# EUR-Lex - 52003IE0398 - EN

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# 52003IE0398

**Opinion of the European Economic and Social Committee on "Simplification" **

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Official Journal C 133 , 06/06/2003 P. 0005 - 0012 *

Opinion of the European Economic and Social Committee on "Simplification"

(2003/C 133/02)

On 18 July 2002 the European Economic and Social Committee, acting under Rule 29(2) of its Rules of Procedure, decided to draw up an opinion on "Simplification" (Single Market Observatory).

The Section for the Single Market, Production and Consumption, which was responsible for the Committee's work on the subject, adopted its opinion on 5 March 2003. The rapporteur was Mr Simpson.

At its 398th plenary session on 26 and 27 March 2003 (meeting of 26 March), the European Economic and Social Committee adopted the following opinion with 81 votes in favour and two abstentions.

1. Introduction

1.1. When presenting the programme of the current Commission to the European Parliament in February 2000(1), President Romano Prodi identified "the promotion of new forms of governance" as one of the four strategic objectives of this Commission's term of office. This included a greater degree of openness on the part of the Commission, simplifying the body of Community law and reducing its volume, the better involvement of civil society in the legislative process and developing connectivity through networking. The objective of these measures, in toto, was to achieve better law-making. However, the Commission recognised that it could not act alone in this endeavour.

1.2. Since October 2000, the European Economic and Social Committee (EESC) has issued three Opinions(2) on the subject of simplifying and improving the regulatory environment of the European Union, reflecting the importance that it attaches to this topic. One of these Opinions(3) was prepared at the instigation of the President of the Commission, Romano Prodi. The EESC has also issued an Opinion on the Commission's 2002 Review of the Internal Market Strategy(4) that dealt, inter alia, with simplification issues and recognised their quintessential importance to the completion of a true Internal Market.

1.3. The first of these Opinions ("Simplifying Rules in the single market": rapporteur Mr Vever)(5) introduced the concept of independent impact assessments, possibly prepared by an external body, and proposed a number of specific measures. It also recommended the adoption of codes of conduct by the various players and set out a Code of Conduct for the EESC.

1.4. The second Opinion ("Simplification": rapporteur Mr Walker)(6) reiterated these proposals and made a number of additional recommendations, including giving legislative texts a finite life ("sunset" legislation), exempting SMEs from some regulations or some parts of some regulations, codifying existing legislation and speeding-up the simplification process.

1.5. In its third Opinion ("Simplifying and Improving the Regulatory Environment": rapporteur Mr Walker)(7): the EESC developed its proposal for an independent body at the European level and suggested that it might be modelled on the Office of Regulatory Affairs in the USA. It also set out an Action Plan for the Commission, the Council, the European Parliament, the EESC, the Committee of the Regions and the Member States. In addition, it proposed a number of further measures.

1.6. A synthesis of the observations and recommendations contained in these previous Opinions is contained in Appendix 1.

1.7. In addition, the EESC held a hearing on 10 September 2002, under the auspices of its Single Market Observatory, on the topic of, "Simplifying Single Market Rules - Which Priorities?"

1.7.1. The hearing concluded that, in contrast to the position in earlier years:

- simplification is now seen as a topic of interest to all groups in society;

- the broad inclusion of actors and the harnessing of different methodologies (including co- and self-regulation) is necessary to make simplification work; and

- the over-riding question now is how to put simplification into practice.

1.7.2. In connection with this hearing, the EESC sent a questionnaire to a wide range of socio-economic organisations and other single market-users. The results of this survey showed that:

- 65 % of respondents think that European legislation is unnecessarily complex;

- 60 % support the Commission's Action Plan but the other 40 % do not think that it goes far enough;

- 90 % think that national legislation is too complex and that simplification measures must be undertaken at national level if the EU simplification plan is to succeed;

- 75 % support the idea of more self-regulation or co-regulation.

1.8. The unsatisfactory nature of the present regulatory environment is widely acknowledged, not least by the Commission, which has committed itself to achieving real and lasting improvements. The EESC commends and supports this intention but considers that such a goal is beyond the reach of the Commission alone. Its realisation will require a meaningful level of commitment from the European Parliament, the Council and the Member States and the concerted efforts of all of them, acting in partnership. The Committee welcomes this further opportunity of lending its active support to such a process.

