Memorandum by the British Chambers of
Commerce (BCC)
INTRODUCTION
The British Chambers of Commerce (BCC) comprises
a national network of quality accredited Chambers of Commerce,
all uniquely positioned at the heart of every business community.
Currently over 100,000 businesses benefit from membership of 61
chambers in our accredited network from growth orientated start-ups
to local and regional subsidiaries of multinational companies
in all commercial and industrial sectors and from all over the
UK.
This response is split into two sections corresponding
to the terms of reference supplied by the Lords European Union
Select Committee. These are set in bold at the beginning of each
section.
The BCC would be prepared to provide oral evidence
if required.
Comments of a general nature, covering all or
large parts of the Work Programme, including questions of the
overall priorities of the Commission's programming, the volume
and types of legislation and initiatives proposed, and the general
direction of the Work Programme
1. The BCC is pleased with the general direction
of the 2007 Work Programme (WP), particularly the emphasis on
the challenges posed by globalisation and the Commission's response
to it. The 2007 priorities are wide ranging and outward facing.
As the EU is a global competitor it is important that EU policy
making takes account of the significant challenges posed by a
rapidly changing world.
2. However, while the framework is correct
we are concerned that the WP lacks substance. Big issues on energy,
migration and reform of the European economy have been highlighted
how these will be addressed is unclear.
3. We are disappointed that the 2007 WP
has not gone further with its list of proposals for simplification
(60 proposals) and withdrawal (11 proposals). Research conducted
by the BCC has found that 75 per cent of regulatory costs to business
since 1998, some £37,814 billion, is EU sourced regulation.[1]
With such a large regulatory burden originating in the Commission
we would expect a more ambitious roadmap for better regulation.
This programme does little to allay fears that the better regulation
agenda is not being taken seriously within European institutions.
We do not see within this list a clear means for the Commission
to deliver on its better regulation targets.
4. The WP lacks transparency. It would be
useful to explain what criteria are applied to items included
in the work programme and why items are included in "the
catalogue" and not in the WP. A better approach would be
for the Commission to include all items to be worked on during
the course of the year in one document and for this to be divided
into three sections: "new", "simplification"
and "withdrawal".
5. The WP fails to make a clear distinction
between "strategic" and "priority". There
is no explanation of how the two sets of objectives interact.
Comments of a specific nature, relating to individual
proposals. In this respect the Committee would be interested to
know, for example, which specific proposals raise concerns in
terms of their scope, content, or with regards to the principles
of subsidiarity and proportionality, and how these concerns could
be addressed.
6. Communication on the Single Market Review
The BCC notes that the WP is responding to the
significant challenges presented to the Single Market by an enlarged
EU, globalisation and technological innovation. The WP also makes
reference to opportunities presented by these changes. The BCC
agrees with the WP's approach, any review should look in detail
at how the Single Market can address both. We would expect the
full review to clarify what it understands the "challenges"
and "opportunities" to be rather than simply alluding
to them. The BCC notes the emphasis on ensuring that the Single
Market continues to benefit the EU at the "citizen level".
We understand the requirement for the inclusion of this as a priority
for 2007, however we would like to see a more explicit explanation
of how benefits at the "citizen level" are delivered.
An obvious means of delivery would be the creation of conditions
in which business and in particular SMEs can thrive and develop.
Delivery of these benefits may not therefore be achieved through
additional directives. We would like the Commission to pay due
regard to the principles of subsidiarity and proportionality—it
is hard to see from the list of communications, directives and
legislative proposals contained within the WP the extent to which
this is a consideration.
7. Communication on combining labour market flexibility
and security
The BCC believes that flexibility of labour
markets is crucial to business prosperity and that if the EU is
to successfully implement the Lisbon Agenda then arriving at common
principles on this is important. We would like to see a wider
debate on the concept of "flexicurity". The BCC urges
the Commission to increase flexibility. A balance must be struck
between ensuring that workers are protected and facing up to the
realities of global competition. Flexibility is key to business
success and we would want to see the flexibility currently enjoyed
by UK business maintained. Any additional regulation, to ensure
social protection should be proportionate.
8. Follow-up on the green paper consultation
on labour law launched on 22 November
We are pleased that the Commission has set a
sensible timetable for the follow-up to the draft green paper.
Clearly the nature of this work will depend on the results of
the consultation currently underway. The BCC has a number of concerns
around "flexicurity"; EU-wide definitions of employment
and self-employment and the concept of a "floor of rights"
for all workers irrespective of their employment status. The BCC
will be submitting a response to the green paper which will address
these points.
9. Package on energy
The BCC supports the Commission's energy policy
objectives: sustainability, competitiveness and security of supply.
Over and above other policy areas, international co-operation
on energy is crucial if these objectives are to be achieved; establishing
a strong European Voice on the issue is likely to hasten progress.
10. Communication on implementation of National
Strategies for Green public procurement
Although the communication is non-legislative
it does propose EU-wide targets on green public procurement. Our
research indicates that UK small businesses are already striving
to improve their green credentials.[2]
Key findings include:
— 52.7 per cent of businesses considered
themselves energy efficient whilst 31.1 per cent were considering
becoming so.
— 81.8 per cent of businesses said
that lower energy bills were the prime motivation to becoming
more energy efficient.
— Reflecting the belief that the business
community has a role to play in tackling climate change, 66.6
per cent listed environmental concerns whilst 48 per cent said
social responsibility of becoming energy efficient.
— The biggest benefit of becoming more
environmentally efficient is lower energy bills, with 76.6 per
cent listing this.
— Of those businesses that have not
introduced or promoted energy efficiency, 29.8 per cent said it
was not a priority whilst 19 per cent said it was too costly.
In this context we would prefer the Commission
to look to increase its advisory role in this area rather than
seeking to monitor and set targets.
January 2007
1 BCC Burdens Barometer 2006. Back
2
BCC Energy Efficiency Survey: The Challenge for Government and
Small Businesses October 2006. Back
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