EN    EN EN 
 
EN    EN  EUROPEAN COMMISSION 
Brussels, 13.4.2011 
SEC(2011) 467 final 
  
COMMISSION STAFF WORKING PAPER 
Overview of responses to the public consultation  
 
 on the Communication ‘Towards a Single Market Act’ 
 
Accompanying document to the 
 
COMMUNICATION FROM THE COMMISSI ON TO THE COUNCIL, THE 
EUROPEAN PARLIAMENT, THE EU ROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMI TTEE OF THE REGIONS  
 
A Single Market Act  
 
Twelve levers to boost grow th and strengthen confidence 
 
"Working together to create new growth" 
  
{COM(2011) 206 final}  
 
EN 2   EN TABLE OF CONTENTS 
 
1. GENERAL OVERVIEW ............................................................................................................. 3  
2. INDIVIDUAL CITIZENS ............................................................................................................ 6  
3. PUBLIC AUTHORITIES ............................................................................................................ 8  
3.1 Member States  ..................................................................................................................... 9 
3.2 Local authorities.......................................................................................................... ....... 11 
3.3 European Economic Area (EEA) countries ....................................................................... 13 3.4 Other public authorities................................................................................................... ... 13 
4.
 ORGANISATIONS ACTING AT EU LEVEL .............................................................................. 13  
5. INDUSTRY FEDERATIONS ...................................................................................................... 14  
6. COMPANIES .......................................................................................................................... 18  
7. TRADE UNIONS ..................................................................................................................... 20  
8. CONSUMER ORGANISATIONS ............................................................................................... 23  
9. NON-GOVERNMENTAL ORGANISATIONS .............................................................................. 25  
10. OTHER ORGANISATIONS .................................................................................................... 28  
 
ANNEX:  THE  50 PROPOSED  ACTIONS  OF THE  SINGLE  MARKET  ACT ............... 31  
 
EN 3   EN COMMISSION STAFF WORKING PAPER 
 
Overview of responses to the public consultation on the Communication  
 
‘Towards a Single Market Act’ 
On 28 October 2010, the European  Commission launched a public consultation in preparation 
of the Single Market Act (SMA), which offici ally closed on 28 February 2011. It was based 
on the Communication ‘Towards a Single Market Act. For a highl y competitive social market 
economy. 50 proposals for improving our work, business and exchanges with one another’1. 
The European Commission received more than 800 contributions from a wi de range of actors, 
including Member States, EU a nd national organisations, regional and local authorities, trade 
unions, business and professional federations, individual companies, NGOs, ‘think tanks’, 
representatives of the academic community and many Europ ean citizens. Most  contributions 
were made via the Commission’s online consulta tion tool (IPM — Interactive Policy Making) 
and several others as separate submissions2. 
This paper presents an overview of the commen ts received, in genera l and according to the 
different groups of stakeholders3. It aims to provide a represen tative, rather than exhaustive, 
summary of the responses received, highlighting those points and areas th at received the most 
comments from stakeholders. Statistical in formation is based exclusively on the 740 
responses received via the online questionnaire, but  submissions sent separately via e-mail or 
post were also taken into full considerati on as part of the non-quantitative review.  
Given the number and breadth of the policy  and legislative actions submitted to public 
consultation, it is not possi ble to include all of the individual comments on them.  
As part of the wider European debate, EU inst itutions and bodies have also been looking at 
the SMA. However, only contributions receive d by the European Commission as responses to 
the public consultation pr oper are included here. 
1. GENERAL OVERVIEW  
Online responses can be broken down as follows, according to the category respondents 
identified themselves with: 
 
Respondents to the online public consultation on the SMA  
• Individual citizens — 248 responses (33.5  %) 
• Trade union — 23 responses (3.1  %) 
                                                 
1 COM(2010) 608 final/2. 
2 Contributions can be accessed online at  
http://ec.europa.eu/internal_market/smact/consultations/2011/debate/index_en.htm . 
3 Categories of respondents in this report correspond to the categories in the online questionnaire, with the 
exception of ‘think tanks’ (considered here as part of ‘Other organisations’) and a new category covering certain 
organisations active at EU level. 
 
EN 4   EN • Industry federation — 79 responses (10.7  %) 
• Company — 64 responses (8.6  %) 
• Consumer organisation — 12 responses (1.6  %) 
• Non-governmental organisa tion — 189 responses (25.5  %) 
• Think tank — 9 responses (1.2  %) 
• Others — 81 responses (10.9  %) 
• Public authorities — 35 responses (4.7  %) 
 
Graph 1 — Categories of online responses  
 
Individual
33%
Trade Union
3%
Industry Federation
11%
Company
9%Consumer 
organisation
2%Non governmental 
organisation
25%Think tank
1%Other 
(organisations)
11%Public authorities
5%
 
The SMA is well received by the majority of those who particip ated in the consultation. Three 
quarters of online respondents view the Act positively, 17.7  % take a neutral view, while 
7.7 % see it negatively. However, a breakdow n of respondents by category reveals some 
variation from the overall average.  
 
     
 
EN 5   EN Graph 2 — Overall assessment of the Single Market Act by online respondents (number 
of responses) 
57131552
NegativeNeutralPositive
 
Respondents were also able to indicate up to ten actions they considered to be the most 
important of the 50 proposed in the SMA. Accord ing to the overall online results, the actions 
on consultation with civil societ y in the preparation and implementation of EU texts (action 
484) and for the improvement of the legal status of entities operating in the field of social 
innovation (action 37) were the mo st popular by far. However, a large number of  respondents, 
in particular NGOs but also individual citi zens and other organisations, submitted identical 
responses to the consultation. Th ese all indicated actions 48 a nd 37 as the most important, and 
included the same explanatory text supporting this choice. 
The full ‘top 10’ list for all 740 respondents5 (taken together) is as follows: 
 
10 actions from the SMA considered the most important  by respondents to the online 
consultation (in descending order)  
1. Consultation and dialogue with  civil society (action 48) 
2. Social innovation (action 37) 
3. Internal market for services (action 4) 
4. Respect for fundamental social rights and soci al impact analysis of legislation (action 
29) 
5. EU patent (action 1) 
6. SME access to finance (action 12) 
7. Electronic commerce (action 5) 
                                                 
4 Action numbers in this document correspond to the numbering in the Communication ‘Towards a Single 
Market Act. For a highly competitive social market ec onomy. 50 proposals for improving our work, business and 
exchanges with one another’. See Annex for the numbered list of actions. 
5 Responses provided online. 
 
EN 6   EN 8. Recognition of professional qualifications (action 33) 
9. National transposition of EU rules (action 47) 
10. Energy efficiency (action 11) 
 
Just outside this ‘top 10’ list, the review of the VAT system (action 20) and the review of 
public procurement rules (acti on 17) follow close behind, in 11th and 12th place, respectively. 
As to the appropriateness of the SMA measures to address the issues and challenges 
identified, most respondents believe the Act ei ther responds adequately (302 responses) or 
partly adequately (366 responses). A small number of respondents consider that the SMA 
does not respond adequate ly (43 responses). 
 
Graph 3 — Answer to the question ‘Does the Single Market Act propose appropriate 
measures to address the issues/c hallenges that are identified?’ (number of responses) 
2943302366
No opinionNoYesPartly
 
 
2. INDIVIDUAL CITIZENS6 
The overall view of individual citizens regarding the SMA is positive, with almost 70  % 
considering it a positive exercise, 18.5  % having a neutral view and only 12.9  % a negative 
opinion.  
The actions considered to be the most importa nt by a relatively large number of individual 
respondents span a broad range. The 10 measures most frequently cited by this stakeholder 
constituency are (in order of importance): 
 
                                                 
6 Almost 250 individual citizens took part in the public consultation. 
 
EN 7   EN 10 actions from the SMA considered most important by citizens  
• Consultation and dialogue with  civil society (action 48) 
• Social innovation (action 37) 
• Transport infrastructures (action 26) 
• Tax obstacles for citizens (action 42) 
• Respect for fundamental social rights and soci al impact analysis of legislation (action 
29) 
• EU patent (action 1) 
• Recognition of professional qualifications (action 33) 
• National transposition of EU rules (action 47) 
• Product safety (action 39) 
• Internal market for services (action 4) 
• Electronic commerce (action 5, equal 10th position) 
 
