Brussels, 25 October 2004

Introduction

EURO COOP welcomes the original Commission Communication as recognition of the importance of the co-operative sector, its contribution to the achievement of Community objectives and as a step towards implementing tailored measures in support of co-operatives.

EURO COOP agrees with the overall aims of the Communication, namely ensuring a level playing field for co-operatives vis-à-vis other forms of enterprises by introducing appropriate measures that take account of co-operatives' different requirements.

EURO COOP also welcomes the Preliminary Draft EESC3 Opinion on the Communication, and largely agrees with the thrust of the text.

We set out below more detailed comments on the following sections of current draft.

General Comments (Section 3)

EURO COOP supports the emphasis on the need to support co-operatives in the new and candidate Member States.

Many EURO COOP member organisations are long-standing, successful consumer co-operatives that do not meet EU and/or national Small and Medium-sized Enterprises. EURO COOP therefore agrees with the Committee that access to Community actions (e.g., business support services, funding) should not be limited to SMEs, but should also be open to co-operatives.

Aspects to be fleshed-out (Section 4)

Regulatory Environment

EURO COOP supports the proposal to establish synergies between all aspects of the regulatory environment that affect co-operatives.

EURO COOP also strongly supports the view that expert forums established at international, EU, national and regional level include representatives of the co-operative sector4.

The Committee should also call on the Commission to ensure that Member States ensure a true, level playing for co-operatives and avoid all legislation, standards, measures, etc. that discriminate against co-operatives.

Competition

EURO COOP supports the stance that simply promoting better dissemination of competition rules as advocated by the Commission will have little impact: the problem is not co-operatives' knowledge or understanding of the application of competition rules; rather, the problem is the very nature of the competition rules themselves, which fail to understand or take account of the co-operative form of enterprise.

Social responsibility and Corporate governance

EURO COOP also finds the Communication does not adequately recognise or encourage the pioneering role played by consumer co-operatives in developing Corporate Social Responsibility, which is today at the very centre of their approach to business.

EURO COOP agrees with the Committee that the debate on Corporate Governance should include the co-operative dimension. EURO COOP therefore notes with regret that the recently-established European Commission high-level forum charged with drafting corporate governance standards, comprises 12 experts, none of whom represent the consumer co-operative sector.

Comments on proposed actions (Section 5)

The Promotion of co-operatives

EURO COOP welcomes the call on the Commission to promote co-operatives in all its Directorate-Generals, including Directorate-General Health and Consumer Protection, as consumer co-operatives' main objective is to work in favour of the health and protection of their consumer-members.

Business support services

EURO COOP agrees with the Committee assertion that the EU Action Plan for promoting entrepreneurship fails to deal specifically with co-operatives.

EURO COOP believes that information provided by business support services must be enterprise-neutral.

Financing

EURO COOP would also support the inclusion of a reference to co-operatives in the EIF5 , and therefore supports the EESC call on the Commission to carry-out without delay its planned appraisal to this end.

Community Objectives

EURO COOP also approves of the Commission intention to ensure that the contributions made by co-operatives to achieving EU objectives are fully recognised, exploited and supported by means of Community programmes, including those in respect of health and consumer protection.

Conclusions

EURO COOP would also call for a detailed timetable to match concrete actions designed to implement the Communication Actions.

Others

EURO COOP believes the following additional elements need to be included in the EESC Opinion:

European Co-operative Statute

The Committee should call on the Commission to use its good offices to encourage Member States to transpose the Statute as soon as possible so as to ensure the consumer co-operatives can commence taking advantage of this key Internal Market measure on time, i.e., August 2006.

MAP

EURO COOP believes that the Committee should call on the Commission to include a specific reference to co-operatives in the next Multi-Annual Programme for Enterprise.

Taxation

While EURO COOP believes existing national taxation rules in respect of co-operatives should remain, it nonetheless believes that the Commission and Member States should examine the possibility of favourable taxation treatment of co-operatives on the basis of their usefulness in regional or social development terms. Co-operatives often offer new possibilities in terms of employment, service provision and overall economic regeneration in remote, sparsely-populated or otherwise disadvantaged areas which otherwise suffer from a lack of capital.

International dimension

EURO COOP finds that the Commission fails to recognise the international dimension, which is encouraged by the sixth co-operative principle of "co-operation among co-operatives". Consumer co-operatives for example actively work towards sustainable development, which can only be successful if tacked at the international-level. Fair Trade is a good example that involves consumer co-operatives in the north providing outlets for produce from co-operatives in the south.

Moreover, internationally-developed norms (e.g., International Accounting Standards) are often developed without reference to, or understanding of, co-operatives. Such norms can adversely affect co-operatives in Europe. The Commission must therefore be vigilant in defending European co-operatives in such matters.

Contribution to maintaining employment

In today's increasingly globalised economy, by the very nature of their strong links to local communities, co-operatives play an important role in the creation and maintenance of employment, which stems the trend towards delocalisation, thus helping to maintain the socio-economic fabric of many regions.

Moreover, co-operatives often provide opportunities for disadvantaged workers that may be unable to find suitable employment elsewhere.

ILO Recommendation on Co-operatives

EURO COOP believes the Committee should call on existing and also candidate Member States to ratify and implement the ILO Recommendation.

1. Version of 29 September 2004
2. COM(2004) 18 final
3. European Economic and Social Committee
4. E.g., International Accounting Standards Board, European Commission Forum on Corporate Governance, European Commission European Consumer Consultative Group, etc.
5. European Investment Fund