Digest No. 13 · 8 May 2026
The Table, No. 13: A threshold that makes room for small traders
This week, Reseated put a practical question to the European Commission: can a threshold designed for smaller traders offer a useful model for other rules?
From the Secretariat
Dear members and readers,
This week’s work brought together three parts of Reseated’s purpose: putting a small-business concern into a formal letter, gathering evidence across councils, and opening a practical way for businesses to make commitments through the pledge program. The common question is how rules and expectations meet the realities of running a small business—with limited time, staff and room for avoidable complexity.
We are grateful to everyone who has filed a report, contributed to a council, or helped make the Assembly’s work possible. The figures below describe our position as of 8 May. They are a record of participation, not a claim that every member or business faces the same conditions.
The week at the table
The lead document this week is RC/TR/2026/21, a 6 May letter to the European Commission’s Directorate-General for Taxation and Customs Union (DG TAXUD). It considers the Carbon Border Adjustment Mechanism’s 50-tonne threshold as a model for small traders.
The letter brings a focused question to a public institution: when a rule includes a threshold that takes account of scale, can that design offer lessons for other requirements affecting small traders? The point is not that every policy can use the same number or exemption. It is that the design of a rule can matter as much as its stated purpose. Thresholds, reporting expectations and implementation details can determine whether a requirement is workable for a smaller operator.
That is the kind of question Reseated aims to make legible. A concern raised by individual businesses can be compared across reports, examined for a recurring pattern and then expressed in a form that a decision-maker can consider. This letter is one step in that process: a council document directed to the public body with responsibility for the relevant area. It should not be read as a response from the Commission or as a change to the underlying rules.
Three evidence submissions were also issued this week: RC/TR/2026/S.2, titled “Small Traders and the CBAM Threshold”; RC/RS/2026/S.2, titled “Keeping a Small Business Open Through Disruption”; and RC/RT/2026/S.2, titled “The Cost of Repeating Business Information.” Together, they show the range of questions being gathered across Trade, Resilience and Red Tape. An evidence submission is a contribution to the record, not an adopted standard or an Assembly finding.
Another practical development came on 5 May, when the Founders Assembly adopted RC/A/2026/7, Pledge Standards for businesses. The pledge program opened the same day. The standards give businesses a way to make a public commitment within a shared framework; they do not substitute for the Assembly’s separate evidence and policy work. We will share further information about participation through Reseated’s channels.
By the numbers
As of 8 May 2026, Reseated has 620 seated members in 49 countries. Members have filed 1,549 reports from 50 countries. The difference between those country counts is intentional: members are counted by where they are seated, while reports are counted by where evidence has come from.
- Platform: 914 reports
- Cashflow: 393 reports
- Fair Play: 94 reports
- Red Tape: 63 reports
- Trade: 47 reports
- Team: 23 reports
- Resilience: 15 reports
Those seven council figures add up to 1,549. Platform and Cashflow currently account for the largest shares of the reports filed. That is a measure of what members have brought forward so far, not a measure of which pressures matter most in every country or sector. The Assembly uses reports as starting evidence for review, rather than treating report volume alone as proof of a problem.
For context, the United Nations estimates that micro, small and medium-sized enterprises make up around 90% of businesses, 60–70% of employment and about half of GDP worldwide. The International Labour Organization estimates that MSMEs account for about 70% of employment worldwide, and that around 80% operate in the informal economy. These global estimates describe the scale of the constituency; they do not replace local evidence. Sources: United Nations and International Labour Organization.
From the table
It is not a quotation or a claim about one identifiable member.
A small trader receives a request to provide information about goods moving across a border. The business has no separate compliance team. The owner handles purchasing, customer questions and the paperwork, often between other tasks. Some information is available from a supplier; some must be checked against invoices or product records. The difficulty is not necessarily understanding why a rule exists. It is working out what applies to this business, what must be reported, and whether the time needed to comply is proportionate to the scale of the trade.
A clear threshold can help answer the first question: does this requirement apply to an operation of this size? It cannot answer everything. The business may still need to understand how a threshold is measured, which records to keep, or what happens when activity changes. But a well-explained rule can prevent small operators from spending time trying to interpret obligations that were not intended for their circumstances.
This is why the Trade letter matters as a design question, not just as a request about one policy. If members’ evidence points to recurring uncertainty, the next task is to test how often it appears, how consistently it affects businesses, how widely it spreads and what corroborates it. The point of the process is to move from an individual account toward a careful, testable description—without exposing the member or overstating what one story can show.
Coming up
Reseated’s Open Tables are monthly. The next session is an opportunity for members to compare experiences, raise questions and hear how council work proceeds; session details will be shared through the usual channels. Members who cannot attend can continue to contribute through the reporting process.
The pledge program is now open following adoption of RC/A/2026/7. Businesses considering a pledge should review the standards before making a commitment, and should make only commitments they can honestly meet. The program is intended to support clear and credible practice, not to create a badge without substance.
Across the councils, submitted evidence will continue to be reviewed before any problem is described as a recurring pattern. The standing method remains: reports are assessed against Volume, Frequency, Consistency, Spread and Corroboration; a draft fix follows only when the evidence supports it; then comes public consultation, an Assembly ballot and, where adopted, letters to the people with authority to act. No future ballot or consultation date is being announced in this digest.
One thing you can do
If a requirement, transaction or routine creates a recurring burden for your business, file a report that describes the practice rather than naming a company. Include what happened, how often it happens, what time or cost it creates, and any records that help corroborate the account. Do not include confidential customer information or details that identify your business unless you have chosen to make them public.
A single report cannot establish a pattern. A clear, specific report can help the Assembly find out whether a pattern exists—and whether a practical fix is worth putting to members and the wider public.