EN Official Journal of the European Union C 133/44

Opinion of the European Economic and Social Committee on the ‘Council Recommendation on the implementation of the broad guidelines for the economic policies of the Member States whose currency is the euro’

COM(2012) 301 final

2013/C 133/09

Rapporteur: Thomas DELAPINA

On 14 August 2012, the Commission decided to consult the European Economic and Social Committee, under Article 304 of the Treaty on the Functioning of the European Union, on the

Recommendation for a Council Recommendation on the implementation of the broad guidelines for the economic policies of the Member States whose currency is the euro

COM(2012) 301 final.

The Section for Economic and Monetary Union and Economic and Social Cohesion, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 21 January 2013.

At its 487th plenary session held on 13 and 14 February 2013 (meeting of 13 February 2013) the European Economic and Social Committee adopted the following opinion by 161 votes to 3 with 9 abstentions:

1. Conclusions and recommendations

1.1 The EESC welcomes the establishment of general economic policy guidelines for the countries of the euro area which will provide a coherent framework for the necessary moves towards deeper integration and for better and more effective coordination.

1.2 In addition, the Committee supports the formulation of recommendations tailored to each country as well as measures to assess their implementation. This will make it possible to take account of differences in economic performance and the different causes of the crisis which vary from country to country.

1.3 However, the EESC would like to use the recommendation as an opportunity to highlight the need for reform of the approach to economic policy, especially in connection with the renewal of the guidelines expected in 2014. The Committee regards the current macroeconomic policy mix as unbalanced, since it overlooks the significance of demand and distributive justice. Several reform measures are showing signs of stabilising financial markets which should enable the current approach to economic policy to put more emphasis on growth policies and job creation. Nevertheless the operational capacity of the banking sector and of financial markets is not yet fully restored. At the same time, the policy of austerity has not provided for a credible expansionary programme to reduce government debt and unemployment. On the contrary, the crisis has worsened – instead of growing its way out of the crisis, the euro area has cut its way into a double-dip recession, with far-reaching consequences, not only economic but also and above all social. In the long term, ignoring these social consequences poses an even greater threat to the growth of the European economy.

1.4 The stabilisation measures of national policies are doomed to failure if they are undermined by developments on the financial markets and by speculation. The Committee therefore calls for stricter regulation of financial markets taking account of the shadow banking systems and coordinated at G-20 level, as well as a scaling back of the financial system, which must be brought back into line with the needs of the real economy. The EESC calls for a ‘real economy renewal’ in Europe, in which entrepreneurial activity, as opposed to speculative motives, takes centre stage once again.

1.5 A credible solidarity-based safety net including a strong building on earned trust could ensure that any speculation against countries in difficulty is futile and thus reduce their financing costs. Common European bonds as well as reduced dependency on ratings agencies could also help lower the financing costs of countries in crisis.

1.6 Measures to consolidate public finances, which are required for a variety of reasons such as the costs of supporting banks, economic stimulus measures and in some countries the collapse of housing and construction bubbles, have varying degrees of urgency and therefore need a broader and more flexible range of timeframes. Furthermore they have to take account of demand effects and they must be coordinated with the social and employment objectives of the Europe 2020 strategy. Growth and jobs are the key factors underpinning successful consolidation. A low budget deficit is primarily the result of favourable overall economic development and of sound governance and not the condition for it.

1.7 Sustainable budgetary consolidation must be based on a balanced approach, taking account of the balance between supply and demand effects, on the one hand, and expenditure and revenue, on the other. The Committee emphatically points out that an integrated budgetary policy framework (fiscal union) not only concerns public expenditure, it also covers public revenue. The Committee calls for a general re-think not only of expenditure but also of tax systems, with due regard for distributive justice. It points to a series of possible measures to strengthen tax revenues to safeguard the financing of the desired level of the social systems and forward-looking public-sector investment. A harmonisation of the tax bases and systems on the basis of in-depth analyses of the various economic systems within the EU would be worthwhile. This would prevent distortions of competition within the Union, instead of continuing to erode public revenues by competitive tax-cutting.

