Danish position on the public consultation: “Small Business, Big World – A new

partnership to help SMEs seize global opportunities”

First of all, Denmark would like to thank the Commission for the opportunity to comment onthe public consultation on “Small Business, Big World – A new partnership to help SMEs seizeglobal opportunities”.The consultation is timely and important. We welcome the initiative to further theinternationalization of SMEs, which constitute a large and very important segment of theEuropean economy. Internationalization of SMEs can contribute at large to growth andemployment. At the same time, we know from experience, that SMEs in general are faced withparticularly complex decision-making when it comes to internationalization due to limitedresources and lack of experience. In order to mobilize the potential of the SMEs, specialattention is needed, i.e. by establishing support programmes to help them overcome theburden to go international.We welcome the Commission’s effort to create a more coherent and effective EU strategy. TheCommission plays an important role in helping SMEs seize global opportunities. We think thatnational efforts matched with the right mix of support programmes on a horizontal levelrendered by the Commission in local markets can increase SMEs’ export potentials. It isimportant that a thorough examination of existing services is carried out in key markets inorder to determine a structure at EU level, which adds value to the SME. As public finances allover Europe are fully stretched, we welcome the Commission’s guiding principles that supportprovided by the EU should not overlap or duplicate initiatives established by Member Statesand/or private organisations in order to secure cost-effectiveness and in respect of the givenpolitical competence in the area of trade policy and trade promotion. Possible initiatives shouldbe in line with the subsidiarity principle.Below please find the Danish position on the following questions:

1) Do you agree that SMEs need public support to tap international markets

(outside the EU)?

We agree that most SMEs would benefit from public support to tap international markets.Especially, markets outside the EU constitute a big challenge to companies, but even exportinternally in the EU, to which many SMEs would look as their first destination of export, can

pose a challenge to SMEs. To achieve results on these markets, SMEs would requireextraordinary support measures.Public support programmes should be evaluated on a regular basis in order to optimizemeasures.

2) In what areas do you feel public support is particularly essential?

Tapping into international markets need thorough consideration and preparation. Companiesplanning to become international, may ask for assistance in any phase of theinternationalization process, ranging from establishing export potential and readiness, marketselection, mode of entry, finance, operation etc. SMEs are also confronted with new politicaland business framework conditions, which will affect their way of doing business abroad. Inour view other areas, in which public support is particular essential, include among othersguidance on protection and enforcement of IPR, removal of NTB’s and trade barriers, e.g.import tariffs,removal of barriers to foreign direct investment, standards, conformityassessment and regulatory issues, technology commercialization, customs regulation, localcontent practices etc.

3) Which institutions do you consider best placed to provide such support?

SMEs are often unaware of the possibilities of international markets or consider the issue toocomplex. Their motivation is often spurred by Member States and/or private organisations,which disseminate information about export possibilities and provide essential guidance. SMEsoften lack information or knowledge about foreign export markets, and feel less confident incommunication in a language different from their mother tongue and in new cultures.Furthermore, it has to be acknowledged that European SMEs are often competitors andtherefore feel more inclined to involve national public and/or private organisations. Theseorganizations have provided services to SMEs for a long time and have build structures andcompetencies, which are tailored to meet the needs and demands of SMEs. Hence, publicsupport at EU level should supplement and complement such initiatives on a horizontal level,where European SMEs are facing the same problems, and leave the business specific problemsto Member States and/or private organisations.EU should not initiate support programmes consisting of export consultancy work for individualcompanies, which is already done by existing initiatives at national level.

4) In which areas could activities at EU level be particularly useful (add value)?

The Commission plays an important role in helping SMEs seize global opportunities. First of allin safe-guarding a well-functioning Internal Market. Mapping framework conditions andremoving trade barriers of common interest to the EU are in our view areas where the EU canadd value as regards external markets. The Commission has an important role to play infinalizing regional and bilateral free trade agreements and in furthering the WTO agenda.Furthermore, the Commission’s role addressed above should be a horizontal one, e.g.gathering and communicating market information, protection and enforcement of IPR, removalof NTB’s and trade barriers, e.g. import tariffs,removal of barriers to foreign direct

investment, standards, conformity assessment and regulatory issues, technologycommercialization, customs regulation, local content practices etc. A useful tool could be anon-line “International Business Portal”, providing first-entry and business relevant informationon foreign markets, further country-specific IPR helpdesks etc. Possible initiatives at EU levelshould benefit companies working in all business areas, e.g. production, services etc. Sharingbest practice and knowledge at EU level can be a valuable supplement to national, regional andlocal initiatives.

