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 Commission to the Council, the European Parliament, the European Economic and Social Committee and the Committee of the Regions   A Single Market Act   Twelve levers to boost growth and strengthen confidence  "Working together to create new growth"   {COM(2011) 206 final}
Date: 2011-04-13
Institutions: European Commission
Subjects: EU employment policy, citizens' Europe, common commercial policy, competitiveness, economic growth, market economy, reflation, single market

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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 COMMISSION TO THE COUNCIL, THE 
EUROPEAN PARLIAMENT, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS  

A Single Market Act  

Twelve levers to boost growth and strengthen confidence 

"Working together to create new growth" 

{COM(2011) 206 final} 

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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 

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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 officially closed on 28 February 2011. It was based 
on the Communication ‘Towards a Single Market Act. For a highly 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 wide range of actors, 
including Member States, EU and national organisations, regional and local authorities, trade 
unions,  business  and  professional  federations,  individual  companies,  NGOs,  ‘think  tanks’, 
representatives of the academic community and many European citizens. Most contributions 
were made via the Commission’s online consultation tool (IPM — Interactive Policy Making) 
and several others as separate submissions2. 

This  paper  presents  an  overview  of  the  comments  received,  in  general  and  according  to  the 
different groups of stakeholders3. It aims to provide a representative, rather than exhaustive, 
summary of the responses received, highlighting those points and areas that received the most 
comments  from  stakeholders.  Statistical  information  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 consideration 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 possible to include all of the individual comments on them.  

As part of the wider European debate, EU institutions and bodies have also been looking at 
the SMA. However, only contributions received by the European Commission as responses to 
the public consultation proper 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. 

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• 

Industry federation — 79 responses (10.7 %) 

•  Company — 64 responses (8.6 %) 

•  Consumer organisation — 12 responses (1.6 %) 

•  Non-governmental organisation — 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 

Public authorities
5%

Other 
(organisations)
11%

Think tank
1%

Non governmental 
organisation
25%

Consumer 
organisation
2%

Company
9%

Individual
33%

Trade Union
3%

Industry Federation
11%

The SMA is well received by the majority of those who participated 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  breakdown  of  respondents  by  category  reveals  some 
variation from the overall average. 

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Graph 2 — Overall assessment of the Single Market Act by online respondents (number 
of responses) 

Positive

552

Neutral

131

Negative

57

Respondents  were  also  able  to  indicate  up  to  ten  actions  they  considered  to  be  the  most 
important of the 50 proposed in the SMA. According to the overall online results, the actions 
on consultation with civil society 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 most popular by far. However, a large number of respondents, 
in  particular  NGOs  but  also  individual  citizens  and  other  organisations,  submitted  identical 
responses to the consultation. These all indicated actions 48 and 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 social 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 economy. 50 proposals for improving our work, business and 
exchanges with one another’. See Annex for the numbered list of actions. 
5 Responses provided online. 

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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 (action 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  either  responds  adequately  (302  responses)  or 
partly  adequately  (366  responses).  A  small  number  of  respondents  consider  that  the  SMA 
does not respond adequately (43 responses). 

Graph  3  —  Answer  to  the  question  ‘Does  the  Single  Market  Act  propose  appropriate 
measures to address the issues/challenges that are identified?’ (number of responses) 

366

302

Partly

Yes

No

43

No opinion

29

2. INDIVIDUAL CITIZENS

6 

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  important  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. 

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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 social 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  SMA  addresses  the  challenges  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 practical internal market problems they face in 
their daily lives.  

Reflecting the all-encompassing nature of internal market policy, individual 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  property  rights  policy  should  be  shaped  and  the  importance  of 
facilitating the recognition of professional qualifications and removing tax obstacles, with the 
example  of  double  car  taxation  mentioned  relatively  often  by  individual  respondents.  A 
number  also  indicate  public  services  as  an  area  that  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 express concerns about the prospects for 
swift  and  appropriate  implementation  and  follow-up  of  the  SMA.  Others  highlight  the 
importance of a consistent and strict implementation 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  citizens.  Others  stress  the  importance  of  ensuring  a 

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fully  democratic  decision-making  process,  where  all  categories  of  stakeholders  can  express 
their views on an equal basis. 

