�7�7�7�7�7�7$):h�<f�7E$T,E#E#T,T,�7$$j"j"�8*�0�0�0T,�$j"$j"h7.�0T,�7�0�0:p6,$$�6j"�! ����� ./��6 h7+8<g8�6R�<�/p�<�6�6�<$ 7\�#R�%��0�'T�(�#�#�#�7�720��#�#�#g8T,T,T,T,888d� 888� 888$$$$$$���� Reply template for the Public consultation on the future of the internal market In accordance with Commission Consultation standards this consultation will be open for 8 weeks (i.e. until 15 June 2006). We kindly invite you to make use of this reply template. You may reply in any of the official languages of the EU, although by replying in English, German or French, you will facilitate our analysis of your reply. Please send your comments by e-mail to:  HYPERLINK "mailto:markt-future-IM-policy@cec.eu.int" markt-future-IM-policy@cec.eu.int Or by regular mail to: Bernhard Friess European Commission DG Internal Market and Services C-107 5/32 B � 1049 Brussels PRIVACY STATEMENT Please be sure to indicate if you do not consent to the publication of your personal data or data relating to your organisation with the publication of your response or if you require us to publish your contribution anonymously. The contact data provided by the stakeholder make it possible to contact the stakeholder to request a clarification if necessary on the information supplied. By responding to this consultation you automatically give permission to the Commission to publish your contribution on the website HYPERLINK http://europa.eu.int/comm/internal_market/strategy/index_en.htm#consultation http://europa.eu.int/comm/internal_market/strategy/index_en.htm#consultation unless your opposition to publish your contribution is explicitly stated in your reply. The Commission is committed to user privacy and details on the personal data protection policy can be accessed at:  HYPERLINK "http://europa.eu.int/geninfo/legal_notices_en.htm#personaldata" http://europa.eu.int/geninfo/legal_notices_en.htm#personaldata �% I / We do not consent to the publication of this reply (tick the box) �% I / We accept this reply to be published anonymously (tick the box) Representative organisation, please state your Name, address (incl. country of residence), e-mail and level of activities (local, regional, national, EU, International) This is a joint response from four national UK business membership organisations:  HYPERLINK "http://www.chamberonline.co.uk/" British Chambers of Commerce: 65 Petty France, 1st Floor, London SW1H 9EU, UK  HYPERLINK "http://www.fsb.org.uk/" Federation of Small Businesses: 2 Catherine Place, London SW1E 6HF, UK  HYPERLINK "http://www.iod.com/is-bin/INTERSHOP.enfinity/eCS/Store/en/-/GBP/IODContentManager-Start;sid=6CaevPQObCLawrCDilqUKlzOelbtGqdIk4s=?TemplateName=homePage.isml" Institute of Directors: 116 Pall Mall, London SW1Y 5ED, UK  HYPERLINK "http://www.pcg.org.uk/cms/index.php" Professional Contractors Group: Sovereign Court, 635 Sipson Road, West Drayton UB7 7BG, UK For more information, please contact  HYPERLINK "http://www.smallbusinesseurope.org" smallbusiness|europe, who coordinated this response: Rue du Luxembourg 23 (bte 2), B-1000, Brussels Email:  HYPERLINK "mailto:benbutters@smallbusinesseurope.org" benbutters@smallbusinesseurope.org Your reply to the questions in the consultation document As indicated in the consultation document we do not expect all stakeholders to be concerned by all questions asked. However, we would be most grateful if you could state hereunder your replies to the questions that matter to you. Summary of key points: Many barriers to a fully-accessible internal market remain for most SMEs. Given SMEs� economic importance, this is a major obstacle to European growth. Easy access to information on the internal market and affordable problem solving would be a great help to SMEs Better regulation, better implementation and enforcement of internal market legislation are priorities for the UK SME community. Post-implementation impact assessment is crucial to this process Special provisions for SMEs should be integral to the internal market The internal market needs to be based on higher levels of entrepreneurship and innovation Many barriers exist in the internal market, particularly for SMEs, which makes it more difficult for them to exploit the opportunities on offer Innovation should not only be considered in terms of Research and Technological Development (RTD) and manufacturing Innovative ideas generated in the EU must also be commercialised in the EU The existing patent system does not guarantee high quality, affordable patents for SMEs Consultations are often not geared to the needs of SMEs Globalisation should not be perceived as a threat, rather an opportunity � improvements in the internal market should always be seen in the global context Member states and EU institutions should better promote the internal market as the basis for growth and job creation in the EU 1) Do you agree with the preliminary analysis of the current situation of the internal market and the challenges it is facing? If not, what is your analysis? 2) In which ways have you benefited from the opportunities offered by the internal market? Where, in your view, does it function well? Where do you see shortcomings? As leading representatives of the UK SME community, we welcome the opportunity to convey the views on the future of the internal market of the single most significant stakeholder group involved in Europe�s pursuit of jobs and growth. The single market is one of the greatest achievements of the European Union over the last fifty years. We are pleased that the Commission is showing no signs of complacency and recognises the need for further progress. We are also encouraged that the Commission points to the advancement of the internal market as key to the pursuit of the growth and jobs strategy � a point that we have consistently emphasised. The owners and managers of SMEs are central to innovation and entrepreneurship in the EU