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Position papers (105)

2021 EMPLOYMENT | LABOUR MARKETS

Response to consultation on collective bargaining agreements by self-employed

The Commission launched an initiative to define EU competition law’s scope of application, to enable an improvement of working conditions through collective bargaining agreements for i.a. solo self-employed. Ceemet emphasized -once more- that when addressing the collective representation and bargaining of a person working through a platform, a distinction must be made if this person is considered an employee or self-employed.

2021 EDUCATION & TRAINING

ILAs - Ceemet response on inception impact assessment

Individual Learning Accounts (ILAs) are set to be part of a Commission proposal for the Council in November/December 2021 based on the outcomes of public consultations. In this 1st phase response Ceemet explains why ILAs might not offer the adequate solution to address the objectives and barriers mentioned in the consultation document.

2021 EMPLOYMENT | LABOUR MARKETS

Response to first phase consultation of social partners on addressing the challenges related to working conditions in platform work

Platform work is a growing phenomenon and the use of platform work, accelerated with the outbreak of the COVID-19 pandemic. Platform work creates new opportunities for workers, self-employed, business and customers, including new jobs and income for those who have difficulties in accessing the traditional labour markets, increased flexibility and autonomy. And although platform work creates opportunities, it also comes along with challenges. For Ceemet the most efficient way to respond to these challenges lies at national level, considering the specificities of national labour markets and industrial relations.

2020 ECONOMIC OUTLOOK

Tech & Industry employer’s views on the Annual Sustainable Growth Strategy 2021

The Metal, Engineering and Tech-based (MET) industries have experienced an unprecedented crisis in recent months. Huge numbers of workers are in short term unemployment and the number of jobs that are in danger of being lost is substantial. With the European Commission's ASGS strategy being published, this position paper takes stock and looks forward.

2020 EMPLOYMENT | LABOUR MARKETS

Reply to 2nd phase consultation on a possible action on fair minimum wages

The reply provides the answers of industries represented by Ceemet on the European Commission second phase social partner consultation under Article 154 TFEU on a possible action addressing the challenges related to fair minimum wages.

2020 BREXIT | FUTURE RELATIONSHIP

Ceemet priorities for the EU-UK Future Relationship

As the EU and UK will remain important economic partners, given history, proximity and the degree of existing integration, it is crucial to get the balance right in the upcoming negotiations on the future relationship. In particular Ceemet members want to see 10 points considered.

2020 EMPLOYMENT | LABOUR MARKETS

Reply to 1st phase consultation on a possible action on fair minimum wages

The reply provides the answers of the industries represented by Ceemet on the European Commission's 1st phase social partner consultation under article 154 TFEU on a possible action addressing the challenges related to fair minimum wages.

2020 EDUCATION & TRAINING

Reply to Commission consultation on the Skills Agenda update

Ceemet welcomes the possibility of contributing to the debate on the update of the Skills Agenda. The majority of the initiatives add value to the debate on skills, but would have more effect if they had been better coordinated.

2019 BREXIT | FUTURE RELATIONSHIP

Ceemet position on future relationship between the EU & the UK

Ceemet has been clear since the outset about our key priorities for the European Technology and Industry sector to ensure a smooth exit for the UK from the EU. This report explores four priorities providing background and setting our specific recommendations for the future relationship between the EU and the UK.

2019 ECONOMIC OUTLOOK

Tech & Industry employer’s views on the Annual Growth Survey 2020

Economic growth continues in some Member States, however at a slower pace, indicating that there are economic clouds on the horizon. This highlights the need for continued reforms of EU labour markets ensuring adequate links between the education systems and those labour markets, which need better support to ensure the digital transformation.

2019 EDUCATION & TRAINING

Building a European Education Area by 2025

A highly skilled mobile workforce is the basis for an internationally competitive industry that provides quality jobs. Ceemet and its members will support the European Commission’s ambition to work towards a European Education Area (EEA). Investing in people and their education and removing the obstacles that hinder (learning) mobility across Europe should be a shared goal of all stakeholders.

2018 SOCIAL PARTNERS

European Pillar of Social Rights: Social partners underline 9 principles

The Pillar is proclaimed and has a non-binding nature. Delivering on the principles of the Pillar is primarily a responsibility of national governments, of public authorities and of Social Partners at all levels. With its trade union counterpart industriAll Europe, Ceemet underlines 9 principles to contribute to the debate.

2018 SOCIAL PARTNERS

Legal migrants & labour market: Social partners paving the way towards integration

The ongoing inflow of people seeking refuge, fleeing poverty, war and persecution is posing a number of challenges to our societies in Europe. Global migration is by no means a new phenomenon. It is an inherent feature of the 21st century. Migrants regardless of their motivation to seek refuge in the EU have to be humanely and responsibly treated. IndustriAll Europe and Ceemet formulated 6 focus points. They cover topics of cooperation between stakeholders, access to education and respect for the principle of equality of opportunity and treatment between national and migrant workers.

2018 EDUCATION & TRAINING

Ceemet view on the future of Vocational Education & Training (VET)

As employers of the Metal, Engineering & Technology-based industries, representing the biggest manufacturing industry in Europe, Ceemet is convinced that a good education policy including excellent Vocational Education and Training (VET), that meets the labour market needs is also key to an effective and sustainable social policy. With this paper, Ceemet seeks to actively shape the future of VET.

