EN    EN EN 
 
EN 1   EN  EUROPEAN COMMISSION 
Brussels, 9.3.2010 
SEC(2010) 197 
  
COMMISSION STAFF WORKING DOCUMENT 
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) 198}  
 
EN 2   EN TABLE OF CONTENTS 
Modifications following the opinion of the Impact Assessment Board..................................... 5 
1. Section 1: Procedural issues and context setting ......................................................... 5 1.1. General context ........................................................................................................... .5  
1.1.1. Political background .................................................................................................... 5 
1.1.2. The Council conclusions.............................................................................................. 6 1.2. Consultation of interested parties................................................................................. 9 1.2.1. Internal consultations .................................................................................................. .9  
1.2.2. Consultation of stakeholders and European citizens.................................................. 10 1.2.2.1 Online consultation .................................................................................................... 10 
1.2.2.2 Consultation meeting ................................................................................................. 11  
1.2.3. Consultation meeting with MS experts...................................................................... 13 1.2.4. External services ....................................................................................................... . 14 
2. Section 2: Problem definition .................................................................................... 15 2.1. Problem ................................................................................................................... ... 15 
2.1.1. The problem in 2005 when the intergovernmental EHL was conceived................... 15 2.1.2. The problem today ..................................................................................................... 16  
2.2. Baseline Scenario: the existi ng intergovernmental EHL ........................................... 17 
2.2.1 Rationale, objectives and procedures  of the intergovernmental EHL........................ 17 
2.2.2 The weaknesses of the current intergovernmental EHL ............................................ 18 2.3. Legal basis and subsidiarity ....................................................................................... 20 3. Section 3: Objectives ................................................................................................. 20 3.1. General objectives...................................................................................................... 22  
3.2. Intermediate objectives .............................................................................................. 22 3.3. Specific objectives ..................................................................................................... 22  
3.4. Operational objectives................................................................................................ 23 3.5. Consistency of these objectives  with other EU policies ............................................ 23 
4. Section 4: Policy options............................................................................................ 24 4.1. Policy options not retained for analysis ..................................................................... 24 4.2. Options retained for analysis...................................................................................... 24 
 
EN 3   EN 4.2.1. Option 1: Status quo (baseline scenario).................................................................... 25 
4.2.2. Option 2: Status quo plus lim ited EU financial support ............................................ 25 
4.2.3. Option 3: The EHL becomes a EU initiative through a decision by the Council and 
the Parliament ............................................................................................................ 25 
5. Section 5: Analysis of impacts................................................................................... 26 5.1. Development of the framework of impacts................................................................ 26 5.2. The chain of effects.................................................................................................... 27  
5.3. Quantification versus qualitative analysis.................................................................. 27 5.4. The likely impacts of the various policy options ....................................................... 28 6. Section 6: Comparing the options.............................................................................. 30 6.1. Criteria for comparing the options ............................................................................. 30 6.2. Comparison of the options against effectiven ess, efficiency and coherence criteria. 31 
6.3. Option 1: Status quo (baseline scenario).................................................................... 33 6.4. Option 2: Status quo plus lim ited EU financial support ............................................ 33 
6.5. Option 3: The EHL becomes a EU initiative through a decision by the Council and 
the Parliament ............................................................................................................ 33 
6.6. Administrative arrangement s and financial impacts.................................................. 35 
6.7. Preferred policy option............................................................................................... 37 7. Section 7: Monitoring and evaluation........................................................................ 40 7.1. The monitoring of the labelled sites........................................................................... 40 7.2. The evaluation of the EHL programme as a whole.................................................... 40 Annex 1: ....................................................................................................................... ............ 42 
Annex 2: ....................................................................................................................... ............ 52 
Annex 3: ....................................................................................................................... ............ 69 
Annex 4: ....................................................................................................................... ............ 74 
Annex 5: ....................................................................................................................... ............ 78 
Annex 6: ....................................................................................................................... ............ 83 
Annex 7: ....................................................................................................................... ............ 89 
 
EN 4   EN List of main abbreviations 
EU: European Union 
EHL: European Heritage Label IA: Impact assessment MS: Member States                Disclaimer: This IA report commits only the Commission's services involved in its 
preparation. The text is prepared  as a basis for discussion and does not prejudge the final form 
of any decision to be taken by the Commission 
  
Lead DG: DG EAC 
Other involved services: SG, SJ, DG ELARG, DG EN TR, DG INFSO, DG MARE 
 
EN 5   EN Modifications following the opinion of the Impact Assessment Board 
The draft IA report was discussed with th e Impact Assessment Board in a meeting on 
25 November 2009. Following this meeting and the opinion of the Impact Assessment Board, several changes have been made to the report. 
Further information on the selection criteria  that will be used to award the EHL has 
been provided. The added value of the EHL and the difference with other initiatives 
in the field of cultural heritage have been clarified. The proposed solutions to foster 
the participation of transna tional sites have been specifi ed. The objectives have been 
redefined in order to clarify the level of ambition of the initiative and to improve the 
coherence with the criteria th at were used to compare the options. The report is also 
more specific about the costs of the initiative  for the EU, but also at national level. It 
clarifies why the option of the attributi on of the label on a temporary basis was 
dropped without further analysis. Finally, it sp ecifies that the par ticipation of MS in 
the EHL would be on a voluntary basis. 
Some further changes which were not di scussed in the Impact Assessment Board 
meeting and were not include d in the Board's opinion, bu t which were mentioned in 
the Impact Assessment Quality Checklist have been made. These changes concern mostly the various tables a nd annexes of the IA report. 
Finally, the report has been slightly adapted in order to take in to account the entry 
into force of the Treaty of Lisbon on 1 December 2009. The legal basis for the EHL is now article 167 of the Treaty on the Functioning of the European Union, and the references to the European Community ha ve transformed into references to the 
European Union. 
 
1. S
ECTION 1: PROCEDURAL ISSUES AND CONTEXT SETTING  
1.1. General context  1.1.1. Political background 
The original concept for a "European Heri tage Label (EHL)" wa s first proposed by 
the French Minister of Culture at the time,  Renaud Donnedieu de Vabres as part of 
the response to the growing gap between th e citizens and Europe, in particular young 
people.  
The scheme was subsequently launched in April 2006 as an intergovernmental 
initiative under the leadership of Fran ce, Spain and Hungary, with the aim to 
"strengthen the support of European citizens for a shared European identity based on 
democratic values and human rights and to  foster a sense of belonging to a common 
cultural space". All European States that wished to were invited to put forward 
cultural heritage sites that were symbolic of Europe's identity and to promote their 
European dimension. Rules of procedure for th e EHL, as well as criteria for selection 
and an application form, were adopted and the initiative was formally launched in 
March 2007 to coincide with the 50th A nniversary of the Treaty of Rome when a 
first series of sites was awarded the EHL. From th e beginnings, the official 
 
EN 6   EN documents of the intergovernmental initiati ve stated that "the  ultimate objective of 
the EHL is to become a Community action". To  this date, a total of 64 sites located 
in 17 EU MS as well as in Switzerland have obtained the label1. At first the 
secretariat was being carried out by France and currently by the Spanish Ministry of 
Culture. The intergovernmental EHL is  analysed in detail in section 2.2. 
The European Parliament supported the de velopment of the EHL, first in its 
resolution of 29 November 2007 on a Renewed EU Tourism Policy: Towards a stronger partnership for European Tour ism (2006/2129(INI)) where it proposes "that 
support be given for the creation of a Europ ean Heritage label aimed at highlighting 
the European dimension of the EU’s sites and monuments" and su bsequently in its 
resolution of 10 April 2008 on a European ag enda for culture in a globalising world 
(2007/2211(INI)) in which it unde rlines "that a European heritage label should be 
established with a view to emphasising th e European dimension of cultural goods, 
monuments, memorial sites, and places of  remembrance, which all bear witness to 
Europe’s history and heritage". 
On 20 November 2008, the Council of Ministers of the European Union adopted 
conclusions inviting the European Commi ssion to submit to it "an appropriate 
proposal for the creation of a European He ritage Label by the European Union and 
specifying the practical procedures for the implementation of the project."  
An IA roadmap was prepared in February  2009. Because of the specificity of the 
agenda planning and of the preparation of the work programme for 2010 due to the 
arrival of a new College of Commissione rs, this roadmap was not published. It 
served however as a communication tool, not ably with the Inter Service Steering 
Group and the external consultant. 
 1.1.2. The Council conclusions 
As mentioned above, right from the start,  the ultimate objective of the EHL was to 
become a EU action. The request of the MS  to transform the in tergovernmental EHL 
into a formal initiative of the EU came howe ver very soon after the official launch of 
the label. The reason for this is twofold.  Firstly, several MS have a very strong 
political interest in the EHL, including France which held the Presidency of the EU at the moment of the adoption of the conclusions and Spain which will hold the Presidency in the first semester of 2010. Sec ondly, after the initial wave of labelling, 
it quickly became evident that the EHL is an initiative which is difficult to implement effectively and, as we will see in  detail in section 2.2. of this report, the 
present procedures and practical arrange ments of the EHL are far from being 
optimal.  
The Council conclusions were an essentia l element in our reflexion because the 
negotiations which led to th e adoption of these conclusi ons gave the MS a first 
opportunity to express their individual opinions on the EHL and on the added value 
of EU involvement, and because the final text  gives a detailed view of their common 
expectations concerning the new EHL. A lthough the Commission retains freedom in 
                                                
 
1 The list of these sites is in Anex 4. 
 
EN 7   EN its right of initiative, th e Council conclusions are an important political backdrop 
which cannot be ignored.  
The conclusions take into considerati on the main provisions of the existing 
intergovernmental EHL and emphasize the im portance of raising the awareness of 
young people of a shared European cultural he ritage and hence the need to promote 
their access to this shared heritage. Accord ing to the conclusions, the creation of a 
EHL by the EU which would aim to emph asize Europe's comm on history in a 
concrete way by enhancing the European dimension of its cultural heritage could contribute: 
¾ to enhancing the value and raising the profile of Memb er States' heritage and 
that of the shared cultural heritage, 
¾  to increasing knowledge and appreciati on among citizens of their history and 
their shared yet dive rse cultural heritage, 
¾ to artistic, cultural and historical edu cation and, in so doing, to stepping up 
intercultural dialogue, esp ecially among young people,  
¾ to the economic attractiveness and sust ainable development of regions, in 
particular through cultural tourism,  
¾ to the sharing of experiences and excha nge of best practices  across Europe as 
regards the enhancement of its cultural heritage, 
¾ more generally, to the prom otion of democratic valu es and human rights that 
form the foundation of European in tegration and European citizenship. 
It is important to underline that the ec onomic dimension of the EHL was not taken 
into account in the inte rgovernmental initiative. 
One of the main concerns of the MS duri ng the negotiations was to avoid duplication 
with existing initiati ves such as the UNESCO World Heri tage List and the Council of 
Europe's "European Cultural Routes" and to seek synergies and complementarities 
instead. It was therefore stated very clea rly during the discussions that the added 
value of the EHL should be based (1) on the contribution made by the selected sites to European history and cultu re, (2) on a clear educationa l dimension reaching out to 
citizens, and (3) on the networking of th e sites. It has become clear during the 
negotiations that the main focus of the EHL must be the interpretation and the promotion of the sites and not on conser vation and protection. It is also very 
important that the EHL, unlike other exis ting initiatives, shoul d not be awarded on 
the basis of the aesthetic value of a site, for exampl e its natural beauty or 
architectural quality, but strictly on the basis of its symbolic value, in other words on 
the basis of what it represents or stands for in the common history of Europe. The 
options which have been tested all take into account this essential starting point. 
 While the EHL is considered as a partic ularly important initiative by several MS, 
notably those which are at th e origin of the intergovernme ntal initiative, some other 
MS were more hesitant about the added valu e of this label and the actual need to 
make it a formal EU initiative. Therefor e, before the adoption of the Council 
 
EN 8   EN conclusions there was a consensus between the MS that the new "communautarised" 
initiative should have very limited c onsequences both on the EU budget and on 
national budgets and that the participation of MS should be  on a voluntary basis.   
In order to improve the implementation of  the EHL, the conclusions dedicate a 
considerable attention to the procedures a nd the practical arrangements of the future 
Label. The MS could reach an agreement on a number of principles:  
¾ The selection of sites shoul d be on a regular basis an d based on criteria that 
are common, clear and transparent; 
¾ The selection should be carri ed out initially at nationa l and then at European 
level based on expert assessment; 
¾ The number of sites covered each time should be reasonable and 
representative; 
¾ The administrative arrangements should be flexible and streamlined, in 
compliance with the subsidiarity principle; 
¾ Recipients should be require d to comply with undert akings they have given 
and could be subject to periodic review; 
¾ Sites already awarded the Label under th e intergovernmental initiative should 
be taken into account and their status defined; 
¾ The initiative could draw on existing EU  funding, without prejudice to the 
support policies conducted by each of the Member States; 
¾ The initiative could al so be open to thir d countries particip ating in the EU's 
Culture Programme as there was an assumption that the costs for these countries might be covered by the programme. 
At the same time, a number of questions we re also left open fo r further analysis 
during the negotiations and th e MS underlined that they  expect the Commission to 
come forward with concrete proposals. Thes e questions which can be summarised as 
follows became a central element of the subsequent consultation process: 
¾ What precisely is a reasonable and representative number of sites? 
¾ Shall the label be attributed to the sites for a limited period of time or on a 
permanent basis? 
¾ Shall the label be attributed on the basis of an open competition or shall there 
be a reserved quota of sites for each MS? 
¾ In the event of a quota system, how to determine the number of sites per 
country and should a system of rotati on between the MS be implemented in 
order to keep control over the total numb er of labelled sites and to help keep 
the selection and monitoring procedures manageable? 
 