5) Do you agree with the presumption that SMEs could benefit

from greater visibility of available support. How could this be achieved?

from (improved) cooperation of organizations providing support

Communication is always important. Many SMEs are unfortunately not aware of the existing EUsupport facilities or do not know how to access them. An easy to use on-line one-stop-shop inthe official languages would help. Member states and/or private organizations could strengthentheir efforts by working together to raise awareness of the EU support programmes. As oftoday, SMEs would often search national websites, before looking into relevant EU web sites.In Denmark, SMEs are familiar with national support measures and institutions.

6) Do you agree that an online portal bringing together relevant information

about doing business in certain markets abroad could be a useful tool

for intermediaries (providing business support)

for SMEs themselves

We recommend that a thorough investigation is carried out of existing portals, where SMEs canget information, in order to avoid duplicating web sites. Based on the findings, a commonoverall portal that incorporates all relevant information might be helpful. The main task is tohave an effective search facility to allow companies to quickly establish, which programmes arerelevant for them.

7) Do you agree that a stock-taking of existing support measures in certain

markets is necessary?

In our view, a stock-taking exercise of existing EU and member state support measures in allrelevant markets would be beneficial.

8) Do you think that it is a good idea to build on existing structures in markets

abroad, such as established national bilateral Chambers of Commerce, to

provide initial support to newcomers from anywhere in the EU? Or would you

prefer new structures to be established to fill any gaps?

Provided that investigations show that there is a need and demand for a special EU set-up, werecommend that EU support measures on horizontal level are incorporated in the local EUdelegation structure abroad, which would remove the issue concerning national bias. Nationalbilateral Chambers of Commerce do not play the same role in all member states, which makesit complicated to build on this structure.

We have noticed that the Commission plans to expand the role of Enterprise Europe Network(EEN) in order to support SMEs to better exploit business opportunities in Europe and in globalmarkets. From our point of view, this expansion of EEN’s role needs to consider andcomplement existing national structures and initiatives set up to support SMEs exportopportunities.Furthermore, a possible commitment of EEN as a part of the future negotiations of the EUmulti-annual Financial Framework for the period 2014-2020 should also be discussed andclosely coordinated with the national authorities responsible for SME policy in each EU memberstate. This would reduce the risk of overlap between the EEN and the existing and well-functioning national business support structures providing SMEs access to markets outside theEU.

9) Do you think that a cooperation and division of labour between existing

European support organizations in a given market

would be useful

could be feasible? What needs to be done to bring this about?

Overlap and duplication should be avoided in order not to spend tax payer’s money twice.Member States and/or private organisations have provided services to SMEs for a long timeand have build structures and competencies, which are tailored to meet the needs anddemands of SMEs. Close cooperation and dialogue at all levels are useful to secure division oflabour if done respecting and in coordination with existing national initiatives.

10)

Do you agree that cluster and network organizations can play an

important role in helping SMEs internationalize and should, therefore, be

strengthened?

Clusters and network organisations can play an important role in helping SMEs internationalize,but they can never stand alone as they are often operational in the individual market.

11)

Do you agree with the guiding principles for new EU support activities as

set out in the proposal? If yes, would you like to see other bodies (Member

States) adhere to such principles as well?

We welcome the guiding principles that actions taken at EU level should be complementary toand not duplicate business support activities that are carried out by Member States and/orprivate organizations. In compliance with the principle of subsidiarity and an appropriatedivision of labour, they should serve to fill gaps or reinforce existing support services whereneeds are not met by other public or private institutions.EU-level support for business should be based on a demonstrated demand and need in themarket concerned.Efficiency in the use of public funds would in our view be achieved best if the local EUdelegations were to enlarge the scope of their activities on the horizontal level in order tosupport SMEs in their internationalization.

We agree that market selection should be based on economic potential and size of the market.A special effort should be made in regards to trade policy initiatives that strengthen SMEmarket access to expanding growth economies such as the BRIC countries and Next 11.Secondly, we agree that the extent of difficulty faced by SMEs in accessing the market shouldalso be taken into consideration. Finally, we agree that new EU level initiatives should only beproposed where there is a clear need, demand and gap in the existing business structures onthe horizontal level. What concerns the existing geographical priorities, e.g. China, India,Thailand, Malaysia etc, we recommend that the same exercise is carried out in order to ensurethe efficient use of public funds and to evaluate its relevance.

13)

Do you miss any important aspects in the overall assessment?