1.8 The Committee urges a re-evaluation of fiscal multipliers in the light of considerable international research, which suggests that in a recession fiscal multipliers differ from country to country and have a significantly more adverse impact on economic growth and employment than was hitherto realised. Policies should capitalise more on the fact that the negative income and employment multipliers of revenue-related measures are generally more limited than those of spending cuts, especially if these revenue-related measures affect population groups with a lower propensity to consume. This could generate possibilities to create jobs and demand, through budget-neutral restructuring, by freeing up resources for expansionary measures, for example in education and employment programmes, and for investment in industry, research and in social services. This in turn helps meet the urgent need to boost confidence among businesses and consumers.

1.9 In surplus countries in particular, such expansionary measures would also promote imports. EU-wide coordination of such measures would be considerably more effective, since the rate of imports for the euro area as a whole (i.e. from third countries) is significantly lower than it is for each individual national economy by itself.

1.10 With a view to achieving the requisite symmetry, when breaking down external economic imbalances surplus countries are called upon to translate their export profits into prosperity gains for broad sections of the population. Such an increase in domestic demand would help reduce their ‘import deficits’.

1.11 Alongside calls for a fresh approach to the macroeconomic policy mix, socially acceptable structural reforms may also strengthen demand and improve the economy's productive capacity.

1.12 In general, focussing on price competitiveness as a way of reducing external economic imbalances, which in many cases is associated with demands for wage restraint, is not useful. Holding down wages in order to promote exports in all euro area countries at the same time not only has serious redistributive consequences, it also reduces overall demand and leads to a downward spiral, in which all countries lose.

1.13 The Committee reiterates its call for a wage policy that makes full use of the scope for productivity, and rejects any requirements imposed by the state and state interference in the autonomous collective bargaining policy as completely unacceptable.

1.14 Other cost factors, which are often more important than wages, are for the most part overlooked. Even the importance for competitiveness of non–price factors is overlooked. Europe will only be successful in the global race if it pursues a ‘high road’ strategy of high-quality added value. A ‘low road’ strategy of competitive undercutting involving other world regions would be doomed to failure.

1.15 Overall, the European social model – through the automatic stabilisers of the social security system – has helped deal with the crisis by supporting demand and confidence. Scaling back this system runs the risk of causing a descent into a deep depression, as in the 1930s.

1.16 In general, the Committee calls for a stronger role for the social partners at national and European level and for closer Europe-wide coordination of wage policy, for example by enhancing the value of macroeconomic dialogue, which should also be introduced in the euro area. The revision of the guidelines should take account of the fact that countries with functioning social partnerships have been better able to cushion the impact of the crisis than other countries.

1.17 Furthermore, the Committee reiterates its appeal for the social partners and other organisations representing civil society to become involved in policymaking as early and as comprehensively as possible. The requisite changes and reforms hold promise and will be accepted only if the distribution of burdens is felt to be fair.

1.18 In short, Europe needs a new model for growth, characterised by measures to tackle unacceptable levels of unemployment and by sufficient scope for future-related investments as well as social and environmental investments, which generate growth and demand. On the basis of budget-policy restructuring and measures to ensure an adequate revenue base with due consideration for distributive justice, social systems must be strengthened with a view to increasing productivity and stabilising demand and confidence. A growth model of this kind will also facilitate sustainable consolidation of public finances.

2. Background

2.1 The Council recommendation of 13 July 2010 on the broad guidelines for the economic policies of the Member States of the Union set the following guidelines, which will remain unchanged until 2014 so that the main emphasis can be put on implementation: — Guideline 1: Ensuring the quality and the sustainability of public finances — Guideline 2: Addressing macroeconomic imbalances — Guideline 3: Reducing imbalances within the euro area — Guideline 4: Optimising support for R&D and innovation, strengthening the knowledge triangle and unleashing the potential of the digital economy — Guideline 5: Improving resource efficiency and reducing greenhouse gases — Guideline 6: Improving the business and consumer environment, and modernising and developing the industrial base in order to ensure the full functioning of the internal market.

2.2 In this connection, on 30 May 2012 the Commission presented its latest ‘Recommendation for a Council Recommendation on the implementation of the broad guidelines for the economic policies of the Member States whose currency is the euro’, which updates the recommendations on the general direction of economic policies in the euro area. In addition, individual country-specific recommendations have been drawn up for all 27 EU Member States. On 6 July 2012, the Council of the European Union adopted the relevant documents.

3. General remarks

3.1 The EESC welcomes the Commission's efforts to establish a coherent framework for better coordination of European economic policies - something which is urgently needed. This is absolutely vital if we are to return to a sustainable path towards growth and jobs. There is a risk that measures which may be useful in reducing imbalances in an individual country could be counterproductive for the euro area as a whole.