EN 9   EN ¾ How to articulate the national level and the European level for the selection 
and monitoring procedures in order to ensure an homogeneous application of 
the rules while respecting the principle of subsidiarity? 
The MS were unanimous that new common, clear and transparent criteria and their 
proper application were essential for the re newed EHL. These criteria were discussed 
at great length during the negotiations and the main elements were included in the conclusions. Several considerations were taken into account. Firstly, the need to ensure that there will be no overlap with other existing initiatives in the field of 
cultural heritage and to guara ntee the added value of the EHL. Secondly, the need to 
ensure that the criteria will be efficient and unambiguous and at the same time that 
they will maintain a degree of flexibility in accordance  with the principle of 
subsidiarity, respecting the multitude and dive rsity of potential sites, and the reality 
that the evaluation of the sites will inevitably have a subjective element. The national and European selection panels therefore need to have some discretion and the 
experience of the European Capitals of  Culture was mentioned as a source of 
inspiration. Finally, it will be important to  adapt the level of requirements for the 
management of the sites to the specificity of each site. A very di verse range of sites 
can potentially be awarded the label: whereas ambitious educational, information or promotion activities could be feasible from prestigious sites with a strong touristic potential, the criteria might well be met in a more modest way in the case of smaller 
sites with a strong symbolic value. 
Because of the lengthy negotiations which already took place in the Council on the 
criteria and the limited room for manoeuvr e on this matter, and because the main 
challenge for the EHL will be the proper application of thes e criteria through an 
effective process, it has been decided to pres ent the criteria in greater detail in annex 
3 to this report and to limit the current IA  to a discussion of the label's administrative 
arrangements. 
1.2. Consultation of interested parties 
Broad consultation has been undertaken in  order to understand the various views on 
the EHL and to obtain necessary evidence. The consultation process started in March 
2009 and was carried out in different stag es for which all the required Commission 
consultation standards were applied. The re sults of the different elements of the 
consultation are summarized below and we re duly taken into  account for the 
subsequent steps of our analysis. 
 1.2.1. Internal consultations 
The existing Inter-service Group for Culture met three times for the IA of the EHL. 
At the first meeting on 9 March 2009 the general context of the EHL and the roadmap for the IA were discussed. The objective of the sec ond meeting on 29 June 
was to present the main results of the public consultation. The aim of the third 
meeting on 19 October was to discuss the first draft of the present IA report. The 
comments of the group were taken into acc ount for the finalisation of the report. 
 In addition to colleagues from various departments of DG EAC, representatives 
from SG, SJ, DG ELARG, DG ENTR, DG INFSO  and DG MARE participated in at 
least one of the meetings. DG COMP, DG RTD, AIDCO, BEPA and ESTAT while 
 
EN 10   EN not present at the meetings ha ve asked to be kept informed  about the various steps of 
the process. DG BUDG, DG AGRI, DG COMM, DG DEV, DG EMPL, DG ENV, 
DG JLS, DG MARKT, DG RELEX, DG REGIO, DG TAXUD and DG TRADE 
were invited but did not pa rticipate in the process. 
 1.2.2.  Consultation of stakeholders and European citizens 
 1.2.2.1 Online consultation 
An online consultation was held between  20 March to 15 Ma y 2009, to gather 
comments from the public. This consultation was carried out with the help of the 
Interactive Policy Making tool and was acce ssible in six languages. We received a 
total of 226 answers. 72% of the answ ers were from i ndividuals, 17%from 
organisations and 11%from public authoritie s. However caution needs to be applied 
when interpreting these figures as it was apparent in some answers that some smaller organisations preferred to answer as indi viduals in order to avoid the burden of 
registering in the Register of  Interest Representatives. 
The consultation consisted of 18 questions. Some of these questions were single 
choice questions and enabled a quantitative analysis to  be made. Other questions 
were open questions intended for a qualitati ve analysis. The statistics displayed 
below are simply meant to indicate the ge neral trends within the consultation. The 
sample is of course limited, making it diffi cult to draw general conclusions at the 
European level. 
The main results of the online consultation were the following
2: 
¾ Only 42% of the participants had previously heard about the 
intergovernmental EHL. This low per centage is surprising given that the 
majority of participants in the consulta tion had a pre-existing interest in the 
cultural heritage field. 
¾ 89% believe that the EHL can contribute  to a greater sense of belonging to 
the EU.  
¾ 90% believe that the involvement of th e EU will bring an added value to the 
EHL.  
¾ Concerning the potential im pacts of the EHL, the following elements were 
mentioned: a greater sense of common belonging, the promotion of European 
values, a higher profile for cultural he ritage, the strong educational value 
especially for young people, and economic development notably through tourism. 
¾ The following challenges and risks were  mentioned: the potentially limited 
impacts of the initiative, heavy bureaucracy, the costs, a risk of duplication with the UNESCO World Heritage List  or the Council of Europe Cultural 
Routes or the lack of clarity concerni ng the objectives and selection criteria 
                                                
 
2 The full report can be consulted at the following link:  
http://ec.europa.eu/culture/our-programmes-and-actions/doc/consultation_analysis_report_160709.pdf 
 
EN 11   EN which was considered as the main wea kness of the current intergovernmental 
initiative. It is very important to note that these perceived risks and challenges 
were mostly expressed in answers which were generally positive to the EHL. The 11% of answers mentioned above which were negative concerning the EHL and the 10% of answers whic h were negative concerning the 
involvement of the EU were either not explained or di d not enable any 
general trends to be drawn.  
¾ The expected benefits from EU involve ment are the following: a strengthened 
legitimacy and credibility for the EH L, clearer and more transparent 
objectives and criteria, greater impact  of the Label due to a permanent 
secretariat, improved coordination between participating countries, 
networking of sites, and bette r visibility of the EHL. 
¾ The originality of the EHL compared to other existing initiatives in the field 
of heritage should be based on: its st rong European dimension, its educational 
dimension, the fact that the symbolic valu e of sites is more important than the 
aesthetic dimension, the fact that pe dagogic and cultural programmes are at 
the core of the initiative rather than conservation, and the added value obtained from the networking of sites. 
¾ Opinions were quite divided concer ning the question of whether the EHL 
should be attributed on a permanent basis (54%) or for a limited duration 
(46%). It is interesting to note that those who were in favour of a limited 
duration generally considered that this  period should be renewable and those 
who were in favour of a permanent at tribution underlined the need for a 
strong monitoring system and ensuring the possibility of withdrawing the 
label if the sites no longer comply with the criteria. 
¾ Opinions were also divided concerni ng national quotas and the number of 
sites which should be attributed to  each country. A significant number of 
participants underlined that any quot a set in advance would end up being 
artificial and arbitrary and preferred instead an open competition at European level which does not take into account the national origin of the candidate 
sites.  
 1.2.2.2 Consultation meeting 
On 10 June 2009, a consultation meeting took place in Brussels
3. This meeting was 
open to all interested individua ls and organisations, rather than a pre-selected set of 
stakeholders. 71 participants registered incl uding representatives of key international 
and national organisations active in the field of heritage, pu blic authorities (national, 
regional and local level), heritage sites which had been awarded the EHL in the 
framework of the intergovernmental initiative, academics and students. 
The meeting was very constructive and generally positive for the EHL. The 
discussions were framed around the same questions as the online consultation and confirmed its main results. The same trends emerged concerning the potential 
                                                
 
3 The report of this meeting is in Annex 1. 
 
EN 12   EN impacts of the EHL, its originality or th e added value of EU intervention, and the 
same divisions appeared concerning the pr actical arrangements for the initiative. 
Five elements need to be underlined: 
¾ Representatives of the French Ministry of Culture which was at the origin at 
the EHL and of the Spanish Ministry of Culture which currently carries out the secretariat of the intergovernmental initiative chose to take part in the 
meeting, and on multiple occasions during the day the other participants made use of that to ask them for precisions concerning the actual objectives and procedures of the intergovernmental initiative. This wa s evidence of how 
little the current intergovernmental  label is known, even by the main 
stakeholders in the heritage sector.  
¾ There was general consensus that the EHL has a value of its own and does 
not overlap with other existing initi atives, such as the UNESCO World 
Heritage List, the Council of Europe Cultural Routes or the EU Prize for Cultural Heritage / Europa Nostra Awards. This was clearly confirmed by the representatives of ICOMOS (cons ultative body for the UNESCO World 
Heritage List), the European Institute of Cultural Routes and Europa Nostra which were present at the meeting. Nevert heless it demonstrated that clearer 
communication would be needed to clarif y the differences, especially for the 
general public (concerning the other in itiatives in the field of cultural 
heritage, see also annex 7). 
¾ Opinions were clearly divided concerni ng the selection pr ocedures to award 
the label. On the one hand, several repres entatives from civil society were in 
favour of an open competition at Europ ean level only in order to encourage 
the application of transnational sites, to ensure that the selection would be 
based on quality alone and to keep the pr actical arrangements light. They also 
underlined that some MS had a greater poo l of relevant site s than others. On 
the other hand, representatives of nationa l authorities insisted on the need to 
have a selection first at national and then  only at European level. In their view 
this would be the only way to deliver a fair geographical distribution of labels across the EU and thus to ensure the continuing participation and commitment of MS in the initiative, a nd the possibility to reach as large a 
number of citizens as possible. 
¾ In a first stage, opinions were also divided concerni ng the attribution of the 
EHL on a permanent basis or for a limited duration. Some representatives from civil society were in favour of a limited duration because this would be more effective in terms of keeping c ontrol over the overall number of sites 
and ensuring that the labelled sites con tinue to comply w ith the criteria and 
remain active. In contrast, managers of  heritage sites were totally opposed to 
a limited duration because this would be  counter-cultural for the heritage 
sector which is used to working on a long-term basis and because this would 
undermine the incentives for sites to invest in their development. They expressed their concern that such a deci sion would be felt by  the sector as a 
very awkward decision imposed by "B russels". The site managers were 
supported by the representatives of na tional authorities who also underlined 
that the EHL would be awarded mainly on  the basis of the symbolic value of 
 
EN 13   EN sites and that this symbolic would not  diminish over time. Over the debate, 
several civil society organisations, not ably Europa Nostra, changed their 
positions and a very clear consensus emer ged amongst all the participants that 
the best solution would be the attribu tion of the EHL on a permanent basis, 
but with a strong monitoring procedure and the possibility to withdraw the label.   
¾ With regards to impacts, there was a consensus amongst pa rticipants that 
these would be first and foremost politic al and educational impacts, in other 
words social impacts, and that the in itiative should focus mainly on these 
social impacts at the outset in order not to blur its message. There was also an interesting view expresse d that the social impacts should actually be 
expressed in terms of 'societal' impacts in order to emphasise that the primary effects were not about social inequality  but about identities. Opinions were 
rather mixed about the potential economi c impacts because a great variety of 
sites can potentially be awarded the la bel and their touris tic appeal will 
greatly depend on their natu re, size or location. Furt hermore, the contribution 
of the EHL will greatly depend on the pres tige the label will acquire and thus 
on its quality and credibility, and this was considered by participants as a 
potential benefit more likely to occur in the long-term (this issue will be further discussed in section 3).  
 1.2.3. Consultation meeting with MS experts 
On 24 June 2009, a meeting took place in Br ussels with experts designated by the 27 
MS
4. The concept of this meeting was differe nt from the meeting with stakeholders 
and citizens. As mentioned above, the MS had already ha d the opportunity to express 
their individual opinions on the EHL dur ing the negotiations for the Council 
conclusions and the adopted text gives a fairly detailed view of their common 
expectations. However a number of issues concerning the practical  arrangements of 
the future EHL were left open for further an alysis. Therefore the aim of this meeting 
was twofold: (1) to inform the MS about th e progresses of the IA and the first results 
of the consultation of stake holders and citizens and (2) to  make substantial progress 
on the questions which were still open. To  this end, a discussion paper summarising 
the main issues at stake and proposing gene ral orientations for the discussions was 
sent to the participants two weeks before the meeting.  
The 27 MS sent experts to this meeting and all of them, including the MS which 
were more reluctant during the negotiati ons for the adoption of the conclusions, 
contributed very constructively to the debate . At this stage it is likely that a very 
large majority of the MS would join  the new "communautarised" label. 
 A general consensus emerged between MS on several issues: 
¾ the EHL should be attributed on a perm anent basis. The two main reasons 
expressed by the 27 MS are very clos e to the conclusions which emerged 
during the consultation meeting with the stakeholders: (1) the label seeks to denote cultural heritage that  has played a key role in European history and 
                                                
