SBS welcomes the publication of the new Single Market Strategy and appreciates its commitment to enhancing the functioning of the Single Market for SMEs, namely:
- A simpler, more SME-friendly Single Market
- The future of the European Standardisation System (ESS) and the role of standards in supporting the Single Market
- Reform of the New Legislative Framework (NLF) and digitalisation of the Single Market
A simpler, more SME-friendly Single Market
SBS appreciates the declared focus of the Strategy on tackling EU policy and legislation that contribute to regulatory and administrative barriers.
One of the main areas for improvement is the harmonisation of EU legislation and its implementation. The “think-small-first” and “once-only” principles should be systematically applied, to streamline administrative and compliance procedures for SMEs across the EU. SBS also supports any initiative aimed at strengthening harmonisation of the Single Market and overcoming fragmentation and national complexities.
Standards play a crucial role in helping SMEs comply with regulatory requirements. SBS urges the Commission to carefully consider pre-existing standards that can be used or adapted to satisfy Essential Health and Safety Requirements across different pieces of EU legislation. Too often the default is to immediately request new standards, leading to an excessive proliferation of standards that causes confusion for SMEs and reduces market uptake of standards.
Another area where SME-friendly legislation and standards can support SMEs is by enabling a truly interoperable Single Market. Across many sectors, increasingly large manufacturers de-facto impose bundled proprietary solutions. This limits consumer choice and economic opportunities for SMEs along supply chains and throughout the product lifecycle, particularly in updates, repair and maintenance. A horizontal and interoperable Single Market would boost SMEs’ role in maintenance, repair, refurbishment and reuse, and help extend product lifecycles.
The future of the European Standardisation System (ESS) and the role of standards in supporting the Single Market
Standards and the European standardisation system (ESS) are essential to the functioning and efficiency of the Single Market. The use of standards significantly eases compliance with legal requirements, supports growth and access to new markets for SMEs. Standards also help ensuring interoperability and safe, high-quality products for consumers and users.
SBS appreciates the central role given to standardisation in the Single Market Strategy, and welcomes proposals like the promotion of machine-readable data formats for European standards. However, while SBS agrees with the need to improve parts of the ESS, the Strategy seems to overlook certain nuances and the tangible improvements achieved since the entry into force of Regulation 1025/2012 on European standardisation.
For instance, strong emphasis is put on how “our standardisation framework struggles to meet market and policy needs, in particular on timeliness and inclusiveness“. While there is some truth to this, SBS cautions against considering “speed“ as a preeminent goal of standardisation in itself.
Speed in standardisation comes at a price: it means either less participation or more flexibility in accepting the final outcome of the process of development of harmonised standards (hENs). There are recent cases (requested hENs on Cyberresilience, Artificial Intelligence, Radio Equipment) where overly ambitious deadlines resulted in an excessive number of technical meetings and/or a proliferation of subgroups within technical bodies. Both put SME experts at a comparative disadvantage compared to larger players, weakening SME input and influence.
It is equally true that SMEs, startups, civil society and academia face financial and capacity constraints to participate. Both at national and European level SMEs face severe challenges in terms of access and balanced participation in the standardisation process. These challenges are discussed also in the Report and Recommendations for inclusiveness in standardisation produced by the High-Level Forum, for which SBS was the lead drafter.
On the other hand, we must highlight the strong improvement in access and participation of SMEs and civil society at European level since the entering into force of Regulation 1025/2012 on European standardisation. This progress is largely due to Annex III of the Regulation, which identifies recognised representative organisations for different stakeholder categories, providing them with additional rights and prerogatives in the development of harmonised standards and vis á vis the European Standardisation Organisations (ESOs).
The improvement of stakeholder access conditions and the cost-efficiency of Regulation 1025 were highlighted by the contractor in charge of the evaluation study during a workshop on the early findings of the Regulation’s evaluation, held in November 2024. SBS looks forward to the full evaluation report and to contributing to the upcoming revision process, which is scheduled to begin in the coming weeks.
SBS acknowledges the Commission proposal to adopt common specifications via implementing acts, announced in the Strategy and in the accompanying Omnibus IV package. While SBS understands the need for a fall-back option when requested hENs are not delivered by the European standardisation organisations (ESOs), several concerns remain. The process for adopting these implementing acts and the mechanisms for stakeholder input are still unclear. Similarly, the criteria to trigger this process, whether due to the non-delivery of hENs by the ESOs and/or the Commission’s need to address an urgent concern, require further clarification.
SBS reiterates the importance of a fully inclusive drafting process for common specifications and stresses that these should only be considered as a last resort measure. The primacy of stakeholder-driven harmonised standards must be preserved as the main way to facilitate compliance and provide presumption of conformity.
Reform of the New Legislative Framework (NLF) and digitalisation of the Single Market
SBS believes that the NLF has played a central role in the achievement of the Single Market, helping to address technological developments and bringing tangible benefits to European SMEs. However, we agree on the need to improve the NLF framework in several areas, while maintaining its fundamental principles. For instance, clear definitions of concepts such as substantial modification, repair, refurbishment and the clarification of obligations and responsibilities of operators carrying out these activities should be provided.
SBS also supports a well-designed and functional rollout and widespread adoption of the Digital Product Passport (DPP). This has the potential to support the transition to more sustainable business models, enable the development of services such as repair, reuse and refurbishment, where SMEs are strongly present. It can also enhance the sustainability of SME-manufactured products and facilitate informed consumer choices. However, the DPP implementation should not be overly complex or costly. SMEs have to be provided with guidance and clear compliance tools to make the DPP a success for EU citizens and all economic actors.
SBS strongly supports a shift towards the digitalisation of the Single Market, provided it reflects the needs and specificities of SMEs and microenterprises, for instance with regards to digital literacy and time and personnel constraints. Digital instructions and declarations of conformity can reduce administrative burdens and compliance costs for SMEs. However, the transition to digital formats involves initial investments in IT infrastructure and staff training, which may be challenging for smaller businesses with limited resources. Therefore, while long-term benefits are anticipated, short-term costs must be considered.