2018 HEALTH & SAFETY

Ceemet position on REACH-OSH overlap

The European Commission published on 5 March 2018 its conclusions on the 2nd REACH Review. It which prioritised the REACH-OSH interface as one of the four issues requiring the most urgent action. Ceemet welcomes the Commission’s suggestion that the interface between REACH and OSH legislation calls for systemic solutions to address the main overlaps and discrepancies between the two legislative frameworks.

2018 COMPETITIVE INDUSTRY

10 Point Plan for a competitive industry sustaining social Europe

Ceemet has drafted a 10 Point Plan for turning today’s and tomorrow’s challenges into opportunities. It lays the groundwork for a facts-based discussion offering ideas from European Tech & Industry employers. It eventually is about why Europe needs industry and why industry needs Europe even more.

2018 HEALTH & SAFETY

Position on 3rd review of the Carcinogens or Mutagens at Work Directive

Ceemet reacted to the Commission's proposal for a 3rd amendment to Directive 2004/37/EC on the protection of workers from the risks related to exposure to carcinogens or mutagens at work (CMD). It aims to add occupational exposure limit values for five substances. Until now, there have been two amendments to this directive, and with more promised, it is crucial to ensure the best outcome in this process for both employers and workers.

2018 EMPLOYMENT | LABOUR MARKETS

Position on the Transparent & Predictable Working Conditions Directive

The Commission published its proposal for a Directive on transparent and predictable working conditions in the EU. The revision follows a REFIT evaluation that aims to make EU law simpler. Ceemet expected a modernised EU Directive which would remove red tape and increase transparency. Unfortunately the opposite is true.

2017 HEALTH & SAFETY

Position on the Commission Communication on Occupational Health & Safety

Ceemet particularly welcomes the focus of the Communication on sharing of best practice, simplifying and reducing administrative burden while maintaining workers' protection and the focus on the culture of compliance in companies. However, the Commission missed the opportunity to make improvements to the existing regulatory regime by removing duplication and outdated provisions.

2017 EMPLOYMENT | LABOUR MARKETS

Position on the European Pillar of Social Rights

The European Pillar of Social Rights aims at re-establishing the connection between the EU and its citizens and is a reaction to the challenges the EU has been facing. Ceemet is unconvinced that this is the right answer to what is actual needed: an increased international competitiveness that ensures more jobs, growth and prosperity within the EU.

2017 EMPLOYMENT | LABOUR MARKETS

Revision of Social Security Regulation

This position paper only focuses on labour mobility of economically active persons, and more in particular posting – or sending – of workers. It does not comment on the proposed changes regarding the coordination of specific social security benefits, notably long-term care benefits, unemployment benefits, social benefits and family benefits. Nevertheless, Ceemet agrees with the changes proposed by the Commission and welcomes the legal clarification.

2017 EMPLOYMENT | LABOUR MARKETS

Position on Work-Life Balance Initiative

The Commission launched its initiative to support work-life balance for working parents and carers. The initiative, besides non-legislative actions, includes a new Directive on work-life balance for parents and carers. Ceemet favours greater support, not legislation, for the progress already made by MET sector social partners.

2017 EMPLOYMENT | LABOUR MARKETS

Reply to 1st phase consultation on a possible action addressing the challenges of access to social protection for people in all forms of employment

The Commission launched within the framework of the European Pillar of Social Rights a first phase social partner consultation on a possible action addressing the challenges of access to social protection for people in all forms of employment in the framework of the European Pillar of Social Rights.

2017 EMPLOYMENT | LABOUR MARKETS

Reply to 1st phase consultation on a possible revision of the Written Statement Directive

The Commission launched within the framework of the European Pillar of Social Rights a first phase social partner consultation on a possible revision of the Written Statement Directive. The aim is to consult the social partners on a possible revision to improve the effectiveness of the Written Statement Directive and on a possible broadening of its objectives.

2017 SOCIAL PARTNERS

New Skills Agenda : No need for new but for swift action

Ambitious Vocational Education & Training (VET) policies are essential. Companies of all sizes and workers have to keep up with the skills development that is required for the Metal, Engineering & Technology-based (MET) sector to remain innovative, competitive and sustainable. Therefore, Ceemet and industriAll Europe are calling for a responsive VET system.

2017 EDUCATION & TRAINING

Position on the New Skills Agenda for Europe

Ceemet welcomes the objectives of the New Skills Agenda for Europe to ensure that the right skills are available within the EU labour force. We share the Commission’s view that there is a need to increase the level of basic skills in Europe, that Vocational Education and Training (VET) should be a first choice and that digital skills are of crucial importance. However, we have reservations with some of the tools proposed to attain these objectives, e.g. Upskilling pathways: New Opportunities for Adults, formerly known as the Skills Guarantee.

2016 SOCIAL PARTNERS

Joint conclusions on adaptability and flexible forms of employment

Joint views on adaptability and flexible forms of employment developed by the “Competitiveness & Employment” working group of the Metal, Engineering and Technology-based (MET) sectoral social dialogue committee.

2016 EMPLOYMENT | LABOUR MARKETS

Reply to the consultation on the European Pillar of Social Rights

It is important to acknowledge that the EU already today has a strong social dimension. Considering the current lack of support for the EU from its citizens the focus should be on how to make EU citizens aware of this existing social Europe and how to inform EU citizens of the advantages of a highly competitive Single Market. Therefore, is the European Pillar of Social Rights (EPSR) really the correct answer to the current climate and the changing world of work?