 
4 The report of this meeting is in Annex 2. 
 
EN 14   EN which therefore has a symbolic value which does not diminish over time, and 
(2) it would be more likely to encourage sites to take a long term approach 
and to invest in their development. The MS also agreed that the permanent attribution of the label should be li nked to strong monitoring and review 
processes and the possibility to withdraw the label;  
¾ a selection procedure at European level only –as advocated by some 
stakeholders- is not acceptable for th e MS. They confirmed their wish for a 
two level approach. Several MS insisted that if the selection should take place 
at one level only, it should  be the national level; 
¾ a rotation system between the MS is an acceptable solution to keep the 
number of sites reasonable and to f acilitate the pract ical arrangements 
(several MS suggested that a good compro mise would be the participation of 
one third of the countries every year); 
¾ there should be a certain element of competition for the attribution of the 
label; 
¾ a permanent secretariat for the EHL is essential;  
¾ the EHL could be open to the count ries participating in the Culture 
programme, but as the implementation of the initiative is quite complex, it is 
wise to start first with the 27 MS before thinking a bout enlarging the 
initiative; 
¾ the application of transnationa l sites should be encouraged.  
However, despite the progress made dur ing the meeting, certain challenging 
questions remained open either because ther e were still divergences between MS (are 
national quotas needed? what is a reasonabl e number of labelled sites?) or, because 
the positions expressed by some of the MS were not entirely free of contradictions 
(How to reconcile the wish to have an open competition at European level with the 
will to keep a pre-selection at national level? how to foster the selection of transnational sites while setting quotas of  sites per country? how to ensure the 
excellence of the EHL and the relevance and quality of the select ed sites without any 
limitations on the number of labels awarded each year?)  
 1.2.4. External services 
Although most of the work has been c onducted in-house, and was based on the 
consultation steps described above, some suppo rt services to assi st the Commission 
in the preparation of the IA have been  asked from ECOTEC as part of a DG 
Education and Culture framework c ontract with this consultant. 
The main tasks requested of ECOTEC were: (1) to identify and analyse the existing 
literature and data in the field (2) to evaluate the strengths and weaknesses of the current intergovernmental EHL (3) to analyse other international cultural and heritage schemes, as well as other EU labe ls, in order to limit risks of overlap and 
learn any lessons (4) to assist the Commission in the analysis of the answers to the online consultation and (5) to provide the Commission with additional expertise 
 
EN 15   EN concerning the identification of the potential  impacts of the EHL, the comparison of 
the options and the definition of monito ring and evaluation indicators. The main 
results of ECOTEC's work are summarized in a report5. Sections 5, 6 and 7 of the 
present report prepared by the services of the Commission draws many elements 
form ECOTEC's support services. 
The regular meetings and exchanges with  ECOTEC experts' also provided the 
Commission with a good opportunity to te st and to fine tune its own ideas 
concerning the objectives of the EHL, the policy options and the development of the 
preferred option. 
2. SECTION 2: PROBLEM DEFINITION  
2.1. Problem 
 2.1.1. The problem in 2005 when the intergovernmental EHL was conceived 
As mentioned in the previous section, the concept of the EHL was born as one of the 
responses to the problem of  the existing gap between th e EU and its citizens and 
between the reality of European integration and people's perceptions. This gap is linked to an important extent to a lack of  knowledge of the history of Europe, of the 
role of the EU and of the f unctioning of its institutions.  
The aim of the EHL was to use the potent ial of cultural heri tage to strengthen 
European citizens' sense of belonging 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 contribution alongside other ini tiatives aimed at addressing the same 
problem such as for example the "Plan D for Democracy, Dialogue and Debate" or "Communicating Europe in Partnership" of DG Communication or the Europe for 
Citizens programme.  
This leads us to a second level of the problem which is that the reading or 
interpretation of cultural heritage in Eur ope, including of the most  symbolic sites of 
our shared heritage, is still to a very la rge extent a national reading. The European 
dimension of our common heritage is insuffi ciently highlighted and its potential to 
stimulate intercultural dialogue  is insufficiently exploite d. 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 have played a key role in building and uniting Europe, 
promoting a European reading of these site s, developing their e ducational potential, 
and fostering the exchange of expe rience and of best practices.  
The launch of the intergovernmental EHL wa s backed by a statistical survey carried 
out in five MS (Finlan d, France, Germany, Hungary and Italy) in March 2007 by 
IPSOS for the French Ministry of Culture
6. This survey showed that 60 % of the 
respondents believed that shared cultural he ritage could contribute to a greater sense 
                                                 
5 The full report can be consulted on:http://ec.europa .eu/dgs/education_culture/evalreports/index_en.htm  
6 http://www.culture.gouv.fr/culture/actualites/index-labeleurope.html 
 
EN 16   EN of belonging to Europe (85% in Italy, 76% in France, but only 11% in Hungary). 
However, the definition of what national heri tage is and what European heritage is 
varied considerably from one country to another, and 49% of the respondents 
believed that European cultural heritage is merely the addition of the national heritage of European countri es, while only 45% believed in  the existence of a truly 
common cultural heritage shared by the inhabi tants of the European Union. It is also 
interesting to note that Hungary, the only new Member State participating in this 
Survey, had a much more hesitant approach  towards the common heritage of Europe 
than the other participa ting countries: 5% only of  the Hungarian respondents 
believed that their national cultural herita ge "is completely a part" of European 
cultural heritage (52% in Italy, average 28%),    59% believed that Europe represents 
a risk for Hungary's own iden tity (13% in Ital y, average 34%), an d 29% only of the 
Hungarian respondents answered that they were more interested in the cultural 
heritage of other EU MS  than a few years ago (51% in Germany, average 44%). 
A Eurobarometer survey on cultural values in Europe carried out for DG Education 
and Culture in September 2007
7 confirmed the overall tendencies of the IPSOS 
survey. The aim of this survey was to m easure public opinion on culture and values 
in Europe and to form an initial insight into the ways in which citizens think and 
behave in this area, as well as to provide benchmarks against which future evolutions can be tracked. The survey was carried out  by TNS Opinion & Social, interviewing 
26,755 citizens in the 27 MS. 53% of respond ents agreed with the statement that 
Europe is too diverse to speak of a co mmon European culture (38% disagreed), 
however 77% agreed that the richness of Europe's culture comes from the history 
shared by its countries. The Eurobarometer also showed that respondents are as 
likely to be interested in arts and culture in  the rest of the world as in other European 
countries (13-14% being very interested and 43% fairly in terested). The survey also 
asked people about the ways in which Eur opeans could be assist ed to get to know 
one another better: 22% answered suppor t to heritage compared to 56% who 
answered teaching of forei gn languages or 41% menti oning increased student and 
teacher exchange programmes like Erasmus. This shows us on the one hand that the ambitions of the EHL in bringing citizens cl oser to each other and closer to Europe 
should remain modest, and that the label wi ll most probably not reach the same level 
of impacts in this respect as student ex changes or language learning. On the other 
hand, this also suggests that the potential role of heritage in developing mutual 
understanding is not sufficient ly recognised and exploited a nd that there is room for 
improvement. 
 2.1.2. The problem today 
In 2009, four years after the concept of the EHL was born, it is obvious that the gap 
between citizens and the EU still exists. This  has been demonstrated recently by the 
disappointing turnout in the European elections in June 2009. This has also been 
demonstrated by a number of Eurobarometer surveys such as for example the Eurobarometer 70 published in December 2008 which shows that the perception of the image of the EU has not improved over the past few years. On the contrary the 
                                                
 
7 http://ec.europa.eu/dgs/education_culture/publ/pdf/culture/barometer_en.pdf 
 
EN 17   EN number of Europeans who have a positive im age of the EU (45%) is at its lowest 
level since the autumn of 20058. 
At the second level of the problem, it is also clear that the EHL did not achieve 
concrete results so far despite the attr ibution of the Label to 64 sites since 20079. The 
European dimension of our common heritage  is still very insufficiently highlighted 
and its potential insufficiently exploited.  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. It would probably have  been surprising to find any major shift so quickly. 
But this is due also to the fact that the EHL is still very far from having reached its full potential and its implementation s hows many deficiencies which need to 
addressed as we will see in the next sect ion, notably concerning the educational and 
networking aspects
10. 
2.2. Baseline Scenario: the exis ting intergovernmental EHL 
 2.2.1 Rationale, objectives and proce dures of the intergovernmental EHL 
The rationale behind the intergovernmental EHL as described in the introduction to 
the EHL adopted by the partic ipating countries on 25 Janua ry 2007 is that "Cultural 
heritage forms an integral part of our European identity and of our shared values and principles. Today’s European culture is  based on a history of border crossing 
exchange and dialogue, of in teraction and transfer of people and values, of ideas, 
artistic movements and works of art.  The EHL was designed to promote the 
transnational European dimension of cultu ral property, monuments, natural or urban 
sites, tangible and intangible, contemporary and traditional heritage and sites that have played a key role in building and uniting Europe." 
The introduction to the EHL outlines the centr al objectives of the initiative which are 
"to strengthen the support of European citi zens for a shared European identity based 
on democratic values and human rights, a nd to foster a sense of belonging to a 
common cultural space". The intergovernme ntal EHL also aims "to encourage 
people’s understanding of, and respect an d support for, their heritage and it 
represents a means of protecting and promoti ng our cultural heritage, with the aim of 
identifying and passing on that he ritage to future generations". 
In order to achieve these obj ectives, participating countries  and labelled sites have to 
undertake education and information activi ties to promote the European dimension 
of heritage, as well as artistic and cultural activities to foster synergies between heritage and contemporary creation and creativit y. They have to ensure the quality of 
facilities, notably accessibility for all memb ers of the public. The establishment of a 
dynamic network of labelled sites is also foreseen. 
Rules of procedure for the EHL were adopted on 25 January 2007. If the main 
responsibility for the selection of sites and the implementation of the label remains at 
                                                
 
8 http://ec.europa.eu/public_opinion/archives/eb/eb70/eb70_first_en.pdf 
9 The list of these sites is in Annex 4. 
10 An evaluation of the intergovernmental EHL was carried out by ECOTEC (see Section 2.2.2). The 
results are part of the ECOTEC report:  
http://ec.europa.eu/dgs/education_culture/evalreports/index_en.htm 
 
EN 18   EN national level, the creation of a European heritage committee composed of the 
Ministries of Culture or their representa tives (supported if necessary by consultative 
bodies) is foreseen. The role of this committ ee is to seek a consensus on the sites pre-
selected at national level and to take the fi nal decision on the attri bution of the Label, 
as well as to establish a quality charter and to adopt the rules for the implementation of the EHL. A withdrawal clause is include d to enable the exclusion from the list of 
sites which do not respect the rules and c onditions. A transitional clause mentions 
that in a first stage each country can designate a maximum of 4 sites. 
 2.2.2 The weaknesses of the current intergovernmental EHL 
The weaknesses of the current EHL became ev ident as soon as the Commission started 
to look into this initiative. To name just two examples:  
¾ Up to the beginning of 2009, absolutely no structured information on the 
EHL was available on the internet. Some bits and pieces such as speeches or 
press releases were scattered on a va riety of sites, but it was almost 
impossible for an interested individua l or organisation to assemble these 
elements into coherent and reliable information. The situation started to 
evolve in March 2009 when the Spanish Ministry of Culture launched the first web-pages dedicated to the EHL. These web pages are however rather difficult to locate for the general public because they are embedded within the Min is try ' s w eb sit e.  T h ey  w ere a lso  initially accessible only in Spanish, and 
the pages are now gradually being translated into ot her languages. This is 
without any doubt one of the reasons why there is not much awareness of the 
existence of the EHL, and why even th e main stakeholders in the field of 
cultural heritage do not have a clear understanding of its precise objectives 
and procedures, as was demonstrated  by the various steps of the public 
consultation. 
¾ As mentioned earlier, 64 si tes in 18 countries have been awarded the label so 
far, but no database with the names and contact details of all the site 
managers exists. To this date, it was not possible for the Spanish Ministry to 
collect the necessary data from the pa rticipating countries, which also means 
that the secretariat of the EHL cannot ge t directly in touch with the managers 
of the 64 sites. 
A more detailed evaluation of the strength and weaknesses of the initiative was 
carried out by ECOTEC as part of their support services and confirmed the first 
impressions. This evaluation was based on a close examination of all the official 
documents of the intergovernmental initiativ e (rules of procedure, application forms, 
etc…), interviews with Ministry officials,  interviews with stakeholders, interviews 
and questionnaires sent to site  managers and site visits.  
The main findings of the evaluation of  the intergovernmental EHL can be 
summarized as follows: 
¾ The lack of clear and transparent obj ectives and procedures is the main 
criticism that was made to the EHL during the negotiations for the Council conclusions and during the public consu ltation.  A deeper examination shows 
that the label actually has fairly amb itious and coherent objectives, even if 
 
