Position Papers

This space provides you with UEAPME’s latest position papers. If you are looking for previous position papers please visit the Archive section.

Date	Position Papers
2008
April	UEAPME position on the proposal for a regulation on the provision of food information to consumers
March	UEAPME comments on the 2nd draft of a Commission Notice on State aid in form of guarantees (Version 21 February 2008)
March	UEAPME comments on the Draft General Block exemption Regulation (revised version February 2008)
March	UEAPME position paper on the proposal for a directive on the conditions of entry and residence of third-country nationals for the purpose of highly qualified employment
March	UEAPME comments on the first draft of the EIB “Findings and conclusions” of the SME Consultation 2007/2008
February	UEAPME reply to the Commission’s 2nd consultation to promote the active inclusion of the people furthest from the labour market
January	UEAPME concept paper on the mobility of apprentices and young people in initial vocational training
January	UEAPME response to the European Commission’s consultation “Growing regions, growing Europe”
2007
December	UEAPME expectations on the proposal for a European Small Business Act (aussi disponible en français)
December	UEAPME position on the Doorstep Selling Directive (85/577/EEC)
December	UEAPME position on the European Commission’s Proposal for a Regulation on the Provision of Food Information to Consumers
December	UEAPME position on the new Employment Guidelines 2008-2010
December	UEAPME position paper on the proposal for a directive on a single application procedure for a single permit for third-country nationals to reside and work in the territory of a Member State and on a common set of rights for third country workers legally residing in a Member State
December	UEAPME position paper on the Draft 2008 joint progress report on the implementation of the Education & Training 2010 work programme
November	UEAPME position paper on the EC Communication "Stepping up the fight against undeclared work"
November	UEAPME’s reaction to the Green Paper "Adapting to climate change in europe"
November	UEAPME’s response to the Consultation on a possible European Private Company (EPC) Statute
November	UEAPME considerations on the upcoming Sustainable Consumption and Production (SCP) action plan
October	UEAPME’s position paper on the Communication from the Commission on a simplified business environment for companies in the areas of company law, accounting and auditing
October	UEAPME comments on the draft Community Guidelines on State Aid for Environmental Protection (Version from 5 October 2007)
October	UEAPME comments on “Energising Europe: A real market with secure supply”, the third legislative package on energy markets
October	"Key challenges facing European labour markets: a joint analysis of European Social Partners": full version, conclusions and recommendations
October	Crafts and SMEs: keys for the success of urban policy
October	UEAPME comments on the Draft General Block exemption Regulation (2007/C 210/10)
October	UEAPME comments on the EC Consultation Document on State aid in form of guarantees
September	UEAPME position paper on the proposal for an EU directive for sanctioning employers employing illegal immigrants
September	UEAPME Position on the EC Communication "Towards Common Principles of Flexicurity: More and better jobs through flexibility and security"
September	UEAPME's reply to the first phase of the consultation concerning cross border transfers of undertakings
July	UEAPME Comments on the initiative from DG Environment on Green Public Procurement (GPP)
July	UEAPME’s response to the second stage consultation of the European Social Partners on “the reconciliation of professional, private and family life”
July	UEAPME Policy message to the Portuguese Presidency: Unleash the growth and employment potential of Europe’s Crafts and SMEs
July	UEAPME considerations on the Breyer report on the proposal for a Regulation concerning the placing of Plant Protection Products on the market
July	UEAPME comments on the Community Guidelines for State Aid for Environmental Protection
June	UEAPME comments on the Draft General Block exemption Regulation
May	UEAPME response to the Green Paper on the Review of the Consumer Acquis
May	UEAPME response to the second stage consultation of the Social Partners on the protection of workers from risks related to exposure to carcinogens, mutagens and substances which are toxic for human reproduction
May	UEAPME report on the practical implementation of Directive 2003/88/EC concerning certain aspects of the organisation of working time
May	UEAPME position on the full accomplishment of the internal market for Community postal services
May	Towards a comprehensive EU contract law: the Regulation on the law applicable to contractual obligations (Rome I)
April	Single Euro Payments Area – SEPA: Needs, Opportunities and Threats for Crafts and SMEs
April	A successful “Energy Policy for Europe” must meet the needs of Crafts and SMEs
April	UEAPME position paper on the Commission’s green paper “Towards a Europe free from tobacco smoke: policy options at EU level"
April	UEAPME response to the Commission’s second stage consultation of the Social Partners on work-related musculoskeletal disorders (MSD)
March	Considerations of UEAPME on sustainable urban transport
March	UEAPME response to the European Commission’s consultation on an "European Credit Transfer System for Vocational Education and Training" (ECVET)
March	UEAPME position on the EC Green Paper "Modernising Labour Law to meet challenges of the 21st century" aussi disponible en Français
March	CSR: Further Red Tape or Chance for SMEs?