1.9. As Commissioner Bolkestein(8) has said, "Markets cannot work without rules but bad rules are a burden that we cannot afford to bear." He advocated that, "Regulation should be rolled back .... competition is our best friend .... emphasis on rules too often suffocates competition." In declaring that rules needed to be simplified as a priority he said that, "We must increase the speed of rule-making; legislation lags behind the market; we are in danger of imposing yesterday's rules on tomorrow's economy."

2. The Commission's Communication

2.1. Recently, the Commission has published a Communication to the European Parliament and the Council in four documents, which makes formal proposals for changes to the way in which the Community governs itself. The first of these documents is a summary Communication(9) reviewing the basic concepts and ideas and is supported by three other more detailed Communications(10) on particular aspects of the proposals.

2.2. The Commission has prepared these Communications in the knowledge that the simplification and better governance of the Community is, in itself, a desirable objective but that the conclusions of the Laeken Convention and the Inter-Governmental Conference (IGC), which will follow in 2004, may have further implications for governance.

2.3. These Communications have identified improvements that can and should be made within the present legislative framework without detracting from the significance of, or waiting for, the proposals that will emerge from the Convention on the Future of Europe for submission to the IGC. The Commission believes that the proposals in the Communications should come into force at the beginning of 2003(11). The Communications should be read and understood in the context of the White Paper on European Governance(12) that was published in July 2001.

2.4. That White Paper set out key assumptions about the failings and weaknesses of the present systems of governance and the need for change. These emphasised, inter alia, a lack of understanding by citizens of the working of the EU. The Commission considers that the measures now proposed are necessary to "strengthen the credibility of the Community in the eyes of its citizens(13)".

2.5. The recent Communications emphasise three approaches to improvements:

(1) an action plan(14) for the improvement of law making through the European institutions(15) and Member States by simplifying and improving the regulatory environment;

(2) improving the process of consultation through the promotion of a stronger culture of dialogue and participation by interest groups(16); and

(3) a more systematic approach to assessing the impact of initiatives(17).

2.6. The details of the Commission's proposals under these headings are summarised in Appendix 2.

3. General comments

3.1. In its previous opinions, the EESC has indicated its acceptance of the need for regulation and made plain the fact that it does not necessarily equate improving the regulatory environment with a process of deregulation. It does, however, share the Commission's concerns that poor-quality regulation is hindering economic development and undermining the quest for full employment by imposing unnecessary compliance burdens on business, and especially small businesses.

3.1.1. Frequently, poor-quality regulation also has the defect of failing to meet its regulatory objectives. Additionally, poor-quality regulations (or legislation) may mean that the Courts are asked to make an interpretation which can be an expensive process, time consuming, and may not meet the original intentions of those who developed the legislation.

3.2. As the EESC has pointed out in its Opinion on the 2002 Review of the Internal Market Strategy ("Delivering the promise")(18), poor quality regulation is costing the European Union upwards of EUR 1000 billion per annum.

3.3. It is not just businesses that suffer the negative impact of poor-quality regulation; national administrations and citizens in their daily lives are also adversely affected. These undesirable consequences stem primarily from the complexity of the regulatory environment and this, in turn, derives from two sources, which constitute separate but related simplification issues that need to be tackled in different ways.

3.3.1. The first of these stems from the obscure, convoluted and sometimes downright contradictory nature of legislative texts. This may be due on occasion to poor legal draughtsmanship in the original document, sometimes even requiring the intervention of the courts to interpret the legislators' intentions. More often, it is attributable to the piecemeal way in which a large body of European legislation has evolved, with amendments to legal texts, amendments to the amendments and legislation which is seen to be needed to meet specific circumstances being tacked on to instruments which were not conceived for that purpose in the first place.

3.3.1.1. Most often, it emanates from the amendments to the original texts that are promulgated in the European Parliament and/or the Council in an attempt to obtain sufficient consensus to ensure that the legislation is enacted. These amendments frequently have the additional effect of negating the impact assessments that were carried out in relation to the original proposals.

3.3.1.2. Another major constituent of this complexity is the sheer volume of the corpus of legislation, both at European and national levels, which makes it difficult to access for all but the most specialised legal experts.

3.3.2. The second source of complexity comes from the widespread differences in the regulatory regimes of the Member States, which have the effect of fragmenting the supposedly single market into fifteen discrete legal jurisdictions. This results:

- partly from delays by the Member States in the transposing of Community legislation into national law;

- partly from the fact that, in the process of transposition, Member States interpret the legislation in the light of their own legal customs and usage, in other words they put a national "spin" on it;

- partly from variations between Member States in the level of enforcement of enacted legislation;

- partly from the derogations and exemptions which Member States extract from the negotiating process which precedes the enactment of much Community legislation; and

- partly from the insistence by Member States on the observance of national agency regulations, established business practices and traditions which, while they may not have the force of law, are nevertheless treated as mandatory.