economy and, as such, are the key creators of jobs and growth. At present, it is the experience of SMEs, both as providers and consumers of goods and services, that the single market is failing on numerous levels. The Commission must not lose sight of this when considering potentially divergent responses to this consultation from other stakeholder groups. As the consultation document points out, the internal market remains incomplete in several areas, notably in the provision and purchase of services. As the services sector is made up predominantly of SMEs, we agree that it is essential that they are able to trade cross-border more easily than at present; the Services Directive must make this a reality. More broadly, the undermining of the country of origin principle, one which we consider to be enshrined in the Treaty of Rome, is illustrated by its replacement in the Services Directive with the nebulous "freedom to provide services". We still believe that the country of origin principle has a key role to play in the advancement of the internal market. It is also important to consider the EU�s internal market in the global context; it must be tuned in such a way as to deal with the ever increasing competitive pressures from outside the EU and to allow Europe�s businesses and citizens to reap the benefits of globalisation. 3) Do you agree with this choice of priorities? Are there others in your view? We agree with the choice of priorities, of which better regulation and better implementation and enforcement are paramount to the UK SME community. EU institutions should remain faithful to the commitments made in the Interinstitutional Agreement on Better Law-Making. Better regulation must continue to become more than just a slogan. There needs to be a real culture shift within all EU institutions and member states, away from the �regulate first, measure later� approach, towards embedding in policy making processes measures to assess the impact of policies, to simplify the regulatory framework, and to consider more systematically alternatives to regulation. In any market, businesses need to be able to respond rapidly to new opportunities and changing trends. This is particularly relevant in the internal market, given the increasing scale and sophistication of global competition. It is vital that policy mechanisms allow SMEs to adapt with minimum levels of regulatory compliance and administrative burdens. This requires an adaptable regulatory framework and a level playing field between member states in terms of implementation of internal market legislation. EU heads of state made a commitment at the 2006 Spring Summit to unlocking business potential, especially that of SMEs, through �specific provisions to encourage SME growth and developments, such as longer transition periods, reduced fees, simplified reporting requirements and exemptions�. Such measures must be integral to the development of the internal market. One major barrier that SMEs face within the internal market is easy access to information, which is critical given the time constraints that they already encounter in running a business. Businesses with low staff numbers must dedicate all of their time to their main line of activity; unlike larger organizations, they cannot afford to devote significant resources to investigating internal market opportunities or schemes run by the EU or national governments. In terms of investing more in information and communication, the Commission should enhance the role of one-stop-shops or single points of contact, as long as they are easily accessible and provide good quality information. 4) Internal market policy fosters economic reforms to which citizens and businesses then have to adjust.� Do you think sufficient account is taken of the costs of making these adjustments?� Why (not)?� Do you think flanking measures are needed to accompany market opening?� If so, what kind? Insufficient account is taken of the costs of making these adjustments. The costs are different for all the millions of businesses across the EU and it is impossible to know what the unintended consequences and general effects of implementing a new regulation will be until the regulation itself is actually imposed.� It would be impossible to track the effects of every single regulation/directive on business, but proper, independently audited pre-implementation impact assessments would go some way to easing the problem, as would post-implementation RIAs, perhaps two years after implementation. 5) In your experience, does the internal market offer sufficient opportunities for businesses? Why (not)? Where do you see barriers? The internal market could offer more opportunities for businesses if it were based on higher levels of entrepreneurship and innovation. One of the main barriers is the lack of an entrepreneurial culture across the EU internal market, which makes it more difficult for people to start a business and for existing SMEs to grow. We recognise that this area is largely the responsibility of the Commission�s DG Enterprise, as well as member states and regional authorities and the situation varies enormously across the EU. However, DG Internal Market has a vested interest in ensuring that SMEs are well supported in conducting business in the internal market, as this is the foundation of its success. Businesses of all sizes still encounter significant barriers in the internal market, for example linguistic and cultural. Given their relative lack of resources, smaller businesses have more difficulty in circumventing these barriers. Policy measures to tackle such barriers are inevitably long-term. The short term objectives should continue to focus on minimizing legal and technical obstacles to the free movement of goods, services, people and capital. We are aware that DG Internal Market is considering a proposal for a European Private