Response from the Danish Government to the public consultation on

the Green Action Plan for SMEs

Denmark appreciates the opportunity to set forth our views on beneficialgreen support measures for SMEs as a source of inspiration for the GreenAction Plan for SMEs.Denmark recognizes the Small Business Act as a fundamental corner-stone for European SME policy and is supportive of ensuring an equallyhigh level of implementation of the ten principles within the act acrossthe Member States. This includes principle 9 regarding enabling SMEs toturn environmental challenges into opportunities. We find that a GreenAction Plan for SMEs is a constructive step towards implementing thisprinciple and ensuring the competitiveness of European SMEs in a globalcontext.Today and henceforth the industry is highly dependent on access to rawmaterials. However, the resources are scarce causing increased globalprices on resources. This makes resource efficiency a significant factorfor the competitiveness of SMEs.In order to strengthen the resource efficiency among European SMEs anambitious Green Action Plan is necessary. On these grounds, Denmarkfinds that the action plan should strive for a focus on the following meas-ures.Improve recycling of industrial wasteRecycling is a crucial element when focusing on enhancing the resourceefficiency for SMEs. It is important to ensure suitable framework condi-tions for exploring new ways of recycling as well as the right incentivesfor the industry to improve its recycling efforts. In that respect, Denmarkemphasises a need for an ambitious European recycling strategy – espe-cially regarding industrial waste. Furthermore, a recycling strategy shouldstress the need for increased upcycling of waste into new materials orproducts of better quality or of better environmental value.

Industrial symbiosisWhen aiming at enhanced resource efficiency we need to challenge ourregular mindsets. We need to think in new ways of exploiting our re-sources – including what is to be perceived as resources. Denmark high-lights the need to focus on commercial cooperation between companies,where the excess resources such as energy, water or waste from one com-pany can become a valuable input resource for another company. Indus-trial symbiosis is a way of ensuring increased competitiveness for allSMEs involved.Greening value chainsFocusing on green innovation across value chains holds a great potentialfor European economic growth and job creation, as well as addressingenvironmental challenges. SMEs often need support in establishinggreener value chains, for instance in order to fully utilize and resell scrapand waste material. It is proposed that the Commission focuses on the po-tentials for resource optimization across the value chain.Green business modelsDenmark urges the Commission to focus on creating awareness and sup-porting knowledge sharing between SMEs on the potentials within greenbusiness models, such as product-service system (also known as a func-tion-oriented business model), Cradle-to-Cradle product innovation andtake-back systems. Green business models can lower businesses’ impacton the environment while being economically viable.Green standardisationThe single market is the driver of European growth and has brought bene-fits and new opportunities to European SMEs throughout more than 20years. Lately, especially the European green industry has grown signifi-cantly – a development that is still ongoing. Denmark views the creationof a single market for green products by further development of greenstandards at EU level as a constructive way of enhancing growth in thissector.Denmark is looking forward to the launch of the Green Action Plan forSMEs and to participating in the further discussions on this importantsubject.