On 11 July, Ceemet issued its position paper on the Commission’s initiatives to improve the quality of traineeships in the EU.
On the proposed Directive, Ceemet calls for the limitation of the scope and believes that traineeships that are part of formal education and training programmes as well as traineeships that are mandatory part of professional training to access certain professions should be excluded from the Directive.
Moreover, we think that the wording of the definitions is too broad and vague and that this can result in legal uncertainty. It is crucial to consider the different national situations when it comes to the practices that are regarded as traineeships and specify which categories are covered by the definition of a “trainee”.
Generally, in the view of Ceemet, the EU binding instrument such as a Directive is not an appropriate legal instrument to regulate the topic of traineeships. With respect to the principle of subsidiarity, the legal aspects of traineeships should be addressed at the national level taking into account the divergencies of national regulatory systems.
On the proposed Recommendation to enhance the quality of traineeships, we also consider that the scope should be limited only to traineeships that are part of active labour market policies and open labour market traineeships. As regards the other provisions in the recommendation, many of them would be advantageous for the trainee but are not feasible nor realistic for SMEs that would not be able to apply them due to the very nature of the company. For example, companies are asked to designate a mentor and supervisor, to consult the trainee when setting specific learning and training objectives etc. We believe that the vast majority of SMEs are not in a position to comply with these requests and against this background, we fear that the recommendation may end up discouraging companies from providing quality traineeships to the detriment of young people.