3. PUBLIC AUTHORITIES

7 

60 %  of  the  public  authorities  that  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 stakeholder constituency as the most important 
were (in descending order): 

10 actions from the SMA considered most 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 infrastructure (action 26, equal 10th position) 

28.6 %  of  online  respondents  in  this  category  believe  that  the  SMA  proposes  adequate 
responses to the challenges 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 consultation 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 representative bodies). The EFTA EEA countries also contributed. 

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3.1 Member States8 

In  their  individual  contributions,  all  Member  State  governments  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  keeping  internal  market 
policies  focused  on  boosting  sustainable  growth  and  creating  jobs,  while  at  the  same  time 
making the single market work for SMEs and citizens. 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 other policy fields, in particular 
consumer,  social,  and  environmental  measures,  should  play  an  important  role  in  the  SMA. 
Other Member States see these other policy 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/authentication (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 public consultation. A large 
number  highlight  the  opportunities  offered  by  electronic  commerce  to  both  consumers  and 
businesses, and the fragmentation that still persists 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  actively  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. 

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A  large  group  of  Member  States  underline  the  importance  of  introducing  unitary  patent 
protection for the promotion of innovation and a knowledge-based European economy. They 
highlight  the  costs  to  businesses  of  the  existing  fragmented  patent  system.  Several  Member 
States  also  support  the  Commission  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  stress  the  importance  of  the  Small  Business  Act 
(SBA) and the ‘Think Small First’ principle. Measures facilitating access to finance for SMEs 
(including  European  venture  capital)  are  particularly  supported  by  Member  States.  Member 
States  also  widely  support  the  full  implementation  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  standardisation  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 facilitate the efficient award of public contracts and promote 
the procurement of innovative and environmentally friendly goods and services. 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-annual  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  largely  seen  as  a  key  missing  link  in  the 
single  market  by  a  significant  proportion  of  Member  States,  as  is  the  single  market  in 
transport generally. 

The  external  aspects  of  single  market  policy  are  also  generally  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  attach  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  such  as  SOLVIT,  and  promote  information  tools 
such as Your  Europe. The Commission proposal  to expand the Internal Market Information 
System  (IMI)  into  a  genuine  network  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 framework without amending it and does not impinge on 
subsidiarity or lead to unnecessary regulatory burden.  

Several Member States underline the importance of Services of General Economic Interest 
(SGEIs),  including  social  services,  for  their  citizens,  and  highlight  the  need  to  clarify  the 
principles that apply to the management and financing of these services. Other Member States 
highlight the differences between various services of general economic interest and favour a 

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sector-specific  approach,  taking  full  account  of  the  subsidiarity  principle,  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  Consolidated  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  competence.  The  proposed  revision  of  the  Energy  Tax 
Directive is also supported by some Member States, but seen more critically by others, which 
stress that national differences in energy generation and consumption patterns mean this issue 
would best be dealt with at national level. The publication of a new VAT strategy is supported 
by  several  Member  States  provided  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 exercise 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 authorities10 

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  flagship  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  regional  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 services to be a fundamental lever for social 
cohesion  and  economic  development.  Local  authorities  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 public services, acknowledge the specificity 
of such activity and uphold the principles of quality, 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  line  between  economic  and  non-economic  activities, 
especially for the provision of Social Services of General Interest (SSGIs). These respondents 
often  mention  the  legal  bases  provided  by  the  Treaty  on  the  Functioning  of  the  European 
Union (TFEU), in particular Article 14 and Protocol No 26 on Services 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 circumstances of public service provision. In their 
opinion, even with the involvement of commercial operators, the provision 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. 