More than 85  % of respondents consider that the SM A addresses the ch allenges identified 
either fully or at least partly.  
A more detailed look at their comments indicates that they set great store by the notion that a 
European internal market should duly factor in citizen, social and consumer  dimensions, 
which they sometimes illustrate by signalling pract ical internal market problems they face in 
their daily lives.  
Reflecting the all-encompassing nature of inte rnal market policy, indi vidual respondents put 
forward comments and concerns touching upon a wide variety of areas . While it is difficult 
to isolate some as more relevant than others in the debate, recurrent comments concern the way a fair intellectual propert y rights policy should be shaped and the importance of 
facilitating the recognition of professional qualifications and re moving tax obstacles, with the 
example of double car taxation mentioned rela tively often by individual respondents. A 
number also indicate public se rvices as an area th at internal market policy should consider 
carefully.  
A particularly frequent comment , also expressed with similar wording by other categories of 
respondents, supports the creation of a European Foundation Statute  and stresses the 
important role of foundations in  pursuing Europe 2020 objectives.  
The importance of citizens and civil society is also highlighted in comments regarding the 
governance  of the single market. Some respondents e xpress concerns about the prospects for 
swift and appropriate implementation and fo llow-up of the SMA. Others highlight the 
importance of a consistent and strict implemen tation of EU rules and see national exceptions 
and opt-outs negatively. Some citizens also point to the importance of respecting local 
specificities and the need  to take into account the fact that the local and daily dimension of the 
internal market is what matters most to citi zens. Others stress the importance of ensuring a 
 
EN 8   EN fully democratic decision-making process, wher e all categories of stakeholders can express 
their views on an equal basis. 
3. PUBLIC AUTHORITIES7 
60 % of the public authorities th at participated in the public  consultation through the online 
questionnaire have a positive view of the SMA. 37.1  % have a neutral view and 2.9  % see it 
negatively.  
The 10 measures most frequently cited by this st akeholder constituency as the most important 
were (in descending order): 
 
10 actions from the SMA considered mo st important by public authorities  
• Public procurement (action 17) 
• Energy efficiency (action 11) 
• Recognition of professional qualifications (action 33) 
• Integrated transport system (action 7) 
• Services concessions (action 18) 
• Standardisation (action 6) 
• Internal market for services (action 4) 
• Ecological footprint of  products (action 10) 
• Services of general economic interest (SGEI) (action 25) 
• Electronic commerce (action 5) 
• SME access to finance (action 12, equal 10th position) 
• Transport infrastructu re (action 26, equal 10th position) 
 
28.6  % of online respondents in this category believe that the SMA proposes adequate 
responses to the chal lenges identified. 65.7  % think it does so only partly, while 2.9  % believe 
it does not. The remaining respondents have no opinion. 
                                                 
7 35 public authorities participated in the public consu ltation through the online questionnaire and a number of 
others sent their contributions via e-mail or post. Most respondents are Member State bodies and local and 
regional authorities (individually or part of representa tive bodies). The EFTA EEA countries also contributed. 
 
EN 9   EN 3.1 Member States8 
In their individual contributi ons, all Member State government s express their broad support 
for the SMA. Given that the EU is only gradually emerging from the economic and financial crisis of 2008-2009, most Member States stress  the importance of keep ing internal market 
policies focused on boosting sustainable growth and creating jobs, while at the same time 
making the single market work for SMEs and citi zens. In this context, many Member States 
recall that the competitiveness imperative should not be seen as irreconcilable with citizens’ 
confidence in the single market.  
The importance of joined-up policy-making to promote coherence between various EU policy 
fields is also highlighted. Some Member States consider that ot her policy fields, in particular 
consumer, social, and environmental measures, should play an important role in the SMA. 
Other Member States see these other po licy fields more in a supporting role. 
 
10 actions from the SMA considered most important by Member State 
governments9: 
• Electronic commerce (action 5) 
• EU patent (action 1) 
• Internal market for services (action 4) 
• SME access to finance (action 12) 
• Small Business Act review (action 13) 
• Copyright (action 2)  
• Standardisation (action 6)  
• Public procurement (action 17) 
• E-identification/authen tication (action 22) 
• Recognition of professional qualifications (action 33) 
• Product safety (action 39, equal 4th position) 
 
Boosting electronic commerce  and advancing the digital single market  are priorities which 
are widely shared by the Member States that participated in the publ ic consultation. A large 
number highlight the opportunities offered by electronic commerce to both consumers and 
businesses, and the fragmentation that still persis ts in this area, arguing that this constitutes a 
new frontier of the single market. Many Member States believe that the existing management 
of copyright in the EU needs to be improved. 
                                                 
8 Member States have participated ac tively in the debate on the re-launch of the single market. A total of 25 
Member States responded to the public consultation, either through the online questionnaire, or, in the majority 
of cases, by means of letters or position papers submitted to the European Commission. 
9 Unlike the other sections in this paper, this list of actions is only partially based on results generated by the 
online questionnaire tool used for the online consultation. Actions indicated as priorities by Member States in 
contributions sent via e-mail or post were also considered. The list should be considered indicative and as not 
prejudicing the official positions of Member States and any Council deliberations. 
 
EN 10   EN A large group of Member States unde rline the importance of introducing unitary patent 
protection  for the promotion of innovation and a knowledge-based Europ ean economy. They 
highlight the costs to businesses of the existi ng fragmented patent system. Several Member 
States also support the Commi ssion proposal for an Action Plan against counterfeiting and 
piracy. 
Promoting SME competitiveness and entrepreneurship  within the single market is 
supported widely by Member States. They stre ss the importance of the Small Business Act 
(SBA) and the ‘Think Small First’ principle. Me asures facilitating access to finance for SMEs 
(including European venture capital) are part icularly supported by Member States. Member 
States also widely support the full implementa tion of the Services Directive, including the 
efficient operation of Points of Single Contact, as a key tool to  help SMEs provide services 
cross-border and establish in other Member States. 
Many Member States are in favour of plans to review  important parts of single market 
legislation , in particular as regards the sta ndardisation system, public procurement 
mechanisms and the system for the recognition of professional qualifications. The latter is seen as very important to improve the mobility  of citizens in the EU. The review of public 
procurement mechanisms should f acilitate the efficient award of  public contracts and promote 
the procurement of innovative and environmenta lly friendly goods and se rvices. Efficient and 
inclusive standardisation procedures are seen as important to support innovation. 
Consumer safety  is a priority for Member States , which widely support the Commission 
plans to establish a multi-annua l action plan for the development of European market 
surveillance as well as for the revision of the General Product Safety Directive. 
Infrastructure , notably transport and energy, is largel y seen as a key missing link in the 
single market by a significant proportion of Me mber States, as is the single market in 
transport generally. 
The external aspects  of single market policy are also ge nerally seen as very significant. 
Indeed, a number of Member States believe that  the external dimension is not given sufficient 
attention in the SMA. 
Many Member States also atta ch great importance to the good governance of the single 
market . Several highlight the need to improve the enforcement of  single market legislation, 
strengthen informal problem-solving tools su ch as SOLVIT, and promote information tools 
such as Your Europe. The Commission proposal to expand the Internal  Market Information 
System (IMI) into a genuine netw ork of public administrations in  Member States is widely 
supported. 
However, a number of measures proposed in the SMA are supported by some Member States 
but seen more critically by others. Member  States support the Commission proposal to 
improve the implementation of the Posting of Workers Directive, but under the condition 
that this clarifies  the existing legal framew ork without amending it and does not impinge on 
subsidiarity or lead to un necessary regulatory burden.  
Several Member States unde rline the importance of Services of General Economic Interest 
(SGEIs) , including social services, for their citi zens, and highlight the need to clarify the 
principles that apply to the ma nagement and financing of these services. Other Member States 
highlight the differences between various servi ces of general economic interest and favour a 
 