3.2 A Europe-wide approach, European thinking and a pro-European mentality are therefore needed. The Committee thus shares the Commission's view that genuine cooperation on economic policy, at least in the Eurogroup, requires deeper integration as well as better and more efficient coordination. In this connection, consideration must be given to differences in Member States' economic output (level and growth of GDP, unemployment rates and trends, size and structure of budget deficit and debt, R&D expenditure, welfare expenditure, current account balance, energy provision, etc.).

3.3 The crisis, which has been ongoing since 2008, started in the USA and has developed into a global crisis. As a result of the crisis, it has become clear that the architecture of monetary union placed too much faith in market forces and fails to properly deal with the risk of imbalances. As the pre-2008 trends in public budgets across the euro area show, lack of budgetary discipline was generally speaking not the cause of the crisis. Debt to GDP ratio in % (source: AMECO 2012/11)

3.4 On average in the euro area, the increase in deficits or debt levels occurred only after the massive use of public funds to rescue the financial system and prop up demand and the labour market, which had collapsed because of the financial crisis (1), and because of falling government revenues, mainly due to the decline in employment. This point is of particular importance for the development of economic policy strategies, since the wrong diagnosis will lead to the wrong treatment. The EESC therefore welcomes in principle the distinction made between individual countries in assessing implementation of the guidelines. One size does not fit all, since the causes of the crisis also vary considerably from country to country.

3.5 However, the EESC would like to use this opportunity to highlight the need for reform of the approach to economic policy. This concerns not only the annual reviews. It is also of special relevance for the next version of the economic policy guidelines in 2014.

3.6 In 2012 Europe was in its fifth year of crisis. Shortly after the current guidelines were set, in its 2010 autumn forecast the European Commission was still predicting that in 2012 GDP would grow by 1.6 % in the euro area and its unemployment rate would be 9.6 %. In actual fact, the euro area has been in recession this year and the unemployment rate has risen to more than 11 %; in some countries it has even gone up to around 25 %.

3.7 In contrast, the US economy is growing – moderately but steadily – at a rate of around 2 %, supported by the continuation of strongly expansionary monetary policy as well as the government's social and fiscal policy strategy. There has been strong growth in consumption, investment and industrial production, with the effect that the unemployment rate is significantly below the peak it reached in October 2009 (2).

3.8 Whereas the 2008 European Economic Recovery Programme, which was heavily influenced by the rapid economic crash following the collapse of Lehman Brothers, acknowledged the need for active steps to strengthen internal demand and regulate markets, economic policy swiftly returned to its traditional focus. The repeated warnings, not least from the EESC, that Europe must grow its way out of the crisis and should not cut its way into the next crisis, went unheeded – and the feared double-dip recession therefore became a reality.

3.9 First of all, the failure of European economic policy relates to the unsuccessful attempts to stabilise financial markets. Significant volatility, high spreads as well as excessive long-term interest rates and high levels of liquidity held by banks show that despite important initial steps towards a banking union, the financial system has yet to return to full operational capacity. The business and consumer uncertainty associated with this continues to limit the chances for growth.

3.10 Second, economic policy has failed to tackle the lack of internal and external demand. The significantly stricter requirements for Member States' budget policies as well as a switch to a restrictive fiscal policy that came much too early, was too radical and occurred in all countries at the same time put downward pressure on all key components of internal demand. Given that the most important trading partners – i.e. the other Member States – are also trying to make savings, it is clear that impetus for growth from external demand will be strictly limited too. This means that in addition to downward pressure on internal demand, there are fewer reciprocal opportunities for exports.

3.11 The current macroeconomic policy is unbalanced, as it neglects issues of demand and distribution. It represents more of the same policy which led to the failure of the Lisbon Strategy, since it overlooked the lack of internal demand in key large Member States and growing distribution inequality. It is one-sided in its focus on policy consolidation and a strategy of lowering costs in order to increase price competitiveness. The Committee welcomes the Commission's request for growth-friendly fiscal consolidation measures, which is also emphasised in subsequent Commission documents as well as in the 2013 annual growth survey (3). However, they appear to exist only on paper, since the empirical data does not yet offer any evidence of their implementation.

