Opinion of the European Economic and Social Committee on the Communication from the Commission to the Council, the European Parliament, the European Economic and Social Committee and the Committee of the Regions — Small, clean and competitive: A programme to help small and medium-sized enterprises comply with environmental legislation COM(2007) 379 final {SEC(2007) 906, SEC(2007) 907, SEC(2007) 908}
Date: 2008-04-22
Institutions: European Economic and Social Committee
Subjects: EU programme, aid to undertakings, application of EU law, environmental law, prevention of pollution, small and medium-sized enterprises

19.8.2008

EN

Official Journal of the European Union

C 211/37

Opinion of the European Economic and Social Committee on the ‘Communication from the
Commission to the Council,
the European Economic and Social
Committee and the Committee of the Regions — Small, clean and competitive: A programme to
help small and medium-sized enterprises comply with environmental legislation’

the European Parliament,

COM(2007) 379 final {SEC(2007) 906, SEC(2007) 907, SEC(2007) 908}

(2008/C 211/09)

On 8 October 2007 the European Commission decided to consult the European Economic and Social
Committee, under Article 262 of the Treaty establishing the European Community, on the

Communication from the Commission to the Council, the European Parliament, the European Economic and Social
Committee and the Committee of the Regions — Small, clean and competitive: A programme to help small and
medium-sized enterprises comply with environmental legislation.

The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing
the Committee's work on the subject, adopted its opinion on 27 March 2008. The rapporteur was
Mr Chiriaco.

At its 444th plenary session, held on 22 and 23 April 2008 (meeting of 22 April 2008), the European
Economic and Social Committee adopted the following opinion by 109 votes with 7 abstentions.

1. Conclusions and recommendations

— simplify and enhance the legal
making laws simpler and clearer;

framework by,

inter alia,

1.1
The EESC welcomes the Commission's initiative setting
up a programme specifically designed to help SMEs comply
with environmental legislation, given both the complexity of the
legislation and the economic and social
importance of SMEs
the
within Europe's
EESC points out that particular attention should be given to
micro-businesses, given the structural difficulties that make
them more vulnerable.

context, however,

economy.

In this

Aware of the complexity of environmental

1.2
legislation,
and hence of the difficulties faced by SMEs in complying, the
EESC welcomes the development of instruments designed to
make it easier to understand. Although over the last decade
there has been increased attention on matters social, and parti-
cularly environmental,
responsibility is not yet
perceived across the business world as contributing to a compa-
ny's competitive edge.

corporate

— cut red tape and reduce administrative burdens;

— develop tailor-made,

sectoral environmental management

schemes, making them more accessible to SMEs;

— build expertise, particularly through SME bodies, by training
local experts to provide professional assistance to SMEs;

— restructure the programme's financial
greater simplicity and effectiveness; and

resources towards

— improve communication and information, particularly in

terms of circulating the results of best practice.

1.3
The EESC feels that the Commission's initiative setting
up a programme to help SMEs comply with environmental
legislation represents a very important first step.

2. Gist of the Commission Communication

The Committee believes that the Commission needs to
1.4
develop a proactive approach towards SMEs by establishing a
structured system of cooperation for companies at local level. In
this context, particular attention must be given to cross-border
cooperation.

1.5

In particular, it is essential to:

— establish the uniformity of environmental

legislation —
given its highly complex nature — harmonising it at
national level, with a view to greater legal consistency;

Helping small and medium-sized companies (SMEs) use
2.1
energy and resources efficiently is the aim of the Commission
communication (1). It does this by providing a legal framework
and measures that reinforce existing policies and initiatives in
line with the particular characteristics of smaller companies. To
this end the communication proposes to create a programme to
help SMEs implement European environmental legislation. The
programme will channel financial resources towards support
networks,
to environmental management
systems, and promote greater awareness of environmental issues
among these companies.

simplify

access

(1) COM(2007) 379 final.

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SME

employs

each individual

2.2 While
than
250 people, in total, there are some 23 million SMEs in the
European Union, representing about 99 % of all EU enterprises
and 57 % of the Union's total economic added value. Being
responsible for such a large percentage of the EU economy's
turnover, the impact of SMEs on the environment is significant.

fewer

2.3 Many companies are not aware of the impact their activ-
ities have on the environment and a majority actually think that
their activities have little or no impact. SMEs also tend to
they are complying with legislation unless told
believe that
otherwise. Under such circumstances the activities of SMEs may
pose increased health and safety risks to workers as well as a
significant threat to the environment. By not integrating envir-
onmental considerations into their economic activities, SMEs
could also lose out on the economic benefits presented by
better environmental management and eco-innovation.

2.4
The Environmental Compliance Assistance Programme
proposed by the Commission is a set of measures that aim to
ensure that SMEs minimise the environmental impact of their
activities and to facilitate compliance with existing legislation.
The programme intends to reduce the burden of compliance by
designing instruments and policies to integrate environmental
concerns into the core of SME activities.

2.5
The measures presented in the communication also cover
the dissemination of information specifically targeted for SMEs,
promoting support networks, and training activities that build
local environmental expertise.

Funding for the programme's measures will come from
2.6
the LIFE+ budget (EUR 5 million for 2007-2013) with addi-
tional funds to be made available through the Competitiveness
and Innovation framework Programme (CIP) and the Structural
Funds.

2.7
A website providing information on EU environmental
policy for SMEs is already available in seven languages and
guides on energy efficiency, air emissions, waste production and
emissions of pollutants into water and soil are planned. A hand-
book on funding opportunities will also be published.

2.8
The new network in support of business and innovation
will participate in implementing the programme from 2008.
This and other SME support networks will play an important
role in helping SMEs translate European environmental policies
into operational measures.