EN 19   EN they leave too much room for divergi ng interpretations, an d that rules of 
procedures were established to try to reach these objectives. The main 
problem is that to this date these rules of procedures were either not applied or insufficiently applied. 
¾ Despite all the enthusiasm and good will shown by the current secretariat of 
the initiative whose activities are pe rformed counting on support from the 
Spanish Ministry of Culture alone, the pr esent form of revolving secretariat is 
not an optimal form of organisation for a complex initiative such as this. The 
lack of continuity does not enable a long term-approach to be developed and 
the building up of the necessary expertise. 
¾ So far, the sites have been selected independently by participating countries 
and the interpretation and application of the selection criteria varied considerably from one country to another. The European committee foreseen in the rules of procedures was never es tablished and as a result there was no 
overseeing body to take the final decisi on on the attribution of the Label and 
to ensure the quality of the process in  all regards. As a consequence, the 
nature of the selected sites, their relevance, and their activities are rather disparate and in some cases difficult to comprehend.  
¾ With the present organisation, there is no means, via the secretariat, to be 
assured that sites gaining the label ar e maintained to any quality levels 
indicated in their original application, or are undertaking activities in line with the label to a degree of quality which reflects the merit associated with the label. 
¾ The educational aspects are regarded as fundamental by the institutional 
stakeholders and the site managers interviewed by ECOTEC, and some sites 
have developed interesting programmes,  however there is no evidence that 
these programmes have evolved since the attribution of the label or that the 
European dimension has been strengthened. 
¾ The networking between sites has limite d itself so far to one meeting 
organised by the French Presidency of  the EU in Avignon in December 2008 
which brought together repr esentatives from the first set of labelled sites. 
Little real progress has been made in promoting the transnational dimension of the EHL. 
¾ Concerning promotion and communicati on, as mentioned before, except for 
the web-pages recently developed by th e Spanish Ministry of Culture very 
little has been done to eff ectively promote the EHL at  a transnational level, 
neither for the heritage and culture co mmunity, nor for the general public. At 
national level, there is no evidence of an effective promotion of the EHL by 
the Ministries. At the level of the 64 labelled sites, 42 have a website and 
only 8 actually display the EHL logo as part of their web-pages. 
¾ The EHL has achieved few concrete result s so far, and since the initial wave 
of labelling there has been little forw ard momentum with the initiative. In 
order to make an impact, the EHL need s to take a qualitative step forward. 
 
EN 20   EN This means at minimum implementing the current rules and procedures, 
before addressing all their limitations.  
2.2.4 How would the problem evolve,  all things being equal?  
In the event that no action is taken by the EU , the most probable scenario is that the 
EHL would continue as an intergovernmenta l initiative, even if several MS have 
raised their concern that under the pres ent revolving secretariat of the EHL the 
durability of the initiative is far from bei ng ensured. After France in the initial phase 
and now Spain, no other MS has volunteered so far to take over the secretariat. Spain 
already drew attention to the burden created  by the current situ ation and underlined 
that such a revolving secretariat could onl y be a transitional so lution while waiting 
for the creation of a permanent secretariat. 
If the EHL continues as an intergovernmenta l initiative, the initiative needs to take a 
qualitative step forward in order to achiev e concrete results and to make an impact. 
However, at the present moment, there is absolutely no sign that the countries participating in the inter governmental EHL are ready to  take a more proactive 
approach without EU involvement. Therefore, the chances are very high that at best 
the intergovernmental approach will conti nue with a very low profile and with no 
significant results.  
2.3. Legal basis and subsidiarity 
The legal basis for this initiative can be found 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 shall 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 ne w common, clear and 
transparent selection criteria, as well as new selection and mon itoring 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 increasing the numb er of MS participating in the initiative, 
fostering the participation of transnational sites and resolving the problems linked to the present revolving secretaria t. According to the MS, this should help to improve 
the value of the initiative in order to en sure the quality, credibility and long-term 
success of the EHL. 
3. S
ECTION 3: OBJECTIVES  
 The proposed objectives for the renewed EHL derive from the objectives of the 
current intergovernmental initiative and fr om the Council conclusions which adapted 
and refined some of these original objec tives, but they were re-evaluated and 
redefined in order notab ly to ensure that they are su fficiently specific, realistic and 
measurable, in other words that they are "SMART" enough. 
 
EN 21   EN As already mentioned, the problem describe d in section 2.1.1 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 . Therefore it has been decided to propose 
four levels of objectives for the EHL: 
¾ At a very basic level, the operational objectives refer to the improvements of 
the practical arrangements which are needed in order to address the deficiencies of the current intergovernmental label, as well as to the actual activities which should be implemente d by the labelled sites. Output 
indicators would thus help to verify that sites receiving the Label have met 
the obligations they agreed to underta ke when they made their application 
and were selected.  
¾ The specific objectives relate to th e direct improvements that sites – 
individually and collectively - would be intended to deliver as a result of their 
activities linked to the EHL designation or that the new practical arrangements would be intended to deliv er. Hence result indicators would go 
beyond simply cataloguing what was done to  look at its direct effects.   
¾ The intermediate objectives are the highest level of impact that the EHL can 
achieve on its own. They refer to the impacts of the EHL on individuals and 
on heritage as a whole. At  this level, the impacts can be measured and / or 
assessed with a degree of certainty with intermediate impact indicators. 
¾ The general objectives reflect the overal l ambition of the EHL and link it into 
the wider EU policy agenda. These goals are subject to many complex influences and whilst the EHL can make some contribution to their 
achievement, separating out and measuri ng that effect would be enormously 
difficult. It is important to repeat on ce again that the ambitions of the EHL 
concerning these general objectives are modest and that the contribution of 
the label will certainly not reach the sa me level of impacts as for example 
student exchanges or  language learning. 
 It should be noted that the economic di mension of the EHL, notably linked to 
tourism, has been included only through specific and operational objectives related mainly to the marketing and the pr omotion of the sites. This is due to a 
number of factors. Firstly, as mentione d earlier, during the consultation process 
many stakeholders insisted that the prim ary effects of the EHL will be and should 
be social ones and they warned that stressing the economic objectives too much 
might blur the message of what the la bel is trying to achieve. The EHL may 
stimulate tourism and associated gains, but it is most appropriate to see these as secondary, indirect benefits.  
Secondly, one of the specifici ties of the EHL is that the symbolic value of the 
sites and their European significance is more  important than their aesthetic value. 
As a result, a great diversity of sites can possibly be awarded th e label, some with 
a potential for touristic "mass appeal", others with less, some which already 
attract numerous visitors before being la belled, and others which are basically 
unknown. As a result it is almost impossi ble to set common economic objectives 
to be reached by all the sites without di storting the central aim of the label.  
 
EN 22   EN Thirdly, the capacity of the EHL to have a significant impact on the number of 
visitors to a site will depend greatly on the quality and the credibility the label 
will acquire and thus on the prestige it wi ll develop. This is a process which will 
take a number of years. It would theref ore seem more appropr iate to consider 
building in more ambitious economic objec tives at a later st age after evaluation 
of the initial functioni ng of the initiative.  
This should however not prevent the MS  and sites wishing to exploit the 
economic dimension of the EHL more activ ely to do so already in the initial 
stage. 
3.1. General objectives 
¾ Strengthen European citizens' sense of belonging to the European Union 
based on shared elements of history a nd cultural heritage, as well as an 
appreciation of diversity. 
¾ Strengthen intercultural dialogue 
3.2. Intermediate objectives 
¾ Enhance the value and profile of  sites which have played a key role in the 
history and the building of the European Union  
¾ Increase European citizens' understanding of the building of Europe, and their 
common yet diverse cultural heritage, esp ecially related to democratic values 
and human rights that underp in European integration 
3.3. Specific objectives 
¾ Develop sites' European significance 
¾ Raise young people's awareness of their common cultu ral heritage 
¾ Facilitate sharing of e xperiences and exchanges of best practice across 
Europe 
¾ Increase access to heritage sites for all members of the public, especially 
young people 
¾ Increase intercultural dialogue, especially among young people, through 
artistic, cultural and historical education 
¾ Foster synergies between cultural he ritage and contemporary creation and 
creativity 
¾ Contribute to the attrac tiveness and the sustaina ble development of the 
regions 
 
 
EN 23   EN 3.4. Operational objectives 
a) Practical arrangements for the EHL 
¾ Ensure the application of  common, clear and transp arent  criteria for the 
selection of the sites 
¾ Foster a fair distribut ion of labels across the European Union  
¾ Introduce a monitoring procedur e to ensure that the labe lled sites respect their 
commitments 
¾ Improve the complementarity with other initiatives in the field of cultural 
heritage, notably through good communica tion with relevant   international 
bodies 
¾ Ensure that the practical arrangements remain light and flexible for the EU 
and the MS 
¾ Increase the visibility at European le vel, notably through the development of 
a website 
¾ Develop transnational networks of sites to develop their European profile and 
exchange 
b) Activities of the labelled sites 
¾ Develop the European dimension of sites through appropriate information 
activities and multilingual signage 
¾ Develop programmes of educational activities 
¾ Undertake marketing and promotion of si tes as tourist destinations locally, 
nationally and at European level 
¾ Develop access to sites thr ough site adaptations, visito r tools, staff training, 
privileged access for the young public 
¾ Develop programmes of cultural activit ies: events, festivals, artist-in-
residence schemes, etc 
3.5. Consistency of these objectives with other EU policies 
These objectives will help to meet the ch allenges mentioned in section 2 alongside 
other initiatives aimed at filling the gap between citizens and the EU such as the 
various EC initiatives in the fiel d of information and communication. 
They will contribute to th e objectives of the European agenda for culture which are 
notably to foster cultural diversity and in tercultural dialogue and to promote culture 
as catalyst for creativity. They are also fully in line with the goals of the new EU strategy for youth to improve access and full participation of young people in society 
and to foster solidarity between youth and society, as well as with other DG 
 
EN 24   EN Education and Culture policies and programme s such as Lifelong Learning or Europe 
for Citizens. 
They are consistent with the activities in the field of heritage and tourism of other 
services of the Commission such as DG Information Society and Media, DG 
Maritime Affairs and Fisheries, DG Regiona l Policy or DG Enterprise and Industry. 
They are also related to the Integrated Guidelines for Growth and Jobs 2008-10 
which continue to emphasise the need to strengthen territorial and social cohesion, 
not least as a consequence of the devel opment of large volumes of cross-border 
migration or to the Renewed Social Age nda which aims to develop cohesive and 
inclusive societies. 
4. SECTION 4: POLICY OPTIONS  
In order to achieve the objectives of the EHL, a wide range of policy options was 
considered. These options were then na rrowed down through an initial screening 
taking into account the techni cal constraints of the EHL. Options which appeared to 
be completely unrealistic or unfeasible were excluded from further analysis. 
4.1. Policy options not retained for analysis 
The Council conclusions mention that th e new EHL should keep "flexible and 
streamline administrative arrangements in  compliance with the principle of 
subsidiarity." This was ind eed a central element in the negotiations for the adoption 
of the conclusions. Without a strong commit ment to keep the co sts limited both at 
national and European leve l and a strong commitment to avoid all unnecessary 
bureaucracy, no agreement could have been  reached between the MS. This same 
concern was also expressed on numerous occasions during the consultation process 
and it has been reinforced by the current c ontext of financial and economic crisis 
which makes it highly unlikely that much f unding will be available either at national 
or European level for the EHL in the coming years. 
In light of these factors we exclude d an option which would have involved 
continuing the EHL as an intergovernmental initiative but with significant financial 
support from the EU to develop sites and th e networking between them, as well as an 
option which would have involved transformi ng the EHL into a EU initiative with 
significant financial s upport to the sites. 
 Because of the very clear consensus wh ich emerged during the consultation phase 
(see sections 1.2.2. and 1.2.3.), all the retained options are based on the attribution of 
the EHL on a permanent basis with a strong monitoring procedure and the possibility 
to withdraw the label. Options based on the attribution of the EHL for a limited 
duration were considered as un- realistic because of the retice nce of a vast majority of 
MS and were therefore excluded from further analysis.  
4.2. Options retained for analysis 
Flowing out of the screening process me ntioned above, three main options were 
developed, with one of the options containing three sub-opt ions.  All of these options 
 
EN 25   EN would have very limited impacts on the EU budget. All of them also respect the 
principles of subsidiarity and proportionality. 
 4.2.1. Option 1: Status quo (baseline scenario) 
The EHL continues as an intergovernmenta l initiative with a secretariat hosted by 
participating countries on a revolving basis (unfunded by the EU) and without any 
EU action. This is the baseline option agai nst which the other options are tested.   
 4.2.2. 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 runni ng costs of the secretariat, part of the 
communication costs, expert meetings a nd networking. Funding would have to come 
from either the current or future Cultu re programme. With this option, no new 
legislation as such is needed, although it mi ght be necessary to take into account the 
specificity of the EHL while preparing the legal base of the future Culture programme 
 4.2.3. Option 3: The EHL becomes a EU in itiative 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 share 
clearly the tasks and responsibilities 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 direct or ganisation of expert meetings by the 
Commission. The Commission w ould also be responsible for the communication and 
the visibility of the EHL at  European level. Three sub-options are possible according 
to the various selection and monitori ng procedures that came up during the 
consultation phase: 
¾ 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 which could be on a rotating basis.  
The sites are then validated by the EU. Monitoring is a MS responsibility. The function of the Commission is to en sure a good coordination between the 
MS and the smooth running of the proce dures and the practical arrangements. 
¾ 3(b) Sites are selected th rough an open selection pr ocess which does not take 
into account the national origin of th e 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. 
¾ 3(c) Sites are pre-selected by MS and th en subject to final selection by an 
independent panel at EU level.  MS no minations could be on a rotating basis. 
Monitoring is primarily a MS responsibi lity, but with supe rvision and review 
by the independent panel. 
 