3.12 Economic policy at European level has not succeeded in introducing measures which help reduce government debt and unemployment simultaneously within the framework of a credible expansionary programme. Deep public spending cuts, especially to welfare, as well as increases in large-scale taxes are having devastating consequences in economies which in any case are already shrinking. Disposable income is being reduced and thus also consumer demand, production and employment. This means that the policy of austerity is acting as a brake on tax revenues much more strongly than originally thought, as the IMF had to admit in its latest forecast (4). It is making the recession even worse, which is ultimately leading to even higher budget deficits – a vicious circle with still no end in sight. The high economic and social costs are reflected in the sharp rises in unemployment.

3.13 It is clear that - primarily on account of the costs of supporting banks, economic stimulus measures and in some countries the collapse of housing and construction bubbles - country-specific consolidation strategies are required in order to put public finances on a sustainable footing. However, the EESC points out that debt reduction programmes must be coordinated with the objectives for economic recovery and the social and employment objectives set out in the Europe 2020 strategy. Growth and jobs are the key factors underpinning successful consolidation, whereas radical savings measures may even raise debt levels in addition to causing immense social problems.

3.14 Even if this Committee opinion focuses mainly on aspects of the macroeconomic policy mix, this should not detract from the importance of structural reforms. Socially acceptable structural reforms in areas such as the taxation system, energy supplies, administration, education, health, residential construction, transport and pensions must help strengthen demand and productive capacity, in which connection consideration must be given to differences in competitiveness between individual countries.

3.15 Regional and structural policy should also put emphasis on increasing productivity, with a view to modernising and developing a sustainable industry and services-based economy. In general, it is fair to say that countries whose national economies have a larger industrial component were affected less severely by the crisis, which suggests the need for appropriate industrialisation strategies.

3.16 However, the Committee would like to expand the predominant, usually rather narrow understanding of the concept of ‘structural reform’. Calls for structural reform should also, for example, take account of the structure of financial market regulation, the structure underpinning coordination of tax systems and the structure of public spending and revenue.

4. Specific comments

4.1 Financial system

4.1.1 The EESC shares the view of the Commission, which highlights the importance of stabilising the financial system and ensuring that it functions smoothly. The basic principle of any successful attempt to tackle and prevent crisis is that the room for manoeuvre in economic policy should not be undermined or jeopardised by financial market speculation. Hence the need for a clear and efficient system of supervision and tighter regulation of financial markets (including the shadow banking system), which pose a bigger risk to stability than any lack of competitiveness. In order to prevent such regulation from being circumvented, relevant steps should be coordinated within the G-20. The financial markets must be reduced to a sensible size. They must once again serve the real economy and should not compete with it (5).

4.1.2 In order to lower the artificially high financing costs of countries in crisis, which are caused by speculation, efforts should be made to reduce dependency on private ratings agencies. At the same time, a credible solidarity-based safety net including a strong building on earned trust could ensure that any speculation against countries in difficulty is futile and thus prevent such speculation. Some important steps in this direction were recently taken (the latest ECB programme to buy up government bonds, the ESM has finally come into effect and is fully operational, etc.). If used under the right conditions, common European bonds may also help ease budgetary pressure in countries beset by crisis (6).

4.1.3 The Committee points to the need to break the link between commercial banks and public debt. In addition, the fragmentation and renationalisation of financial markets must be reversed by stabilising the sector. Stepping up moves towards a banking union could also contribute to stabilisation at European and national level, together with effective tools for the recovery and resolution of credit institutions (7).

4.2 Public budgets

4.2.1 Sustainable budgetary consolidation must be geared not only to ensuring a balance between supply and demand effects. It must also create a balance between expenditure and revenue. Furthermore, in many countries a disproportionate burden has been placed on labour as a factor of production. A general re-think not only of expenditure but also of the entire tax system is therefore needed, with due regard for questions of distributive justice between different kinds of income and wealth. This also means demanding an appropriate contribution from those who benefited most from the mistakes made on the financial markets and the bank rescue packages paid for using taxpayers' money.

4.2.2 With regard to revenue, a number of approaches exist for producing the necessary increase in tax revenues: a financial transaction tax (repeatedly called for by the Committee (8)), energy and environmental levies, closing tax havens (9), decisive action to combat tax evasion, taxation of large fortunes, property and inheritance, taxation of banks to internalise external costs (10), and harmonising tax bases and systems in order to eliminate distortions of competition within the Union, instead of continuing to erode public revenues by competitive tax-cutting. It is often overlooked that an integrated budgetary framework (‘fiscal union’) would also extend to revenue, and not only concern public expenditure.