EN 11   EN sector-specific approach, taking full account of the subsidiarity princi ple, over a horizontal 
policy approach at EU level. 
Taxation  too is an issue over which Member States  differ, in particular as regards the 
Commission proposal for a Common Consolidat ed Corporate Tax Basis (CCCTB). While 
supported by several Member States as a means to improve single market coherence and to 
facilitate cross-border activities by businesses,  especially SMEs, other Member States argue 
that this issue falls under national competen ce. The proposed revision of the Energy Tax 
Directive is also supported by some Member Stat es, but seen more cri tically by others, which 
stress that national differences in energy generation and consumption patterns mean this issue 
would best be dealt with at na tional level. The publication of  a new VAT strategy is supported 
by several Member States provide d it will lead to a reduction in administrative burdens, 
especially for SMEs, and will help in fighting VAT fraud.  
A few Member States support a European approach to collective redress  to provide 
consumers with an additional instrument to exerci se their rights, but this  view is not shared by 
other Member States, which point to the risks of adopting a US-style system with limited benefits for consumers. 
3.2 Local authorities
10 
Local authorities are generally appreciative of  the SMA as a coordinated and open policy 
exercise. Like other respondent categories, they sometimes ask for the EU to ensure 
consistency between the SMA and the EU2020 flagsh ip initiatives. They often request that 
any policy aiming to foster the internal market  duly takes into account the local, citizen and 
social dimensions, works hand in hand with EU  cohesion policy, and considers geographical 
diversity and the need to minimise administrative burdens. 
While in many cases responses reflect specific local or regi onal concerns, a few general 
suggestions and comments are frequently found across a significant number of responses. The 
area of Services of General Interest (SGIs)  attracts a substantial amount of comments from 
local authorities, which widely consider public se rvices to be a fundamental lever for social 
cohesion and economic development. Local author ities often insist that, in developing and 
implementing competition, public procurement and other single market legislation, the EU 
should respect their autonomy in  the provision of pub lic services, acknowle dge the specificity 
of such activity and uph old the principles of qu ality, access, affordability and subsidiarity. A 
large number of respondents say that this should be incorporated in secondary EU legislation 
to establish clear rules and a dividing lin e between economic and non-economic activities, 
especially for the provision of So cial Services of General Inte rest (SSGIs). These respondents 
often mention the legal bases provided by th e Treaty on the Functioni ng of the European 
Union (TFEU), in particular Ar ticle 14 and Protocol No 26 on Se rvices of General Interest. 
Local authorities also often raise the issue of state aid rules applicable to SGIs. They call on 
the EU to reconsider them given the special ci rcumstances of public service provision. In their 
opinion, even with the involvement of commercial  operators, the provisi on of public services 
is often at a very local level and therefore hardly ever has an impact on trade between 
Member States.  
                                                 
10 A number of regional and local authorities participated in the consultation, individually or as part of 
associations. Their contributions were sent through the online questionnaire or as separate submissions. 
 
EN 12   EN The issue of public service financi ng is often linked with remarks on public procurement  
policy. Public authorities welcome simplificatio n in this area but many demand that public 
procurement rules should be adapted to the n eeds of public service pr ovision, especially when 
it comes to SSGIs, and that coope ration between public authorities should be exempted from 
internal market law under cer tain conditions. Views vary am ong respondents on the extent to 
which public procurement should factor in social , ethical and environmental considerations. A 
large group of stakeholders in th is group also voice concerns as to the very need and potential 
impact of any initiative by the European Commission on service concessions . They highlight 
the importance of allowing flexibility in this area. 
Some local authorities, although not all re spondents, also suppor t the extension of universal 
service obligations  to new areas, especially to broadba nd, which is seen as a key lever for 
local development and integration.  
Respondents in this category also attach great importance to transport , energy and 
environmental  policy. While acknowledging a role for the European Union, especially for 
trans-European networks, they sometimes r ecall their competence in local transport 
arrangements, which the EU should respect. 
Some authorities, mainly regional administratio ns, also support measur es more specifically 
aimed at businesses, competitiveness and innovation , like a unitary patent system, 
initiatives for small and medium -sized enterprises (SMEs), inve stment financing and taxation. 
They consider training and recognition of skills and qualifications to be an important element 
of the SMA as well. Some respondents, mainly from Germany, highlight the role of locally 
based financial institutions in providi ng financing for SMEs and innovation. 
There is a also a clear will among many local a nd regional administrations to be better and 
more fully involved in the governance  of the EU single mark et, including in a more 
institutionalised and structured wa y, reflecting their role as actors that work close to citizens 
and are often responsible for the practical im plementation and communication of EU policies 
on the ground. A number of local authorities su pport the use of points of single contact (in 
their broad meaning) and the Internal Market Information System (IMI). 
A number of local authoritie s also call for proportionality in the implementation of the 
Services Directive , with some associating a substantial administrative burden with the 
Directive. Some respondents oppose further  tax harmonisation in the EU.  
Respondents representing cross-border regions  highlight the special  importance of single 
market policy for them. They say that key missi ng links in the single ma rket affect them in 
particular, and support actions, li ke the elimination of tax obsta cles for citizens or seamless 
transport solutions, that can address those gaps. 
Some other respondents, includi ng Europe’s outermost regi ons and representatives of 
mountain areas, stress that the SM A should take into account the difficulties and specificities 
of certain territories in taki ng advantage of the opportunities o ffered by the single market. 
These regions in particular point to accessibi lity, competitiveness and regional integration as 
the three key areas needing attention, given th eir impact on the possibility for citizens and 
companies to reap the benefits of the single market, for example in terms of mobility and 
access to SGEIs and to broadband, which they describe as key to development. 
 
EN 13   EN 3.3 European Economic Area (EEA) countries11 
As equal partners in the EU single market through the EEA Agreement, the EEA countries  
(Iceland, Liechtenstein and Norw ay) welcome the SMA. For them , the effective governance 
of the single market in its broad sense, incl uding internationally, is very important. They 
favour better implementation and enforcement of single market rules and the use of tools like 
the Internal Market Information System (IM I), SOLVIT and Your Europe, which they 
consider important to promote awareness and confidence in the single market. They also 
strongly support actions to crea te a true digital single ma rket, like those on e-commerce, 
eSignature, e-Identification a nd radio spectrum. EEA countries also support a strong SME 
dimension in the SMA and measures to promote the mobility of students and professionals. Norway in particular highlights the importance of striking a balance be tween the market and 
social dimensions of the single market, whil e Liechtenstein singles out intellectual property 
rights and company law as  worthy of attention. 
3.4 Other public authorities 
A few public authorities other than governments and local authorities contributed to the public 
consultation, including some bodi es representing specific profe ssions. Their views have been 
taken into account in this paper,  but are covered in other secti ons for the sake of consistency 
and conciseness. 
4.
 ORGANISATIONS ACTING AT EU LEVEL12 
The Eurosystem, the Group of the Progressive Alliance of Socialists & Democrats (S&D 
Group) in the European Parliament, and the Pub lic Services Europa Intergroup contributed to 
the public consultation. 
According to the Eurosystem , priority should be given to ar eas with the highest potential for 
increasing growth and supporting price stabil ity and the conduct of monetary policy. The 
Eurosystem supports the initiatives to complete  the single market for services, including the 
full implementation of the Services Directive an d the further integration of the retail banking 
services and mortgage markets. It also we lcomes the initiatives for the recognition of 
professional qualifications, the transferability of pensions, e-commer ce, public procurement 
and improved access for SMEs to capital markets. It supports creating a global playing field and the promotion of regulatory conver gence and internat ional standards. 
The S&D Group  calls for the SMA to reflect a stronger political vision and a holistic 
approach, consistent with the EU 2020 Strate gy objectives. It believ es the single market 
policy should include a stronger and unambiguous citizen, social and consumer dimension. In 
the economic area, the S&D Group supports invest ment in EU added-value projects and a 
legislative and regulatory framework for their financing. S&D also considers it important for 
action to be taken against the grey econom y, and to ensure reciprocity in access to 
international public procurement as well as better tax coordination. It also considers 
                                                
 
11 The EFTA EEA countries submitted a joint contribution. Liechtenstein and Norway also made individual 
submissions. 
12 This section covers the organisations operating at EU level that contributed to the public consultation proper. 
As mentioned in the introduction, EU institutions, EU bo dies and national parliaments have also examined the 
Single Market Act as part of the wider debate and through institutional mechanisms. 
 