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The  issue  of  public  service  financing  is  often  linked  with  remarks  on  public  procurement 
policy.  Public  authorities  welcome  simplification  in  this  area  but  many  demand  that  public 
procurement rules should be adapted to the needs of public service provision, especially when 
it comes to SSGIs, and that cooperation between public authorities should be exempted from 
internal market law under certain conditions. Views vary among respondents on the extent to 
which public procurement should factor in social, ethical and environmental considerations. A 
large group of stakeholders in this 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 respondents, also support the extension of universal 
service  obligations  to  new  areas,  especially  to  broadband,  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  recall  their  competence  in  local  transport 
arrangements, which the EU should respect. 

Some  authorities,  mainly  regional  administrations,  also  support  measures  more  specifically 
aimed  at  businesses,  competitiveness  and  innovation,  like  a  unitary  patent  system, 
initiatives for small and medium-sized enterprises (SMEs), investment 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 providing financing for SMEs and innovation. 

There is a also a clear will among many local and regional administrations  to be  better and 
more  fully  involved  in  the  governance  of  the  EU  single  market,  including  in  a  more 
institutionalised and structured way, reflecting their role as actors that work close to citizens 
and are often responsible for the practical implementation and communication of EU policies 
on  the  ground.  A  number  of  local  authorities  support  the  use  of  points of  single  contact  (in 
their broad meaning) and the Internal Market Information System (IMI). 

A  number  of  local  authorities  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 missing links in the single market affect them in 
particular,  and  support  actions,  like  the  elimination  of  tax  obstacles  for  citizens  or  seamless 
transport solutions, that can address those gaps. 

Some  other  respondents,  including  Europe’s  outermost  regions  and  representatives  of 
mountain areas, stress that the SMA should take into account the difficulties and specificities 
of  certain  territories  in  taking  advantage  of  the  opportunities  offered  by  the  single  market. 
These regions in particular point to accessibility, competitiveness and regional integration as 
the  three  key  areas  needing  attention,  given  their  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. 

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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 Norway) welcome the SMA. For them, the effective governance 
of  the  single  market  in  its  broad  sense,  including  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  (IMI),  SOLVIT  and  Your  Europe,  which  they 
consider  important  to  promote  awareness  and  confidence  in  the  single  market.  They  also 
strongly  support  actions  to  create  a  true  digital  single  market,  like  those  on  e-commerce, 
eSignature,  e-Identification  and  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 between the market and 
social  dimensions  of  the  single  market,  while  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 bodies representing specific professions. Their views have been 
taken into account in this paper, but are covered in other sections for the sake of consistency 
and conciseness. 

4. ORGANISATIONS ACTING AT EU LEVEL

12 

The  Eurosystem,  the  Group  of  the  Progressive  Alliance  of  Socialists  &  Democrats  (S&D 
Group) in the European Parliament, and the Public Services Europa Intergroup contributed to 
the public consultation. 

According to the Eurosystem, priority should be given to areas with the highest potential for 
increasing  growth  and  supporting  price  stability  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 and the further integration of the retail banking 
services  and  mortgage  markets.  It  also  welcomes  the  initiatives  for  the  recognition  of 
professional  qualifications,  the  transferability  of  pensions,  e-commerce,  public  procurement 
and improved access for SMEs to capital markets. It supports creating a global playing field 
and the promotion of regulatory convergence and international standards. 

The  S&D  Group  calls  for  the  SMA  to  reflect  a  stronger  political  vision  and  a  holistic 
approach,  consistent  with  the  EU  2020  Strategy  objectives.  It  believes  the  single  market 
policy should include a stronger and unambiguous citizen, social and consumer dimension. In 
the  economic  area,  the  S&D  Group  supports  investment  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  economy,  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 bodies and national parliaments have also examined the 
Single Market Act as part of the wider debate and through institutional mechanisms. 

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legislation  is  needed  on  the  horizontal  social  clause,  the  posting  of  workers,  Services  of 
General Economic Interest (SGEIs) and Social Services 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  market  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 needs. It advocates a 
strong  political  vision  for  public  service,  guarantees  for  its  quality  and  accessibility,  and  a 
clear legal framework for public providers, using 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  applied  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  promotion  of  social  economy  actors  and  the 
introduction of European statutes, including for associations. 