3.3.3. In this context, the EESC notes with regret the disappointing progress which has been made in the transposition of EU legislation into national law in the Member States(19). While transposition deficits have decreased markedly over the last ten years, this trend has been reversed in the last six months and two-thirds of Member States fail to meet the target of a deficit of 1,5 %. The majority of them will have their work cut out to meet the target of zero overdue Directives by the Spring Council meeting of 2003. Meanwhile, the number of infringement cases has increased considerably over the last ten years and there has been little progress in reducing the infringement cases involving misapplication of legislation.

3.3.4. The net effect of all this is to create distortions of competition and discourage intra-Community trade. It is virtually impossible for businesses, and especially small businesses, to understand the extent of their legal obligations when trading with a Member State in which they are not established; too often, faced with the complexities and risks involved, they simply prefer not to avail themselves of the opportunity.

3.4. The EESC has previously argued in two separate opinions(20) that the volume of direct EU legislation is relatively low. The proportion of legislation which emanates directly from the EU and directly affects individual citizens will vary from country to country. However, the vast majority of legislation is composed of a hierarchy of national laws, government ordinances, agency regulations, collectively-agreed regulations and byelaws at regional, municipal and local levels. This hierarchy is pyramidal in shape; the further down one goes, so the volume of legislation increases, the transparency diminishes and the consistency declines.

3.5. Logically, therefore, the EESC supports the thrust of the Commission proposals for a more informed decision-making process based on more rigorous preliminary assessments.

3.6. The EESC has reservations about some aspects of the processes now being introduced.

3.6.1. The introduction of the impact-assessment measures and the wider consultation network has been presented in the context of a European Union of 15 Member States. The enlargement of the EU will make these changes more wide-ranging and complex. In the early years, an expectation of simplification may be blurred by the consequence of expansion. Nevertheless, an improved understanding of the rationale of EU regulation and legislation will be just as important in the new Member States as for the present Members.

3.6.2. Similarly, there is a danger that improved decision-making at the centre of the Community may be achieved at the risk of enhancing the perception of further centralisation unless there are safeguards to ensure that the principle of subsidiarity is protected and strengthened.

3.6.3. The EESC notes that, whilst the proposed changes may codify the preparation of legislation and regulation, these changes (in themselves) do not introduce any steps to reduce the amount of, and impact of, existing legislation. Simplification through deregulation will call for other proposed actions.

3.7. The EESC is well established as a conduit between many aspects of organised civil society, the social partners and the Commission. This relationship has proved mutually beneficial to all the parties involved. The Commission has now created an enhanced mechanism for consultation and is, in part, relying on the new media/internet to facilitate this process.

3.8. To maximise the benefit to be gained, the EESC recommends that the Commission should ensure that the appropriate specialist sections of the EESC are able to draw on consultative responses to strengthen the work of the Committee in preparing its opinions for the Commission. Possibly the Parliament would wish to make a similar suggestion.

3.9. This suggestion would call for appropriate administrative arrangements and also an acknowledgement of the implications for the time-tabling of the various stages of legislative preparation.

3.10. The EESC notes that it is encouraged by the Commission to take a more proactive role(21) and signifies its willingness to do so.

3.11. The EESC welcomes the fact that the Commission has committed itself(22) to be more transparent in the way in which it exercises its right of initiative and take greater account of diversities. In particular, it welcomes the Commission's assurance(23) that it will endeavour to ensure that "the substance of its legislative proposals are restricted to the bare essentials."

3.12. The EESC would stress the need to implement the Commission's proposals within the shortest possible time-frame.

3.13. The Committee would point out that in the context of the simplification process the existing levels of European standards, including social, environmental and consumer protection, should not be lowered. These standards should not fall victim to the simplification process either through their cancellation or through any changes to them.

4. Specific comments

4.1. The EESC has consistently supported Commission proposals for wider consultation. However, the formal consultation process should not be limited to interlocutors of the Commission's own choosing. There is a need to engage all stakeholders in the process. It is important to avoid a situation where Commission proposals merely represent the shopping lists of the most influential lobby groups. The consultation process will not work unless all the actors throw their weight behind it. Small businesses and their representative organisations need to be more pro-active and put more resources into the process. Simplification will only work if it takes into account the views of those who are affected by it.