2016 EMPLOYMENT | LABOUR MARKETS

Reply to 2nd phase consultation on possible action addressing the challenges of work-life balance faced by working parents & caregivers

As stated in Ceemet's reply to the 1 phase social partner consultation, it fully supports the general objective to increase the participation of women in the labour market. However, the observations of the employers’ organisations within the framework of this first phase consultation appear to not have been taken into account by the Commission. A sufficient framework already exists at EU level.

2016 SOCIAL PARTNERS

How to promote a fit for purpose European sectoral social dialogue

From its start, the Juncker Commission has highlighted the importance of a well-functioning Social Dialogue and took an initiative to relaunch Social Dialogue. Ceemet and industriAll Europe are in general supportive of the “A New Start for Social Dialogue” statement. Representing the biggest industrial sector, both want to set out their views about sectoral social dialogue and what we consider are the pre-requisites for a well-functioning, efficient, value-adding sectoral social dialogue at EU level.

2016 HEALTH & SAFETY

Position on the review of the Directive on Carcinogens or Mutagens at the Workplace

The Commission aims to add or revise occupational exposure limits for a number of substances by amending annexes one and three of the Directive. While Ceemet welcomes the revision of this Directive and see its benefit as a method to protect workers from exposure to carcinogens and mutagens, there are a number of factors with which we take issue in its construction.

2016 EMPLOYMENT | LABOUR MARKETS

Position on review of Posting of Workers Directive

The Commission has stated that the proposed revision to the Posting of Workers Directive (96/71/EC) intends to “address unfair practices and promote the principle that the same work at the same place should be remunerated in the same manner.” However, Ceemet believes that there are existing opportunities for improving the implementation and enforcement of the Posting Directive that do not require any revision, particularly one as substantial as that proposed on 8 March 2016. Instead, the proposed revisions will create unintended barriers to the free movement of services. They would hinder, not promote labour mobility across the EU.

2015 EMPLOYMENT | LABOUR MARKETS

Reply to 1st phase consultation on a 'New Start' for Work-Life Balance

In the social partner consultation, Ceemet expresses its fully support the general objective to increase the number of women in the labour market. However, there is no need for legislative action to revise existing EU Directives, nor to create legislation on other forms of leave. The current directives provide for adequate EU level minimum standards.

2015 EMPLOYMENT | LABOUR MARKETS

Position on European Economic Governance and deepening the EMU

The Commission published their proposals for deepening European Monetary Union (EMU) and Ceemet wonders, are we on the road to a European wage coordination?

2015 JOINT POSITIONS

EU employers joint letter on possible consolidation of Information & Consultation Directives

As part of its REFIT programme that aims at cutting back legislation, the Commission wants to consolidate 3 EU Directives on the information and consultation of workers. EU employers ask the Commission not to pursue this initiative, which would have no effect in reducing red tape, and would result in a harmful impact on companies.

2015 EDUCATION & TRAINING

Position on Riga Conclusions

Ceemet welcomes the Vocational Education & Training (VET) strategy that was agree in Riga. It re-focuses of the medium-term deliverables in VET, stressing the necessity of excellence in VET. But Ceemet minds to be cautions against pushing apprenticeships as a panacea for youth unemployment.

2015 EMPLOYMENT | LABOUR MARKETS

Reply to consultation on a consolidation of the EU Directives on Information & Consultation of workers

The Commission started in the context of its REFIT programme that aims at cutting back legislation, to consolidate 3 Direction related to Information & Consultation of workers.

2015 HEALTH & SAFETY

Position on Working Time Directive

The Working Time Directive sets out minimum rules for the protection of workers. It is a health and safety measure which has over time done little to either clarify or simplify the law. Employers have found many practical solutions to the problems which the directive has caused, but at a cost to them. Ceemet members do not seek a revision of the Directive, but out of pragmatism, look ahead to future developments and what these might mean for Europe’s manufacturing employers.

2015 COMPETITIVE INDUSTRY

Position on Transatlantic Trade & Investment Partnership

Ceemet calls for the swift delivery of a sustainable Transatlantic Trade & Investment Partnership (TTIP)

2015 HEALTH & SAFETY

Position on Occupational Safety & Health evaluation

Ceemet outlines in this position paper its priority policy recommendations regarding the new EU Strategic Framework on Health and Safety at Work 2014-2020 and the Commission’s ongoing evaluation of all existing EU occupational safety and health (OSH) legislation.

2014 COMPETITIVE INDUSTRY

Comment on Juncker Plan of a €300 bn investment package

Commission President Juncker’s planned a €300 bn investment package to support achieving the new commission priorities for jobs, investment and growth. The package will be key to strengthening Europe’s competitiveness. There is now a consensus that Europe needs a new model of growth, with a more sustainable balance between consumption and industrial production. This better balanced and lasting growth must be underpinned by industry and will rely on innovation, trade and, crucially, investment which cannot any longer be based on increasing debt.

2014 HEALTH & SAFETY

Reply to consultation on Working Time Directive

Ceemet has chosen to not comment in detail on the transposition and implementation of the Directive at Member State level. Instead, Ceemets views concern issues that are related to the EU Directive and not to national transposition and are set out in the response to question five.