EN 14   EN legislation is needed on the ho rizontal social clause, the pos ting of workers, Services of 
General Economic Interest (SGEIs) and Social Se rvices of General Interest (SSGIs), together 
with more ambitious initiatives for consumer protection. It also supports measures for the 
development of the social economy sector. The Group also attaches great importance to the 
implementation and enforcement of single mark et legislation and to  dialogue with civil 
society, where the special role of social  partners should be fully recognised. 
In its contribution, the Public Services Europa Intergroup  focuses on the broader area of 
public services (Services of General Interest — SGIs, SGEIs and SSGIs).  It believes that the 
SMA can be an opportunity to rebalance economic objectives and social ne eds. It advocates a 
strong political vision for public service, gua rantees for its quality and accessibility, and a 
clear legal framework for public providers, usi ng the legal base offered by the Treaty on the 
Functioning of the European Union (TFEU). It  would like the notions of public service and 
general interest to be applie d across sectoral policies, like digital and transport policy. The 
role and autonomy of local authorities in this  area should be fully recognised in the view of 
the Intergroup, which also supports the prom otion of social eco nomy actors and the 
introduction of European statut es, including for associations. 
5. INDUSTRY FEDERATIONS13 
Of the 79 federations that partic ipated in the IPM exercise, 83.5  % gave a positive overall 
assessment of the SMA, and none gave a negative assessment.  
The 10 measures most frequently cited by this st akeholder constituency as the most important 
were (in descending order): 
  
10 actions from the SMA considered most important by industry federations 
• EU patent (action 1) 
• Internal market for services (action 4) 
• International tr ade (action 23) 
• Electronic commerce (action 5) 
• SME access to finance (action 12) 
• VAT (action 20) 
• National transposition of EU rules (action 47) 
• Counterfeiting and piracy (action 3) 
• Small Business Act review (action 13) 
• Standardisation (action 6) 
                                                 
13 79 industry federations responded to the online consultation, while many others submitted position papers 
outlining their views. Respondents in this category also  include bodies representing social economy actors. A 
few organisations representing non-EU business interest s submitted their views, which have been taken into 
account in this section of the paper. 
 
EN 15   EN  
76 of the 79 federations consider that the SMA partly or fully addresses the issues and 
challenges identified by the Commission. 
A large number of respondents in  this category welcome the co mprehensive approach of the 
SMA. Some of them invite the European Commission to adopt a more focused and strategic 
approach , and to seek coherence with the other policy areas  and the EU 2020 flagship 
initiatives.  
In general, business federations see the single market as the EU’s engine for growth, job 
creation and competitiveness.  A number of respondents, es pecially from the social 
economy, also highlight the potential of the single market to support social cohesion and objectives other than profit. 
Many industry federations regret that the potential of the single market is not being fully used, 
frequently due to barriers to the free movement  of goods, services, people and capital, and 
the ensuing fragmentation . The diverging national (and sect oral) rules and approaches to 
consumer protection are often regarded as problematic. Simplification, integration and more  
harmonisation  are seen as solutions by many responde nts in this categ ory, although some 
associate the latter with risks of over-regulat ion and damage to the diversity of economic 
models in Europe. The proposed action to redu ce administrative burdens associated with 
accounting obligations is of ten welcomed, especially by SME representative bodies.  Smart 
regulation principles , proportionality and subsidiarity, a nd the use of impact assessments are 
also seen as important by a large numb er of respondents in this category. 
Pan-European federations like the European A ssociation of Craft, Small and Medium-Sized 
Enterprises (UEAPME), BUSINESS EUROPE and the Association of European Chambers of 
Commerce and Industry (Eurochambres) agree with  various national and sectoral associations 
on the need to improve the governance  of the single market. This should take the form of 
better and rapid implementation and enforcement of rules, and the promotion of informal 
problem-solving tools, with SOLVIT and the Internal Market Information System (IMI) 
frequently mentioned. ‘One-stop shops’  and points of single contact, as well as the Enterprise 
Europe Network (EEN), are of ten described as very useful  instruments. Some business 
federations would like to see the Commission use infringement proceedings more resolutely, 
and single out the problem of ‘over-implement ation’ by Member Stat es (‘gold-plating’). 
Above all,  political will and commitment at all levels is often cite d as an important missing 
link. 
There is widespread support amongst business federa tions for the idea of the single market as 
a ‘base camp’ for  being competitive in a globalised world . Pursuing trade liberalisation in the 
context of the World Trade Organisation (WTO) and regulatory dialogues  with other regions 
of the world are seen as efforts that need continued support. Views vary on proposals for 
symmetry of access to public procurement.  
The importance of ensuring that small and medium-sized  enterprises (SMEs)  benefit from 
new single market initiatives, and are not put at any disadvantage, is a recurrent theme in this 
category too, particularly am ong organisations representing SMEs like UEAPME. Many 
commend ‘Think Small First’ as a key guiding prin ciple for the SMA, and call for consistency 
and coherence with the Small Business Act (SBA).  They call for due acc ount to be taken of 
the unique characteristics and problems of SMEs (through an ‘SME test’), in areas like public 
procurement, e-commerce, environment and clim ate change. Some responses also highlight 
 
EN 16   EN the diversity of the ‘SME universe’ itsel f, and call for specific attention to micro-enterprises  
and the  self-employed .  
A desire for an effective internal market for services  also clearly emerges from industry 
federation responses. The full application of th e Services Directive, including the effective 
operation of Points of Single Contact, is seen as essential to this end by many respondents. 
Respondents supporting initiatives in this area , like BUSINESSEUROPE, refer to the high 
growth potential of services. Th e use of ‘mutual evaluation’ pr ocesses is often commended as 
an example of an effective working relations hip between the European Commission and the 
Member States. Some social economy respondent s, however, say a better understanding of its 
added value is needed and call for the involvement of social economy actors. Some industry 
federations also call for the EU not to  neglect the free circulation of goods. 
A certain number of federati ons representing social econo my undertakings welcome the 
inclusion of a social economy  dimension in the SMA and the acknowledgement of the 
plurality of business models , their objectives and governance  forms. The introduction of 
European legal structures for the various types of actors (cooperatives, mutual societies, 
associations and foundations) is en couraged as a way to facilita te their cross-border activity 
and contribution to social and economic goals. Social economy actors call on the EU to take 
into account their specificity in initiatives on public proc urement, access to financing, 
accounting rules and corporate governance, among others. The role  of social economy 
undertakings in the provision of Services of General Interest  (SGIs) is also sometimes 
stressed, including by a group of experts from  the scientific community. Some social 
economy bodies also highlight the importance of  definitions and clarity of concepts, in 
particular regarding corporate social respons ibility as such. The issue of the funding of 
initiatives in this area, which is  associated with a l ong-term perspective, is also discussed by 
some respondents, including the venture phila nthropy association. A number of industry 
stakeholders also comment on the proposed Social Business Initiative. Some, especially 
SME federations, believe that th is should be done in a way that  does not unfairly differentiate 
between undertakings and does not place traditiona l commercial companies at a disadvantage. 
Proposals on  access to finance and private investment and venture capital  are also very 
often welcomed by industry stakeholders, incl uding asset management, private equity and 
venture capital bodies. Some stress that new meas ures should benefit all types of companies, 
irrespective of their line of bus iness, size or nature, and that  forms of access to finance other 
than financial markets should be taken into co nsideration in the SMA. The venture capital 
industry recalls that making companies invest ment-ready through mentoring and coaching is 
equally important. SME bodies call for proper c onsideration of the possible consequences of 
the new Basel III requirements on bank lendin g for their access to finance, while certain 
social economy representatives cite Solvency II rules as possibly problema tic in this context.  
A number of business federations raise some concerns or express outright opposition to SMA 
proposals on the social  dimension  and consider that Articl e 9 of the Treaty on the 
Functioning of the European Union (TFEU) is a sufficient guarantee for the respect of social 
rights, not requiring further legislation. A nu mber of social economy actors, on the other 
hand, argue that the social dime nsion should find proper room in the SMA. Most respondents 
commenting on the Posting of Workers Directive  agree on the need to ensure better 
implementation, but are against any revision of the Directive itself. 
Intellectual property rights are also singled out as an area of great interest for industry 
federations, in particular by the content, ICT and publishing sectors. There is considerable 
 