4.1.1. To ensure that the views of all the civil society players concerned are taken into consideration, it is very important not to exclude a priori specific organisations, and consequently the people whom they represent, from the Commission's consultations. In other words, consultation should not be limited solely to organisations with a European structure; otherwise, civil society bodies will not be able to make an input if there is no European umbrella organisation for their sector or if they do not belong to such an umbrella organisation. Rather, the Commission should give greater publicity to its legislative proposals and actively encourage views from all directly concerned organisations (local, regional, national and pan-European). All persons, organisations or businesses which are, or are likely to be, affected by proposed legislation have a legitimate locus in the consultation process and the right to make their voice heard.

4.1.1.1. The EESC has already recommended(24) that the consultation process should be widened by inviting submissions from all interested parties so that consultation should be effectively at the option of the consultee. It advocates that full use should be made of the Internet to provide ease of access for this purpose.

4.1.1.2. The EESC shares the Commissions concerns(25):

- to ensure the quality and particularly the equity of consultations leading up to major political proposals;

- to systematise and rationalise the wide range of consultation practices;

- to guarantee the feasibility and effectiveness of the process;

- to ensure the transparency of consultation from the point of view of the bodies or persons consulted; and

- to demonstrate accountability by making public, as far as possible, the results of the consultation and the lessons that have been learned.

4.2. The EESC accepts that a process of wider consultation may extend the time interval between the introduction of a legislative proposal and its eventual enactment but considers that time spent in ex-ante consultation is time gained, not lost, because it leads to a greater degree of consensus and wider acceptability of legislative proposals.

4.3. Presumably, it is implicit in the new system that the EESC would be consulted about the content of the main policy-impact assessments but the Committee suggests that this should be acknowledged explicitly.

4.4. The EESC reiterates its conviction that impact assessments should be prepared for all legislative proposals but, as it has already indicated(26), the impact assessments prepared by the Commission are frequently invalidated by amendments to the draft legislation that are introduced in the European Parliament or the Council. There is no point in improving the quality of Commission impact assessments, and requiring their universal application, if they are negated by subsequent amendments to the text. It is, therefore, essential that both in the Parliament and the Council, where a proposed amendment would introduce changes not covered by the impact assessment, it should be supported by an impact assessment and that these assessments should be drawn up at least to the same standards as those submitted by the Commission.

4.4.1. The EESC reiterates its position that there is a need for an independent, inter-institutional body to monitor the process of impact assessment. It also considers that this process should be based on a system of Regulatory Impact Analysis (RIA).

4.4.2. The EESC endorses the Council's recommendation that impact assessments should be made publicly available. It also welcomes the Commission's intention(27) to prepare impact assessments in line with the European sustainable development strategy.

4.5. The EESC warmly welcomes the Commission's decision(28) to add, where appropriate, a review clause, or even a revision clause, to its legislative proposals. It endorses the Commission's concern to preserve legal certainty for operators when applying this process.

4.6. In addition to widespread consultation in the formulation stage of the legislative process there is a need for systematic and formalised ex-post consultation procedures. Small businesses, in particular, are unlikely to get involved in ex-ante consultations because most of them are too concerned with their day-to-day problems to be aware of the existence of pending legislation but they will provide feedback on the impact of legislation once it has come into force; much the same applies to the smaller and less well-organised civil society bodies. This ex-post feedback should then be used to refine and improve the process of preparing subsequent impact assessments.

4.7. This year marks the tenth anniversary of the introduction of the single market and simplification has been on the European agenda for the whole of that time but there is very little evidence of any practical progress. This is particularly true in relation to the acquis communautaire, which currently runs to some 85000 pages. Much of this is of such impenetrable obscurity that it leaves many people confused and contributes in no small measure to a feeling of disenchantment with the concept of "Europe". The process of codification could reduce this text to around 22000 pages, a reduction of the order of 75 %.

4.7.1. It is regrettable that this work was not initiated in the earliest stages of the enlargement process in order to reduce the burden imposed on the candidate countries in fulfilling their obligation to adopt the acquis. The Commission needs to embark on a concerted programme of codification as a matter of urgency. As Mr Patrick Cox, the President of the European Parliament, has said(29), "We have created a legal jungle ... there is no single area of public policy which has been subjected to a single act of codification." Despite the Commission's good intentions, one is left with the impression that they are too busy adding to the acquis to have any time for codifying or simplifying it.

