Consultation: General Block Exemption Regulation

NWDA Response

1. There should be a block exemption for not for profit social enterprises which are expected to become self sustaining in the future

2. There should be a "substantial effect on trade" test incorporated into the preamble

3. EC should extend the R&D block exemption to Innovation

4. The SME block exemption should be extended to large companies who sub-contract all or substantial sections of the project to SME's

5. The training aid threshold for EU notification should be increased with corresponding reduction in intervention rates for large companies

6. There should be a block exemption for culture, tourism, sport and film which goes beyond the Ecomusee de Alsace line of cases in that it covers recipients who attract  EU visitors but on a not for profit, educational or research basis

7. Training aid block exemption should be extended to trainers as well as trainees, particularly where former are not procured. It should also be extended to "training capital" eg bricks and mortars of vocational centres and creation of training curriculum in FE colleges

8. Further clarification is needed on the practicalilities (eg the sort of documents or evidence needed) to prove incentive effect and verify the same. Would OFFPAT appraisal processes suffice ?

9. There should be a block exemption where an intermediary body sub-contracts 100% of the project less its own expenses and profit margin (independantly market valued) to third parties on an entirely procured basis.

10. There should be a general block exemption for smaller incubation schemes