EN 17   EN support across the board for th e introduction of a unitary EU patent  regime. Views vary on 
copyright -related measures, for example on the role  and functioning of rights management 
intermediaries, the nature of the competition in the environment in which they operate, 
territorial licensing, and measures to overcome the current EU market  fragmentation. Some 
respondents also mention private copying levi es as worth further attention. Regarding IPR 
enforcement , responses suggest a high degree of expectation from industry federations 
regarding further EU action on c ounterfeiting and pira cy, which are considered very serious 
plagues affecting creativity, jobs  and growth, and consumer choi ce and safety. The role of 
customs is frequently mentioned. 
There is also widespread support among business representati ve bodies for the digital single 
market , in particular the need to im prove conditions for the uptake of e-commerce  in the EU. 
A large number of respondents cite a variety of obstacles, includi ng legal, economic and 
logistical barriers, with the liability regime a pplicable to intermediaries frequently mentioned. 
Unlocking the potential of digital signature, e-Id entity and e-Procurement is often described 
as conducive to a be tter functioning digital single market. 
Alongside general acknowledgm ent of the importance of standardisation  for internal market 
purposes and the need to adap t it to new challenges, a si gnificant number of responses 
consider that standardisation should be driven by the market and fully involve the private 
sector, taking into account the specific needs of SMEs.  
A large number of respondents welcome measur es on taxation, especial ly VAT, provided they 
facilitate cross-border economic activity, and li ft the administrative burden on companies. 
Different VAT rates for online and offline creativ e products is also raised as an issue by a 
number of respondents. The introduction of a Common Consolidated Corporate Tax Base 
(CCCTB)  is seen as a good initiative  in that direction by some  respondents, while others 
oppose it, stating that it contradicts the princi ple of fiscal sovereig nty. Industry federations 
often call for the CCCTB regime to remain opti onal and not linked to the fixing of minimum 
taxation levels by Member States.  
On Services of General Interest (SGIs),  most comments were rece ived from social economy 
actors, who see the need to clarify rules appli cable to them, especially procurement and state 
aid rules, in particular where Social Services  of General Interest (SSGIs) are concerned. A 
few other actors call for action to ensure more competition in the provision of Services of General Economic Interest (SGEIs) and to in clude the revision of the Monti-Kroes package 
on the application of state aid rules to pub lic service compensation in the SMA.   
While some business organisations say the planned review of EU procurement  rules might 
be premature or simply not needed, other i ndustry respondents welcome measures aimed at 
simplification and reducing access barriers. The in clusion of social or environmental aspects 
in public procurement is viewed cautiously by many respondents, while others, mainly social 
economy representatives, support this. Accordi ng to many industry fe deration stakeholders, 
legislation in the area of 
services concessions  is not warranted. 
Regarding actions concerning the envi ronment and climate change , industry federations 
generally support the need to act, particularly on energy effi ciency, but would not like to see a 
higher administrative and fina ncial burden placed on companie s. In the opinion of many 
respondents, harmonised European approaches ar e preferable to fragmentation. However, a 
number of respondents call on EU policy-makers to consider what has already been put in 
place by industry and argue for voluntary approa ches, which is also the preferred option for 
 
EN 18   EN many respondents with regard to social and environmental responsibility and non-financial 
reporting. 
A substantial number of industry federatio ns express concerns about plans for collective 
redress  and, in many cases, their full opposition. In contrast, many favour alternative 
dispute resolution  methods. 
An efficient and seamless transport system  and energy infrastructures capable of ensuring 
affordable energy and security of supply are invariably seen as an important precondition for the success of the single market. Many indu stry respondents are looking forward to the 
publication of a White Paper on Transport Poli cy and European Union Guidelines for the 
development of the trans-Eu ropean transport network.  
Measures to facilitate  mobility  are generally supported by i ndustry federations, including 
Eurochambres, with views varying on the pr eferred scope and approaches, for example 
concerning the proposed ‘Youth on the Move card’  and ‘European Skills Passport’. A number 
of respondents stress that the r ecognition of professional qualific ations and the recognition of 
other skills, for example acquired on the job,  non-formally and informally, are equally 
important. 
Product safety and market surveillance  are also considered impor tant areas, particularly by 
the retail commerce sector, some representati ves of which call for a retail strategy.   
Some industry federations also put forward actions that they consider  missing  in the SMA. 
The adoption of a European Private Company Stat ute and the review of data protection rules 
are frequently mentioned. Respondents from non- EU countries ask for the SMA to take fully 
on board its international and European Economic Area (EEA) dimension.  
6.
 COMPANIES14 
Overall, the individual companies that responded  to the public consultation online view the 
SMA positively (73.4  % of those who responded online).  
The 10 measures most frequently cited as th e most important were (in descending order): 
  
10 actions from the SMA considered most important by companies  
• SME access to finance (action 12) 
• Corporate governance (action 38) 
• Internal market for services (action 4) 
• Social business (action 36) 
                                                 
14 In addition to the large nu mber of responses received th rough horizontal or sectoral  federations, 64 individual 
companies participated in the online public consultation, from various industries, including the social economy, 
while a number of others submitted position papers outlining their views. 
 
EN 19   EN • EU patent (action 1) 
• Private investment and ve nture capital (action 16) 
• International tr ade (action 23) 
• Energy efficiency (action 11) 
• Social innovation (action 37) 
• Electronic commerce (action 5) 
• Pensions (action 31) (equal 10th position) 
 
A large number of companies believe that the SMA partly respond s to the challenges 
identified (65.6  %). 21.9  % believe the SMA fully res ponds to the challenges.  
Individual responses often reflect concerns regarding specific sectors  of the internal market, 
and illustrate them with practical examples15.  
Comments of a more horizontal nature very often reflect companies’ concerns and ideas 
regarding the business environment  in which they operate. Respondents here generally 
favour actions to reduce administrative burdens and costs and to facili tate their operations, 
particularly across borders. Ac tions mentioned as helpful incl ude fostering e-Signatures and 
e-Identity, implementing an effective Europe an payment policy (including standards and 
interoperability), tackling infrastructure bottlenecks, and ensuring a truly pan-European 
transport system based on an in ternal market for transport. 
A number of companies, particularly  very large businesses, point to divergent regulatory 
approaches  across the EU as a key barrier to the realisation of a true single market. The 
services market and the right of establishment are sometimes mentioned as problematic areas, 
particularly by retailers. They poi nt out that such differences re sult in administrative costs and 
complexity for businesses, and prevent customers from taking full advantage of the opportunities offered by the single market. They favour European approaches to aspects like 
consumption, production, taxation, energy, th e environment and consumer rights. 
There is wide support fo r keeping the needs of SMEs  high on the SMA agenda. Many point 
out that SMEs are the first to suffer from misgui ded or incomplete internal market legislation 
and argue that the ‘Think Small Fi rst’ principle should be promoted  further. Related to this is 
the frequent interest expressed by companies in SMA actions to facilitate access to finance . 
Some companies would like to se e them implemented in a way that keeps entrepreneurs in the 
driving seat, accompanied by a thorough implementation of the Late Payments Directive and as part of a broader policy a pproach in support of innovation.  
Social economy undertakings, in line with their repr esentative bodies, welcome the SMA’s 
acknowledgement of the diversity  of existing company structures in Europe, and often 
highlight the importance for internal market polic y to support social and societal objectives as 
well. Some social economy respondents support the introduction of Eu ropean statutes for 
                                                
 
15 The positions of companies are widely reflected in the section devoted to industry federations. 
 
EN 20   EN entities like mutual societies and foundations. They also ask the EU to consider their 
specificities in other actions su ch as on access to finance. A cer tain degree of expectation is 
also to be found among compan y stakeholders regarding th e proposed Social Business 
Initiative. 
Measures to foster creativity and to defend intellectual property  as a key asset of the 
European economy are also often comment ed upon by company respondents. Companies 
frequently express support fo r the introduction of a unitary EU patent  and stress the 
importance of a unitary patent litigation syst em. Copyright policy is  often discussed in 
association with the digital single market . For some respondents, its completion is a priority 
to be tackled in its diverse but interconnected aspects, including intermedia ry liability and 
infrastructure aspects. 
Some respondents in this category, mainly large companies, also support actions to ensure a 
level-playing field  for European companies at international level , in particular as regards 
reciprocity  in access to public procurement. 
For a large number of companie s, correct, uniform and timely transposition and 
enforcement  of EU law is essential for EU policy to  bear fruit for them and for consumers 
and citizens. Some also warn against the risks of over-regulation and call for more 
consistency between EU and nati onal initiatives. Some respondent s consider that the ‘Smart 
Regulation’ principle sh ould apply to the SMA. 
7. TRADE UNIONS16 
The views of trade unio ns on the SMA vary: 30.4  % of respondents view it positively, 43.5  % 
neutrally and 26.1  % negatively. The 10 measures most fr equently cited by this stakeholder 
constituency as the most important were (in descending order): 
 
10 actions from the SMA considered most important by trade unions  
• Respect for fundamental social rights and soci al impact analysis of  legislation (Action 
29) 
• Posting of workers to other Member States (action 30) 
• Public procurement (action 17) 
• Services of general economic interest (SGEI) (action 25) 
• Pensions (action 31) 
• Industrial restruct uring (action 32) 
• Corporate governance (action 38) 
                                                 
16 23 respondents to the online questionnaire identified themselves as trade unions, encompassing organisations 
active at European and national level and from various s ectors. Some trade unions, in cluding the European Trade 
Union Confederation (ETUC), sent separate contributions. One trade union organisation from a European 
Economic Area (EEA) country also sent a contribution. 
 