4.8. In the context of the single market it is preferable that European legislation should be promulgated by way of Regulations rather than Directives because the former, being binding, are not susceptible to mutation in the transposition process and therefore do not give rise to distortions in intra-Community trade, as is the case with Directives. The EESC is aware that it is frequently more difficult and protracted to secure agreement in the Council for Regulations, because of their binding nature, but considers that the measure of success is not the speed of passing legislation but its impact on the real economy. The EESC hopes that the Laeken Convention on the Future of Europe will address this issue.

4.9. The EESC is pleased to note that a rolling programme of review for simplification and the reduction in volume of the acquis is about to be launched(30) and it calls upon the Council, the European Parliament and the Member States to cooperate fully in this programme in order to deliver meaningful results within the shortest possible timescale.

4.10. In order to be effective, this programme will require the active cooperation of the Council, the European Parliament and the Member States to process the amending legislation in a timely and accurate manner. As the latest Internal Market Scoreboard shows(31), the record of the Member States in this regard does not augur well for the prospects of persuading them to cooperate effectively in a process of simplification and reform of the regulatory environment; if their performance does not improve, attempts to reduce the volume of the acquis by a process of codification or recasting of legislation are likely to worsen the situation rather than improve it.

4.11. The EESC finds it unconscionable that, on average, the elapsed time between the introduction of a legislative proposal by the Commission and its eventual incorporation in the statute books of the Member States is eight years(32). It therefore agrees with the Commission on the desirability of speeding up the process of law-making.

4.12. In its previous Opinions, the EESC has consistently stressed the need for legislation to be accessible to those whom it affects. It is therefore pleased to note the Commission's intention to improve the accessibility and transparency of Community legislation, whether in preparation or already adopted, by expanding public access to EUR-Lex(33) and exploring other options, such as Internet forums.

5. Debate in the Council of Ministers

5.1. The Commission proposals, as outlined in the four documents of the Communications, have now been considered by the Council of Ministers in the format of the Competitiveness Council(34). In a discussion and resolution on Simpler Legislation, the Council has welcomed the Action Plan, the proposals for systematic consultation of interested parties and the use from 2003 of impact assessments to be attached to all substantial regulatory proposals. The Council recommends that these impact assessments should be made publicly available.

5.2. The Council also endorsed the call for Member States to play their full parts in the processes.

5.3. Perhaps with some significance, the Council conclusions are less than explicit in reference to the actions and commitments of the Council itself. In a rather more general statement the Council states its intention to provide "fresh impetus" and requests the Permanent Representatives Committee to "give due consideration to setting up a working party on better regulation" (et al).

5.4. The Council may be understandably reluctant to comment on, or make decisions on, the current decision-making relationships between the Council and the Commission before there is greater clarity in the conclusions expected from the Convention on the Future of Europe and the following IGC.

5.5. The EESC would, however, wish to restate its support for a more streamlined executive decision-making structure within the European institutions and, in particular, improved systems within the Commission, including a strong degree of internal monitoring. The proposed Action Plan outlines possible administrative changes that would command support.

5.6. The debate on simplification of the means of governance and better regulation has moved dramatically in the past year. This momentum must be continued in the preparation and follow through to the IGC in 2004.

6. The need for Partnership Agreements

6.1. One of the reasons why there has been so little progress to date has been the failure to create partnership. What is needed are not only partnerships at the Council level, where they will be difficult to achieve, but also with the other institutions. Further agreement is needed at the administrative level within and between the institutions and the Member States to implement the principles of simplification.

6.1.1. It has to be recognised that not everyone shares the same objectives but this should not be allowed to inhibit the development of an atmosphere of trust, cooperation and mutual confidence between the various players. This spirit needs to be formalised and encapsulated in partnership agreements. The various players need to enter into commitments to consult and liaise with each other.

6.2. In order to make a positive contribution to the implementation of the process of simplifying and improving the regulatory environment, objectives which have too often been frustrated in the past by a combination of indifference and self-interest, these agreements must involve the acceptance of binding commitments by all the signatories to work actively and expeditiously for the achievement of the agreed objectives. There is a need to inculcate a culture of dialogue and participation.

7. Conclusions

7.1. The EESC wishes to stress the seriousness of the issues related to simplification, better regulation and improved governance and the importance of finding an effective solution to the identified problems in this area within the near future. It reiterates that it does not see this primarily as a deregulatory issue. The choice is not only between regulation and self-regulation but between good, harmonised regulation and poor-quality, fragmented regulation at both the European and Member State levels.