5. INDUSTRY FEDERATIONS

13 

Of  the  79  federations  that  participated  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 stakeholder 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 trade (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  interests  submitted  their  views,  which  have  been  taken  into 
account in this section of the paper. 

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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 comprehensive 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,  especially  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  sectoral)  rules  and  approaches  to 
consumer protection are often regarded as problematic. Simplification, integration and more 
harmonisation  are  seen  as  solutions  by  many  respondents  in  this  category,  although  some 
associate  the  latter  with  risks  of  over-regulation  and  damage  to  the  diversity  of  economic 
models  in  Europe.  The  proposed  action  to  reduce  administrative  burdens  associated  with 
accounting  obligations  is  often  welcomed,  especially  by  SME  representative  bodies.  Smart 
regulation principles, proportionality and subsidiarity, and the use of impact assessments are 
also seen as important by a large number of respondents in this category. 

Pan-European  federations  like  the  European  Association  of  Craft,  Small  and  Medium-Sized 
Enterprises (UEAPME), BUSINESSEUROPE 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  often  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-implementation’  by  Member  States  (‘gold-plating’). 
Above all, political will and commitment at all levels is often cited as an important missing 
link. 

There is widespread support amongst business federations 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  among  organisations  representing  SMEs  like  UEAPME.  Many 
commend ‘Think Small First’ as a key guiding principle for the SMA, and call for consistency 
and coherence with the Small Business Act (SBA). They call for due account to be taken of 
the unique characteristics and problems of SMEs (through an ‘SME test’), in areas like public 
procurement,  e-commerce,  environment  and  climate  change.  Some  responses  also  highlight 

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the diversity of the ‘SME universe’ itself, 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  the  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. The use of ‘mutual evaluation’ processes is often commended as 
an example of an effective working relationship between the European Commission and the 
Member States. Some social economy respondents, 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  federations  representing  social  economy  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 encouraged as a way to facilitate 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  procurement,  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  responsibility  as  such.  The  issue  of  the  funding  of 
initiatives in this area, which is associated with a long-term perspective, is also discussed by 
some  respondents,  including  the  venture  philanthropy  association.  A  number  of  industry 
stakeholders  also  comment  on  the  proposed  Social  Business  Initiative.  Some,  especially 
SME federations, believe that this should be done in a way that does not unfairly differentiate 
between undertakings and does not place traditional commercial companies at a disadvantage. 

Proposals  on  access  to  finance  and  private  investment  and  venture  capital  are  also  very 
often  welcomed  by  industry  stakeholders,  including  asset  management,  private  equity  and 
venture capital bodies. Some stress that new measures should benefit all types of companies, 
irrespective of their line of business, size or nature, and that forms of access to finance other 
than  financial  markets  should  be  taken  into  consideration  in  the  SMA.  The  venture  capital 
industry recalls that making companies investment-ready through mentoring and coaching is 
equally important. SME bodies call for proper consideration of the possible consequences of 
the  new  Basel  III  requirements  on  bank  lending  for  their  access  to  finance,  while  certain 
social economy representatives cite Solvency II rules as possibly problematic 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  Article  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  number  of  social  economy  actors,  on  the  other 
hand, argue that the social dimension 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 

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support across the board for the 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  levies  as  worth  further  attention.  Regarding  IPR 
enforcement,  responses  suggest  a  high  degree  of  expectation  from  industry  federations 
regarding further EU action on counterfeiting and piracy, which are considered very serious 
plagues  affecting  creativity,  jobs  and  growth,  and  consumer  choice  and  safety.  The  role  of 
customs is frequently mentioned. 

There is also widespread support among business representative bodies for the digital single 
market, in particular the need to improve conditions for the uptake of e-commerce in the EU. 
A  large  number  of  respondents  cite  a  variety  of  obstacles,  including  legal,  economic  and 
logistical barriers, with the liability regime applicable to intermediaries frequently mentioned. 
Unlocking the potential of digital signature, e-Identity and e-Procurement is often described 
as conducive to a better functioning digital single market. 