EN 26   EN 5. SECTION 5: ANALYSIS OF IMPACTS  
5.1. Development of the framework of impacts 
In order to undertake the impact assessm ent a range of potential impacts were 
identified. These were derived from cons ideration of a number of sources: from a 
review of the literature relating to the im pact of culture and heritage; from an 
analysis of the objectives of the EHL; a nd from the comments and perspectives of 
individuals, organisations and MS who pa rticipated in the consultation process. 
A number of considerations were importa nt in assembling the list of potential 
impacts and then determining the likely impact of the EHL. 
It is clear from the objectives of the EHL th at the primary direct effects of the Label 
are likely to be social ones.  As alrea dy mentioned in secti on 1.2.2.2., the participants 
in the consultation meeting placed par ticular emphasis on the political and 
educational dimensions and they stressed th at the EHL should be concerned mostly 
with social / societal changes. A majority  of the impacts examined in table 1 are 
therefore social / societal impacts. 
Included in these social / societal imp acts are the potential impacts on fundamental 
rights. As pointed out several times in the preceding sections of this report, European common values are at the core of the EH L and one of the foundation stones for the 
initiative concerns the building of a shar ed European identity based on democratic 
values and human rights.  It should therefore be noted that the label is likely to have 
positive impacts (and certainly no negative ones) and thereby make a contribution to the objectives of the Charter of Funda mental Rights of the European Union. 
Concerning the economic benefits of the EHL,  as discussed in section 3, they should 
rather be considered as secondary or indirect  benefits in a first stage.  The potential 
impacts of the EHL on the local tourism i ndustry have however been analysed. Some 
economic impacts are also possible in rela tion to innovation and creativity.  One of 
the objectives of the EHL is to link cu ltural heritage to contemporary cultural 
activities and creation. Much will depend here on individual sites and their immediate local context, and on the extent  to which active progr ammes of linking to 
creative industries and artists etc are built in to sites' projects – and then delivered.  
And this will depend in part on the extent to which this is emphasised during the selection process. 
In relation to environmental impacts, these are unlikely in general to be substantial.  
There is a risk that tourist footfall could become a problem at some sites but as we 
have seen, this should remain limited in a first stage.  The EHL is also not primarily about conservation.  There are a number of ac colades in that doma in already (e.g. the 
UNESCO World Heritage List or the Europa  Nostra Awards, as well as numerous 
designations at national level) and whilst the EHL may secure the future of some 
sites for future generations that would othe rwise not have been saved, it is important 
that it does not become seen as a Label for sites that could not secure one of these other designations. 
Finally, the EHL will have no negative impacts on third countries. On the contrary, if 
at some stage of its devel opment the EHL opens up to thir d countries participating in 
 
EN 27   EN the Culture programme as suggested by the Council conclusions, the potential 
benefits of the EHL will extend to these countries. 
5.2. The chain of effects 
The most direct effects of the Label will be on the sites themselves and then on 
individual citizens: indeed without those impacts on the sites, positive impacts on 
individuals will not be achieved.  Thus the primary effects should be on raising the 
European dimension and the profile of sites, and on increasing access, especially for young people.  Once such improvements are ac hieved we would then expect to see 
benefits on individuals in terms of in creased interest in and understanding of 
European heritage, and Europe's cultural diversity.   
Clearly at this point in the chain of e ffects, however, the po ssibility of positive 
effects starts to become affected by many other factors.  The ultimate goal of the 
EHL is to change individual attitudes, and not  just in terms of a person's view on this 
or that subject, but at a very deep-rooted level, namely their identity.  Not only is this a very complex area, but it raises an insurm ountable difficulty in terms of attributing 
someone's 'change of mind' to the EHL or  indeed to any other single effect.  
Compared to the other influences on some one's identity, a visit to a labelled site 
clearly – in general – should not be counted as a ma jor influence, although equally 
we cannot rule out the possibility that for any one indi vidual a visit to  certain sites 
could have a profound impact.  For this r eason, it would be unrealistic to expect the 
EHL in general and in aggregat e to have anything other than  a modest effect in areas 
such as the level of a greater sense of bel onging to the EU and intercultural dialogue.  
Still less would we then antic ipate a strong effect on behaviour such as participation 
in the democratic process. 
5.3. Quantification versus qualitative analysis 
It has not been possible to make quantitati ve estimates of the likely impacts for the 
EHL.  No data is for example available from the sites which were awarded the EHL 
under the intergovernmental initiative that would enable us to construct reliable 
estimates of effects. Furthermore, if there is a growing literature on cultural heritage, 
most of the evidence about the socio-economic  benefits of heritage is of a very 
general or unquantified natu re. The literature review carried out by ECOTEC did 
help to understand the broad types of imp act that might be possible and the likely 
balance of social, economic and environmental impacts, but it did not help with estimating the potential magnitudes of any e ffects and it did certainly not help to 
understand the effect that a designation such  as the EHL might have over and above 
the impacts that would be taking place in the absence of the designation. Even the 
most prestigious designations such as th e UNESCO World Heritage  List have been 
the subject of very few detailed studies  and in the UNESCO's own words: "the 
economic impact for local communities when a site is inscribed on the World Heritage List is still to be measured"
11.  Consequently, the a ssessment of options is 
conducted in qualitative and comparative terms. In the following section, an 
assessment is made of each option in te rms of whether it would lead to an 
improvement or deterioration in an impact. 
                                                 
11 http://unesdoc.unesco.org/images/0018/001809/180960m.pdf 
 
EN 28   EN With a view to measuring th e impacts of the EHL in the future, section 7.2.  proposes 
a set of indicators for the evaluation of  the initiative which should enable also a 
quantitative analysis of the Label. 
5.4. The likely impacts of th e various policy options 
The summary table below presents a comparative assessment of the likely impact of 
the EHL under the different options. It wa s developed in clos e cooperation with 
ECOTEC and is based on the external expe rtise provided by the consultant. Against 
each impact an indication is given of the likely difference of each impact compared 
to the baseline. In the full table in annex 5, an explanation is also provided as to the 
assessment made.  Naturally these differen ces depend on a chain of causality that 
runs from the changes envisaged under each  option and further discussion of this is 
provided in the subsequent section that deals with efficiency, effectiveness and coherence. 
 
EN 29   EN  
Table 1:  Comparison of options in terms of likely impacts compared to the baseline option 
Option 3: EU initiative…  
 
Option Option 1: 
Status quo Option 2: 
Status quo plus 
EU funding ..with MS 
selection 
(a) ..with EU level 
selection (b) .. with MS pre-
selection and 
EU level 
approval (c) 
KEY: 
=  baseline or equivalent to baseline             + to +++ minor to major improvement compared to baseline    
 - to --- minor to major worsening compared to baseline 
SOCIAL/SOCIETAL IMPACTS 
Increased access to cultural 
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 = = = = = 
ECONOMIC IMPACTS 
Positive effects on the local 
tourism industry, including 
number of people employed = = (+) (+) (++) 
Development of links with 
cultural and creative industries = = (+) (+) (+) 
Development of innovation and 
creativity = = (+) (+) (+) 
ENVIRONMENTAL IMPACTS 
Negative effects linked to over-
development of tourism = = + + + 
Protection of cultural heritage = = + = + 
 
 
EN 30   EN 6. SECTION 6: COMPARING THE OPTIONS  
6.1. Criteria for comparing the options  
Having looked at the likely impacts of the di fferent options we turn  in this section to 
an assessment in terms of three main criteria: effectiveness, efficiency and coherence. However, within these general cr iteria there are a range of sub-criteria to 
consider. These derive from the key featur es of the current EH L, from the Council 
conclusions, from the consultation process, and from the lessons learnt from other 
labelling and award schemes.  The criter ia selected are shown below and reflect 
closely all of the objectives proposed in section 3: 
Effectiveness 
¾ Representativeness – As mentioned above, it is important that the EHL is able 
to deliver a fair distribution of Labels across the EU Member States to ensure 
continuing participation and commitment in the development of a shared European identity. 
¾ European dimension, significance of sites – It is essential for the EHL that 
national interpretations of culture and history are balanced with interpretations of sites' European significance. 
¾ Transnationality and networking – This needs to be a key component of the 
EHL if it is to realise its aspirations to build a shared understanding of 
European cultural heritage. Inter alia it will enable the sharing of good 
practice, for example in relation to ways of improving access to sites. 
¾ Visibility and profile – Having a high profile will be important for the EHL 
as it seeks to impact on the attitudes a nd identities of Europeans, and is also 
central to improving access, especial ly for young people, where new and 
creative ways may need to be found to open up sites. 
¾ Artistic, cultural and historical e ducation – Effective programmes of 
educational activities will be centr al to the success of the EHL in 
promulgating the role of sites in European culture and heritage and 
demonstrating the importance of interc ultural dialogue to the development of 
tolerance and understanding. 
¾ Programmes of cultural activities – It is important that the culture and 
heritage of EHL sites do not ossify a nd that their relevance to contemporary 
life is demonstrated through links to  contemporary cultu ral activities and 
creativity.  Programmes of cultural activ ities will be an important means by 
which this can be achieved. 
 
  
 
EN 31   EN Efficiency  
¾ Selection processes – These are core to differentiating the options and 
different options offer different combinations of advantages and 
disadvantages. 
¾ Delivery and compliance – Options are likely to vary in their ability to 
implement effective monitoring and evaluation processes. 
¾ Administrative arrangements – It is important that wh ichever option is chosen 
the resulting administrative arrangements are 'flexible and streamlined/light'.  
¾ Financial effects – Related to the preced ing point, considerat ion also needs to 
be given to the financial implications  for the EU for each of the options. 
¾ Communication with other international bodies – Gi ven the nature of the 
EHL concept and the existence of similar schemes, the ability to communicate with other bodies will be an important feature of the Label 
going forward. 
Coherence 
¾ Limitations of trade-offs across social, economic and environmental domains 
– The economic impacts of sites, though likely to be limited (as discussed in 
the preceding impact assessment), may bring negative environmental effects, and to mitigate these, conservation will need to be one of the criteria in 
awarding the Label.  It is important to assess the extent to which the options 
will affect this trade-off.   
¾ Synergies and complementarities with other initiatives – Synergies and 
complementarities offer the prospect of  increasing the impact of the EHL. 
Some options may be more likely  to offer them than others. 
¾ Participation of third countries in the Culture program me – Although such 
participation is likely to take plac e only once the EHL is well established, 
consideration should be given to which option is more likel y to deliver this 
effectively and efficiently. 
In the following section each of the options is  assessed against each  of these criteria 
in terms of whether they would be likely to achieve an improvement or a worsening 
compared to the baseline position. 
6.2. Comparison of the options against e ffectiveness, efficiency and coherence 
criteria 
The summary table below, prepared in cooperation with ECOTEC, presents the 
scores of the options. The full table, including the comments, is in annex 6.
 
