CHAPTER 2: PRODUCTION OF IMPACT ASSESSMENTS
Impact Assessment Guidelines
6. The Third Strategic Review reaffirms
the Commission's commitment to an "integrated approach"
to impact assessments (IAs). This approach is intended to produce
a balanced assessment, taking into account the benefits and costs
of the economic, social and environmental impacts of initiatives.
All legislative proposals included in the Commission's annual
Legislative and Work Programme which are likely to have significant
impact are supposed to receive a full impact assessment.
7. In January 2009 the Commission issued
new Impact Assessment Guidelines,
designed to assist the various services in the production of IAs.
The Guidelines explain that IA is "a process that prepares
evidence for political decision-makers on the advantages and disadvantages
of possible policy options by assessing their potential impacts"
to be taken into account by the College of Commissioners when
deciding on which legislation to adopt.
8. Dr Alexander Italianer, Chair
of the Impact Assessment Board, summarised the changes:
"We introduced an explicit subsidiarity
test, if you like. Also improvement of consultation was an important
topic. And finally the services, through the guidelines, received
improved guidance on how to measure certain impacts like social
impacts, consumer impacts, impacts on small and medium-sized enterprises,
competition and so on" (Q 60).
9. As to whether the new Guidelines had
improved the quality of IAs, he suggested that the required standard
of IAs had been raised yet the rate of resubmission requests
had remained the same, and reasoned that "if the rate of
resubmissions stays the same then, mathematically speaking, the
quality of the reports should have increased, but that is nothing
more than a mathematical inference!" (Q 60).
Impact Assessment Board
10. In order to monitor the work of the
Commission services in the production of IAs, the Commission set
up in 2006 the Impact Assessment Board (IAB), operational from
2007, under the chairmanship of Dr Italianer. The IAB is
part of the Commission, but independent of the individual services
which produce both legislation and IAs. Dr Italianer explained
to us that the IAB
"is a group of high-level Commission officials
that is independent with respect to the other services. It works
directly under the authority of President Barroso. My four other
colleagues are directors and are all appointed in a personal capacity
but they come from the various strands in the Commission that
also form the various components of a typical impact assessment"
11. The IAB examines all IAs and issues
opinions on their quality, often requiring the service concerned
to resubmit an improved version. In 2008 32% of IAs required resubmission.
The Rights of Ship Passengers Regulation
|While we were conducting this inquiry, we also scrutinised a proposed Regulation on the Rights of Ship Passengers. We took this as a case study into how an impact assessment is produced and then assessed by the Impact Assessment Board.
In 2005-06, DG TREN commissioned a study on the level of protection of passenger rights in the EU maritime sector. This study identified problems with regard to passenger rights across Europe. This was particularly the case with passengers of reduced mobility (PRMs).
The Commission then launched a public consultation, and a stakeholder meeting was held. There was "virtual unanimity" concerning the need for minimum standards for the protection of passengers' rights. DG TREN then commissioned a preparatory study from PricewaterhouseCoopers. This examined the economic, social and environmental impacts of four policy options: no action, EU legislative action, national legislation and sector-specific voluntary agreements. The results of this study were fed into the impact assessment.
A draft IA was submitted to the IAB in September 2008. They found that it was "well-structured, written in a clear and non-technical language and accessible to the non-specialist reader". However, they recommended that a clearer justification was needed of the scope of the initiative and the extent to which passengers were already covered at national level. They also recommended that a more developed analysis of the various options was necessary, along with a more accurate assessment of the costs and the impact on SMEs. The draft IA was resubmitted to the Board a further two times, and finally released along with the proposal on 4 December 2008.
We asked Dr Italianer whether IAs were often resubmitted three times and he told us that it was extremely rare: "I think this has happened only in four cases in 2008 and in 2009 it never happened" (Q 58). His explanation of why this dossier was so problematic is as follows:
"One cause may be insufficient scoping
In the first instance, it was not at all clear if a certain number of the rights that were being looked at in this particular proposal were already covered by all passenger transport activities that were covered by public service obligations, so it was not even clear to which type of activities the initiative was supposed to apply. Secondly, there was a scoping issue as regards the extent to which there was cross-border activity involved because many passengers are being shipped
Then there was an issue of substance on the costs, which were not sufficiently elaborated and on which we had to come back" (Q 59).