4.2.3 In some Member States, a marked increase in the efficiency of the tax collection system is called for.

4.2.4 The traditional approach to budgetary consolidation has been to cut public spending. However, the idea that spending cuts are likely to be more successful than revenue increases remains an unproven dogma. The empirical evidence from countries in crisis such as Greece shows that the hopes of ‘non–Keynesian effects’ have been in vain. Against a backdrop of spending cuts, there can be no crowding-in of private investment based on increased confidence if internal demand is weak throughout the monetary union as a result of austerity policies. Furthermore, spending cuts, to welfare systems or public services for example, generally have a regressive impact, worsening distribution inequality and putting downward pressure on consumption. That being said, there is certainly scope for cuts to certain unproductive expenditure, such as in the area of armaments.

4.2.5 Instead, policies should capitalise on the considerable differences between the revenue and employment multipliers of various budgetary policy measures. According to nearly all empirical studies, the multipliers of tax measures are less than those of spending-related measures. A policy of targeted increases in government revenues could thus free up resources which are urgently needed, for jobs programmes for example, especially those for young people.

4.2.6 A redistribution of this kind with a neutral effect on the budget balance would immediately generate jobs and demand, without putting strain on public finances. In addition to the positive impact on the domestic economy, such measures would create expansionary impulses for the entire monetary union by boosting imports, especially if they were taken by surplus countries.

4.2.7 EU-wide coordination of such expansionary measures would be considerably more effective, since the rate of imports for the euro area as a whole (i.e. from third countries) is significantly lower than for each individual national economy by itself.

4.3 External economic imbalances

4.3.1 It is essential to monitor the performance of the current account and its components in the context of a Member State's productivity weaknesses and the ensuing private and public financing problems, in order to ensure that any (re)action is timely. However, in reducing imbalances in the trade balance, attention must be paid to symmetry: the exports of one country are the imports of another. Consequently, smaller imbalances cannot be achieved solely through a reduction in deficit countries. Surplus countries too are required to take action, by strengthening domestic demand to boost imports and thus reduce their ‘import deficits’.

4.3.2 From a European perspective, the energy sector in particular is an exception, with all Member States effectively having large trade deficits (11). A redevelopment of the European internal market from an environmental point of view should reduce dependency on fossil fuel imports through the internal use of Europe's own alternative energy sources. In addition, the solar energy sector in the southern periphery offers a further opportunity for improving trade balances within Europe.

4.3.3 In efforts to tackle external economic deficits, too much emphasis is generally put on the role of price competitiveness. Focussing purely on price competitiveness would be risky. The German model (wage restraint to promote exports or suppress imports) as a simultaneous guide for all countries can only lead to a race to the bottom, given the high proportion of internal trade in the euro area.

4.3.4 The different trends in unit wage costs are generally seen as one of the central causes of the crisis, resulting in calls for lower wage costs. Regardless of the serious redistributive consequences of lowering the wages share, which suppresses demand, other relevant cost factors (such as energy, materials and financing costs) are being overlooked here (12).

4.3.5 For example, in the period before the crisis between 2000 and 2007 real unit wage costs were falling in Portugal, Spain and Greece (13). Excessive nominal profit increases have done as much to push up prices as nominal wage increases.

4.3.6 It is still the case that almost 90 % of overall demand in the EU comes from EU Member States. As far as wage trends are concerned, the EESC therefore stands by the view it expressed in its opinion on the 2011 annual growth survey: ‘Appropriate wage policies have a key role to play in dealing with the crisis. Keeping wage rises in step with productivity growth and targeted in the national economy as a whole will, from a macroeconomic viewpoint, make sure a proper balance is struck between sufficient growth in demand and price competitiveness. The social partners must therefore work to avoid wage restraints along the lines of a beggar-thy-neighbour policy and gear wage policy instead towards productivity’ (14).

4.3.7 Furthermore, the importance for competitiveness of non-price factors is usually underestimated (15). In this connection, reference is made to the European Commission's definition of ‘competitiveness’ as ‘… the ability of the economy to provide its population with high and rising standards of living and high rates of employment on a sustainable basis’ (16).

