EN    EN EN 
 
EN 1   EN  EUROPEAN COMMISSION 
Brussels, 9.3.2010 
SEC(2010) 198 
 
COMMISSION STAFF WORKING DOCUMENT 
SUMMARY OF THE IMPACT ASSESSMENT  
 
 
Accompanying document to the 
  
Proposal for a 
 
DECISION OF THE EUROPEAN P ARLIAMENT AND OF THE COUNCIL 
 
establishing a European Union action  for the European Heritage Label 
  
{COM(2010) 76 final} 
{SEC(2010) 197}  
 
EN 2   EN EXECUTIVE SUMMARY  
This impact assessment will accompany the proposal for a Decision of the European 
Parliament and of the Council establishing a European Union action for the European 
Heritage Label. 
1. P ROBLEM DEFINITION  
The original concept of the European Her itage Label (EHL) was born as one of the 
responses to the gap between the reality of the EU and the perceptions of its citizens. 
This gap is linked to an im portant extent to a lack of  knowledge of the history of 
Europe, of the role of the EU and of the functioning of its institutions. 
The scheme was subsequently launched in April 2006 as an intergovernmental 
initiative. To date, a total of 64 sites located in 17 EU MS as well as in Switzerland have obtained the label. The aim of the or iginal EHL was to use the potential of 
cultural heritage to strengthen European citizens’ sense of be longing to Europe and 
promote a sense of European identity. It is important to note that right from the start, 
it was clear that the EHL alone could not fill the gap between citizens and the EU. It was meant more modestly to be one cont ribution alongsid e other initiatives in the 
field of communication, education, culture or citizenship aimed at addressing the 
same problem.  
This leads us to a second level of the problem which is that the reading or 
interpretation of cultural heritage in Europe, including of the most symbolic sites of our shared heritage, is still to a very large extent a na tional reading. The European 
dimension of our common her itage is insufficiently highlighted and its potential to 
stimulate intercultural dialogue is not optim ally exploited. This situation has been 
clearly acknowledged by the Minister s of Culture who launched the 
intergovernmental EHL and this initiative ai med to tackle this problem by identifying 
and designating sites which ha ve played a key role in building and uniting Europe, 
promoting a European reading of these site s, developing their educational potential, 
and fostering the sharing of e xperience and best practices.  
However, the intergovernmental EHL has not achieved concrete re sults so far. This 
is due in part to the fact that the EHL is only very recent and that the problem it seeks to address is complex and deep-rooted. This is due also to the fact that the EHL is 
still very far from having reached its fu ll potential and its implementation shows 
many deficiencies which need to be addr essed. This was confirmed by an evaluation 
of the initiative carried out by the external consultant ECOTEC as part of their support services for this imp act assessment, which demonstrated for example that as 
a consequence of the current selection procedures, the nature of the selected sites, 
their relevance, and their activities are rath er disparate and in some cases difficult to 
comprehend; that the EHL lacks visibility even among the main st akeholders in the 
heritage sector; and that little progress has been made  so far on the educational 
dimension and networking between labelled site s. In order to achie ve concrete results 
and to make an impact, the EHL needs a more proactive approach and to take a 
qualitative step forward. 
 