EN 21   EN • Internal market for services (action 4) 
• Consultation and dialogue with  civil society (action 48) 
• SME access to finance (action 12) 
• Recognition of professional qualifications (action 33) (equal 10th position) 
 
Most consider that the SMA only partly  addresses the existing challenges (60.9  %). 21.7  % 
believe it does not, 13  % that it does, and 4.3  % have no opinion. 
In general, trade union organisations advocate a stronger social focus  in the EU’s internal 
market policy, which they would like to see incl uded in the SMA to a greater extent. In the 
opinion of a number of respondents in this category, the European Social Model should 
remain the main reference: high social standa rds should not be seen as limitations, quality 
employment should be pursue d, and single market freedoms should not impinge on national 
social policy.  
As advocated by the European Trade Union Confederation (ETUC), trade union respondents 
generally insist on the importance of upholding the fundamental rights  affirmed by the 
Charter of Fundamental Rights of the European  Union, and promoting the application of the 
horizontal social clause  in Article 9 of the Treaty on the Functioning of the European Union 
(TFEU). A number of responses , including ETUC’s, refer in pa rticular to the right to 
negotiate and conclude collec tive agreements and the right  to take collective action. 
A large number of trade uni on stakeholders call for a Social Protocol  to be added to the EU 
Treaties, in order to clarif y that economic freedoms do not take precedence over fundamental 
social rights. A number of res ponses also advocate EU action to safeguard social principles in 
the form of secondary European legislation. Many responses relate this to  the desire to clarify 
that the case law of the Court of Justice of th e European Union (CJEU) does not call social 
rights into question. ETUC and a few other res pondents also ask for the creation of special 
chambers in the CJEU specialising in labour an d social law. Trade un ions generally support 
social impact assessments  in the formulation of EU legislation, and ask for international 
social and human rights standards and sust ainable development considerations to be 
integrated within trade agreements. 
Regarding specific proposals, a recurrent theme in trade union responses is the request for 
revision of the Directive on the Posting of Workers . This demand is backed in some cases 
by arguments based on the protection of the funda mental right to strike  and to bargain for 
better conditions, respect for different industrial re lations systems in the EU, and the ability of 
Member States to use legi slation to provide equal pr otection for posted workers. 
On pensions , while welcoming discussions on the matter, trade unions believe the EU should 
respect the fact that it has no competences in the organisati on, financing or structuring of 
national pension systems. They are ofte n against one-size-fits-all solutions. 
Responses often support more fiscal harmonisation  in Europe to prevent tax competition and 
encourage better corporate governance. Some find the pr oposed Common Consolidated 
Corporate Tax Base (CCCTB) insu fficient as it is only a ‘28th regime’, which would not be 
 
EN 22   EN compulsory for all companies. A number of tr ade unions also favour the introduction of a tax 
on financial transactions. 
The role and quality of public services  in Europe’s economy and society is also emphasised 
by a large number of respondents, who stress th at the objective of any action in this area 
should be to help public authorities deliver quality public services  and not to promote 
competition for the sake of it. Clarity on Services  of General Interest (SGIs), in particular 
Social Services of General Interest (SSGIs),  is called for by some trade unions, based on the 
existing Treaty Protocol on Services of General Interest. Some call for a legal framework, especially for SSGIs, and would like to see an evaluation of the previous liberalisation and 
privatisation processes. For some respondents,  certain services, like broadband access, should 
be subject to universal  service obligations. 
Trade unions generally welcome the openi ng of consultation and discussions on public 
procurement policy . They support measures to includ e social, ethical and environmental 
requirements in procurement processes. A number of trade union stakeholders also 
commented on the idea of introduc ing a legislativ e initiative on service concessions . Some 
are against it, as they see a risk  of introducing blanket solutions that they consider inadequate. 
They ask that public authorities should re tain the ability to use in-house solutions. 
On corporate governance,  for some respondents it is fundamental to ensure the proper 
involvement of trade unions in discussions on  the matter and to seek the participation of 
employees in corporate governance itself.  
Some trade unions respondents al so favour renewed support for innovative social and 
participative entrepreneurship , and support an adequate legislative framework to this end. 
However, some say that certain basic services  should still be provide d by the state. Others 
also call for the EU to give due considerati on to employee participation rules when changing 
or setting up new legal structures.  
Training, mobility and recognition of qualifications  also emerge as important to trade 
union respondents. Some call for Member States to  ensure consistency in their policies with 
European frameworks such as the European Qualification Framewor k (EQF). Some would 
welcome more detail on the proposed ‘Yout h on the Move Card’ and ‘European Skills 
Passport’ and how they relate to existing EU tools. For trade unions, respect for fundamental 
rights as well as sufficient fina ncial support for those wishing to engage in mobility should 
receive attention. 
Trade union responses also almost always comment on the proposal for industrial 
restructuring  and welcome the opening of a consultation on a framework for this subject. For 
them, this matter is of high importance a nd should involve European trade unions.   
Some respondents are also cautious on meas ures to facilitate  the operation of venture capital 
funds  across Europe and consider that venture capit al should be subject to stricter controls. 
Some trade unions would also like to see a stronger social dimens ion in the internal market 
for services . While being generally supportive of an SME  focus in policy, some trade unions 
recall that SMEs do not necessari ly have the ambition to operate internationally, so the focus 
should be on limiting administrative burdens  rather than on further liberalisation. 
Many trade unions favour legislation to ensure access to 
basic bank accounts  for all, 
accompanied by proper counselling. They see this as  an instrument for social inclusion and in 
 
EN 23   EN any event as a prerequisite for participation in society and fo r access to employment, health 
care, housing and other services.   
Environmental sustainability goals should also be pursued by the SMA, according to some 
trade unions, with particular attention to th eir relationship with so cial policy (e.g. energy 
poverty). 
Some respondents also commented on alternative dispute resolution  (ADR) mechanisms. 
For a number of them, it is important to gua rantee to all parties clear information about 
available ADR mechanisms, and to make sure that they do not preclude access to court 
redress at a later stage.  
Regarding the governance of the single market , trade union respondents, while generally 
supporting reinforced consultati on and dialogue with civil soci ety, invariably reiterate the 
value and specificity of social dialogue  in the EU in general. In  their opinion, it should be 
used systematically from the early stages of initiatives. 
A few organisations representing companies or industry sectors,  including from the social 
economy, also submitted their views under this category. Their views have been taken into account in this paper, but are covered in other sections for the sake of consistency and 
conciseness. 
8.
 CONSUMER ORGANISATIONS17  
The large majority of consumer organisations pa rticipating in the online consultation (9 out of 
12) have a positive overall view of the SMA.  Two respondents view it neutrally and one 
negatively. 
The 10 measures most frequently cited by this st akeholder constituency as the most important 
were (in descending order): 
 
10 actions from the SMA considered most important by consumer organisations  
• Product safety (Action 39) 
• Passenger rights (action 43) 
• Alternative dispute resolution and collective redress (action 46) 
• Consultation and dialogue with  civil society (action 48) 
• Energy efficiency (action 11) 
• Internal market for services (action 4) 
• Electronic commerce (action 5) 
• Standardisation (action 6) 
                                                 
17 Twelve consumer organisations, operating at EU, national or regional level, and from different countries in the 
EU, participated in the online consultation. A few others sent contributions separately. 
 