7.1.1. It is not just a question of simplification but of legislative effectiveness and legal certainty. Simplification needs to be implemented as a matter of urgency but, to be effective, it must be a continuous and permanent process and transparency is the key to its success. There is a need to engage all the stakeholders in every aspect of the process. The EESC therefore strongly supports the Commission's proposals for wider consultation; this should include ex post consultation and a preparedness to use this feedback to improve the process of preparing subsequent periodic impact assessments.

7.1.2. The EESC broadly supports the proposals contained in the Commission documents and particularly welcomes the extension of regular impact assessments to the Commission's annual work programme.

7.2. The codification of the acquis communautaire, which could bring about a dramatic reduction in its volume and a commensurate improvement in its clarity, coherence, accessibility and effectiveness, is a process that is long overdue. It should be initiated without further delay and prosecuted with determination and perseverance.

7.3. The success of the simplification initiative will depend, inter alia on the formation and execution of an effective partnership agreement between all the players involved in the legislative process at both the European and Member State levels and a resolve to use their best endeavours to achieve the stated objectives.

7.4. The EESC advocates that impact assessments should be based on a formal system of Regulatory Impact Analysis. Their preparation should be a mandatory requirement for all bodies that exercise legislative powers, whether of initiation or amendment, at both the European and Member State levels. If amendments to the draft legislation invalidate the original impact assessment, these amendments should be supported by an amended impact assessment.

7.5. The EESC applauds the Commission's resolution(35) to bring the principles of accountability, proportionality, transparency and legal certainty to bear in improving the regulatory environment. Governance which lacks these principles cannot be truly democratic. The EESC calls upon the European Parliament and the Council to commit themselves firmly in the same direction. As the Commission says(36), the achievement of better law-making is a veritable ethical requirement.

7.6. At the Lisbon Summit meeting in March 2000, the European Union adopted the mission statement, to become within ten years, the most competitive and dynamic knowledge-based economy in the world, capable of sustaining economic growth with more and better jobs and greater social cohesion. The improvement of the regulatory environment and the removal of distortions in the single market caused by differences in regulatory regimes are essential to the realisation of that ambition.

7.7. In the final analysis, the success of this project will depend upon the existence of the necessary political will to carry it through. It is to be hoped that this political will exists.

Brussels, 26 March 2003.

The President

of the European Economic and Social Committee

Roger Briesch

(1) COM(2002) 705 final.

(2) OJ C 14, 16.1.2001, OJ C 48, 21.2.2002 and OJ C 125, 27.5.2002.

(3) OJ C 125, 27.5.2002, p. 105.

(4) OJ C 241, 7.10.2002.

(5) OJ C 14, 16.1.2001.

(6) OJ C 48, 21.2.2002.

(7) OJ C 125, 27.5.2002.

(8) Speaking at the hearing on Simplification held under the auspices of the SMO at the EESC building on 10 September 2002.

(9) COM(2002) 275 final, 5.6.2002.

(10) COM(2002) 276-278 final.

(11) COM(2002) 275 final, para. 6.

(12) COM(2001) 428 final.

(13) COM(2002) 278 final - Introduction.

(14) COM(2002) 278 final - Introduction.

(15) An apparent omission is that the Commission refers only to the Council and the Parliament. It does not refer to the EESC or the Committee of the Regions.

(16) COM(2002) 277 final.

(17) COM(2002) 276 final.

(18) OJ C 241, 7.10.2002, p. 180.

(19) Internal Market Scoreboard No 11, November 2002.

(20) OJ C 48, 21.2.2002, p. 130 and OJ C 125, 27.5.2002, p. 105.

(21) COM(2002) 277 final, Section II.

(22) COM(2002) 275 final.

(23) COM(2002) 275 final.

(24) OJ C 125, 27.5.2002.

(25) COM(2002) 275 final.

(26) Op cit.

(27) COM(2002) 275 final.

(28) COM(2002) 278 final.

(29) In an address to the Plenary Session of the EESC on 19 September 2002.

(30) COM(2002) 705 final.

(31) COM(2002) 705 final.

(32) Commission presentation to the EESC's Single Market Observatory, 18 December 2002.

(33) http:/www.Europa.eu.int/eur-lex/en/index.html

(34) Press statement on the conclusions of the Council on 30 September 2002.

(35) COM(2002) 275 final.

(36) COM(2002) 275 final.