12. We asked Dr Italianer what the
IAB does when it receives an impact assessment. He explained:
"We check whether the draft has a well-formulated,
what we call problem definition, that the objectives that are
being sought by the initiative are well-specified, that the options
that are being studied are realistic; that there is indeed a case
for EU intervention and subsidiarity is being analysed. Then our
scrutiny focuses on the measurement or the assessment of the impact
of the various options, there is comparison, and at the end of
the process there are arrangements for the monitoring and evaluation"
13. Many of our witnesses thought that
the IAB was doing a good job, although some expressed concerns
about the structure of the Board. Claudio Radaelli, Professor of
Political Science at the University of Exeter Centre for European
Governance, described it as "like a clumsy bumble bee that
should not fly according to the logic of physics, yet it flies"
(p 4). He went on to praise Dr Italianer's chairmanship
of the Board, stating that "it is hard to imagine how the
next Chair of the Board will be able to match Alexander Italianer's
skills" (p 5). This was echoed by the Government, who
argued that the "success of the IAB has, to a large extent,
been the result of the quality of its board members" (p 44).
14. Institutionally, the IAB is part of
the Commission, and its board members are drawn from the Commission
services, that is, the departments producing the impact assessments.
The Commission explained that board members must declare any conflict
of interest and that this happened on six occasions in 2008. The
resubmission rate for IAs produced by services with members on
the board was 33%, compared to 32% for those without (p 27).
Dr Italianer argued that:
"The main evidence of our independence is
the fact that the opinions that we write on the draft impact assessments
are publicly available. It is quite rare that inside a public
administration body dissenting opinions come out publicly, but
this is one of the cases where this happens" (Q 56).
15. We received evidence from several
witnesses criticising the IAB for a lack of independence. Open
Europe argued that the appointment of board members by the President
of the Commission stripped the Board "of the vital independence
it would need to seriously pick up the fight against the steady
stream of new regulations" (p 64). Business Europe also
argued in favour of an independent Board (p 58), while the
Government suggested that "a couple of non-executives could
be added to its members to reinforce its independence" (p 44).
16. Witnesses also thought that the Board
might be tasked with "assessing whether the final legislative
proposal properly [met] the results of the impact assessment"
(Malcolm Harbour, p 60), that individual stakeholders should be
able to address their opinions directly to the Board (Business
Europe, p 57), and that the opinions of the Board should be binding
(Business Europe, p 57; Open Europe, p 66).
17. On the question of whether IAB opinions
should be binding, Professor Radaelli argued that the current
system of sending draft IAs back for resubmission is "precious
learning. We may lose that kind of learning with a more adversarial
posture of the Impact Assessment Board" (Q 12). The
Government suggested that the role of the Board could be strengthened
by its commenting on the draft IAs earlier and that "when
it is unhappy with the quality of an assessment, even after revision,
this should trigger an oral procedure with the College of Commissioners"
18. We are encouraged by the apparent
success of the IAB so far. However, there are concerns that this
has been the result of the quality of its current board and that
this may not continue. Any move to increase the independence of
the IAB, for instance by including non-executives, should be done
carefully to ensure that the expertise of the Board is preserved.
19. Purely measuring resubmission rates
is not sufficient to determine the quality of impact assessments,
and an independent assessment of their conformity to the Guidelines
may be warranted.
How an Impact Assessment is produced
20. Impact Assessments are produced by
the lead service for each proposal, in consultation with the IAB
and interested parties from other services, through an impact
assessment steering group (IASG). Dr Italianer described
this as "a fairly elaborate process" (Q 58). The
Impact Assessment Guidelines recommend that the steering group
should be set up early in the legislative process. Every proposal
envisaged as forming part of the Commission Legislative and Work
Programme (CLWP) should be accompanied by a "Roadmap"
setting out the scope and methodology of the impact assessment
(or an explanation of why one is unnecessary), and addressing
issues such as timing and the composition of the steering group.
This should be done before the CLWP is produced in order to allow
the production of the IA itself in a timely fashion.
21. With regard to the involvement of
several Directorates General in the IASG, Professor Radaelli
argued that it had "made a virtue out of a vice. The vice
is the natural suspicion that each DG has for what the other DGs
are doing. The virtue is that with an impact assessment procedure
they have to speak the language of evidence-based policy"
22. The Commission places great importance
on the production of the IA by those who are also developing the
policy. Dr Italianer explained that it "is done in parallel
with the development of the proposal so there is a kind of cross-fertilisation
between the analysis and development of the proposal" (Q 58).