Company Statute, following a feasibility study commissioned by DG Enterprise. This has been presented as a useful measure for breaking down barriers encountered by SMEs trading in more than one member state. We would certainly support any initiative that would fulfil this important objective, yet remain uncertain as to how this statute, in practical terms, would do so. We are also concerned that negotiations between member states may prove as protracted as those for the Company Statute (SE) unless there is greater clarity and political momentum. We emphasize our willingness to contribute to these discussions and urge DG Internal Market to consult carefully with stakeholders before preparing any proposal, making a particular effort to ensure that it receives input from the SME community across all 25 member states. We welcome the Commission�s home state taxation proposal, which introduces a new, voluntary, simplified tax regime for small businesses operating across national borders. SMEs operating across EU borders encounter administrative difficulties in calculating profits according to the different tax rules in each of the member states. This voluntary system retains the corporate tax rates of the member states, but allows small businesses to calculate all of their profits according to the tax rules of the country where they are based. Whether within the euro zone or not, high charges and long delays when transferring payments across borders remain a significant obstacle to the internal market, not only for businesses, but also for consumers. It is important to SMEs that electronic payments between member states are as easy, cheap and secure as they are already domestically. This would represent a significant step in allowing SMEs to reap the benefits of the internal market. We therefore support the objectives of the Directive on Payment Services in the Internal Market. It should not only be a question of whether the internal market offers many opportunities for businesses, but more importantly whether businesses can exploit those opportunities. This is often much more difficult for SMEs. We welcome, for example, the Services Directive, which we hope will eliminate some of the barriers that currently exist. Our support, however, is guarded, since despite some minor improvements in its current form, the directive is not as robust as it could have been. We feel in particular that the directive�s success in easing SMEs� ability to provide and purchase services across borders, rests on the good will of member states, and fear that member states that are not fully committed to the internal market may implement the directive in a half-hearted manner. We therefore call upon the Commission to monitor closely its implementation following adoption. 6) Do you consider that the internal market is 'innovation-friendly'? Why (not)? Where, in your view, are the main barriers to innovation? Which steps should be taken in order to ensure that the internal market is more innovation-friendly? 7) Do you consider that the current IPR regimes foster growth and innovation? In your experience, where is more focus or action needed? In the UK, SMEs are responsible for 64% of commercial innovations.�However, many of these innovations are not linked with RTD. The Commission has, historically, placed too much emphasis on RTD and manufacturing. The new Competitiveness & Innovation Programme is a small step in the right direction, but more must be done to reflect accurately the broad nature of innovation and the key role that new, small and growing businesses play therein. Many innovative ideas originating in the EU are being commercialised outside the EU. This worrying trend must be halted and reversed for obvious reasons. The Commission has a contribution to make and can be instrumental in the creation of a more entrepreneurial environment that facilitates and encourages the commercialisation of ideas. This transfer of innovation in the internal market also necessitates better links between academic institutions and business. As part of a broader strategy for fostering growth and innovation, IPR is an essential part of the EU internal market. Appropriate IPR protection must be available for differing types of innovations, so that patents, copyrights and trade marks are applied where they are most suitable. Patents are currently attracting particular attention within the EU. We feel that successful patent policy should ensure that patents are of high quality and reward genuine innovation. This, in turn, will offer the EU a competitive advantage compared to both new and existing competitors and represent a step towards achieving the Lisbon goals. The lack of an agreement on a Community Patent is therefore a barrier to innovation in the internal market, as the existing systems are fragmented and do not guarantee high quality patents. Care must be taken to ensure that any reform allows granting of patents only where they guarantee innovation. This may require considerable reform to existing institutions such as the European Patent Office. Any new patent system must be democratically accountable and the rules of the system, particularly concerning what can and cannot be covered, must be clear and transparent. It is a myth that making patents cheaper will alone encourage many more SMEs to use patents, as the cost of defending a patent against infringement by a larger competitor can never be easily absorbed by a small firm. Therefore the most important changes to the EU�s IPR regime for smaller businesses are improvements in the quality of patents and a more structured use of other forms of protection to enhance competitiveness across the EU by ensuring that IPR protection remains accessible for SMEs. 8) In your experience, do Member State authorities apply procurement rules in a way that gives businesses sufficient opportunity for market