EN 3   EN 2. A NALYSIS OF SUBSIDIARITY  
On 20 November 2008, the Council of Ministers of the European Union adopted 
conclusions inviting the European Comm ission to submit to it ‘an appropriate 
proposal for the creation of a European Heritage Label by the European Union and specifying the practical procedures for the implementation of the project’.  
The legal basis for the EHL can be f ound in Article 167 of  the Treaty on the 
Functioning of the European Union. This  article gives the EU the mandate to 
‘contribute to the flowering of the cultures of the MS, while respecting their national 
and regional diversity and at the same tim e bringing the common cultural heritage to 
the fore’. The EU should also encourage ‘cooperation between MS’ in the field of 
culture and ‘if necessary, s upport and supplement their action’. In accordance, with 
the Council conclusions, the participation of  the MS would be on a voluntary basis. 
EU involvement in the EHL is expected to reinforce coordination between MS and 
thus to contribute to the development and the application of new common, clear and 
transparent selection criteria, as well as new selection and monitoring procedures for 
the EHL, thereby ensuring the relevance of th e sites in the light of the objectives. The 
results of the evaluation of the current EH L mentioned above dem onstrated that this 
could not be achieved with the intergove rnmental arrangements. Other expected 
benefits of EU action are an increase in  the number of MS participating in the 
initiative and a solution to the problems li nked to the present rotating secretariat. 
This should help to improve the value of th e initiative in order to ensure its quality, 
credibility and long-term success. 
3. O
BJECTIVES OF EU INITIATIVE  
As mentioned above, the gap between the EU  and its citizens is a broad and complex 
problem which cannot and will not be solved  by the EHL alone. Different initiatives 
address this issue in complementary ways a nd it is important to stress that the label 
will certainly not have an impact on the same level as for example student exchanges or language learning. Theref ore it has been decided to  propose four levels of 
objectives for the renewed EHL, with ge neral objectives which reflect the overall 
ambition of the EHL and link it into the wider EU policy agenda and intermediate objectives which are the highest level of im pact that the EHL can achieve on its own. 
At a more basic level, specific a nd operational objectives are included. 
3.1. General objectives 
Strengthen European citizens’ sense of belonging to the European Union, based on 
shared elements of history and cultural heritage, as well as an appreciation of 
diversity. 
Strengthen intercultural dialogue. 
3.2. Intermediate objectives 
Enhance the value and profile of sites which have played a key role  in the history and 
the building of the European Union. 
 
EN 4   EN Increase European citizens’ understanding of the building of Europe, and their 
common yet diverse cultural he ritage, especially related to democratic values and 
human rights that underpin European integration. 
3.3. Specific objectives 
Develop sites’ European significance. 
Raise young people’s awareness of their common cultu ral heritage. 
Facilitate sharing of experiences and ex changes of best practice across Europe. 
Increase access to heritage sites for a ll members of the public, especially young 
people. 
Increase intercultural dialogue, especia lly among young people, through artistic, 
cultural and historical education. 
Foster synergies between cu ltural heritage and contempor ary creation and creativity. 
Contribute to the attractiveness and the sustainable development of the regions. 
3.4. Operational objectives 
a) Practical arrangements for the EHL Ensure the application of co mmon, clear and transparent criteria for the selection of 
the sites. 
Foster a fair distri bution of labels across the European Union. 
Introduce a monitoring procedure to ensure  that the labelled sites respect their 
commitments. 
Improve the complementarity with other initiatives in the field of cultural heritage, 
notably through good communication with  relevant international bodies. 
Ensure that the practical arrangements rema in light and flexible for the EU and the 
MS. 
Increase the visibility at European leve l, notably through th e development of a 
website. 
Develop transnational networks of sites to develop their European profile and 
exchange. 
b) Activities of the labelled sites 
Develop the European dimension of sites th rough appropriate information activities 
and multilingual signage. 
Develop programmes of educational activities. 
 