2014 COMPETITIVE INDUSTRY

Comment to Commission's CSR strategy

The Commission launched a public consultation on the implementation of its Corporate Social Responsability (CSR) policy. Ceemet responds to respond to the consultation by commenting and assessing the Commission’s CSR strategy and the followed actions.

2014 EMPLOYMENT | LABOUR MARKETS

Position on Commission's proposal for IORP II Directive

The Commission’s proposal to revise the activities and supervision of Institutions for Occupational Retirement Provision (IORP) is overly burdensome for employers and with no real benefits for employees.

2014 HEALTH & SAFETY

Position on Mental Health at the Work Place

Employers in the Metal, Engineering and Technology based industry (MET) sector understand how Occupational Safety and Health (OSH) concerns can be multifactorial, impacted by both work and non-work contributory factors. Workplace mental health which includes psycho-social risks is one example.

2014 HEALTH & SAFETY

Letter to Commissioner Andór on upcoming OSH Communication

Ceemet believes that any Occupational Safety & Health strategy should be postponed until the Commission completes its evaluation and review of the existing OSH legislation.

2014 COMPETITIVE INDUSTRY

Statement to EU Council highlighting industrial competitiveness

Ahead of the meeting with Heads of State and Government, Ceemet expresses its support for the ambitious "Mission Growth" goal of bringing industry's contribution to GDP to 20% by 2020.

2014 HEALTH & SAFETY

Advocating a universal approach to chemicals at EU level

It is essential that EU policy makers adopt a universal and holistic approach to the management of chemicals. This means coordinating the interaction between requirements for the environment, health and safety, major hazards, storage, use and transportation.

2013 EMPLOYMENT | LABOUR MARKETS

Commenting the Social Dimension of the Economic and Monetary Union

The Commission published its Communication on the Social Dimension of the Economic and Monetary Union (EMU) aiming to deepen social integration of the EMU. It makes a link between the economic and labour market reforms and “the social implications of these reforms that are necessary to boost jobs, growth and enhance competitiveness”. But it are Member States that are responsible for the running and financial sustainability of their chosen social policy models.

2013 EDUCATION & TRAINING

Reinvent education with industry - position on the “Rethinking Education" Communication

Ceemet welcomes Commission ́s renewed efforts to speed up and catalyze education reform, but stresses the need to properly involve industry representatives and warns against oversimplifying benefits of dual systems.

2013 EMPLOYMENT | LABOUR MARKETS

Comments on proposal to oblige companies to disclose non-financial Information in their annual reporting

The Commission’s new proposal to review the accounting Directives (78/660/EEC & 83/349/EEC) regarding disclosure of non-financial and diversity information by certain large companies and groups is counterproductive. The initial definition and the essence of corporate social responsibility (CSR) is its voluntary nature. Therefore, an obligation for disclosure of non- financial information is in contrast to the spirit of CSR.

2013 HEALTH & SAFETY

Reply to consultation on EU Occupational Safety & Health Policy Framework

Ceemet welcomes the opportunity to put forward the Metal, Engineering & Technology-based (MET) industries' views on the 2007-2012 EU OSH strategy and future direction.

2013 SOCIAL PARTNERS

EU Alliance for Apprenticeships - focus on VET excellence say social partners

Ceemet & industriAll Europe welcome the Commissions renewed efforts to speed up and facilitate education reform, but stress the need to properly involve sectoral and local level social partners and caution against oversimplifying benefits of dual systems.

2013 JOINT POSITIONS

Ceemet & ORGALIME statement ahead of EU Council

The EU Council is set to pave the way on how to move forward to achieve the 20% of GDP industrial share target, proclaimed by the Commission Communication “A Stronger European Industry for Growth and Economic Recovery”. Ceemet and ORGALIME refer to its joint Manifesto to achieve the objectives.

2013 JOINT POSITIONS

Industry statement on EMF transposition

In connection with the Trialogue process underway, a broad industry alliance wishes to present our view relating to the transposition date of the new ElectroMagnetic Fields (EMF) Directive.

2013 SOCIAL PARTNERS

EU interference in wage setting is not supported by Ceemet, ECEG, EURATEX & industriAll

EU interference in wage setting lacks legal basis, ignores social partners’ autonomy and is opposite of what industry needs to bring Europe out of the crisis. The EU must rather look more into aspects of improving international competitiveness of manufacturing industry and do so with an improved, transparent procedure of social partner involvement, in particular from the sector level. IndustriAll Europe, Ceemet, ECEG and EURATEX are the EU recognised social partner organisations for their respective sectors.

2013 EDUCATION & TRAINING

The importance of Continuing Education & Training in MET industry

While much of the discussion on Continuing Education & Training (CET) centers on increasing uptake, Ceemet would like the debate to focus more on the impact of CET. The Metal, Engineering and Technology-based (MET) industry is a key driver of Europe’s economy and skilled and motivated people are pivotal in keeping manufacturing innovative and competitive. It is therefore absolutely essential that CET supports growth and jobs. It will only do so if better understood and targeted to the needs of the labour market and learners.