EN 32   EN Table 2:  Comparison of the opt ions against effectiveness, e fficiency and coherence criteria 
Option 3: EU initiative…  
 
Option Option 1: 
Status quo Option 2: 
Status quo 
plus EU 
funding ..with MS 
selection 
(a) ..with EU level 
selection (b) .. with MS pre-
selection and EU 
level selection (c) 
KEY: 
=  baseline or equivalent to baseline             + to +++ minor to major improvement compared to baseline                         
- to --- minor to major wors ening compared to baseline  
EFFECTIVENESS 
Representativeness  = = +  - + 
European dimension – significance 
of sites = (+) + +++ ++ 
Transnationality and networking = + + +++ ++ 
Visibility, profile and access = + ++ ++ +++ 
Artistic, cultural and historical 
education = = + ++ ++ 
Programmes of cultural activities = = + ++ ++ 
EFFICIENCY 
Selection processes = = + ++ +++ 
Delivery and compliance 
(monitoring and QA) = (+) ++ + +++ 
Administrative arrangements at 
EU and MS level = - - -- --- 
Financial impacts for the EU = - -- --- -- 
Communication with other 
international bodies = + ++ +++ +++ 
COHERENCE 
Limitation of trade-offs across 
social, economic and 
environmental domains = = + + + 
Synergies and complementarities 
with other initiatives = = ++ +++ +++ 
Participation of third countries in 
Culture programme  = = +++ +++ +++ 
 
EN 33   EN  
6.3. Option 1: Status quo (baseline scenario) 
As already mentioned in section 2.2. and illustrated in tables 1 and 2, if the EHL 
continues as an intergovernmental initiative, it would need to take a qualitative step forward in order to reach concrete result s and to make an impact. However, at the 
present moment, there is absolutely no sign that the countries participating in the 
intergovernmental EHL are ready to take a more pr oactive approach. On the 
contrary, the adoption of the Council conclu sions suggests that the MS are convinced 
that the EHL can only reach its full potential  through the 'communautarisation' of the 
label. Without such a 'communautarisation', the chances are very high that at best the 
initiative will continue with a very low profile and with no significant results. Option 1 would also imply that the Commission ignores the request made by the Council. 
6.4. Option 2: Status quo plus limited EU financial support   
Thanks to the additional funding, this opti on is likely to deliver a small number of 
effectiveness and efficiency improvements compared to the baseline scenario which would feed through into some  minor improvements on a limited range of impacts.  
The most significant effectiveness and effi ciency gains are likely in the areas of 
transnationality/networking, and visibility /profile where additional funding might 
facilitate an increase in relevant activ ity including marketing and promotion.  These 
improvements might then feed through into  slight improvements in individuals' 
access to cultural heritage, including possi bly youth access.  There might also be 
some enhancement in the emphasis placed on the European significance of sites (e.g. 
through support to expert meetings) which, combined with the increased visibility 
and profile of sites, might deliver a rise  in interest in and knowledge of common 
European heritage.  However, with th is option there is no guarantee that the 
numerous shortfalls in the practical arrangements and in  the implementation of the 
initiative analysed in secti on 2.2.2. would be tackled effectiv ely, and, as a result, that 
the overall quality of the initiative would improve significantly. It is also unlikely 
that this option would lever any significant benefits in terms of improved educational 
or cultural activity programmes. Option 2 (as option 1) would finally lack the 
strengthened legitimacy and credibility that  comes from being an EU initiative and 
which was mentioned on numerous occasions during the public consultation. For all these reasons, it is very unlikely that th e minor improvements that could be realised 
under option 2 would feed through in to wider and deeper impacts. 
6.5. Option 3: The EHL becomes a EU initia tive through a decision by the Council 
and the Parliament  
The most substantial improvements in im pacts would be achieved by making the EHL 
a EU initiative. Within this broad option, the sub-option of MS selection with a EU 
secretariat (3a) would probabl y deliver less marked improvements across the range of 
impacts and the fewest effectiveness and efficiency gains.  This option 
 
EN 34   EN would involve a less 'activ e' EU level which would pr obably mean less emphasis 
placed upon and ability to real ise in particular the Europe an dimension, as well as 
transnationality and networking, or less likelihood of achieving improvements in education and cultural activity  programmes. It would also  make it less likely that 
visibility and profile could be raised to th e same degree as with a stronger EU tier.  
As regards selection processes, transparen cy and clarity would probably not be as 
strong as under sub-options 3b and 3c and it would not be as possible to ensure the consistent application of criteria.  The international aspects of the EHL (communication with other in ternational bodies and synerg ies and complementarities 
with other initiatives) woul d also probably be weaker under sub-option 3a.  As a 
consequence of these weaknesses, sub-op tion 3a would probabl y not deliver the 
same level of improvements in impacts as  could be achieved under 3b and 3c.  With 
weaker visibility/profile and less emphasis on the European dimension and 
transnationality/networking, this sub-option would be less likely to increase the 
numbers of individuals accessing cultural he ritage and especia lly appreciating its 
European aspects. 
In contrast, more active EU involvement  (sub-options 3b and 3c) would be more 
likely to deliver greater bene fits on account of: being able to ensure a greater focus 
on the European dimension, on transnatio nality and networking, and on enhancing 
educational programmes and programmes of cu ltural activities; being better equipped 
in terms of marketing and promotion; and ha ving an enhanced capability in relation 
to monitoring and evaluation and adherence to quality standards.   These factors would give sub-options 3b and 3c the prope nsity to drive up performance across a 
range of impacts, especially the social/societal ones.   
Naturally, for the reasons already not ed, even under these sub-options the 
achievement of greater economic impacts w ould be difficult at the outset, although 
some minor improvements to economic impa cts would be possible if links were 
made to other areas of EU policy and programmes (in the ar eas of cultural and 
creative industries and innovation and creativity for example), and through 
networked activity in relation to tourism.  These would probably be realised over the 
longer term.  Through the new selection cr iteria and the enha nced monitoring 
capacity that would be achievable under a EU  initiative, some positive impact might 
be possible in relation to the attenuation of negative environmental effects linked to 
the development of tourism, but this is likely to be limited. 
If we compare now sub-options 3b (selecti on at EU level only) and 3c (combined 
MS and EU level selection), sub-option 3c o ffers the prospect of the same or better 
level of improvement as 3b across all imp acts, except the increased understanding of 
cultural diversity (Table 1). In relation to the two impacts related to access, sub-option 3c is likely to deliver greater improve ments by being better ab le to ensure that 
priority is accorded and delivered, not l east through the commitment from and links 
between ministries that could be forged at  national level. This was referred to very 
strongly during the consultation process. In relation to the effectiveness and 
efficiency criteria, sub-option 3c is  also preferable on the basis that: 
¾ it would continue to ensure a fair di stribution of sites across Europe and 
hence be more likely to ensure the ownership and the commitment of all 
 
EN 35   EN Member States, even if this implies the equal treatment of all the MS while 
the pools of relevant sites may differ  from one country to another;  
¾ it is likely to be more effective in rela tion to the visibility and profile of the 
EHL since both levels could be engaged in marketing and publicity; 
¾ it would be able to draw both on MS and EU resources  in relation to selection 
and monitoring, whilst ensuring a consiste nt application of criteria and the 
engagement of all EU countries in the complex process of realising a shared 
sense of European identity; 
¾ it would realise the same improvements as  the EU only model (3b) in relation 
to the criteria related to communicati on with other international bodies and 
coherence. 
6.6. Administrative arrangemen ts and financial impacts 
Whilst sub-option 3c offers the advantages me ntioned above, it is  also necessary to 
take into account the extent to which ad ministrative arrangements across the options 
and sub-options are 'flexible and streamlined'.   This requires us to take into account 
the fact that there is some trade-off betw een overall efficiency and effectiveness and 
the burden of administration: the lightest and most flexible administration is not 
necessarily the most effective or efficient; balance is key. 
Option 1 would have no impact at all fo r the EU. All administrative arrangements 
and costs remain at MS level. 
With option 2, the only involvement of the EU would be through a grant to support 
part of the running costs of the secretariat, pa rt of the communica tion costs, expert 
meetings and networking. Funding would have  to come from either the current or 
future Culture programme. One basis to es timate the size of the grant for the EHL, 
could be the current EU Prizes for herita ge, literature, architecture or music which 
cover selection procedures, visibility a nd some staffing costs, but no networking. 
These grants range from 200 000 € to 360 000 € for total budgets which range from 
333 333 € to 704 000 €. It needs to be pointed out that by definition grants consist of 
co-financing only, meaning that the recipient organisations must also put in resources 
of their own, which would not be straig htforward with an intergovernmental 
arrangement. It also needs to be recal led that EU grants are subject to open 
competition, which creates uncertainty and reduces the reliability of this option. 
With option 3, the administrative arrangement s and the costs would be greater for the 
EU. A secretariat would be provided by the Commission. Some limited financial 
support would be provided to assist the tr ansnational networking of the sites. The 
Commission would also be responsible for the communication and the visibility of 
the EHL at European level. On the basis of  the experience of th e European Capitals 
of Culture they can be estimated as follows for the 3 sub-options.  
   
 
EN 36   EN  
Costs per year Sub-option 3a  Sub-option 3b Sub-option 3c 
Secretariat 1 staff member 
122 000 € 2 staff members 
244 000 € 2 staff members 
244 000 € 
Selection - 400 000 € 200 000 € 
Visibility 250 000 € 250 000 € 250 000 € 
Networking 300 000 € 300 000 € 300 000 € 
Total 672 000 € 1 114 000 € 994 000 € 
 The costs for visibility and networking would remain the same across the three 
options. The variations are linked to the selection procedure. With selection at 
national level only (3a), there would be no co sts at EU level and less staff needed in 
the secretariat. With selection at EU leve l only and thus without  the filtering of the 
pre-selection at national level, the number of applications to evaluate by the independent panel of experts would be mu ch higher which would increase the linked 
costs. 
With option 3, the only compulsory expenses  for a MS would be the costs of their 
own pre-selection (3c) or selection procedur e (3a) and of the monitoring of the sites 
located on the national territory (3a and 3c). If a parallel is drawn with the European 
Capitals of Culture, the selection process in MS typically occupies one member of 
staff in the national ministri es or organising bodies du ring the relevant period. Any 
additional costs would be a national ma tter. Sub-option 3b with selection and 
monitoring at EU level would have much  fewer administrative and financial 
implications for the MS, but as seen in section 1.2.3., the MS were not in favour of 
this option during the consultation meeti ng and preferred a two level approach.  
It is very difficult to quantify the costs for the MS, as the nature and the size of the 
selection and monitoring procedures will greatly depend on the specificities of each MS. The needs will not be the same for a big MS with a large pool of potential sites, 
than for smaller MS with only a few potenti al sites. In accordance with the principle 
of subsidiarity, each MS should also have the possibility to establish the type of 
selection or monitoring procedure which is the most adapted to the national context. 
A flexible approach should enable each MS to choose the most cost-effective 
solution.  
As a conclusion, option 3c is not the light est option but, as we have shown in the 
previous sections, greater benefits would be realised across most of the criteria and 
hence greater cost-effectiveness would be achieved. Furthermore, the increase of the 
administrative and financial "burden" is not expected to be significant compared to 
the baseline or the other options, and it woul d be spread across the EU and MS. This 
option would also have the advantage of having greater pol itical "buy in" or 
 
EN 37   EN commitment by the MS, which would conseque ntly make it more likely that the sites 
would be made a priority in accessing f unding through national sources or nationally 
administered sources. 
6.7. Preferred policy option  
On the basis of the assessment above, as we ll as of the consu ltation process, the 
preferred option is option 3c (combined MS  and EU level selection). With this 
option, the EU involvement brings a clear  added value to the EHL and enables 
benefits that could not be achieved by MS acting alone. The most marked 
improvements in impacts would be in shor t-term effects wher e there would be a 
strong connection to the improvements in eff ectiveness and efficiency.  Direct effects 
on factors such as a sens e of belonging to the EU, intercultural dialogue and 
participation in the democratic process re main of course more limited since such 
high level impacts are affected by a vast a rray of influences, and, as discussed in 
section 2, the EHL is only one initiative amongst many others. 
In order to work effectively and on the basis of the results of the IA and of the public 
consultation, the main features of the selected option should be the following: 
¾ An overall legal framework to transform the EHL into a EU initiative 
provided by a Decision of the Council and Parliament.  This  Decision would, 
inter alia,  specify the objectives and rules gove rning the label, establish clear, 
common and transparent selection criter ia, and specify the arrangements for 
monitoring and evaluation. We have s een in section 2 that the present 
objectives and rules of th e intergovernmental EHL leave too much room for 
diverging interpretations by the MS and this has harmed to the overall coherence and quality of the label so far. It is also essential to ensure that all the future rules will de facto be applied, and that they will be applied evenly 
by all the participating MS.   
¾ The participation of the MS s hould be on a voluntary basis. 
¾ A clear division of responsibilities is n eeded between sites, MS and EU level 
in terms of selection, delivery, and m onitoring and evaluation in order to 
avoid overlaps, share the administrative burden, and thus ensure that the practical arrangements remain as lig ht and flexible as possible.  
¾ In order to emphasize the added valu e of the EHL compared to other 
initiatives in the field of heritage such  as the UNESCO World Heritage List,  
the Council of Europe Cultural Routes or  the EU Prize for cultural heritage / 
Europa Nostra Awards, the criteria of the EHL should be based clearly on the 
symbolic value of sites for Europe's iden tity and the role they have played in 
the history and the building of Europe, on the quality of the programme they 
submit and on the quality of their ma nagement plan. A good communication 
between the EHL and the other initiatives will be needed in order to foster 
synergies. This should be facilitated  notably by the fact that both the 
European Institute of Cultural Routes and Europa Nostra receive EU grants in the framework of the Culture programme. 
 