23. Dr Italianer was keen to stress
that "[t]he idea behind an impact assessment is that it is
an aid to decision-making although it should not replace decision-making
The objective is to give an overview of the various possible
policy options and their impact so that the decision-makers, the
policy-makers if you like, can take an informed decision"
24. On the content of the IA, Professor Radaelli
suggested that "there is little point in pushing towards
predictive impact assessments, something where everything is costed
to the last euro, because we know that regulation at the EU level
is a hypothesis
that has to be implemented by the Member
States via transposition and then via administrative action"
(Q 6). A practical example of this, in relation to the current
proposed Regulation on Biocides, was given by Steve Coldrick of
the Health and Safety Executive:
"there is a lack of transparency about how
some of their figures are estimated
[We also] have doubts
about the credibility of some of the baseline assumptions from
which cost savings are estimated
For example, cost savings
in data sharing are based on investments in animal testing of
somewhere between 7 billion and 13 billion, which
seems implausible when you consider that the total size of the
market is around 1.5-3 billion per year
although there is a mention of small and medium sized enterprises
in some policy areas and examples of individual level impacts,
there is not enough information to gain an overall picture of
how small and medium sized enterprises will be affected by all
policy areas, and so by the regulation as a whole" (Q 80).
25. Taking a wider view, the Minister
for Better Regulation, Ian Lucas MP, told us that "There
are impact assessments that have been made that have been very
helpful to us
but I do not think that all of the impact
assessments that have been made at the present time are of sufficiently
high quality" (Q 90).
Which proposals should be accompanied
by an IA?
26. The Impact Assessment Guidelines do
not define specifically which proposals are liable to an IA: this
is decided by the Secretariat General each year. However, they
do state that IA will, in general, be necessary for "all
legislative proposals of the Commission's Legislative and Work
Programme (CLWP) and for all non-CLWP legislative proposals which
have clearly identifiable economic, social and environmental impacts
and for non-legislative initiatives
IAs should also be produced for comitology measures
likely to have significant impacts.
27. Some of our witnesses claimed that
these principles were not being observed. The Government stated
that "there have been occasional examples where an impact
assessment has not accompanied a significant proposal" (p 43).
The Minister explained in his oral evidence that they were referring
in particular to a proposal on electronic VAT invoicing "that
we think is a significant proposal which could actually bring
about savings of 18 billion across the European Union"
28. Professor Radaelli said that
"[s]ome proposals that are in the annual legislative programme
escape impact assessment whilst others are added on. Thus, there
is no purpose in having some criteria that then you do not use
in real life" (Q 2). Dr Italianer defended the
performance of the Commission, claiming that "as far as I
know, the only items that escape impact assessments are those
items that are either some kind of report without any policy proposals
or that are consultative documents like Green Papers which, by
definition, are the start of the consultative process" (Q 69).
The Commission would like to see IAs performed on any proposal
with a "significant impact or that is sensitive in a political
sense" (Q 69).
29. With regard to IAs being performed
on items which were not included in the CLWP, Dr Italianer
suggested that this might be necessary "for instance in the
area of financial regulation, which is a very hot topic and which
we could not foresee when the work programme for this year was
being prepared" (Q 69). Other witnesses have criticised
the Commission for not having produced adequate IAs of proposals
arising out of the recent financial crisis (City of London Corporation,
p 58; Sharon Bowles MEP).
30. Professor Radaelli suggested
that the fault lay with the principle itself, of trying to determine
which proposals require an IA by reference to their inclusion
in the CLWP: "There is little point in doing impact assessments
of an average study, or to look in detail at costs and benefits
of pilot projects, white papers, and framework communications"
(Q 2). The need for an IA is meant to be determined according
to the principle of proportionate analysis, that is, the depth
of the assessment should reflect the significance of the proposal.
Professor Radaelli criticised the revised Impact Assessment
Guidelines on this issue:
On pages 15 and 16 they seem to argue that it
is the legal nature of the option that suggests the level or depth
of analysis, whereas proportionality should be impact driven and
cost-benefit driven. The guidelines seem to suggest that if you
have a comitology issue, then you have this kind of analysis;
if it is self-regulation, you need another type of analysisthe
legal nature of the instrument seems to dictate the depth of analysis,
which does not make much sense in an IA framework" (Q 10).