2013 COMPETITIVE INDUSTRY

Position on the General Data Protection Regulation

Ceemet welcomes the aim of the General Data Protection Regulation (GDPR) initiative to uniform rules on data protection throughout Europe, in order to ensure a high degree of data protection for individuals and overcome barriers to the movement of personal data. However, the overly detailed employer obligations will create more administrative burden and compliance costs for companies without a proportionate privacy benefit.

2013 JOINT POSITIONS

Joint industry statement on Electromagnetic fields Directive

This statement on the proposed revision of the Electromagnetic fields (EMF) Directive is presented by the following bodies representing industries that will be impacted by the requirements of the revised EMF Directive: ACEA (automobile manufacturers), BNE (broadcasting), Ceemet (manufacturing), CLEPA (automotive suppliers), ENTSO-E (electricity transmission), EURELECTRIC (electricity), Euro Chlor (chlorine production), EBU (broadcasting), EWA (welding), ORGALIME (mechanical, electrical, electronic and metallic engineering).

2012 EMPLOYMENT | LABOUR MARKETS

Reply to consultation on Transnational Company Agreements

Ceemet replied to the Commission staff working document and consultation on “Transnational company agreements: realising the potential of social dialogue”. An exchange of experience among companies with Transnational Company Agreements (TCA) could be useful to support those companies who are interested in these agreements in addition to Commission support in maintaining the existing database, which is a good tool.

2012 EMPLOYMENT | LABOUR MARKETS

Position: New EU Economic governance is importance but no intervention in wage setting

Ceemet underlines the importance of the EU’s Europe 2020 strategy and new Economic Governance in restoring international competitiveness and economic growth in Europe. However, Metal, Engineering & Technology-based (MET) industrie representative insists though that the European institutions must respect the autonomy of social partners / employers and workers and does not intervene with wage setting at any level.

2012 SOCIAL PARTNERS

Ceemet, ECEG & indistriAll publish joined view on Institutions for Occupational Retirement Provision

Revision of Institutions for Occupational Retirement Provision (IORP) Directive must not lead to higher costs and shrinking occupational pensions. Ceemet, ECEG and industriAll Europe publish a joint statement on the planned initiative on IORP within the context of the White Paper on “an agenda for adequate, safe and sustainable pensions”. All three believe that it is unnecessary to change the regulation.

2012 HEALTH & SAFETY

Position on Commission proposal to amend the Electromagnetic fields Directive

Ceemet has been following closely the ongoing work concerning a review of the electromagnetic fields (EMF) Directive, in order to make it proportionate and workable. Whereas some progress has been achieved over the last few months, the Metal, Engineering and Technology-based (MET) industry employers consider that there is still room for improvement in the body of the Directive as well as in the exposure limitation system as defined in the annexes.

2012 EMPLOYMENT | LABOUR MARKETS

Comment on EP draft report on information & consultation of workers and restructuring

Ceemet has learned that the European Parliament is discussing a possible resolution under article 225 TFEU, recommending that the Commission should propose a directive on “Information and consultation of workers, anticipation and management of restructuring”. Therefore, Ceemet is deeply concerned by both the procedure of the Parliament with regard to the proposal and the contents of the proposal itself.

2012 EMPLOYMENT | LABOUR MARKETS

Reply to consultation on gender balance in corporate boards in the EU

In its reply, Ceemet stated that it does not support a quota for women in boards and believes in a voluntary company code of conduct/ agreements concerning gender balance in corporate boards. Member States could do much more to enable the natural evolution of increase in women participation in the labour market, certain industry sectors such as Metal, Engineering and Technology-based (MET) industries and finally increased presence in corporate board.

2012 JOINT POSITIONS

Ceemet, ECEG and EURATEX joint statement on Green Paper on Restructuring

Employers organisations Ceemet, ECEG and EURATEX welcome the positive overall approach of the Commission to the necessity of restructuring for companies to be able to adapt to continuous change in the economy and society.

2012 EMPLOYMENT | LABOUR MARKETS

View on on Commission White Paper “An Agenda for Adequate, Safe and Sustainable Pensions”

Concerns reflected in the White Paper are broadly shared across Europe. Ceemet agrees that well-functioning pension systems are extremely important to the stability of public finances and that pension reforms may be necessary. However Ceemet does not support all the solutions outlined by the European Commission and strongly questions the initiatives in the field of occupational pensions announced in the White Paper.

2012 EMPLOYMENT | LABOUR MARKETS

Comment on the 'Employment Package' of the Commission

Employment policies are essential to support growth. Ceemet welcomes the employment package as it acknowledges the necessity to promote enabling conditions for job creation. The European Commission rightly highlights the need for labour market reforms to adapt to longer-term structural transformations affecting Europe's relative competitiveness in the global economy.

2012 EMPLOYMENT | LABOUR MARKETS

Response to the Commission Green Paper on Restructuring

Against the background of the importance of the topic Ceemet welcomes the opportunity given with the Green paper on “Restructuring and anticipation: what lessons from recent experience” to share its views on some of the questions raised in the latter. In its response Ceemet will comment primarily on issues which are of particular importance for the Metal, Engineering and Technology-based (MET) industries.

2012 EMPLOYMENT | LABOUR MARKETS

Comment on EU’s Smart Regulation agenda

2012 provides a unique opportunity for the EU to raise the ambition of its Smart Regulation agenda and better align it with the overriding imperative of driving stronger economic growth. Ceemet strongly supports the EU’s Smart Regulation agenda. In these challenging economic times, Europe needs to send out a clear message that it is open for business.