EN 38   EN ¾ In a first stage, the pre-selection of th e sites should take place at MS level, 
and then in a second stage, the final selection should take place at EU level 
with the help of a panel of independen t experts. This would ensure both a 
robust application of criteria and the giving of appropriate prominence to the 
European dimension, whilst also preservi ng an equitable distribution of sites 
across the EU.  
¾ A pre-established rotation system with  the participation of a limited number 
of MS each year, as discussed during the consultation phase, could have helped to keep the number of sites and the administrative burden reasonable 
while ensuring the long-term commitment  of all MS. However, a consultation 
of the Legal Service of the Commission showed that this solution was not applicable for reasons of  discrimination between the MS. Therefore, an 
alternative solution would be to give each  MS the possibility to participate in 
the selection procedure each year, but after three successive years dedicated 
to the selection of new sites, each f ourth year would be reserved for the 
monitoring procedure. 
¾ This two-stages approach needs to be  linked to national quotas, but these 
quotas must keep a certain flexibility because some countries have a greater 
pool of potential sites than  others and all MS may not wish to propose the 
same number of sites. It is also politica lly very sensitive to attribute different 
quotas to the MS. Therefore the best comp romise seems to be to give to each 
MS the possibility to pre-select up to a maximum of two sites every year in 
which a selection is made. These nati onal quotas will keep the process 
manageable at European level by avoi ding a too high number of applications 
from certain MS, while at the same tim e working as an incentive for all the 
voluntary MS to actually participat e in the selection procedure.  
¾ A certain element of competition should also be kept between the sites at EU 
level for the purpose of ensuring the general quality of the sites and thereby the prestige and credibility of the initi ative. The panel of independent experts 
should therefore have the po ssibility to choose between  the sites pre-selected 
by a MS and should select a maximum of one site per MS. A special priority 
should be given by the panel to sites with a strong transnational dimension. This should be facilitated by the selecti on criteria in which the cross-border 
or pan-European nature of the sites w ill be clearly mentioned (see annex 3). 
Special provisions should also be de signed to enable the participation of 
several sites located in different MS which gather around one specific theme 
to propose a single applicati on, or the partic ipation of single sites which are 
geographically situated on the territory of at leas t two different MS. Such 
"transnational sites" should follow the same procedure as other sites for their application and should be pre-sel ected by one of the concerned MS. 
However, if the panel of independent experts judges that such "transnational 
sites" respect all th e criteria, priority should be gi ven to these sites during the 
final selection. 
¾ The label should be attributed on a pe rmanent basis because the symbolic 
value of the selected sites will not diminish over time and in order to encourage sites to take a long term approach and to invest in their 
development. However, in order to maintain the quality and the credibility 
 
EN 39   EN also in the long term, a strong monitoring system is needed to ensure that the 
labelled sites respect their commitments, as well as the possibility to withdraw the label. This monitoring s hould also take place first at national 
and then at European level. 
¾ The consultation process has shown that it does not make sense to try to 
define what a "reasonable" number of labelled sites means numerically. Any 
number would be arbitrary. At the same  time, it became clear that with too 
few sites, there would be an inadequa te geographical spread and it would be 
harder to reach citizens for practical geographical reasons, which might 
undermine the initiative's objectives. Ther efore, there should be no cap from 
the outset on the total number of site s which will be awar ded the EHL, but 
the number of sites should increase slowly  and progressively in order to keep 
the initiative manageable and to ensure  its overall quality and credibility. The 
cap on the number of selected sites fo r each MS at each selection round will 
contribute to this. 
¾ Because the implementation of the ru les of the EHL will be a complex 
process, the EU action should in a firs t stage start with the 27 MS. It could 
then in a second stage be enlarged to the third countries participating in the 
Culture programme if the practical arrangements prove to be sufficiently strong and efficient. 
¾  The Commission should provide the perman ent secretariat of the initiative in 
order to ensure a greater stability th an under current arrangements and enable 
expertise to be built up. This soluti on would enable to draw on existing 
experience such as for example in the framework of the European Capitals 
for culture or the EU Prize for Cultural Heritage / Europa Nostra Awards. It 
will however demand additional resources wh ich need to be made available.  
In order to keep the practical arrangemen ts as light and flex ible as possible, 
certain administrative tasks could be externalized through tendering 
procedures.  
¾  Transitional measures need to be taken in order to define the status of the 
sites which were awarded the EHL in th e framework of the intergovernmental 
initiative. In order to ensure the overall coherence of the initiative, these sites 
will need to be re-assessed against the new criteria. 
¾ In order to keep the im pact on the EU budget lim ited without harming the 
overall quality of the initiative, funding at EU level should remain restricted 
to the costs of the secretar iat, the costs of the European panel of experts, the 
visibility of the initiative at Europe an level and some networking activities 
for the sites. On the basis of the experience of the European Capitals of Culture, this should not exceed a maximum of 1,5 million Euros a year, 
including the additional human resources needed to run the action (one administrator and one assistant). 
¾ At a national level, the only compulsory expenses for a MS would be the 
costs of their own pre-selection proce dure and of the monitoring of the sites 
located on the national territo ry. As the nature and th e size of the selection 
and monitoring procedures will greatly depend on the specificities of each 
 
EN 40   EN MS, the costs will vary from one MS to  another. A flexible approach should 
enable each MS to choose the most cost-effective solution according to the national context. Any additional costs would be a national matter. 
7. S
ECTION 7: MONITORING AND EVALUATION  
Monitoring and evaluation are crucial to ensure  the effectiveness of the initiative, its 
credibility and its prestige. The monito ring and evaluation framework of the EHL 
will comprise two elements whic h need to be distinguished: 
7.1. The monitoring of the labelled sites 
As already mentioned in the previous secti on, the aim here is to verify that labelled 
sites have met the obligations they agr eed to undertake when they made their 
application and were selected. This monito ring will be under the re sponsibility of the 
MS who will report to the European panel ev ery 4 years. A set of indicators to be 
taken into account will be  provided by the Commission. In  the event that specific 
sites no longer meet their obligations, ther e will be a possibility to withdraw the 
Label. 
7.2. 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 program me and the actual cumulative impact of the EHL at 
programme level. The aim will be to identify in which respects the programme is working well, where there is room for improvement and, crucially, how this improvement might best be achieved in the future. The monitoring of the labelled sites will of course feed into this evaluation. The evaluation will be under the 
responsibility of the Commission and will take  the form of an external evaluation 
every 6 years. 
Concerning the effectiveness of the pro cesses involved in operating the programme, 
the annual selection process,  the monitoring and evalua tion plan, as well as the 
communication and marketing plan shoul d be taken into consideration. Key 
indicators could include: 
¾ the number of sites selected annually;  
¾ the number and quality of th e monitoring activities;  
¾ the number of promotional events held  by EHL sites, the number of new EHL 
websites launched;   
¾ the networking and transnational initiatives established.  
The impacts and outcomes of the EHL will be examined against the 
operationalisation of the objec tives described in section 3.  Key indicators should be 
defined in the social, economic and envir onmental areas. Social indicators could 
include:  
¾ numbers reporting that their interest in cultural heritage has increased; 
 
EN 41   EN ¾  numbers saying their appreciation of common European history has 
increased; 
¾  numbers of activities organise d by the sites towards young people; 
¾  collaboration projects between EHL sites; 
¾  number of cultural activities create d or activities raising the awareness on 
democratic values/human rights.  
Economic indicators could include:  
¾ number of direct or i ndirect jobs created;  
¾ number of jobs safeguarded;  
¾ increase in  visitors numbers;  
¾ number of partnerships projects between EHL site s and cultural and creative 
industries; 
¾  number of partnerships projects between EHL sites and local business 
activities or leverage effect of inve stment on heritage on private and public 
sources.  
Environmental indicato rs could include:  
¾ number of sustainable manageme nt plans adopted by the sites; 
¾  improved access to the sites with sustainable transport; 
¾  landscapes and historic environment conditions.  
Key measurement methods for these indicators  could include visitors' surveys, site 
managers' surveys, focus groups, case studies  or quantitative and qualitative analysis.  
 
EN 42   EN ANNEX 1: 
       
MEETING SUMMARY 
EHL PUBLIC CONSULTATION MEETING 
10 JUNE 2009 
 
 
 
EN 43   EN  
 EUROPEAN COMMISSION 
Directorate-General for Education and Culture 
 
Culture, Multilingualism and Communication 
"Culture" programme and actions  
 
EUROPEAN HERITAGE LABEL PUBLIC CONSULTATION MEETING  
10 June 2009 Charlemagne Building (Sicco Ma nsholt room), Rue de la Loi 170, Brussels 
SUMMARY  OF THE  MEETING 
The meeting was open to all interested individuals  and organisations. 71 participants registered 
including representatives of interna tional and national organisations ac tive in the field of heritage, 
public authorities (national, regional and local level) , heritage sites which were awarded the European 
Heritage Label in the framework of the intergove rnmental initiative, academics and students. The list 
of participants is attached. 
After the opening by the European Commission and a presentation of the first results of the online 
consultation on the European Herita ge Label, the discussions with the participants were centred 
around four questions: what are the potential impacts of  a label in the field of cultural heritage? What 
is the added value of the European Heritage La bel? Which role for the European Union in the 
European Heritage Label? How to implement the European Heritage Label effectively? 
1. OPENING BY THE EUROPEAN COMMISSION 
Ms Ann Branch, Head of the Culture Programme and Actions unit opened the meeting recalling that 
this would be a consultation meeting, organised in order to listen to stakeholders' views on the 
European Heritage Label. 
She highlighted the context of the European Her itage Label: its beginnings as an intergovernmental 
initiative, the call of the Council Conclusions of 200 8 to make it a European Union initiative and the 
steps taken by the Commission in order to prepare its proposal to the Council and the Parliament: the 
online consultation, the current public consultation me eting and a similar meeting with Member States 
experts, taking place on 24 June. The Commission would prepare an impact assessment report to summarize feedback received and examine the a dvantages and disadvantages of different ways of 
implementing the Label. This report would acco mpany the Commission proposal on the European 
Heritage Label, foreseen by February 2010. 
2. PRESENTATION OF THE FIRST RESULTS OF THE ONLINE 
CONSULTATION ON THE E UROPEAN HERITAGE LABEL 
Mr Jean-Philippe Gammel, the official responsib le for the European Heritage Label in the 
Commission’s Culture Programme and Actions unit, presented the results of the online consultation, 
which ran from 20 March until 15 May and receive d 226 responses. The presentation is attached. 
3. OPEN DISCUSSION: WHAT ARE THE POTENTIAL IMPACTS OF A 
LABEL IN THE FIELD OF  CULTURAL HERITAGE? 
Ms Branch invited comments, on the basis of the following questions: 
 
EN 44   EN 3.1. What social impacts? 
Firstly, most participants commented that the ma in EHL impact would be political: EHL should build 
a bridge between the European project and the citizen, by exploiting the potential of common history and heritage, without fearing enteri ng into controversial debates: European history was often complex 
and sometimes sensitive. 
EHL should be a way of affirming European identity within the EU, but also a way of promoting this 
identity and European values linked to it abroad. Sec ondly, participants wished to better focus social 
impacts by speaking of societal impact: EHL would not have a direct impact on social inclusion, but could lead to a better integration of EU citizen s, who would improve their capacities to seize 
opportunities at home and abroad in Europe. Educa tional impacts should also be mentioned in this 
section as EHL shall have a strong educational di mension, with programmes involving young people 
through schools, online learning or young tourists. 
3.2. What economic impacts? 
Participants had mixed opinions on th e economic impacts, which were c onsidered to mainly relate to 
tourism. Some foresaw an increase of touris m on EHL sites. While this might boost local 
development, it was recommended to promote sustainabl e tourism on the basis of lessons learnt in the 
management of the Unesco Worl d Heritage Sites. Some other participants found it difficult to 
anticipate the impact on tourism, with the argument th at the EHL sites were likely to be already well 
known. Nevertheless the quality of the cultural aspec t of the visit should improve notably through a 
better interpretation of the sites, and it was hope d that this would lead to increasing numbers of 
targeted visitors, especially young people. In any case,  although a raise in tourism was likely, it would 
take time to have a real impact. The example of tourist packages linked to Unesco World Heritage 
sites was mentioned. 
3.3. What environmental impacts? 
Most remarks focussed on the importance of promo ting sustainable tourism to which there was a 
reference in the Council conclusions. Although EHL did not aim at conservation, it should under no 
circumstances endanger the sites. Appropriate clauses  should be included in the award criteria in order 
to ensure respect for the sites and their eco-systems.  
3.4. How to maximize the positive impact s of the European Heritage Label? 
Participants were unanimous in indicating that a big communication effort would greatly increase the 
EHL impact, along with a strong educational dimension.  
A clear selection framework, publicised over Europe would be of great help. Attention should be 
given also to the extent to which the organisations managing the sites worked on promoting European values and history. Networking among the awarded sites through Europe would also increase their 
impact. 
3.5. Are there models of good practices to follow? 
Unesco's studies on impacts were referred too, alon g with the experience of some existing European 
Heritage Label sites and best practices from European Capitals of Culture. 
4. OPEN DISCUSSION: WHAT IS TH E ADDED VALUE OF THE EUROPEAN 
HERITAGE LABEL? 
Ms Branch introduced the topic recalling that this  was at the core of the Council Conclusions. A 
preliminary survey to compare the Label with ot her existing initiatives had been undertaken by an 
 