4.3.8 Not least because of the sharp rise in national spreads, the income account in countries beset by crisis has become more important. The analysis of the imbalances must not therefore be limited to the development of the trade balance.

4.4 The European social model and social dialogue

4.4.1 The European social model gives Europe a comparative advantage in global competition. The welfare state also contributes to economic success when economic output on the one hand and social balance on the other are not seen as opposites but are understood to support each other.

4.4.2 The automatic stabilisers of social security systems have helped deal with the crisis and supported demand in Europe and prevented it from falling into depression, as in the 1930s. The social security systems are also of great importance psychologically, since they reduce the risk of panic saving and thus stabilise consumption.

4.4.3 In some countries with a functioning social dialogue (such as Austria, Germany and Sweden) the social partners played an important part in reducing the risk of increased unemployment as a result of falls in production. In addition to support from economic and social policy measures, business and sector-based agreements among the social partners made a significant contribution to maintaining existing employment (e.g. through short-time working, reducing overtime accumulated, use of holiday entitlements, leave for training, etc.). These experiences should be taken into account in the development of the latest guidelines and in annual country reports.

4.4.4 European governments are called upon to strengthen the role of the social partners at European and national level. The partners should be supported in stepping up efforts to achieve Europe-wide coordination of wage policy. In addition, attempts should be made to enhance the value of macroeconomic dialogue; such dialogue should also be established for the euro area.

4.4.5 In any case, free collective bargaining must also be safeguarded in the crisis: wage policy should be set within the framework of free collective bargaining by competent associations of employers and employees. National targets or even intervention such as government-prescribed wage cuts should be rejected and are unacceptable (17).

4.4.6 Alongside the role of the parties to collective bargaining, the significant role of other organisations representing civil society, such as consumer organisations, must also be acknowledged. Especially in times of crisis, these are indispensible as the mouthpiece of citizens and as partners in civil dialogue.

4.4.7 The requisite changes and reforms hold promise only if a balance is found between economic and social goals and the distribution of burdens is felt to be fair (between countries, income groups, capital and labour, sectors, different population groups, etc.). Fairness and social balance are key requirements for public acceptance of consolidation measures; otherwise social cohesion will be put at risk and there could be a dangerous upturn in populism and anti-EU sentiment. The Committee reiterates in this connection its urgent recommendation that the social partners and other organisations representing civil society should become involved in policymaking as early and as comprehensively as possible.

Brussels, 13 February 2013. The President of the European Economic and Social Committee Staffan NILSSON

(1) For a detailed and nuanced account of how the financial and economic crisis came about, see OJ C 182, 4.8.2009, p. 71, point 2,

(2) See the European Commission's 2012 autumn forecast.

(3) COM(2012) 750 final.

(4) The IMF outlook published on 9 October states that fiscal multipliers in the crisis may have been between 0.9 and 1.7, whereas originally an estimation of around 0.5 had been taken as a basis (see IMF 2012, http://www.imf.org/external/pubs/ft/weo/2012/02/pdf/text.pdf).

(5) OJ C 11, 15.1.2013, p. 34.

(6) For the discussion on stability bonds, Eurobonds, project bonds etc. see OJ C 299, 4.10.2012, p. 60, and OJ C 143, 22.5.2012, p. 10.

(7) OJ C 44, 15.2.2013, p. 68.

(8) Most recently in OJ C 181, 21.6.2012, p. 55.

(9) OJ C 229, 31.7.2012, p. 7.

(10) i.e. to make sure that future costs of banking crises do not have to be financed by the taxpayer.

(11) EU-27: 2.5 % of GDP (2010).

(12) For example, in the Spanish export sector, wage costs amount to only 13 % of total costs. Source: Carlos Gutiérrez Calderón/ Fernando Luengo Escalonilla, Competitividad y costes laborales en España (competitiveness and labour costs in Spain), studies from 1st May Foundation, 49 (2011, http://www.1mayo.ccoo.es/nova/files/1018/Estudio49.pdf).

(13) See statistical annex of European Economy, autumn 2012.

(14) OJ C 132, 3.5.2011, p. 26, point 2.3.

(15) OJ C 132, 3.5.2011, p. 26, point 2.2.

(16) COM(2002) 714 final.

(17) OJ C 132, 3.5.2011, p. 26, point 2.4.