UEAPME position paper on the proposal amending Directive 2005/36/EC on the recognition of professional qualifications
15 May 2012
The European Association of Craft, Small and Medium-Sized Enterprises (UEAPME) published its position on the proposal amending Directive 2005/36/EC on the recognition of professional qualifications and Regulation on administrative cooperation through the IMI System COM (2011) 883/2.
UEAPME would like to recall the reasons why the Directive is of paramount importance for its members. Professional qualifications constitute the basis of activities provided by crafts, trades and SMEs. They serve as the best proof for the competences of the professional concerned and at the same time guarantee the quality and security for goods and services provided to consumers.
The recognition of qualifications supports the fundamental freedom of service provisions and establishment in the European Union. It should ensure the good functioning of the Internal Market and facilitate the mobility of professionals in view of a better matching of supply and demand on the labour markets in Europe.
Against this background, UEAPME is fundamentally in favour of simplification and modernisation of the Directive as long as it respects a number of key principles:
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the requirement of high quality education and training;
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the guarantee of fair competition between all professionals;
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the freedom for Member States to regulate professions;
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the assurance of quality and security for consumers.
UEAPME opinion on the amendments to the Directive as proposed by the European Commission in December 2011
UEAPME can generally support:
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the proposal on the introduction of a European professional card;
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the proposal for improving the Directive in terms of advanced administrative cooperation through the compulsory use of the IMI system;
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the modernisation of Annex IV covering most of the crafts professions while respecting certain conditions.
UEAPME has a number of concerns with the following elements of the new Commission’s proposal:
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In the case of free provision of services:
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regarding professions with health and safety implications, the removal of the possibility for Member States to prior check the qualifications and to set up possible compensation measures as well as introducing a new obligation to justify the list of professions concerned by article 7&4;
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the deletion of the two years of professional practice when a service provider is accompanying the service recipient.
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The changes introduced in the mechanism for recognition of professional qualifications defined in Article 13 of Directive 2005/36/EC.
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The introduction of the recognition of the new concept of partial access to the professions.
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The inclusion of remunerated traineeships.
Full Position Paper
© UEAPME