EN 24   EN • Respect for fundamental social rights and soci al impact analysis of legislation (action 
29) 
• Counterfeiting and piracy (action 3) 
• Ecological footprint of pr oducts (action 10, equal 10th position) 
• Accounting rules (action 14, equal 10th position) 
• Private investment and ventur e capital (action 16, equal 10th position) 
• Social business (action 36, equal 10th position) 
• Access to basic banking se rvices (action 40, equal 10th position) 
 
Answers regarding the appropriate ness of proposed measures to  address current challenges 
are more nuanced, with 33.3  % believing the SMA includes appr opriate measures to address 
the issues identified, 50  % believing it does so partly, one respondent stating it does not and 
one with no opinion. 
Consumer organisations, and the European  Consumers’ Organisation (BEUC) in particular, 
call for more emphasis, priority and space for the needs and requirements of consumers . 
They consider that without real consumer em powerment, citizens’ confidence in the single 
market and demand for products and servic es will be difficult to restore.   
Pan-European consumer organisations also suggest that the SMA should embrace a more 
holistic view  of single market policy, avoid differen tiating between meas ures by businesses 
versus consumers and citizen s, and acknowledge that cert ain measures, for example on 
standardisation and energy effici ency, are important for EU soci ety as a whole. They also 
highlight the importance of consid ering single market policy as re levant to the daily lives of 
consumers, irrespective of the cross-border or domestic nature of their activities. 
For consumer organisations, the protection of consumer rights and their enforcement  
should be central to single market policy and the SMA. They welcome in particular the 
proposed initiatives on alte rnative dispute resolution me thods, which are frequently 
mentioned as a fruitful solution, and express expectations regarding measures for collective 
redress. For some consumer organisations, m easures for dispute resolution and informal 
problem-solving should fully take into account th e existing structures and their potential.  
Governance in general is considered important by consumer organisations. Some call for a 
better evaluation of the practical application of EU consumer rule s in this field, and for more 
resolute action to ensure the correct, uniform and quick transposition of EU legislation in 
Member States. Consumer organisations would like to be more invol ved in single market 
governance, for example in the defini tion of the Consumer Scoreboard. 
Consumer organisations point to persistent barriers  for consumers seeking to buy goods and 
services across borders, especially online. A number of problem areas requiring action are 
mentioned, from difficulties in s eeking redress in the case of problems to delivery issues, and 
from safety and privacy concerns to lega l restrictions. Electronic commerce and product 
safety, sometimes in conjunction, are frequent ly mentioned by consumer stakeholders, and 
 
EN 25   EN alternative dispute resolution for online transactions is seen as essential for the SMA by some 
of them.  
Better coordination of market surveillance  is also mentioned as im portant in order to make 
sure that EU standards and laws  are effective. According to some consumer organisations, the 
issue of its funding should be addressed. For othe rs, the safety and quality of services, in 
parallel with product safety, should al so be subject to policy attention. 
Intellectual property  proposals are also commented upon by some consumer representatives. 
BEUC supports the introduction of an EU pate nt but does not consider the proposed actions 
on counterfeiting and piracy as priorities. BEUC  asks the European Commission to take the 
social impact and the Charter of Fundamental  Rights fully into account when considering 
initiatives in this field. 
Respondents in this category al so suggest a review of the Directive on Copyr ight in the 
Information Society and a legislative propo sal on private copying levies as additional 
measures for the SMA. Other measures that consumers consider missing  are regulation of net 
neutrality, to avoid divergi ng national approaches, the revi sion of the Data Protection 
Directive, initiatives for consumer protection in  the area of financial services, the expected 
Directive on Energy Efficiency and Savings, a nd the Action Plan on Sustainable Consumption 
and Production (SCP). 
9. NON-GOVERNMENTAL ORGANISATIONS18 
Among the 189 NGOs that participated in the online consultation, 85.2  % (161 respondents) 
give a positive overall asse ssment of the SMA, and 4.2  % view it negatively.  
The 10 measures most frequently cited by this st akeholder constituency as the most important 
were (in descending order): 
 
10 actions from the SMA considered most important by NGOs  
• Consultation and dialogu e with civil society19 (action 48) 
• Social innovation20 (action 37) 
• Social business (action 36) 
• Respect for fundamental social rights and soci al impact analysis of legislation (action 
29) 
• Public procurement (action 17) 
                                                 
18 A very large number of non-governmental organisations (NGOs), 189 in total, responded to the online 
consultation, while a number of others submitted positi on papers outlining their views or expanding their online 
contribution. NGO respondents encompass a wide constituency. Many are active in the broader social 
dimension, but some respondents also represent specific professions or business sectors.  
19 As mentioned in the General overview  section above, a very large number of respondents, in particular in the 
NGO and individual categories, submitted an identical response to the consultation, indicating action 48 (consultation and dialogue with civil society) and actio n 37 (social innovation) as priorities for the SMA, and 
attached the same explanatory text supporting this choice. 
20 Ibid. 
 
EN 26   EN • Services of general econo mic interest (action 25) 
• Internal market for services (action 4) 
• Corporate governance (action 38) 
• SME access to finance (action 12) 
• VAT (action 20) 
 
177 of the 189 NGOs consider that the SMA pa rtly or fully addresses the issues and 
challenges identified by the Commission. 
In general, NGOs are supportive of  the SMA, and see the language used on the need to restore 
citizen confidence in the single market as a step in the right direction. A large number encourage policy makers to be ambitious in the identification of priority  actions and in their 
actual implementation. 
Most NGOs strongly support the in clusion and mainstreaming of social, environmental, 
democratic, civic, consumer and equal opportunity principles in the SMA, which, 
according to some of them, should be reflected in the appropriate choice of indicators. Many 
respondents point out that sing le market policy should take into account the interests and 
views of all Europeans, as citizens with ri ghts, workers, consumer s, and service users 
(particularly public service users) , equally and irrespective of f actors such as disability, age, 
revenue, social conditions, ethnicity or area of residence. As outlined notably by the Platform 
of European Social NGOs (Social Platform), the SMA should support the pursuit of social 
cohesion and the ‘social market economy’ (i n line with Article 3 of the Treaty on the 
European Union — TEU). Subsidiarity and pr oportionality are also sometimes recalled as 
guiding principles of action in this area. 
NGOs often take the TFEU’s social clause
21, its provisions on gender equality22 and the 
fight against discrimination23, and the Charter of Fundamental Ri ghts of the European 
Union  as key legal references. Some responde nts also recall the obligations of the United 
Nations Convention on the Rights of People with Disabilities.  Factoring access and 
accessibility for disabled citizens into single market policy is indeed strongly advocated by 
some NGOs. A high number of NGOs also suppor t assessments of policies and legislation in 
terms of fundamental rights. Some call for all acto rs in civil society to be fully involved in 
this kind of exercise, under a ‘p articipatory’ approach. Some also suggest carrying out a study 
on the social impact of the liber alisation of network services. 
Several responses from NGOs support proposals to look into and improve the legal 
structures of actors active in the soci al economy, notably foundations, cooperative 
societies and mutual associations . In particular, a large number of similar responses 
welcome the announced proposal for a European Foundation Statute , highlighting the 
growing contribution of foundations to the EU ’s objectives of ‘smart, sustainable and 
inclusive growth’. Some ask the European Commission to include associations  as well in this 
proposal and to look into a European statute for them. 
                                                 
21 Article 9 TFEU. 
22 Article 8 TFEU. 
23 Article 10 TFEU. 
 
EN 27   EN The idea of a Social Business Initiative  is also seen with intere st by NGOs. The recognition 
of the diversity of entrepreneurs and enterpri ses contributing to the European economy with 
business models not focused on profit-making is de scribed as important for the single market. 
Clear definitions and a common understanding of wh at is meant by the social economy are, 
for some respondents, key to the success of th e initiative and necessary  to avoid confusion 
and misuse of concepts.  
A reinforced dialogue with civil society  in the preparation and im plementation of policy and 
legislation is also very much favoured by all NG Os. Some see this as a key way to restore the 
confidence of citizens in the Single Market and their interest and engagement with European 
affairs. They ask for it to be systematic , structured, covering the full policy cycle, 
implemented with concreted deliverables in  mind, and concretely supported by adequate 
budgets and legal tools. Some NGO actors point to the practi cal disadvantages sometimes 
suffered by civil society actors, wh ether linguistic, cost-related, logi stical or relate d to the lack 
of technical expertise. More broadly, equality of treatment for all stakeholders in consultation 
and dialogue is considered a key prerequisite.   
Some respondents also elabor ate on other single market governance aspects. They support 
the reinforcement and expansion of instrume nts like SOLVIT, sometimes providing specific 
practical suggestions, and suppor t alternative dispute resoluti on. Transparency, integrity and 
public accountability are also cited as key princi ples for the governance of the single market. 
Public services also rank high on the NGO agen da. For many, any EU inte rvention in the area 
of Services of General Interest (SGIs) , in particular Social Services of General Interest 
(SSGIs) , should make sure that the necessary flexib ility of provision is respected and the 
principles of universal access, high quality, ac cessibility and affordability are taken into 
account. These principles should, for some, also be  taken into consideration in the evaluation 
of the Services Directive. For a number of respondents, SSGIs in particular require careful 
consideration, with specific objectives and ch aracteristics that, for example, EU rules on 
procurement and services should respect. The importance for the propo sed Communication on 
SGIs to provide legal certainty is often mentioned. For others, a legal instrument is needed. 
Social NGOs also express concerns and call for more clarity on the Commission’s plans for 
the reform of public procurement rules . They frequently state th at public procurement rules 
must not be to the detriment of quality and social standards, and call for the consideration of alternatives to procurement fo r SSGIs and the exercise of ca ution in introducing EU rules on 
services concessions. On the other hand, so me respondents highlight the potential of 
procurement to pursue environmental and societal objectives. 
Ensuring access to services like banking and the internet  are also considered by a number of 
NGOs as an important tool to make single market  policies more socially oriented and at the 
same time update them in accordance with new societal trends. Some support the extension of 
universal service obligations a nd the SGI label to these areas. 
The importance of ensuring that 
microenterprises  and independent workers  benefit from 
the EU single market is also mentioned by NGO respondents, with access to capital and a favourable regulatory environmen t considered key measures.  
Some respondents identify standardisation  as an important tool for improving the lives of 
certain social categories, notably elderly c itizens and people with disabilities, and for 
fostering the emergence of new professions and services, whose positive impact on the environment and society shoul d not be underestimated.  
 