31. In their written evidence the Commission
"the need for an impact assessment on a
European initiative [cannot] be easily established on the basis
of objective ex ante (quantitative) criteria
integrated approach to impact assessment requires that even impacts
that cannot be easily quantified/monetised, or may be limited
in their total size, should nevertheless be fully considered and
analysed if they have important repercussions for specific groups,
sectors or regions" (p 24).
32. The broad consensus among our witnesses
was that IAs should be produced wherever there was likely to be
a significant impact, but they differed in the details of their
suggestions. Tina Sommer of the Federation of Small Businesses
(FSB) thought IAs should be for both legislative and non-legislative
proposals, pointing to the CE standard
on enhanced supply-chain security: "It is not a law; it is
a standard which is supposed to be voluntary but as such it does
not have an impact assessment and as such it does not measure
what it does to small business" (Q 17). She suggested
that the test should be whether there would be an impact on small
business and, if so, "we definitely need an impact assessment"
(Q 17). By contrast the British Chambers of Commerce argued
that "Impact Assessments should be targeted only at legislative
instruments: regulations and directives" (p 55). Business
Europe suggested impact assessments should be conducted on "all
initiatives, including decisions taken by comitology committees,
notices and guidelines and decisions regarding international agreements"
(p 57). The Minister hoped that the Commission would "ensure
that, in every significant case, in every proportionate case,
the assessments are made" (Q 91).
33. Of particular interest was the application
of IA to comitology proposals. Professor Radaelli suggested
that this was important because "in comitology we get a bit
closer to the specificity of the rule, the particular features
of the regulatory regime, and so on; and therefore it is easier
then to reason in terms of cost-benefit and look at who is affected
and how" (Q 2). Most witnesses, as described above,
argued that the main consideration should be the significance
of the proposal, rather than its origin. For instance, the Minister
said "I think that any significant proposal that comes forward
should be subject to impact assessment, whether it is through
the comitology process or through the Commission itself"
34. Dr Italianer referred to the
Framework Directive on Ecodesign as resulting in comitology proposals
which "have an economic impact where it would be useful to
do an impact assessment", but he warned that "it would
be going a bit too far if all comitology proposals were accompanied
by an impact assessment given their sheer number. In 2008, for
instance, we had 1,258 comitology proposals" (Q 69).
The Commission said it was "currently examining how to identify
where such proposals would benefit from impact assessment"
35. We agree that impact assessments
should be performed wherever a proposal is likely to have a significant
impact. Particularly with regard to comitology proposals, there
would be value in further work to determine which measures are,
and are not, accompanied by an impact assessment, and whether,
in practice, the selection is appropriate.
36. The 2009 Impact Assessment Guidelines
suggest Commission services should base their IAs on
"information gathered from stakeholders
(hearings, conferences), and results of consultation documents
such as Green Papers. In many cases you will have to rely on data
available at national or regional level in the Member States.
You may need the support of Member States and/or stakeholders
to identify and use these data, and you should seek this support
as early as possible."
37. The Guidelines call for Roadmaps to
be produced as soon as it seems likely an item will be included
in the Commission Legislative and Work Programme (CLWP), and "[a]s
the Roadmaps for CLWP items are published in parallel to the CLWP,
i.e. at a relatively early stage in the planning process, you
should encourage stakeholders to examine these and to give early
feedback on your plans for the IA."
38. Consultations are supposed to include
the following key elements:
- Clear, concise consultation documents
- Unambiguous questions and problems
- Consultation of all relevant target groups
- Sufficient publicity
- Sufficient time for participation: not just the
minimum eight-week period
- Published results
- Acknowledgment of responses
39. Four themes emerged in our discussion
of consultation: the deadline, publication of draft IAs, the ability
of SMEs to engage with the process and the weight given to responses
from various bodies.
40. The Minister suggested that the eight-week
consultation period "is very short
it is a very demanding
deadline for small businesses" (Q 115). The British
Chambers of Commerce suggested that the minimum period should
be extended to 12 weeks (p 56). The Commission said that
departments should extend the deadline for "complex or sensitive
proposals" (p 26), but we have not seen evidence as
to how often this actually occurs.