EN 5   EN Undertake marketing and promotion of sites as tourist destinati ons locally, nationally 
and at European level. 
Develop access to sites through site adap tations, visitor tools, staff training, 
privileged access for the young public. 
Develop programmes of cultura l activities: events, festivals, artist-in-residence 
schemes, etc.. 
4. P OLICY OPTIONS  
The Council conclusions mention that th e new EHL should keep ‘flexible and 
streamline administrative arrangements in  compliance with the principle of 
subsidiarity.’ This same concern to k eep the costs limited both at national and 
European level was also expressed on num erous occasions durin g the consultation 
process and it has been reinforced by the current context of financial and economic 
crisis which makes it highly unlikely that much funding will be available either at 
national or European level for the EHL in th e coming years. In view of these factors 
we excluded an option which would have  involved continuing the EHL as an 
intergovernmental initiative but with signi ficant financial support from the EU to 
develop sites and the networ king between them, as well as an option which would 
have involved transforming th e EHL into an EU initiative  with significant financial 
support to the sites.  
As a result of this initial screening process,  three main options wh ich appeared to be 
realistic and feasible were developed, with one of the op tions containing three sub-
options. All of these options would have very limited impacts on the EU budget. All 
of them also comply with the principl es of subsidiarity and proportionality. 
4.1. Option 1: Status quo (baseline scenario) 
The EHL continues as an intergovernmental  initiative with a secretariat hosted by 
participating countries on a rotating basi s (unfunded by the EU) and without any EU 
action.  
4.2. Option 2: Status quo plus limited EU financial support  
The EHL continues as an intergovernmental initiative with limited financial support 
from the EU budget to support part  of the running costs of th e secretariat, part of the 
communication costs, expert meetings a nd networking. Funding would have to come 
from either the current or future Culture programme.  
4.3. Option 3: The EHL becomes an EU initia tive through a Decision by the Council 
and the Parliament  
This Decision would specify the objectives and the rules of the ne w Label, define the 
common selection criteria, se t up the selection and monito ring procedures and clearly 
allocate the tasks and responsibilitie s between the MS and the Commission. A 
secretariat would be provided by the Co mmission. Some limited financial support 
would be provided to assist the transnational networking of  the sites, either through 
calls for proposals or by the organisation of expert meetings by the Commission. The 
 
EN 6   EN Commission would also be re sponsible for the communicati on and the visibility of 
the EHL at European level. 
Three sub-options are possible according to  the various selection and monitoring 
procedures that came up dur ing the consultation phase: 
3(a) Selection of sites is undertaken  by the MS against common, clear and 
transparent criteria. Each year the MS put  forward sites up to a maximum number 
and according to country quotas. The sites are then validated by the EU. Monitoring 
is a MS responsibility. The function of  the Commission is to ensure a good 
coordination between the MS and the sm ooth running of the procedures and the 
practical arrangements. 
3(b) Sites are selected through an open se lection process which does not take into 
account the national origin of the candidate sites by an expert committee at European 
level. A limited number of Labels could be  awarded each year. Monitoring functions 
would also be undertaken at EU level. 
3(c) Sites are pre-selected by MS and then subject to final selection by an 
independent panel at EU level. Monitoring is primarily a MS responsibility, but with 
supervision and review by the independent panel and the possi bility of withdrawal of 
the designation.  
5. A SSESSMENT OF IMPACTS  
In order to undertake the im pact assessment a range of  potential impacts were 
identified in cooperation with the extern al consultant. They were derived from 
various sources: from a review of the literatu re relating to the impact of culture and 
heritage; from an analysis of the objectiv es of the EHL; and from the comments and 
perspectives of the indivi duals, organisations and MS that participated in the 
consultation process. 
The following impacts were analysed: 
5.1. Social / societal impacts: 
Increased access to cultu ral heritage resources. 
Increased access to heritage for young people. Increased interest in and knowledge  of common European heritage. 
Increased understanding of European cultural diversity. 
Increase in intercultural dialogue. Greater sense of belonging to the European Union. Stronger participation in the democratic process. 
 