entry? We are aware of a French government proposal, presented to the ECOFIN Council on 5 May, which advocates that a percentage of public contracts in the EU be reserved for SMEs, in a similar way to the USA�s Small Business Act. We do not instinctively believe that such positive discrimination towards SMEs would prove the most effective solution. However, there must be an end to the existing negative discrimination against smaller businesses that restricts their ability to learn of, tender for and win public contracts. For instance, some member states require substantial financial guarantees which only large firms can provide. We call for public procurement rules that are equally accessible to all businesses. In particular, public authorities need to offer smaller contracts, to make the tendering process simpler and less costly, to use more sophisticated and flexible supply chains that offer greater potential roles for SMEs and to speed up payment procedures. More fundamentally, public sector practices and structures need to encourage civil servants to consider all of the options, rather than relying on established relations with larger suppliers. While harder to achieve, such a fundamental cultural and procedural shift would in the long run reap greater rewards for the public sector, the tax payer and the SME community alike. 11) Do you think that voluntary standards for services would be beneficial? If so, in which sectors should they be introduced? Voluntary standards for services can often be a more effective way of regulating service providers and self-regulation often allows for a much quicker response to policy demands and market trends than traditional legislative instruments. Examples of this already exist in many sectors, especially ICT and online trading. However, care must be taken to ensure that any voluntary standards are easily accessible and inexpensive, to allow all businesses, including SMEs to adopt them. Otherwise, the danger is that voluntary standards lead to unfair competition, as only certain businesses are able sign up to them. We have been encouraged by the Commission�s approach to Corporate Social Responsibility, acknowledging that voluntary measures by businesses are the best way to achieve results in this area. Most SMEs already function in a socially responsible manner, often providing the lifeblood of their local community by offering employment opportunities and helping to maintain a sustainable local economy. We believe that burdening SMEs with reporting requirements for CSR related measures is not the right approach to improving performance � CSR is much more likely to be achieved if it is market driven. We acknowledge that legislative instruments are necessary in order to complete the internal market, the best example at present being the Services Directive. In this case legislation is the most appropriate solution to ensuring that unjustified, protectionist standards set down by member states are abolished and that the internal market in this field is realised. 12) What are your views on how we carry out consultations on internal market policy? For instance, what are your views on the consultation process, and on the relevance and presentation of issues in our consultation documents? We have some criticisms of the way in which the issues are presented in this consultation document. Many of the questions are very general, while others are particularly specific; a balance needs to be struck between the two. This points to a general problem in the way that many consultations are presented, which is often not appropriate for SMEs. Many smaller businesses have difficulties in responding when presented with a lengthy consultation document, with very general questions. The parameters need to be narrowed down for smaller businesses to be able to give their opinions. Responding to this consultation would also have been considerably easier were an online form � rather than a Word document that does not contain the questions and parameters � available. There is a real danger that many SMEs are side-lined from the consultation process through not being able to monitor and remain abreast of specific policy developments. We acknowledge our own role in raising awareness of relevant issues, but call on DG Internal Market to look at its own communication practices too. 13) What are your views on the way we carry out impact assessments on internal market policies? In your experience, are we using the right policy instruments to achieve the objectives? We encourage DG Internal Market to continue to assess the impact of internal market policies and to view this as a natural part of the policy-making process. We maintain that it is better to take time to assess thoroughly the likely impact of policies, despite the criticisms of the delays that this can lead to. We believe strongly that it is more important to get the policy right and to choose the most appropriate instrument for delivery, rather than force through an ineffective or damaging law because of tight timetables or short-term political goals. Many policy instruments are available to the Commission and the merits of each in fulfilling the policy objective needs to be weighed up carefully. This includes systematically considering the value of alternatives to regulation. It is also of great importance to small businesses that the impact of other policies on the internal market is taken into account, as well as the impact on SMEs. This requires better coordination across the Commission DGs. We reiterate the importance of post-implementation impact assessments in assessing the actual effect of specific policy measures (see question 4 above). 