41. Professor Radaelli suggested
that there was a problem with the publication of the IA simultaneously
with the proposal. It was only available for consideration (beyond
the Impact Assessment Board) "when the College of Commissioners
gives the green light to a proposal" (Q 6). The Government
agreed. They argued that "there is scope for greater stakeholder
engagement with the development of impact assessments, particularly
by allowing the opportunity to comment on draft versions"
42. Open Europe and Business Europe both
argued that draft IAs should be made available, on the grounds
that this would enable interested parties to establish which stakeholders
had been consulted (Open Europe, p 65) and enable stakeholders
to address concerns directly to the Impact Assessment Board (Business
Europe, p 57).
43. However, Professor Radaelli warned
that publication of draft IAs might result in "some European
Parliament quarters representing special interests (and many pressure
groups of course) [abusing] procedures for negative political
reasons" (p 3).
44. Another common theme was the difficulty
of engaging with the consultation process, particularly for small
businesses. The FSB pointed to SMEs' "difficulty understanding
regulatory language and Euro-jargon" (p 14). Tina Sommer
of the FSB suggested that proposals themselves were "extremely
difficult to read" but that a proposal, rather than an IA,
"probably has to be in a legal language" (Q 17).
Open Europe described as "laughable" the idea that members
of the public would be able to understand an EU IA (p 65).
45. The FSB told the Committee that they
produced summaries of the consultations for the benefit of their
members and that their members were able to submit their own responses
(QQ 29, 31). But this raises a further problem for small
businesses. Dr Italianer told us that "[t]he idea is
that all relevant stakeholders are involved" in the consultation
process (Q 32) but it was not clear how feasible this was.
Tina Sommer raised a concern over the use of responses from individual
businesses and business representatives: "If an organisation
does not consult with its members, the actual small businesses,
they can say what they like. How does the Commission know that
they are really representative?" (Q 31) The new Impact
Assessment Guidelines advise that "[n]ot all interest groups
are equally able to take part in consultations or express their
views with the same force
you may need, therefore, to make
specific efforts to ensure that all relevant stakeholders are
both aware of and able to contribute to the consultation."
46. Dr Italianer told us that the
Commission "actually distinguish between two types of contributions.
One is individual contributions, and this can be an individual
SME or it can be a multi-national company, or there could be a
contribution from an organisation that claims to be representative
of a group of stakeholders, like for instance a business organisation"
and that "the only thing we require is that when in an impact
assessment the consultation is being discussed a balanced view
is given that covers all the stakeholders" (Q 72).
47. The burden of participating in consultations
was also a concern to some of our witnesses. The FSB said that
"small businesses do not have time to respond to consultations"
(p 14). In relation to regulation generally, Steve Coldrick
of the HSE argued that the provision of data is expensive and
that streamlining the process will not automatically "enable
small and medium sized enterprises to succeed in a regulated environment
that requires a lot of data" (Q 87).
48. The Government also produce impact
assessments of EU proposals, designed to assess the impact on
the UK, rather than the EU as whole. The Health and Safety Executive
has had particular problems in gathering data for the UK impact
assessment on the Biocides Regulation, which we discuss in greater
detail in paragraphs 67-70. When we asked why the consultation
had proved problematic, Robin Foster suggested that IAs might
be too "high level" for SMEs engage with, that is, they
deal with EU or UK-wide issues and do not always obviously apply
to the concerns of a particular small enterprise (Q 83).
We put this to the Minister who agreed and added that "it
is very difficult for a small business to keep abreast of what
all the proposals that are going around are from legislative bodies"
(Q 114). He went on to suggest that the SME Envoy
has an important role in helping SMEs to engage with "the
behemoth that is the European Union" (Q 115).
49. Further work could be undertaken
to establish, for a representative sample of proposals, the length
of consultation period actually applied to each proposal, at what
stage in the process it was launched, how widely it was disseminated,
how many responses were received, and from whom.
The SME Test
50. Our discussion of consultation was
focussed on the experience of small businesses, mainly because
it seems that they have more trouble engaging with the process
than larger organisations. Another aspect of the IA system relating
to small businesses is the "SME test" in which "[t]he
IA should analyse whether SMEs are disproportionately affected
or disadvantaged compared to large companies, and if so, options
should cover alternative mechanisms and flexibilities in approach
that might help SMEs to comply."
51. Dr Italianer explained that the
IAB "look at this systematically. You will also find in the
annual reports of the Board that this is one of the items that
is being looked at, but the proposals do not always lend themselves
to really single out SMEs" (Q 70).
52. The Minister thought "the fact
of the SME test is a very positive step forward. It is very early
to assess it as far as the EU is concerned" and "I cannot
come up at this stage with concrete examples of what it has been
able to achieve" (Q 112).
