UEAPME Position Paper on the Communication from the Commission
on
"An Internal Market Strategy for Services"
COM(2000)888 of 29/12/2000
Introduction.
This communication is intended to initiate a process of adapting the Internal Market
to the fundamental changes in the way in which services are offered and taken up.
UEAPME fully supports the idea expressed in the Communication "that the Internal
Market must come to be seen as the natural domestic market for all service providers,
especially SMEs, and for their customers." UEAPME also welcomes and supports the
European Commission's initiative "to undertake an all-embracing and systematic
analysis of the persistent barriers to free movement of services and their spill-over
effects across economic sectors."
However, UEAPME is of the opinion that the Commission in its strategy should take
SMEs more into account. SMEs must be put in a position from which they can
compete on a level playing field with big industry within a global economy. Policymakers at European level have to take into account the specific characteristics and
needs of SMEs, as SMEs suffer from the disadvantage of having limited human and
financial resources and of being more locally bound.
The Commission states "the tendency to think and act at a national level first and
consider the Union's wider market as an afterthought must be redressed." Although
the local and regional markets constitute and remain the most important markets for
the majority of SMEs, UEAPME recognises that it is very important and essential to
open the EU market for all SMEs in the services sector.
The Commission aims to set up a comprehensive Internal Market Strategy for the
removal of barriers to services. Thus, the objective of the Communication is restricted
to draw up a strategy. The Communication also gives only a vague overall picture of
the strategy and does not indicate the concrete issues or particular problem areas.
Furthermore, the Commission states that it is imperative to remove any unjustifiable
barrier, without giving any definition of what "unjustifiable" means. Therefore, it is
very difficult for the stakeholders to give fundamental remarks on the Commission's
Communication.
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Specific remarks.
- Concerning international trade in services, the Communication seems to suggest that
the barriers are mainly due to regulatory rules, as they are, in fact, more
administrative.
- The views expressed in the Communication on the new economy seem to be out-ofdate, considering the problems that many of these enterprises have nowadays.
UEAPME recalls that the Lisbon Summit highlighted also the fact that sustainable
economic growth with more and better jobs should be assured. Therefore, it is
important not only to improve the free movement of 'new' services, in which SMEs
are very active and successful, but also to guarantee a stable structure for services in
the so-called 'old' economy. In the Communication, no attention is given to the
services of the 'old' economy, which are mainly furnished by SMEs, depend on the
local market and which provide considerable employment. Furthermore, no reference
is made to labour-intensive services, which face specific challenges. Also the socalled new employment fields, have to be taken more into account. Everyday services
(home-help, child care, …), services improving the quality of life (housing
improvements, security, local public transport, local shops,…), cultural and leisure
services (tourism, audio-visual sector, sports, cultural heritage,…) and environmental
services (waste management, water management, energy saving,…) are indeed
expected to be main jobcreators in the years to come.
- The Communication especially highlights the benefits of the achievement of the
Internal market for services of the 'new' economy. UEAPME urges the Commission to
investigate and to take into account also the impact of the proposed measures to the
other sectors.
- In its new strategy, the Commission recommends that, "successful companies with
winning formulas which satisfy consumers and achieve high levels of productivity,
should be free to try to use their business approach (or business model) across the
European Union." In the view of UEAPME SMEs, in particular micro enterprises and
craft enterprises, play the biggest part in the European economy even though they are,
as individual firms, economically not that strong. It is imperative to find measures to
ensure a balanced existence between SMEs and larger enterprises. So, every
enterprise, small or large, should be able to benefit from the Internal Market of
services, be it as a provider or as a customer.
- UEAPME welcomes the Commission's concern in the Strategy to take care that
effective systems to deal with cross-border complaints, dispute resolution, redress and
enforcement, are in place. However, these systems should not impose more or new
red tape on SMEs.
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Timing.
The timing proposed in the Communication seems rather unrealistic. UEAPME also
has its doubts as to the way the Commission will take into account the results of this
consultation of all interested parties, given that "Stage 1 - Actions for 2001" have
already started.
The text of the Communication seems also to suggest that some decisions have
already been taken before the analysis, which must still be subject to a consultation.
Indeed, Action 1 of Stage 1, foreseen for 2001, announces the launch of new
initiatives to remove Internal Market barriers, e.g. on commercial communications
(sales promotions). Without awaiting the results of the analysis, the Commission has
taken for granted that barriers exists in these fields which have to be removed. In the
opinion of UEAPME it is indispensable to undertake first an analysis (including the
possible impact on SMEs) prior to proposing the harmonisation or removal of existing
regulations.
Consultation.
In the Annex concerning the "Two stage approach", action 4, the Commission states
that the results of the survey will be presented to a forum of high level experts from
the Member States and interested parties to discuss and solve, where possible,
identified problems. This is insufficient. The representative SME-organisations have
to be informed and consulted during the two stages at national and European level on
all the propositions.
Brussels, May 2001