2.9
The staff working document attached to the communica-
tion presents a selection of case studies and examples of good
practice implemented by SMEs across Europe and the world.

3. General comments

The EESC welcomes the Commission's programme, parti-
3.1
cularly for its recognition of the importance and value of SMEs
to the economy and European society.

In view of this, the EESC stresses the importance of the
3.2
decision of the Feira European Council of 19 and 20 June
2000 (2)
to endorse the European Charter for small enter-
prises (3) and its statement that ‘small enterprises are the backbone
of the European economy’ and that ‘they are a key source of jobs and
a breeding ground for business ideas’. One of the priorities of the
Charter is to enhance the growth and competitiveness of busi-
ness, not only at local level, but also in the context of a globa-
lised market.

3.3
Companies must integrate environmental impact assess-
ments into their management system. Therefore, given that the
majority of SMEs — and particularly small and micro-businesses
— generally do not apply an environmental policy, it will be
necessary to introduce integrated environmental management
whilst ensuring that administrative burdens are kept
to a
minimum.

The first step is to increase awareness that these practices
3.4
are not simply constraining or more costly but rather a means
of improving a company's competitiveness and creating long-
term added value.

3.5
SMEs that manage to continually monitor these activities,
for example through environmental management schemes, are
also able to expand the management areas subject to controls
and coordinate into a single strategic plan both the relevant
economic and financial data and that relating to the company's
impact (4). In this way, besides the
social and environmental
economic and environmental benefits ensuing from an efficient
and rational use of resources, safety in the workplace is also
safeguarded by changing the way work is organised.

3.6
The EESC therefore agrees that a long-term strategy
needs to be adopted and rapidly implemented by the Member
States.

4. Specific comments

Comments on the measures proposed in the Commission's action plan

Better regulation in design and implementation of poli-
4.1
cies: In this context, better regulation means increasing the invol-
vement of SMEs in framing environmental policies that are
based on best practice analysis. Best practices, when properly
identified and promoted, represent the most economically effi-
cient means of supporting the implementation of environmental

(2) http://www.consilium.europa.eu/ueDocs/cms_Data/docs/pressData/

en/ec/00200-r1.en0.htm.

(3) http://ec.europa.eu/enterprise/enterprise_policy/charter/docs/charter_en.

pdf.

(4) Cf. A comparative analysis of the environmental management, performance
and innovation of SMEs and larger firms based on the OECD database, Julien
Labonne, July 2006.

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legislation. The aims of reducing administrative burdens and
cutting red tape at EU, national and regional
levels and
increasing clarity must not only be envisaged in terms of
possible new legislation, but must also be a consideration in any
revision of the current rules.

this could be achieved,

4.2 More accessible tailor-made environmental management
schemes: Integrating environmental concerns into strategic deci-
sions with a view to growth and innovation will enable firms
not only to comply with existing legislation, but also to pilot
new, better practices taking account of both freedom of initia-
tive and legal constraints to meet the specific requirements of
small and micro-businesses. In particular, there is a need to
encourage the adoption of environmental management schemes
ISO). With regard to EMAS (European
(such as EMAS or
Eco-Management Audit Scheme),
for
example, by inserting SME-friendly provisions into the relevant
regulation, implementing the rules in line with the structure of
SMEs (5), and gradually reducing inspections and requests for
information from registered companies. All of this would be
intended as an incentive for SMEs to come on board, given that
currently only Italy, Germany and Spain are seeing a substantial
level of registration. The EESC hopes that the Commission will
take account of these proposals and of the EESC's opinion on
climate change and civil society of July 2006 (6), particularly for
the purposes of the current EMAS revision. Finally, the EESC
calls on the Commission to seek useful elements within the
various informal and non-codified instruments at
local and
regional level to expand the current environmental management
schemes, as only the direct
involvement of SMEs and SME
bodies at local level can help change the current situation.

Brussels, 22 April 2008.

4.3
Focused financial assistance and a multi-annual financial
programme: The sheer number of financial instruments avail-
able may be confusing and may mean that the instruments do
the
function effectively. The EESC therefore hopes that
not
Commission will publish as soon as possible its planned hand-
book setting out new funding opportunities for projects that
support improved environmental compliance and performance
among SMEs. Taking a long-term view, the Committee believes
that all SME-related measures should preferably come under a
single budget heading.

4.4
Building local environmental expertise for SMEs: Profes-
sional experts are needed to provide technical assistance to
SMEs. To this end, the EESC would stress the need to involve
local SME bodies and the institutions. Furthermore, costs must
be set at reasonable levels for the services provided, and SMEs
must be able to train and avail themselves of in-house consul-
tants.

4.5
Improved communication and more targeted informa-
tion: The planned new multilingual website, linked to the SME
portal (7), must become the main source of information for SME
support networks on EU environmental policy and SMEs. The
EESC considers it crucial to ensure immediate access to the
information and direct contact between the EU institutions and
SMEs.

the Commission's

The EESC welcomes

4.6
initiative in
launching the Enterprise Europe Network — an important new
European support network for businesses within the EU and
beyond. The EESC considers it crucial that the EU continue to
build up services to SMEs, particularly with regard to cross-
border trade and investment; technological cooperation between
SMEs and large companies; innovation; awareness of EU funding
sources; and SME research programmes.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS

(5) ‘Guidance to verifiers on the verification of SMEs, particularly small
and micro-businesses’, in Appendix IV to the Commission Recommen-
dation of 7 September 2001 on guidance for the implementation of
Regulation (EC) No 761/2001 of the European Parliament and of the
Council allowing voluntary participation by organisations in a Com-
munity eco-management and audit scheme (EMAS).

(6) NAT/310 — Meeting the challenges of climate change — the role of civil

society.

(7) http://ec.europa.eu/enterprise/sme/index.htm.