Alongside general acknowledgment of the importance of standardisation for internal market 
purposes  and  the  need  to  adapt  it  to  new  challenges,  a  significant  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 measures on taxation, especially VAT, provided they 
facilitate  cross-border  economic  activity,  and  lift  the  administrative  burden  on  companies. 
Different  VAT  rates  for  online  and  offline  creative  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  principle  of  fiscal  sovereignty.  Industry  federations 
often call for the CCCTB regime to remain optional and not linked to the fixing of minimum 
taxation levels by Member States.  

On Services of General Interest (SGIs), most comments were received from social economy 
actors, who see the need to clarify rules applicable 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 include the revision of the Monti-Kroes package 
on the application of state aid rules to public 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  industry  respondents  welcome  measures  aimed  at 
simplification and reducing access barriers. The inclusion of social or environmental aspects 
in public procurement is viewed cautiously by many respondents, while others, mainly social 
economy  representatives,  support  this.  According  to  many  industry  federation  stakeholders, 
legislation in the area of services concessions is not warranted. 

Regarding  actions  concerning  the  environment  and  climate  change,  industry  federations 
generally support the need to act, particularly on energy efficiency, but would not like to see a 
higher  administrative  and  financial  burden  placed  on  companies.  In  the  opinion  of  many 
respondents,  harmonised  European  approaches  are  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 approaches, which is also the preferred option for 

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many  respondents  with  regard  to  social  and  environmental  responsibility  and  non-financial 
reporting. 

A  substantial  number  of  industry  federations  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  industry  respondents  are  looking  forward  to  the 
publication  of  a  White  Paper  on  Transport  Policy  and  European  Union  Guidelines  for  the 
development of the trans-European transport network.  

Measures  to  facilitate  mobility  are  generally  supported  by  industry  federations,  including 
Eurochambres,  with  views  varying  on  the  preferred  scope  and  approaches,  for  example 
concerning the proposed ‘Youth on the Move card’ and ‘European Skills Passport’. A number 
of respondents stress that the recognition of professional qualifications 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 important areas, particularly by 
the retail commerce sector, some representatives 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 Statute 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. COMPANIES

14 

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 the 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 number of responses received through 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. 

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•  EU patent (action 1) 

•  Private investment and venture capital (action 16) 

• 

International trade (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  responds  to  the  challenges 
identified (65.6 %). 21.9 % believe the SMA fully responds 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  facilitate  their  operations, 
particularly across borders. Actions  mentioned as helpful include fostering  e-Signatures and 
e-Identity,  implementing  an  effective  European  payment  policy  (including  standards  and 
interoperability),  tackling  infrastructure  bottlenecks,  and  ensuring  a  truly  pan-European 
transport system based on an internal 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 point out that such differences result 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, the environment and consumer rights. 

There is wide support for keeping the needs of SMEs high on the SMA agenda. Many point 
out that SMEs are the first to suffer from misguided or incomplete internal market legislation 
and argue that the ‘Think Small First’ 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 see 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 approach in support of innovation.  

Social  economy  undertakings,  in  line  with  their  representative  bodies,  welcome  the  SMA’s 
acknowledgement  of  the  diversity  of  existing  company  structures  in  Europe,  and  often 
highlight the importance for internal market policy to support social and societal objectives as 
well.  Some  social  economy  respondents  support  the  introduction  of  European  statutes  for 

15 The positions of companies are widely reflected in the section devoted to industry federations. 

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entities  like  mutual  societies  and  foundations.  They  also  ask  the  EU  to  consider  their 
specificities in other actions such as on access to finance. A certain degree of expectation is 
also  to  be  found  among  company  stakeholders  regarding  the  proposed  Social  Business 
Initiative. 

Measures  to  foster  creativity  and  to  defend  intellectual  property  as  a  key  asset  of  the 
European  economy  are  also  often  commented  upon  by  company  respondents.  Companies 
frequently  express  support  for  the  introduction  of  a  unitary  EU  patent  and  stress  the 
importance  of  a  unitary  patent  litigation  system.  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  intermediary  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  companies,  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 national initiatives. Some respondents consider that the ‘Smart 
Regulation’ principle should apply to the SMA. 

