There is no evidence of an adverse overall impact of existing environmental regulation on industry competitiveness. The WTO suggests that competitiveness problems exist among industrialised countries rather than between industrialised countries and developing countries. Small and medium-sized enterprises are often responsible for a disproportionate share of environmental damage. They should be helped by targeted national or EC mechanisms to help them adopt clean production techniques. Adverse effects on the financial, banking and insurance sectors are unlikely - provided liability is concentrated on the operators.
Transaction costs are important.
But this is not paralleled in European experience. It will therefore be important to analyse the reasons for these differences and avoid what causes high transaction costs. The Commission considers that the most appropriate course would be an EC framework directive on environmental liability. The details of such a framework directive should be worked out consultations. Interested parties have until 1 July 2000 to send comments to the Commission.