2011 JOINT POSITIONS

EU industry joint statement on Electromagnetic fields Directive

After several years of extensive consultation with stakeholders and Member States, while it still includes areas which present problems for different sectors of industry, some good progress had been achieved with the Commission’s proposal of 14 June. This is notably in terms of simplification and additional flexibility, which should be retained.

2011 EMPLOYMENT | LABOUR MARKETS

Position on draft conclusions on Transnational Corporate Agreements

Ceemet welcomes the Commission initiative to exchange information and views related to the relatively recent phenomenon of Transnational Corporate Agreements (TCAs), with different stakeholders and interested parties. However, it feels that the draft working paper presented by the Commission fails to reflect the fact that no common understanding of a TCA has so far existed.

2011 HEALTH & SAFETY

Views on the Council Presidency compromise proposal on the Electromagnetic fields Directive

While some of the changes in the Presidency Compromise Proposal are welcome, Ceemet believes that it does not solve the remaining issues in the Commission’s proposal (compliance with non-measurable values). It would complicate further the situation for Metal, Engineering and Technology-based (MET) companies by removing the relative flexibility that is provided in the commission’s proposal with the distinction of health and safety effects especially when it applies to low frequency range.

2011 HEALTH & SAFETY

Position on a proposal for a Directive on Electromagnetic fields

Over the past years, Ceemet has been preparing for a review of the Electromagnetic fields (EMF) Directive, in order to make it proportionate and simple. Whereas some progress has been achieved, we are still concerned that the proposed Directive may unintentionally prohibit processes that do not cause adverse physical effects. The Directive has to be workable.

2011 EDUCATION & TRAINING

Views on the modernisation of Higher Education

In the context of a globalized economy, there is consensus on the fact that only high value-added business strategies based on high value-added products, services and solutions are sustainable for European industry. Against this background, the importance of the education sector and the Higher Education (HE) sector in particular for a robust, sustainable industry must not be underestimated.

2011 JOINT POSITIONS

Joint letter to Koos Richelle (DG EMPL) on Electromagnetic fields proposal

Ceemet and Orgalime wrote to DG EMPL Director General Koos Richelle in the context of the possible adoption -in the near future- of the draft proposal for a revised directive on protecting workers' from exposure to electromagnetic fields (EMF).

2011 EMPLOYMENT | LABOUR MARKETS

Reply to 2nd consultation on Working Time Directive

Ceemet replied that a revision of the Directive was not desirable as it would risk undermining the balance and solutions found at national and local level notably through collective agreements. It is at national level that efforts need to be made to allow the optimal utilisation of the potential flexibility that exists in the Directive and to leave to social partners the necessary room for manoeuvre to combine companies’ and employees’ needs for flexibility in working time organisation. After closing the first stage consultation, the Commission concluded that a revision was unavoidable.

2011 COMPETITIVE INDUSTRY

View on Commission's Single Market Act

The Commission Communication with 50 proposal aims to relaunch the single market and make full use of its potential. Ceemet is convinced that the European Single Market is a success story that must be supported by all actors.

2011 EDUCATION & TRAINING

Position on an 'Agenda for new skills and jobs'

The Commission launched the flagship initiative by setting out 13 key actions aimed at reforming labour markets, upgrading skills and matching them with market demand. Ceemet welcomes the target to achieve by 2020 an employment rate for women and men of 75 % for the 20-64 years age group and agrees that the fact that the New Skills and Jobs Agenda reiterates the importance of strengthening flexicurity policies, recognises their positive effects during the crisis and proposes reinforcing its four components.

2010 EDUCATION & TRAINING

Position on skills shortages in the MET sector

Skills shortages can be overcome by a joint effort. All stakeholders should together do its fair share to close the skills gap an keep Europe's industry competitive.

2010 EDUCATION & TRAINING

Response to Communication on a new impetus for European cooperation in VET to support the Europe 2020 Strategy

Ceemet welcomes the overall positive messages regarding Vocational Education & Training (VET) included in the communication on “A new impetus for European cooperation in Vocational Education and Training to support the Europe 2020 Strategy”. While the European Commission acknowledges the role it can play in facilitating cooperation and encouraging modernisation and greater uptake of VET (both iVET and CVET), it also rightly underlines that this role is mainly to support and supplement the work of national governments and stakeholders.

2010 HEALTH & SAFETY

Position for a holistic approach of EU Health and Safety legislation

Ceemet is committed to improving the management of risks to health and safety and so further protecting employees from harm. Not only is it morally the right thing to do, but it also represents good business. Ceemet fully recognise the responsibility of employers to provide safe working conditions and protect their employees from harm. Action taken by employers over the years has greatly reduced accident and ill health rates in manufacturing industry. With its members, Ceemet is committed to promoting further improvement.

2010 HEALTH & SAFETY

Reply to 2nd stage consultation on the Electromagnetic fields Directive

Ceemet welcomes the European Commission’s consultation and its willingness to look again at a wide range of issues in the original directive that created serious problems for industry. These need to be fully addressed to result in proportionate and efficient protection.