March	Joint statement -- Spring Summit: no time for complacency, warn European business organisations
February	UEAPME comments and observations on the Discussion Paper of DG Internal Market on the simplification of accounting rules for small and medium-sized companies
February	UEAPME position paper on the article 138 consultation on blood-borne infections
January	Position of UEAPME and NORMAPME on the Methodology for the Ecodesign of Energy- Using Products Directive (MEEuP)
January	UEAPME position paper on adult learning
January	UEAPME’s Reply to the questionnaire sent to the European Social Partners concerning the follow-up of Communication COM (2006) 159 – “Guidance on the posting of workers in the framework of the provisions of services”
January	Comments of UEAPME and the UEAPME NORMAPME Healthcare Forum regarding the Commission Consultation on Community action on health services
2006
December	UEAPME open letter to Mr Peer Steinbrück, German Federal Minister of Finance, on the “VAT package” standstill at the Economic and Financial Affairs Council auch verfügbar auf Deutsch
December	UEAPME position paper on the commission’s communication “The demographic future of Europe – from challenge to opportunity”
November	UEAPME position on the Communication from the Commission on “Global Europe – Competing in the world”
November	UEAPME amendments to the proposal for a Regulation of the European Parliament and of the Council concerning the placing of plant protection products on the market
November	UEAPME’s response to the first stage consultation of the European Social Partners on “the reconciliation of professional, private and family life”
November	Position of the UEAPME Construction Forum regarding the Proposal for a Directive of the European Parliament and of the Council on Waste (COD 2005/0281)
October	Joint Employers’ Analysis of the Key Challenges Facing Europe’s Labour Markets
October	European Innovation Policy: Take SMEs on Board too
October	Facilitating the access of SMEs and crafts to public tenders aussi disponible en Français
October	UEAPME position on the Commission’s proposals for enhancing supply chain security
October	UEAPME comments on the revised proposals from the European Commission on the amended new "de minimis" block exemption
October	UEAPME Working Group on Foodstuffs: Position Paper on Obesity
September	UEAPME RETAIL FORUM Position on the Communication from the Commission on the implementation of Directive 1998/6/EC of the European Parliament and the Council of 16 February 1998 on consumer protection and the indication of prices of products offered to consumers. COM (2006) 325 Final
September	UEAPME position paper on the European Institute of Technology (EIT)
August	UEAPME’s position paper on the “European Transparency Initiative”
August	UEAPME’s priorities for the second reading of REACH
August	UEAPME’s amendments for the second reading of REACH
July	UEAPME’s comments on the draft regulation on “LIFE +” and the first draft of the “LIFE +” multi-annual plan
July	UEAPME’s priorities for the second reading of REACH
July	UEAPME’s Position Paper on free movement of goods in the non-harmonised area
June	UEAPME's contribution to the public consultation on the future of the Internal Market
June	UEAPME position paper on the priorities for the upcoming Community Health and Safety Strategy 2007-2012
June	UEAPME Position Paper on the informal consultation document of the European Commission “Towards a Europe Free From Tobacco Smoke: Policy Options at EU level”
June	Position of the UEAPME NORMAPME Healthcare Forum regarding the suggestion to modify the Commission proposal relating to ANNEX VIII of Proposal for a Directive amending Council Directive 93/42/EEC of 14 June 1993 concerning medical devices
May	Comments on the Consultation Documents from the European Commission on State Aid relevant for SMEs
May	Comments of the UEAPME NORMAPME Healthcare Forum regarding the idea of introducing a general obligation to have a quality management system for manufacturers covered by the Proposal for a Directive amending Council Directive 93/42/EEC of 14 June 1993 concerning medical devices
April	UEAPME reply to the Questionnaire on the effect of the provision of Council Directive 2001/23/EC of 12 march 2001 on the approximation of the laws of the members States relating to the safeguarding of employee’s rights in the vent of transfers of undertakings, businesses or part of undertakings or businesses
April	UEAPME position on the Commission’s consultation on action at EU level to promote the active inclusion of the people furthest from the labour market
April	UEAPME Position on European Globalisation Adjustment Fund
March	UEAPME concept paper on Measures for improving mobility of apprentices in the framework of the Leonardo da Vinci programme 2007-2013 and of the studies undertaken by the European Commission with the budget line “Guy-Quint” on an “Erasmus style” programme for Apprentices
March	Comments of the UEAPME NORMAPME Healthcare Forum regarding the Proposal for a Directive amending Council Directive 93/42/EEC of 14 June 1993 concerning medical devices
March	European Policy for Crafts and SMEs: Now it’s time for concrete actions
March	UEAPME’s evaluation of the European Parliament’s vote on the Services Directive
March	UEAPME position paper on the Commission’s Communication on Implementing the Community Lisbon Programme: Fostering entrepreneurial mindsets through education and learning - COM (2006) 33 final
February	UEAPME position paper on the proposal for a directive on improving the portability of supplementary pension rights
February	UEAPME's position on the revision of the Eco-Label criteria on tissue papers (first draft proposal of 8th February 2006)
January	Position Paper on the reduction of the CIP budget
January	UEAPME Position Paper on the Commission's communication: 'Working together, working better'
January	Response to the consultation on the Posting of Workers Directive
January	UEAPME reply on the Commission services draft working document "Report by the Commission services on the implementation of Council Directive 1999/70/EC of 28 June 1999 concerning the framework agreement on fixed-term work concluded by ETUC, UNICE and CEEP"