EN 7   EN 5.2. Economic impacts: 
Positive effects on the local tourism i ndustry, including number of people employed. 
Development of links with cu ltural and creative industries. 
Development of innovation and creativity. 
5.3. Environmental impacts: 
Negative effects linked to ove r-development of tourism. 
Protection of cultural heritage. The analysis of the various impacts showed  that the primary di rect effects of the 
EHL would be social ones. Economic bene fits should rather be considered as 
secondary or indirect benefits in a first st age, although this does not preclude MS and 
sites from pursuing them more actively. The capacity of the EHL to have a significant impact on the number of visitors to  a site may increase over time, but this 
will depend on the quality, credibility and prestige of the label as it develops. Environmental impacts are unlikely in general to be substantial. 
The analysis also demonstrated that th e transformation of the EHL into a EU 
initiative through a Decision by the Council and the Parliament (option 3) would 
bring a clear added value and enable benefits that could not be achieved by MS 
acting alone, even with EU financial suppor t. Among the three sub-options of option 
3, the sub-option of MS selection with an EU  secretariat (3a) would probably deliver 
less marked improvements across the range of impacts.  
Between sub-options 3b (sel ection at EU level only) and 3c (combined MS and EU 
level selection), sub-option 3b offers the pr ospect of a better level of improvement 
only concerning the increased understanding of cultural diversity, while sub-option 
3c is likely to deliver greater improvement s on several fronts, including increased 
access to cultural heritage resources, in creased access to heritage for young people 
and, in the longer term, positive effects on the tourism industry, including the 
number of people employed.  
6. C
OMPARISON OF OPTIONS  
Having looked at the likely impacts of th e different options we turned to an 
assessment in terms of three main criteria: effectiveness, efficiency and coherence. 
However, within these general criteria there were a range of sub-criteria to consider. These derived from the key features of the current EHL, from the Council Conclusions, from the consultation process, and from the lessons learnt from other 
labelling and award schemes. The criteria  selected closely mirrored all of the 
objectives proposed for the renewed EHL. 
In relation to the effectiveness of the opti ons, we considered the fair distribution of 
Labels across the MS, the promotion of the European dimension of the sites, 
networking between the sites, the visi bility and profile of the EHL, the 
 
EN 8   EN implementation of educational activitie s and the implementation of cultural 
activities. 
In relation to the efficiency of the options , we analysed the selection processes, the 
delivery and compliance, the administra tive arrangements required, the financial 
impacts, and communication with  other international bodies. 
Finally, concerning the coherence of the options, we took into account the limitations 
of trade-offs across social, economic and environmental domains, the synergies and 
complementarities with other initiatives, and the possibi lity of participation by non-
EU countries, although such pa rticipation is likely to ta ke place only once the EHL is 
already well established. 
The comparison of the options has shown cl early that, here too, sub-options 3b and 
3c offer the prospect of the most significant improvements. Between the two sub-options, 3c (combined MS and EU level select ion) is preferable on the grounds that it 
would ensure a fairer distribu tion of sites across Europe a nd hence be more likely to 
ensure the ownership and the co mmitment of all Member States . It is also likely to be 
more effective in relation to the visibility  and profile of the EH L, since both levels 
could be engaged in marketing and publicit y, and it would be able to draw on both 
MS and EU resources for selection and monitoring, whilst ensuring a consistent 
application of criteria. Fina lly, option 3c also proved to be the most cost-effective 
option. 
6.1. Preferred policy option: 
On the basis of the assessment above, as well as of the consu ltation process, the 
preferred option for the EHL is option 3c.  
7. M
ONITORING AND EVALUATION  
The monitoring and evaluation framework of  the EHL will comprise two elements 
which need to be distinguished: 
The monitoring of the labelled sites 
The aim here is to verify that labelled sites have met the obligations they agreed to 
undertake when they made their application and were selected. This monitoring will 
be under the responsibility of the MS, which will report to the European panel. After a period of dialogue, in the event that speci fic sites no longer meet their obligations, 
there will be a possibility to withdraw the Label. 
The evaluation of the EHL programme as a whole 
This evaluation will need to combine a focus on examining both the processes 
involved in operating the progr amme and the actual cumulative impact of the EHL at 
programme level. The aim will be to iden tify in which respects the programme is 
working well, where there is room for improvement and, crucially, how this 
improvement might best be achieved in th e future. The monitoring of the labelled 
sites will of course feed into this ev aluation. The evaluation will be under the 
responsibility of the Commissi on and will take the form of an external evaluation 
every 6 years.