Europaudvalget 2024-25
EUU Alm.del Bilag 257
Offentligt
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29 January 2025
2025 - 667
MarRay
Danish contribution to the Commission's Call for Evidence on the Hor-
izontal Single Market Strategy
Strengthening The European Single Market is a corner stone in the efforts
to improve European competitiveness. The Danish Government welcomes
the initiative to develop a horizontal Single Market Strategy by June 2025,
which should improve the functioning of the Single Market to the benefit
of European companies and citizens.
The Single Market is one of the EU’s biggest assets to boost competitive-
ness with its more than 23 million companies and 440 million consumers
1
.
Without an effective Single Market, industrial activities and production
will not thrive in the EU. The Single Market can propel the green and dig-
ital transitions, which must be a driver for competitiveness giving EU com-
panies an edge in the global race. We need to tap into the potential of the
Single Market using it as catalyst and driver of European competitiveness.
The Commission estimated in its communication "The Single Market at
30" that up towards EUR 713bn could be added to the European economy
by the end of 2029 if remaining barriers to the Single Market for goods and
services are eliminated
2
. This underscores the importance of continued ef-
forts to enhance enforcement of Single Market rules at both EU and na-
tional levels and to continue work on removing barriers to the free flow of
goods and services.
Based on this we encourage the Commission to include the following in the
Single Market Strategy.
Reduce regulatory burdens through digitization, standardization and
automation
First, the strategy must contribute to reducing the regulatory burdens on
companies, not least SMEs. This should be done by simplifying existing
rules and seizing the potential of digital tools, data sharing infrastructure
1
2
Single Market at 30, 16.3.2023.
Single Market at 30, 16.3.2023.
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and standardization to make it easier for companies to comply with report-
ing requirements and thereby contribute to reaching the objective of reduc-
ing reporting obligations by 25 percent (35 percent for SMEs).
Making the best of digital tools, the European Digital Identity Wallet
should play a prominent role considering its potential to reduce administra-
tive burdens and costs, enable smoother cross-border data sharing and dig-
ital transactions, and ease compliance with reporting requirements.
To achieve these goals, the Commission should propose an ambitious hor-
izontal action plan for reducing administrative burdens, including mapping
reporting requirements to make a baseline, outlining a roadmap of next
steps and including measures for regular follow-up on results.
A fundamental part of the action plan should be to establish a common EU
approach on how to make digitalisation, standardisation, and automation a
core driver for burden reduction for businesses, which can then be applied
broadly across the various regulations that businesses are required to report
on.
Remove barriers to the free movement of goods and services
Second, the strategy must contribute to removing barriers to the free move-
ment of goods and services so that companies, not least in areas with high
growth potential, can reap the full benefits of a market with more than 400
million consumers. This involves addressing lacking or ineffective imple-
mentation and gold plating of EU rules. The notification of national tech-
nical regulations is an important tool in this regard and we must safeguard
the existing notification procedures to avoid new barriers on the Single
Market.
Update the New Legislative Framework and broaden the use of mu-
tual recognition
The NLF remains the foundation for the free movement of goods and has
served as a well-functioning and fit-for-purpose framework for harmonised
product regulation. However, it must be adapted and strengthened with spe-
cific aims to meet future challenges, ensuring the safety, security, and com-
pliance of products throughout their lifecycle. In doing so, we should avoid
unnecessary administrative burdens and aid businesses in their green and
digital transitions fostering their resilience. Moreover, within the non-har-
monised area we should ensure the continued use of mutual recognition
when applicable, while broadening the knowledge of the principle.
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Solve the responsibility-gap in global e-commerce
During the last decade, consumer habits in the Single Market have changed
significantly and new business models have emerged that threaten the com-
petitiveness of European economic operators. Today, many goods are
shipped directly to consumers from outside the EU. With limited obliga-
tions to ensure compliance regarding safety, social responsibility and
safety, online marketplaces act as a gateway for third country sellers to
place their products on the EU-market from a distance without a traditional
importer acting as an intermediary. This results in a compliance deficit as
no economic operator can effectively be held responsible for the compli-
ance of products within the current legal framework.
Although initiatives to solve the challenges have been taken in the Digital
Services Act and gradually in the General Product Safety Regulation and
the Ecodesign Regulation, the compliance deficit remains. All in all, the
current legislation regarding compliance of products is no longer fit for its
purpose of ensuring the competitiveness of responsible economic opera-
tors, keeping consumers safe and thereby maintaining a strong Single Mar-
ket.
To solve the growing issues, the responsibility gap in the current product
legislation must be solved and updated and online marketplaces must be
given obligations that match the key role they play in the current market.
Enhancing the enforcement of the Single Market rules strengthening
infringement procedures
Enforcement of the Single Market rules is a key instrument in addressing
unjustified barriers and fragmentation of the Single Market. Concentrating
on the proper enforcement and addressing unjustified barriers that signifi-
cantly impede the Single Market's functioning and the European economy
could greatly enhance the benefits of the Single Market for companies. We
therefore suggest taking a targeted approach to enforcement focusing on
the breach of rules with a significant impact on the free movement, building
assessments of economic impact, resource availability, or its broader im-
pact on other areas on the European cohesiveness inspired by the Single
Market Scoreboard.
In addition to the Commission’s work addressing infringements, we can
build on and strengthen existing instruments such as SOLVIT and SMET
to ensure an efficient follow-up on structural barriers.
Detailed contributions
In the Call for Evidence the Commission requests input on the barriers and
challenges affecting the operation of the Single Market as well as possible
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initiatives to address them. To this effect [Five] non-papers addressing the
issues highlighted above are provided as annexes to this contribution:
•
•
•
•
Danish non-paper on Building the reporting landscape of the future.
Roadmap for contributing to 25 % burden relief through automated
reporting.
Danish technical paper on the revision of the New Legislative
Framework.
Non-paper on enhancing the enforcement of the Single Market rules
by strengthening infringement procedures by Denmark.