7. TRADE UNIONS

16 

The views of trade unions on the SMA vary: 30.4 % of respondents view it positively, 43.5 % 
neutrally  and  26.1 %  negatively.  The  10  measures  most  frequently  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 social 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 restructuring (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 sectors. Some trade unions, including the European Trade 
Union  Confederation  (ETUC),  sent  separate  contributions.  One  trade  union  organisation  from  a  European 
Economic Area (EEA) country also sent a contribution. 

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• 

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 included 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  standards  should  not  be  seen  as  limitations,  quality 
employment should be pursued, 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  particular  to  the  right  to 
negotiate and conclude collective agreements and the right to take collective action. 

A large number of trade union stakeholders call for a Social Protocol to be added to the EU 
Treaties, in order to clarify that economic freedoms do not take precedence over fundamental 
social rights. A number of responses 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 the European Union (CJEU) does not call social 
rights  into  question.  ETUC  and  a  few  other  respondents  also  ask  for  the  creation  of  special 
chambers in the CJEU specialising in labour and social law. Trade unions generally support 
social  impact  assessments  in  the  formulation  of  EU  legislation,  and  ask  for  international 
social  and  human  rights  standards  and  sustainable  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  fundamental  right  to  strike  and  to  bargain  for 
better conditions, respect for different industrial relations systems in the EU, and the ability of 
Member States to use legislation to provide equal protection 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  organisation,  financing  or  structuring  of 
national pension systems. They are often 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  proposed  Common  Consolidated 
Corporate Tax Base (CCCTB) insufficient as it is only a ‘28th regime’, which would not be 

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compulsory for all companies. A number of trade 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  that  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  opening  of  consultation  and  discussions  on  public 
procurement  policy.  They  support  measures  to  include  social,  ethical  and  environmental 
requirements  in  procurement  processes.  A  number  of  trade  union  stakeholders  also 
commented  on  the  idea  of  introducing  a  legislative  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 retain 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  also  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  provided  by  the  state.  Others 
also call for the EU to give due consideration 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  Framework  (EQF).  Some  would 
welcome  more  detail  on  the  proposed  ‘Youth  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  financial  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 and should involve European trade unions.   

Some respondents are also cautious on measures to facilitate the operation of venture capital 
funds across Europe and consider that venture capital should be subject to stricter controls. 
Some trade unions would also like to see a stronger social dimension in the internal market 
for services. While being generally supportive of an SME focus in policy, some trade unions 
recall that SMEs do not necessarily 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 

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any event as a prerequisite for participation in society and for 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  their  relationship  with  social  policy  (e.g.  energy 
poverty). 

Some  respondents  also  commented  on  alternative  dispute  resolution  (ADR)  mechanisms. 
For  a  number  of  them,  it  is  important  to  guarantee  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  consultation  and  dialogue  with  civil  society,  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 ORGANISATIONS

17  

The large majority of consumer organisations participating 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 stakeholder 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. 

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•  Respect for fundamental social rights and social impact analysis of legislation (action 

29) 

•  Counterfeiting and piracy (action 3) 
•  Ecological footprint of products (action 10, equal 10th position) 
•  Accounting rules (action 14, equal 10th position) 
•  Private investment and venture capital (action 16, equal 10th position) 
•  Social business (action 36, equal 10th position) 
•  Access to basic banking services (action 40, equal 10th position) 

Answers  regarding  the  appropriateness  of  proposed  measures  to  address  current  challenges 
are more nuanced, with 33.3 % believing the SMA includes appropriate 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  empowerment,  citizens’  confidence  in  the  single 
market and demand for products and services 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 differentiating between  measures by businesses 
versus  consumers  and  citizens,  and  acknowledge  that  certain  measures,  for  example  on 
standardisation  and  energy  efficiency,  are  important  for  EU  society  as  a  whole.  They  also 
highlight the importance of considering single market policy as relevant 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  alternative  dispute  resolution  methods,  which  are  frequently 
mentioned  as  a  fruitful  solution,  and  express  expectations  regarding  measures  for  collective 
redress.  For  some  consumer  organisations,  measures  for  dispute  resolution  and  informal 
problem-solving should fully take into account the 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 rules 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  involved  in  single  market 
governance, for example in the definition 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 seeking redress in the case of problems to delivery issues, and 
from  safety  and  privacy  concerns  to  legal  restrictions.  Electronic  commerce  and  product 
safety,  sometimes  in  conjunction,  are  frequently  mentioned  by  consumer  stakeholders,  and 

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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 important 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  others,  the  safety  and  quality  of  services,  in 
parallel with product safety, should also be subject to policy attention. 