53. Tina Sommer of the FSB also welcomed
the introduction of the test (Q 30), but written evidence
from the BCC warned that "its effectiveness will depend on
the extent to which it is able to quantify or even identify additional
cost" (p 56).
54. We welcome the SME test, but it
is too early to assess how well it works. We recommend that the
inclusion of the test is assessed in the near future to determine
whether it adds value.
55. As part of the Better Regulation agenda,
the Commission has been pursuing a policy of reducing administrative
burdens, that is, the costs to businesses of complying with EU
information requirements. In 2007 the European Council endorsed
a target of 25% administrative burden reduction by 2012.
56. An assessment of the anticipated administrative
burden should be included in the impact assessment. The Commission
Impact Assessment Guidelines explain that
"[t]he assessment of
should begin with a full mapping of information
obligations for each of the options. This mapping should show
how policy options differ in terms of information obligations.
You should then determine which are likely to impose significant
administrative burdens (usually through a qualitative assessment
of the likely number of entities concerned as well as the frequency
and complexity of required actions)."
57. EU impact assessments are intended
to be "integrated", that is, to take into account the
likely environmental, social and economic costs and benefits.
Professor Radaelli expressed concern that the focus on administrative
burdens could undermine the "integrated" nature of IAs.
He warned that the "emphasis on administrative burdens
pushes us back to the old logic of special assessments. It disintegrates
the logic of integrated impact assessment" and risks the
creation of a "legal kebab" in which the various areas
of assessment are included separately in the IA but not considered
as a whole (p 2 and Q 4). He argued that administrative burdens
should be assessed in an IA "only when and how they are relevant
to the overall appraisal of the impact of the proposal, they are
not a separate category of costs" (p 2).
58. The Minister disagreed. "I do
not accept it. I think that administrative burden reductions are
very, very important" (Q 103). With regard to the 25%
reduction campaign, he warned that "[t]he steps forward that
the Commission have made in recent years have begun to be taken
on board by the European Parliament but perhaps less so by the
Council, and I think that the progress that the European Union
will make will be constrained by the lack of buy-in right across
the board" (Q 108).
59. Dr Italianer defended the "integrated"
nature of IAs, saying that "[w]e are generally satisfied
that [the economic, environmental and social] aspects are being
covered, although we are trying to improve the assessment of the
social and environmental impacts because this is not always easy
to quantify" (Q 62).
60. Evidence from some of the business
representatives argued that costs to businesses should be taken
more seriously in IAs. The FSB argued that "regulatory pressure
throughout the entire regulations chain should be taken into account.
This means that as well as administrative burdens there should
be attention on the compliance costs" (p 14). The British
Chambers of Commerce argued that IAs should "take into account
the cumulative burden that regulation can impose in areas like
employment" (p 55).
61. The administrative burdens campaign
is worthwhile and the inclusion of an administrative burdens section
in EU impact assessments is a positive move. We recognise that
an over-emphasis on burdens might affect the balance of an integrated
impact assessment but we have seen no evidence to suggest that
this is actually happening.
7 SEC (09) 92 Back
If the IAB is unsatisfied with the quality of an impact assessment,
it requests that the Commission service responsible resubmits
an improved version for consideration. Back
Op. Cit. p 6 Back
Op. Cit. p 8 Back
Op. Cit. p 6 Back
Measures adopted by the Commission under a power given in a legislative
act of the Council or Council and Parliament, for the purpose
of making detailed subordinate provisions. A comitology measure
is subject to scrutiny by a committee of the representatives of
the Member States. Following the coming into force of the Lisbon
Treaty "delegated legislation" is no longer subject
to a comitology procedure, but for the purpose of this report
the same considerations apply to it. Back
European Union Committee, 3rd Report (2009-10): Directive on
Alternative Investment Fund Managers (HL Paper 48), QQ 375-384 Back
The "CE" marking, which stands for "Conformité
Européenne", may be placed on products conforming
to certain standards. Back
Op. Cit. p 17 Back
Op. Cit. p 18 Back
Op. Cit. p 19 Back
Op. Cit. p. 19 Back
The SME Envoy has been appointed by the Commission to facilitate
communication between the Commission and small businesses. The
Envoy is currently Françoise Le Bail, who is also Deputy
Director-General at DG Enterprise and Industry. Back
Op. Cit. p 39 Back
Op. Cit. p 41 Back