Ref. Ares(2022)1789387 - 10/03/2022
From:
 (CAB-BRETON)
To:
CAB BRETON ARCHIVES
Subject:
FW: Follow up to our meeting on 23rd September
Date:
jeudi 14 octobre 2021 17:30:34
Attachments:
image001.jpg
image002.jpg
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2021_10_05_ZDH Kompakt_Data Act_EN.pdf
2021-03-22_ZDH Kompakt_Supply Chain Act_Do not overburden SMEs.pdf
2021_07_27_Overview_sustainable corporate governance and CSR in the German Skilled Crafts sector.pdf
2021_06_21_Kompakt_DMA_DSA_EN.pdf
From: SKONIECZNA Agnieszka (CAB-BRETON) 
 
Sent: Monday, October 11, 2021 10:11 AM
To: 
(CAB-BRETON) 
Subject: FW: Follow up to our meeting on 23rd September
To register , if not done
From: 
 <
 On Behalf Of 
Sent: Tuesday, October 5, 2021 11:56 AM
To: SKONIECZNA Agnieszka (CAB-BRETON) 
Cc: 
 (GROW) 
Subject: Follow up to our meeting on 23rd September
Dear Agnieszka,
Thank you very much for the interesting meeting two weeks ago. At the meeting
we had discussed a number of points on which I would like to follow up as
discussed:
- Regarding the upcoming Data Act I have attached a short position “ZDH
Kompakt”, which we published yesterday. I have also attached one
regarding the current negotiation of the DMA.
- On the subject of SMEs in supply chains, please find our short position
and a collection of examples in the German Skilled Crafts Sector. In
addition, as discussed we are in the process of compiling statistical data
and data from a questionnaire we have sent to our companies regarding
the weight, role and needs of craft companies in the value chains with a
particular focus on the 14 ecosystems identified by the European
Commission. We will send you our conclusions as soon as possible
- You have also suggested that if we have any concrete examples of a less
than adequate application of the SME Test, I should let you know. In the
"Fit for 55" package, little consideration has been given to the "Think
Small First" principle and the mandatory SME test. In particular, it was not
sufficiently examined which effects the proposals have particularly on
SMEs. This applies both to the individual proposals and to the effects
resulting from the interaction between the different proposals of the very
comprehensive package. Very general statements such as "SMEs can
benefit from new business", are not satisfactory and show once again
that the mandatory SME test is not being taken seriously. However, only
by strictly applying this test, bureaucratic burdens as a result of new
legislative proposals (or legislative packages) can be seriously identified
and prevented for SMEs
Of course I am available for any further questions and am looking forward to
following up with you on these issues in the near future.
Best regards,
 European Affairs

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German Confederation of Skilled Crafts
and Small Businesses (ZDH)
Rue Jacques de Lalaing, 4
B-1040 Brussels
Phone:+
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