Intellectual property proposals are also commented upon by some consumer representatives. 
BEUC supports the introduction of an EU patent 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  also  suggest  a  review  of  the  Directive  on  Copyright  in  the 
Information  Society  and  a  legislative  proposal  on  private  copying  levies  as  additional 
measures for the SMA. Other measures that consumers consider missing are regulation of net 
neutrality,  to  avoid  diverging  national  approaches,  the  revision  of  the  Data  Protection 
Directive,  initiatives  for  consumer  protection  in  the  area  of  financial  services,  the  expected 
Directive on Energy Efficiency and Savings, and the Action Plan on Sustainable Consumption 
and Production (SCP). 

9. NON-GOVERNMENTAL ORGANISATIONS

18 

Among the 189 NGOs that participated in the online consultation, 85.2 % (161 respondents) 
give a positive overall assessment of the SMA, and 4.2 % view it negatively.  

The 10 measures most frequently cited by this stakeholder constituency as the most important 
were (in descending order): 

10 actions from the SMA considered most important by NGOs 

•  Consultation and dialogue with civil society19 (action 48) 
•  Social innovation20 (action 37) 

•  Social business (action 36) 

•  Respect for fundamental social rights and social 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 position 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  action 37 (social  innovation)  as  priorities  for  the SMA,  and 
attached the same explanatory text supporting this choice. 
20 Ibid. 

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•  Services of general economic 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  partly  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  inclusion  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  single  market  policy  should  take  into  account  the  interests  and 
views  of  all  Europeans,  as  citizens  with  rights,  workers,  consumers,  and  service  users 
(particularly public service users), equally and irrespective of factors 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’  (in  line  with  Article  3  of  the  Treaty  on  the 
European  Union  —  TEU).  Subsidiarity  and  proportionality  are  also  sometimes  recalled  as 
guiding principles of action in this area. 
NGOs often take the TFEU’s social clause21, its provisions on gender equality22 and the 
fight against discrimination23, and the Charter of Fundamental Rights of the European 
Union  as  key  legal  references.  Some  respondents  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 support assessments of policies and legislation in 
terms  of  fundamental  rights.  Some  call  for  all  actors  in  civil  society  to be  fully  involved  in 
this kind of exercise, under a ‘participatory’ approach. Some also suggest carrying out a study 
on the social impact of the liberalisation of network services. 

Several  responses  from  NGOs  support  proposals  to  look  into  and  improve  the  legal 
structures  of  actors  active  in  the  social  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. 

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The idea of a Social Business Initiative is also seen with interest by NGOs. The recognition 
of the diversity of entrepreneurs and enterprises contributing to the European economy with 
business models not focused on profit-making is described as important for the single market. 
Clear definitions and a common understanding of what is meant by the social economy are, 
for  some  respondents,  key  to  the  success  of  the  initiative  and  necessary  to  avoid  confusion 
and misuse of concepts.  

A reinforced dialogue with civil society in the preparation and implementation of policy and 
legislation is also very much favoured by all NGOs. 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  practical  disadvantages  sometimes 
suffered by civil society actors, whether linguistic, cost-related, logistical or related 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  elaborate  on  other  single  market  governance  aspects.  They  support 
the reinforcement and expansion of instruments like SOLVIT, sometimes providing specific 
practical suggestions, and support alternative dispute resolution. Transparency, integrity and 
public accountability are also cited as key principles for the governance of the single market. 