2010 EMPLOYMENT | LABOUR MARKETS

Reply to 1st phase consultation of the Working Time Directive

Acknowledging that fundamental changes have occurred in the world of work over the last 20 years, the Commission has invited the social partners to reflect broadly on the kind of working time regulation the EU will need in order to cope with the challenges of the 21st century.

2009 EDUCATION & TRAINING

Reply to Green paper "Promoting the learning mobility of young people"

For companies it is essential to have a highly skilled, committed and adaptable workforce. Against this background, Ceemet sees in “learning mobility” an important tool contributing to: the preparation for mobility of workers and the development of important soft skills (language, culture, adaptability) which are important in a globalised, technologically fast-paced industry.

2009 HEALTH & SAFETY

Position on the proposal for a Directive amending Council Directive 92/85/eec on the safety and health at work of pregnant workers

Ceemet is committed to the overall goals of the proposal. However, the employers consider that the changes set out in the Commission’s proposal would have an adverse impact on many European companies, without necessarily improving the reconciliation of professional, private and family life for pregnant and breastfeeding women. This is because the Commission’s proposed changes to the duration of maternity leave, when this leave can be taken and the level of maternity pay as well as changes to associated employment rights will result in increased costs and administrative burdens for many European employers.

2009 HEALTH & SAFETY

Reply to 1st phase consultation on review of Electromagnetic fields Directive

The Directive 2004/40/EC on the minimum health and safety requirements regarding the exposure of workers to the risks arising from physical agents (electromagnetic fields) was ill conceived and would have had unintended adverse effects on our sector. Therefore Ceemet welcomes the review of the Directive and hope it will address the Metal, Engineering and Technology-based (MET) industries' concerns.

2009 HEALTH & SAFETY

Position regarding possible options for a forthcoming Commission initiative on musculoskeletal disorders

Simplification of EU legislation as part of the “better regulation” agenda is a necessity. However, merging two directives into one does not necessarily imply real simplification or improvement of legislation. In Ceemet's view, simplification should lead to coherent and accurate legislation which is easier to understand and to implement.

2008 SOCIAL PARTNERS

Reply to consultation of Commission Communication on Social Dialogue

Dialogue between the social partners at sector level can contribute to improving the economic and business environment that supports the development of competitive and profitable companies in the best possible way, thus also helping to promote sustainable employment and conditions in the industry sector. Ceemet therefore finds it unacceptable and irrelevant that the Consultation on European sector social dialogue was open to the general public and not exclusively addressed to the parties involved, i.e. the social partner organisations.

2007 EMPLOYMENT | LABOUR MARKETS

Position on the Commission Communication “Towards Common Principles of Flexicurity: more and better jobs through flexibility and security"

Ceemet welcomes the statement in the Commission’s Communication that the focus should shift from job security to employment security and that a better balance between rights and responsibilities is needed. However, the Flexicurity debate will only have a very limited effect if it is simply reduced to a discussion on the right balance between flexibility and security, between costs and benefits as well as between rights and obligations. Employment and working conditions always represent, to a certain extent, a point of balance resulting from discussions and negotiations between stakeholders.

2007 JOINT POSITIONS

Ceemet & Orgalime position on the Electromagnetic Fields Directive

Ceemet & Orgalime are seeking a complete review of the European Physical Agents Directive on Electromagnetic Fields (EMF), in line with the agenda for better regulation in Europe. both associations are not aware of any evidence base to confirm that exposure to EMF, at the levels likely to be associated with non-specialist working environments, causes harm to people. Therefore additional legislation to control exposure is unnecessary.

2007 EMPLOYMENT | LABOUR MARKETS

Reply to Green paper"Modernising labour law to meet the challenges of the 21st century"

Ceemet welcomes the launch of a debate on the modernisation of labour law to meet the challenges of the 21st century. According to the Commission, the Green Paper “looks at the role labour law might play in advancing a “flexicurity” agenda”. Labour law has traditionally been aimed at protecting employees and, in general, contributes to considerable “security” of employment. Reading the Green Paper, Ceemet has the impression that the broad concept of “flexicurity” is still overemphasizing “security”-related aspects to the detriment of the “flexibility” approach.

2007 EDUCATION & TRAINING

Reply to consultation on establishing a "European Credit system for Vocational Education and Training”

Ceemet supports the objectives of enhanced mobility and improved transparency of qualifications and welcomes a concept promoting the “learning outcomes” approach as described in the consultation document. However considering the number of questions raised by the concrete implementation of European Credit system for Vocational Education and Training” (ECVET), Ceemet believes it is crucial that beforehand pilot projects and studies on ECVET are conducted and that their results are accessible and thoroughly discussed.

2007 EDUCATION & TRAINING

Position on the proposal for European Qualifications Framework for lifelong learning

Ceemet welcomes the main goals of the European Qualifications Framework (EQF), namely a greater transparency and improved comparability of the qualifications in the different European vocational and higher education systems. However, Ceemet would like to underline that the EQF can only be of indicative and voluntary nature.

2006 SOCIAL PARTNERS

Position on the announced initiative on a "Optional framework for transnational collective bargaining"

Ceemet considers that the trend towards more flexibility in and the greater decentralisation of collective bargaining arrangements that are now evident in many EU Member States is in sharp contrast to the Commission’s idea of establishing a framework for transnational collective bargaining. In the important area of collective bargaining, which is the core activity of many of our national member organisations and which reflects their different industrial relations histories and cultures, particularly in the enlarged European Union, such an intervention would be totally inappropriate.