EN 28   EN Some NGOs also often have  precise and vocal views on environmental proposals . They call 
for action to address a number of aspects th at they consider neglected, for example the 
beneficial effect that reduced consumption can  have on the general eco logical footprint and 
the adverse impact that environmentally orient ed taxation can have on the most vulnerable 
households or disadvantaged terr itories. Social and environmen tal reporting by companies is 
also considered an area worthy of attention. 
VAT policy is also identified as important by NGO respondents. Specific comments mainly 
concern the potential of VAT policy for poverty reduction or mitigation, but also the relevance of VAT for their own work. 
Certain NGOs, including European federations  or those representing spec ific professions, also 
stress the importance of focusing on mobility measures , such as transport, recognition of 
qualifications, student mobility, and access to professions in ot her countries. Mobility is 
viewed by some respondents as a way to main tain fundamental soci al rights and provide 
vulnerable groups with the ability to find opport unities within a broader space than their home 
country. For other NGOs, volunteers  should also be considered  in initiatives facilitating 
mobility. 
Some horizontal business organi sations and others representing specific industrial or 
professional sectors  responded within this category. Their vi ews have been taken into account 
in this paper, but are covered in other sections  for the sake of consistency and conciseness. 
10.
 OTHER ORGANISATIONS24  
A large majority of the organisations that id entified themselves as ‘Other’ or ‘Think tank’ 
(78.9  %) have a positive view of the SMA. 13.3  % view it neutrally, while 7.8  % express a 
negative opinion. 
The 10 measures most frequently cited by this st akeholder constituency as the most important 
were (in descending order): 
 
10 actions from the SMA considered mo st important by other organisations  
• Social innovation (action 37) 
• Consultation and dialogue with  civil society (action 48) 
• Public procurement (action 17) 
• Internal market for services (action 4) 
• SME access to finance (action 12) 
• EU patent (action 1) 
                                                 
24 90 organisations of a diverse nature responded to the online questionnaire identifying themselves as ‘Other’ or 
‘Think tanks’. A number of other contributions not necessarily attributable to any particular category in the 
online questionnaire categories were received separately by the Commission and taken into account in this 
section of the paper. 
 
EN 29   EN • Small Business Act review (action 13) 
• Recognising skills and training (action 35) 
• Recognition of professional qualifications (action 33) 
• Services of general economic interest (SGEI) (action 25) 
• Respect for fundamental social rights and soci al impact analysis of legislation (action 
29, equal 10th position) 
• National transposition of EU  rules (action 47, equal 10th position) 
 
Half of the respondents in this category stat e that the SMA partly  proposes appropriate 
responses to the issues it seeks to address. 44.4  % believe it does so in full, 2.2  % that it does 
not, while the rest have no opinion. 
Organisations responding in this category repres ent a wide variety of interests, views and 
constituencies, as also reflected in the contributions received from two Economic and Social 
Councils  in Member States25. The recognition of the plurality of actors active in the single 
market is itself often one of the demands in  the responses, for example regarding micro-
enterprises and crea tive industries.  
This category includes organisations  concerned with activities of general economic interest, 
for example the  European Centre of Employers and En terprises providing Public Services 
(CEEP). They generally welcome the SMA and its acknowledgement of the importance of 
Services of General Interest (SGIs), but would like to see a more proactive policy, including 
legislative initiatives, in this area. They highlight  the role of SGIs for social cohesion and their 
resilience to the economic and financial cris is. For CEEP in particular, new secondary 
legislation should clarify Article  106 of the Treaty on the Functioning of the European Union 
(TFEU), guarantee the subsidiarity principle and ‘in-house’ management, reinforce the 
economic and financial conditions  under which SGEIs can be pr ovided, and clarify how the 
role of local authorities can be  respected in this area. As a social partner, CEEP also 
comments on proposals regarding pensions, industrial restruct uring, professional 
qualifications, public procurement and taxati on, and expresses caution on the proposal for 
services concessions. The social housing sector also commented on the SMA, calling for appropriate solutions for access to capital market s in support of affordable housing, a review 
of public procurement and state aid rules, a nd an ambitious Social  Business Initiative. 
A number of organisations representing  professions  responded to in the public consultation in 
this category. Their comments are largely about initiatives on the mutual recognition of professional qualifications, in some cases reflecting professi on-specific issues, and on 
mobility. Some professional groups also point to practical obstacles they  still encounter in 
providing services in another EU  Member State, for example in connection with insurance 
and liability regimes. Proper transposition a nd implementation of EU rules governing the 
professions is also mentioned as fundamental  by a number of prof essional organisations. 
                                                
 
25 The contributions from the Economic and Social Councils were very broadly based and have been taken into 
account throughout this paper. 
 
EN 30   EN A group of financial institutions with a publi c mandate contributed to the consultation, 
focusing on the issue of long-term investment , for which they see a great need in the current 
economic circumstances. They suggest that th e EU should proceed to create a regulatory 
framework conducive to such investment, and to  develop a new instrument combining public 
and private components, providing de tailed views on how to do that. 
The recognition of the role of standards  in achieving the internal market, in particular for 
numerous SMA actions, is strongly advocated  by standardisation organisations. They 
highlight the crucial role of standards in fostering intra and extra-EU trade, but also in strengthening productivity, re ducing costs, supporting qu ality and supporting dispute 
resolution. Standards organisations  consider that the reform of  the European standardisation 
framework should incorporate service standard isation and be based on the existing system. 
Think-tank  contributions range from general analyses  of the place of th e SMA in growth and 
recovery strategies and the new EU institutional framework to assessments of specific actions against broad policy objectiv es or in relation to ce rtain economic sectors.  
A number of responses in this category, incl uding those addressing th e social economy, the 
broader citizen and social dimension in the SMA, public services and local government, 
foundations, copyright policy and intellectual property rights, a nd private investment have 
been taken into account, along w ith some from horizontal and sectoral industry federations. 
However, for the sake of conciseness and cons istency, their main comments are covered in 
other sections of this paper. 
 
EN 31   EN ANNEX:  THE  50 PROPOSED  ACTIONS  OF THE  SINGLE  MARKET  ACT 
1. EU patent 
2. Copyright 
3. Counterfeiting and piracy 
4. Internal market for services 
5. Electronic commerce 
6. Standardisation 
7. Integrated transport system 
8. Energy taxation 
9. Business-to-business services 
10. Ecological footprint of products 
11. Energy efficiency 
12. SME access to finance 
13. Small Business Act review 
14. Accounting rules 
15. Project bonds 
16. Private investment and venture capital 
17. Public procurement 
18. Services concessions 
19. Common consolidated corporate tax base (CCCTB) 
20. VAT 
21. Interconnection of business registers 
22. E-identification/authentication 
23. International trade 
24. International public procurement 
25. Services of general economic interest (SGEI) 
 
EN 32   EN 26. Transport infrastructures 
27. Energy infrastructures 
28. European radiospectrum 
29. Respect for fundamental social rights and social impact analysis of legislation 
30. Posting of workers to other Member States 
31. Pensions 
32. Industrial restructuring 
33. Recognition of professional qualifications 
34. Student mobility 
35. Recognising skills and training 
36. Social business 
37. Social innovation 
38. Corporate governance 
39. Product safety 
40. Access to basic banking services  
41. Responsible lending and borrowing 
42. Tax obstacles for citizens 
43. Passenger rights 
44. Evaluating implementation of rules with Member States 
45. Information exchange between public authorities (IMI) 
46. Alternative dispute resolution and collective redress 
47. National transposition of EU rules 
48. Consultation and dialogue with civil society 
49. One-stop-stop for information and assistance 
50. Informal problem-solving tools