Public services also rank high on the NGO agenda. For many, any EU intervention in the area 
of  Services  of  General  Interest  (SGIs),  in  particular  Social  Services  of  General  Interest 
(SSGIs),  should  make  sure  that  the  necessary  flexibility  of  provision  is  respected  and  the 
principles  of  universal  access,  high  quality,  accessibility  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  characteristics  that,  for  example,  EU  rules  on 
procurement and services should respect. The importance for the proposed 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 that public procurement rules 
must not be to the detriment of quality and social standards, and call for the consideration of 
alternatives to procurement for SSGIs and the exercise of caution in introducing EU rules on 
services  concessions.  On  the  other  hand,  some  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 and 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 environment considered key measures.  

Some  respondents  identify  standardisation  as  an  important  tool  for  improving  the  lives  of 
certain  social  categories,  notably  elderly  citizens  and  people  with  disabilities,  and  for 
fostering  the  emergence  of  new  professions  and  services,  whose  positive  impact  on  the 
environment and society should not be underestimated.  

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Some NGOs also often have precise and vocal views on environmental proposals. They call 
for  action  to  address  a  number  of  aspects  that  they  consider  neglected,  for  example  the 
beneficial  effect  that  reduced  consumption  can  have  on  the  general  ecological  footprint  and 
the  adverse  impact  that  environmentally  oriented  taxation  can  have  on  the  most  vulnerable 
households or disadvantaged territories. Social and environmental 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 specific professions, also 
stress  the  importance  of  focusing  on  mobility  measures,  such  as  transport,  recognition  of 
qualifications,  student  mobility,  and  access  to  professions  in  other  countries.  Mobility  is 
viewed  by  some  respondents  as  a  way  to  maintain  fundamental  social  rights  and  provide 
vulnerable groups with the ability to find opportunities within a broader space than their home 
country.  For  other  NGOs,  volunteers  should  also  be  considered  in  initiatives  facilitating 
mobility. 

Some  horizontal  business  organisations  and  others  representing  specific  industrial  or 
professional sectors responded within 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. 

10. OTHER ORGANISATIONS

24  

A  large  majority  of  the  organisations  that  identified  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 stakeholder constituency as the most important 
were (in descending order): 

10 actions from the SMA considered most 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. 

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•  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 social 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  state  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  represent  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 creative industries.  

This category includes organisations concerned with activities of general economic interest, 
for  example  the  European  Centre  of  Employers  and  Enterprises  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  crisis.  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 provided, and clarify how the 
role  of  local  authorities  can  be  respected  in  this  area.  As  a  social  partner,  CEEP  also 
restructuring,  professional 
comments  on  proposals 
qualifications,  public  procurement  and  taxation,  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 markets in support of affordable housing, a review 
of public procurement and state aid rules, and an ambitious Social Business Initiative. 

regarding  pensions, 

industrial 

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  profession-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  and  implementation  of  EU  rules  governing  the 
professions is also mentioned as fundamental by a number of professional organisations. 

25 The contributions from the Economic and Social Councils were very broadly based and have been taken into 
account throughout this paper. 

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A  group  of  financial  institutions  with  a  public  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  the  EU  should  proceed  to  create  a  regulatory 
framework conducive to such investment, and to develop a new instrument combining public 
and private components, providing detailed 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,  reducing  costs,  supporting  quality  and  supporting  dispute 
resolution. Standards organisations consider that the reform of the European standardisation 
framework should incorporate service standardisation and be based on the existing system. 

Think-tank contributions range from general analyses of the place of the SMA in growth and 
recovery strategies and the new EU institutional framework to assessments of specific actions 
against broad policy objectives or in relation to certain economic sectors.  

A number of responses in this category, including those addressing the social economy, the 
broader  citizen  and  social  dimension  in  the  SMA,  public  services  and  local  government, 
foundations,  copyright  policy  and  intellectual  property  rights,  and  private  investment  have 
been taken into account, along with some  from  horizontal  and sectoral industry federations. 
However,  for  the  sake  of  conciseness  and  consistency,  their  main  comments  are  covered  in 
other sections of this paper. 

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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) 

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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 

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