2006 COMPETITIVE INDUSTRY

Position on Communication on “Implementing the Community Lisbon Programme”

Ceemet welcomes the Commission Communication “Implementing the Community Lisbon Programme: a policy Framework to strengthen EU manufacturing - towards a more integrated approach for industrial policy”. Industrial policy does not normally fall within the remit of Ceemet. However, since several topics in the Communication refer to social policy related issues, Ceemet feels that it should respond to this Communication focusing only on initiatives announced by the Commission which have a link with social matters.

2005 EDUCATION & TRAINING

Position on consultation on European Qualifications Framework for lifelong learning

Ceemet wonders if there is truly a need for an European Qualifications Framework (EQF) for lifelong learning. For companies, it is the transparency and the comparability of occupational qualifications of employees which are more important.

2005 EMPLOYMENT | LABOUR MARKETS

Position on the Communication on role of the EU in anticipating and accompanying restructuring

Ceemet welcomes the generally positive introduction of the Communication that it is vital for companies to adapt to change. And although it is necessary to accompany these changes in such a way as to ensure that their effects on employment and working conditions are as short-lived an limited as possible, Ceemet does not fully support the measures that are being proposed by the Commission to achieve this objective.

2005 EMPLOYMENT | LABOUR MARKETS

Position on Communication on 'Social Agenda'

Ceemet welcomes the fact that the Commission reaffirms that the sustainable development of Europe is based on “balanced economic growth” which is thus, and Metal, Engingeering and Technology-based (MET) industry employers are sharing this finding, a precondition for “full employment and social progress”. However, in Ceemet’s view, the Social Agenda is very wide-ranging and to a certain extent contradictory. Although we share most of the goals of the Commission, we do not share its ideas of how best to achieve these.

2005 JOINT POSITIONS

Ceemet & Orgalime proposed amendments on "Optical Radiations" for the European Parliament

Employers’ organisations in Europe recognize that good health and safety management is an essential feature of profitable and sustainable businesses, but the dossier on the minimum health and safety requirements regarding the exposure of workers to the risks arising from physical agents is at odds with the Commission's better regulation principles. Ceemet and Orgalime believe that this Directive places a disproportionate administrative burden and assessment cost on companies without corresponding health benefits. This negative impact will be felt most keenly in the manufacturing sector and even more disproportionately by small and medium sized enterprises.

2004 SOCIAL PARTNERS

Position on Communication on "Enhancing the contribution of European social dialogue"

Ceemet acknowledges that the ”Partnership for change in an enlarged Europe - Enhancing the contribution of European social dialogue” demonstrates the importance that the Commission attributes both to the enlarged European Union and to social dialogue at Community level. An autonomous dialogue in the appropriate form between the social partners at inter-professional and sector level can contribute to creating a more favourable economic climate and therefore help to improve competitiveness, innovation and growth. This can then lead to improved employment opportunities and enhanced social cohesion.

2004 COMPETITIVE INDUSTRY

Reaction to the Kok II Report "Facing The Challenge - The Lisbon Strategy for growth and employment"

The Kok II Report rightly stresses that the disappointing delivery of the European Union and, in particular of the EU Member States to the Lisbon Agenda is due to an overloaded agenda, poor coordination and conflicting priorities. Therefore, the second Kok report concentrates on measures to increase economic growth in the European Union which has become even more urgent because, since the Lisbon Agenda was formulated in March 2000, the general economic situation in the European Union has clearly deteriorated. Ceemet supports the idea of national action plans, although it is not convinced that the Commission's annual reports will have the desired impact.

2004 JOINT POSITIONS

Ceemet & Orgalime comments & proposed amendments on "Optical Radiations"

Unlike for electromagnetic fields, there is no scientific uncertainty with regard to the risks for the eye or the skin that derive from exposure to optical radiations. Therefore, the risk assessment is carried out without incorporating additional safety margins by measure of precaution, just as for assessing the risk to have one’s hand cut by a knife, given its sharpness and applied pressure. The manufacturer of a machine tool that emits optical radiation already carries out an adequate risk assessment, which takes into consideration the realistic conditions of use and foreseeable misuse of such a machine by the operator, or make use of existing standards. Ceemet & Orgalime believe that the necessary safety and protective devices and training are provided .

2004 EMPLOYMENT | LABOUR MARKETS

Position on aspects of the Communication on the organisation of Working Time

Ceemet expresses its strong support for the UNICE position paper of 4 March 2004 on the Commission’s Communication on the review of the Working Time Directive. Ceemet argues that a range of national and European legislation already protects the health of safety of workers to a high degree and that any new legislation should not introduce new rigidities or administrative burdens, especially for SMEs. Also, the current text of the Directive is already quite detailed and sometimes unduly and unnecessarily confusing, thus leading to some legal uncertainty .

2004 JOINT POSITIONS

Ceemet & Orgalime comments & amendments to MEP Perez-Alvarez draft report on the exposure to risks from physical agents

Ceemet & Orgalime would like to share their concerns with the members of the European Parliament and suggest some improvements to the Council common position. These comments take into account the amendments proposed by the Rapporteur, Mr. Perez-Alvarez, in his report of 3 February 2004, which was tabled for the Employment Committee meeting of 17 February 2004.

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