16) In which fields do you see the greatest need to step up cooperation between Member State authorities in order to make the internal market work? As previously stated, cooperation between member state authorities will be critical to the successful implementation of the Services Directive, to ensure that all businesses across the EU, particularly SMEs, have the same opportunities to provide services in other member states. This, of course, was the original intention of the Services Directive. However, to achieve this will require a real commitment from member states and the establishment of effective structures for communicating and cooperating with each other. DG Internal Market has a pivotal role to play in making sure that member state authorities� implementation of the Services Directive is effective in opening up service sector markets to businesses across the EU. There remains insufficient co-operation between member states in the mutual recognition of rules on non-harmonised goods. This leads to a lack of information and subsequently legal uncertainty for small businesses wishing to sell goods in other member states. Other fields in which cooperation between member state authorities needs to be stepped up include consumer policy agreements, small claims and consumer redress. 18) What is your view on current mechanisms for enforcing internal market rules at the national level? What should be improved? 19) What is your experience (if any) of the Commission�s infringement policy in the field of the internal market? Which type of infringement cases should we handle as a priority? 20) Do you agree with the need to step up coordination and responsibility in Member States for managing the internal market? What (further) assistance could the Commission give in this respect? Policies to improve the internal market will only be effective if all member states implement them correctly and promptly. At present, the Commission�s infringement process is not sufficiently effective in ensuring that member states implement internal market laws correctly; the process should be made quicker and sanctions on member states should be applied more strictly. We draw attention to some of the recommendations made in the European Parliament�s report on the implementation, consequences and impact of the internal market legislation in force. In particular we support the call on the Commission to �establish a transparent fast-track infringement procedure for internal market test cases�, as well as improving the �monitoring of the implementation of and compliance with Community law�. We further support the call for Commission implementation reports to not only analyse the instruments used to implement legislation, but also the actual application of the legislation in the member states. We would also like to stress the importance to the UK SME community of ensuring that member states do not impose�additional requirements at national level when transposing Community legislation ("gold-plating"). DG Internal Market should play a major role in making sure that the internal market is not being distorted by uneven implementation or over implementation of EU legislation. The SOLVIT system is a good method of registering and solving disputes over enforcement of internal market rules. However, this system is not widely enough known or used amongst the business community and therefore is not reaching its full potential. The Commission and member states should do more to make it more visible. We recognise the contribution we can make as business organisations to increased awareness of SOLVIT and are currently considering various initiatives we could take. 21) In your experience, does internal market regulation take sufficient account of the bigger picture of international competitiveness? If not, in which areas do you see problems and what could be done? When considering their competitive edge, businesses, increasingly including SMEs, do not think purely in European terms � they think globally. Recently, globalisation has been used as a scapegoat for problems in the European and national economies. However, globalisation should not always be seen as a threat, rather as an opportunity. Internal market regulation must simply ensure that the internal market functions well, as this gives businesses the best chance to compete internationally. As acknowledged in the consultation document, the internal market is far from a reality in all sectors, therefore completion through regulatory but also non-regulatory measures would be the best proof for business that the Commission takes international competitiveness seriously. It is also important to see DG Internal Market�s role as part of a wider effort by the Commission in ensuring that the different DGs work together to develop a more encompassing, horizontal approach to the development of the rules that govern markets. This is necessary in a constantly evolving, complex global economy. 24) In your experience, do Member States and the EU institutions do enough to promote the opportunities presented by the internal market? Which concrete actions would you suggest for improving the situation? If truly successful, the opportunities presented by the internal market should not need promoting by member states or the EU institutions � its success should speak for itself. The effectiveness of the internal market is not based on how well the opportunities it offers are promoted, rather whether these opportunities exist and how easy it is for businesses, particularly SMEs, to realise them. EU institutions and member states could, however, do much more to promote the benefits and importance of improving the functioning of the internal market. This is the basis for growth and job creation in the European economy, without which the standard of living and social conditions afforded by European citizens could not be maintained. For more information, please contact  HYPERLINK "http://www.smallbusinesseurope.org" smallbusiness|europe, who coordinated this response. 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