EN 45   EN external consultant, Ecotec, providing support to the Commission in the preparation of the impact 
assessment report. The discussion was guided by the following key questions: 
4.1. What should the originality of this Label be, taking into account other existing 
national or international initiatives in the field of cultural heritage? 
There was a general consensus that EHL had a va lue on its own and did not overlap with other 
existing initiatives, such as the Unesco World Herita ge List, the Council of Europe Cultural Routes 
and the Europa Nostra awards. This was confirme d by the representatives of ICOMOS (consultative 
body for the UNESCO World Heritage List), the Inst itute of Cultural Routes a nd Europa Nostra which 
were present in the meeting. Nevertheless clear  communication would be needed to clarify the 
differences for the general public. 
Stakeholders involved in the Unesco World Herita ge List underlined that the Unesco initiative had 
very different criteria: sites must be universal, authentic and with architectural value. The World 
Heritage List was first and foremost a prize for conservation, while the Label should aim at raising 
awareness. It could not be ruled out that a site  was awarded both by Unesco and EHL, on condition 
that it matched the different criteria required by the respective awards. The aims of the Council of 
Europe  Cultural Routes were more similar to those of EHL, did not focus on specific sites but rather 
on themed routes across different countries, an d complementarity with EHL seemed possible. 
Participants felt there was scope for EHL, as it shoul d award sites with a symbolic value for Europe, 
with a strong educational focus and not necessarily of great aesthetic value. Furthermore it was observed that EHL was open to contemporary sites,  such as the Gdansk sh ipyards, as well as to 
immaterial heritage, as long as it was attached to a s ite. Some participants felt that the transnational 
dimension should be emphasised. EHL criteria should be defined in such a way that they did not leave 
grey zones with other existing activities. As the Label was aimed at citizens, a communication plan 
should be required from competing sites as part of the selection criteria. 
4.2. Which selection criteria would enable  this specificity to be highlighted? 
Participants commented that selection should not in volve much bureaucracy for the sites and for the 
Member States. On the one hand, some participants  proposed a European selection process, with sites 
applying directly to a European panel. This would ensure a consistent interpretation of the European 
dimension and would encourage the participation of transnational s ites proposed by more than one 
country. As one participant put it “ How will the European value be ensured by 27 national 
committees, each with their own national interpretations of history?”  On the other hand, organisations 
currently managing the intergovernmental Label were  more sceptical about skipping a national level 
of selection, arguing that this could help to filter out many applications, thereby lightening the burden 
for the European panel. They favoured a two-stag e selection procedure, first at the national level, 
followed by the European level. 
The participants were also divided on whether the panel should be composed of independent experts, 
linked to civil society or whether it should be comprised of national representatives supported by 
expert advice. ICOMOS, the Institute of Cultural Routes and Europa Nostra reported on the selection 
procedure of their respective initiatives. The repre sentative of ICOMOS underlined that the procedure 
for the World Heritage List had become very h eavy over the years and strongly recommended learning 
from this experience in order to implement a lighter  approach for the Label. A single level selection 
approach could be the solution. 
4.3. How to enhance the European dimension of our cultural heritage? 
An awarded site should have cultural and historic  meaning for several countries, across Europe, for 
instance by highlighting the contribution of artists coming from different countries, or remembering 
events with an impact on many countries. A ttention should be given to the interpretation and 
 
EN 46   EN transmission of the symbolic value of these sites. Sites should be living places, communicating not 
only about the sites themselves but also about the European project. 
As the European cultural space reac hed beyond current EU borders, so me participants proposed that 
that EHL should be open to coopera tion with neighbouring countries, in order to help build bridges 
and value common European memories. It was also mentioned that sites should be very carefully 
selected, in order to avoid reigniting recent memories of some conflicts. 
4.4. How to promote the access of young pe ople to European cultural heritage? 
As expressed earlier, participants emphasised the e ducational efforts EHL sites should make in order 
to involve schools and other educational organisations , for instance through virtual visits and learning 
facilities based on new technologies. Sites could also  cooperate with tourism associations to promote 
visits by young people. 
5. OPEN DISCUSSION: WHICH ROLE FO R THE EUROPEAN UNION IN THE 
EUROPEAN HERITAGE LABEL? 
After the specificity and the added value of the Eur opean Heritage Label, the debate focussed on the 
potential benefits of transforming the intergovernme ntal initiative into a formal EU initiative. The 
discussion was guided by the following key questions: 
5.1. Would the Label benefit from a closer involvement of the European Union? 
Stakeholders were in agreement with the Council th at a closer involvement of the European Union 
would help in broadening the ge ographical coverage, defining clearer and more transparent criteria 
and procedures, as well as improving the visibility of  the Label, all of which were difficult with a 
rotating secretariat. 
5.2. What role for the European Union in the selection process of the sites and in the 
monitoring process? 
Some participants felt that a formal designation by the Council of Ministers would be important 
symbolically and help the visibility of the initiativ e. Some other comments referred to the Commission 
as a permanent secretariat, playing a role similar to  the one it ensured for the European Capitals of 
Culture. This permanent secretariat would ensure a consistent monitoring of the awarded sites and 
facilitate networking among them. 
6. OPEN DISCUSSION: HOW TO IM PLEMENT THE EUROPEAN HERITAGE 
LABEL EFFECTIVELY? 
The discussion was preceded by a presentation by Fr ench and Spanish representatives who had been 
ensuring the secretariat of the intergovernmental Labe l since its creation in 2007. They described the 
concept of the Label, the current number of sites (it had been agreed that each country participating in 
the Label could award up to 4 Labels) and the ne w website of the initiative hosted by the Spanish 
Ministry of Culture. They saw the Label's first years as a transition towards a Community initiative 
which would broaden the scope of the initiative a nd increase the number of participating countries. 
Some networking among the sites was already in place, but this aspect needed to be further developed. 
Many questions were raised by the participants to  the French and Spanish representatives in order to 
clarify the aims and functioning of the current in tergovernmental initiative. This confirmed that the 
EHL currently lacked visibility and was still rather unknow n, even by the heritage sector itself. It also 
confirmed that in order to have an effective impact  in the future, the new Label would need to have a 
strong communication strategy. The debate was then guided by the following key questions: 
 
EN 47   EN 6.1. How to ensure that the number of sites awarded the Label will remain reasonable 
and representative? 
As the Label started as an intergovernmental initiativ e, a given number of awards per country were set 
out. With the EU taking the lead, some participan ts questioned this approach as it would prevent 
transnational applications (unless a special quota was foreseen). On the one hand the number of 
awarded Labels should be limited to  ensure their value and prestige,  on the other hand bigger countries 
would be penalised if they had the same quota as smaller ones. In the case of national quotas, it was 
mentioned that in view of the aim of the initiative to  reach citizens, it would be important that for the 
sites to be sufficiently spread out geographically in  order to ensure that all citizens had reasonable 
access to such a site over the long run. 
Another suggestion was to fix quotas over Europe focussing different categories/sectors, like the 
Europa Nostra Prize. Alternatively quotas for sect ors could also be fixed at national level (plus 
national quotas). One participant suggested a categori sation of sites: Europe of artistic creators; 
Europe of architecture, styles and landscapes, Europe  of the sacred and spirit, Europe of industry, 
Europe of democracy. 
6.2. Should the Label be attributed on a perm anent basis or for a limited time only? 
Most participants felt that, for the sake of consiste ncy, the Label should be attributed on a permanent 
basis, as its symbolic value did not change over ti me. Nevertheless periodic review should be possible 
to ensure that the key communication and educatio nal activities were still in place. It was mentioned 
by one participant that EHL sites could receive  a Commission grant for communication activities, 
either on a temporary basis and renewable or perman ent but subject to monitoring. This would provide 
incentives to keep EHL sites up to the requested level, in a simila r way as the Melina Mercouri prize 
did for the European Capitals of Culture. Nevert heless it was noted that a communication strategy 
would take time to be implemented; this shou ld be considered while fixing the time span for 
monitoring or renewals. 
6.3. How to raise the profile and visibilit y of the European Heritage Label? 
Participants suggested linking the EHL to the European Heritage Days, encouraging national 
coordinators to include EHL sites available in the Days programmes. It was also recommended, that, 
although EHL could be awarded to immaterial her itage, this should nonetheless be anchored to a 
physical site. Partnership with local authoriti es and civil society was considered essential. A 
participant noted that EHL was two-fold, coupling th e symbolic value of a site with a communication 
effort. In order to ensure that communication would be well conducted co mpeting sites should not 
only provide a communication plan, but also some evidence of the quality of their current communication work. EHL awarded sites should clearly  explain to visitors how and why they had 
been chosen. 
6.4. How to keep the administrative arrangemen ts light and flexible both at European 
and national level? 
As a general remark it was suggested to keep EHL as open as possible in terms of categories, sectors 
and definitions. As the question of eligibility of priv ate sites was raised, participants suggested that 
private sites should be eligible if they provide d reasonable assurance of their capacity and with a 
guarantee of the Member States concerned (as in the case of Unesco). 
7. CONCLUSIONS AND CLOSE OF THE MEETING 
 
EN 48   EN Ms Branch closed the meeting re calling next steps in preparing the proposal, which should be 
adopted by the Commission in February 2010 and then submitted to Parliament and Council 
during the Spanish presidency.  
 
LIST OF REGISTERED PARTICIPANTS 
 
Name First Name Organisation 
Arribas Pérez Beatriz Delegación Perman ente de Castilla y León ante la UE 
Arrizabalaga Esperanza Oficina del Gobierno de Cantabria en Bruselas 
Balogh Zoltán Representation of Eszak-Alfold Region in Brussels 
Barraca de Ramos  Pilar  Spanish Ministry of Culture; Subdirección General de 
Protección del Patrimonio Histórico 
Bentz Prof. Dr. 
Martin Deutscher Archäologen-Verband e.V. 
Bolton Holloway Julia Association of Significant Cemeteries in Europe 
Broehl Maximilian Vertretung des Landes Nordrhein-Westfalen bei der 
Europäischen Union 
Bucher Jean-Marc  Ville de Troyes, France Callizo Azqueta Silvia Delegación del Gobierno de Navarra, Brussels 
Cardama  Maruxa South West UK Brussels Office 
Castenholz Frank Vertretung der Frei en Hansestadt Bremen bei der EU 
Castro Alexis Culture Lab Chambron Claire-Lyse Ministère de la culture et de la communication, France Chameroy Fabienne Student Chaney Edward  Southampton Solent University 
Cormann Tatjana Ministerium der Deutschsprachigen Gemeinschaft - Abteilung 
Kulturelle Angelegenheiten 
Coxen  Alexandra English Heritage  
d'Alessandro Alberto  Ministri per i Beni e le Attività Culturali  + Associazione via 
Francigena 
D'Almeida Henri Ministère de la culture et de la communication, France 
 
EN 49   EN Devillers Ghislaine Département du Patr imoine; Région wallonne de Belgique 
Engelke Thomas Hanse-Office - Joint Representation of the Free and Hanseatic 
City of Hamburg and the State Schleswig-Holstein to the EU 
Favel Bruno Direction de l'architecture et du patrimoine; Ministère de la 
Culture et de la Communication, France 
Fourcroy Nicolas ESSA - European  States Stud Association Garcia Alvarez Ana María Student Gasc Fanny Antenne Interrégionale  Auvergne-Centre-Limousin 
Gerber Oliver Mission de la Sui sse auprès de l'Union européenne 
Gluck  David ECOTEC 
Hervé Julie EUROCITIES Honoré Frederique Site archéologique et musée du Coudenberg  Hornung Stefanie  Büro des Landes Berlin bei der EU  Hurtado Ory Alejandro Andalusian delegation in Brussels  
Infante Claude Confrontations Europe 
Ingelaere  Pascale  Gouvernement de la Région de Bruxelles-Capitale Jungeblodt Gaia ICOMOS Internati onal Council on Monuments and Sites  
Lecci Silvia GEIE Culture-Routes Europe; Institut Européen des Itnéraires 
Culturels 
Lekakis Stelios  ELLINIKI ETAIRIA  - Society for the Environment and 
Cultural Heritage 
Leon Burgos Diego Delegation of the Gove rment of the Canary Islands, Brussels 
Leopold Amandine  AVEC - Alliance de Villes Européennes de Culture Mariucci  Andréa  Gouvernement de la Région de Bruxelles-Capitale 
Martín Ramos Miguel Angel European Academy of Yuste Foundation  
Martinez soliño Gemma Maria Delegacion del Gobierno de Canarias en Bruselas 
McCoshan Andrew ECOTEC Meissnitzer Heidi  Permanent Representation of Austria to the EU Miroir Mme Commune d'Anderlecht - Echevine à la culture Morales Margarita  Oficina de la Región de Murcia 
 
EN 50   EN Papaioannou  Maria   
Patricio Teresa ICOMOS Wallonie - Bruxelles 
Peuziat Jean-Philippe Représentation des Régions Breta gne, Pays de la Loire et 
Poitou-Charentes à Bruxelles 
Pintus Barbara Culture Lab 
Pradayrol Sophie  Développement touristique & Prom otion internationale - Ville 
de Troyes 
Quadvlieg-
Mihailovic S.  Europa Nostra 
Quémarec France Direction de l'architecture et du patrimoine; Ministère de la 
Culture et de la Communication, France 
Röhrs Dr. Friedrich Permanent Representation of Germany to the EU Ruiz Paniagua Blanca Junta de Castilla y León  Sarazá Jimena  Pablo  Delegación de la Junta de Andalucía, Brussels 
Sexauer Katharina Büro des Landes Berlin bei der EU  
Simeone Gian Giuseppe Culture Lab Stiévenart M. Commune d'Anderlecht Teller Sarah   Student Thomann Stephanie  Representation of the state of Saarland (Germany) at the EU 
Thys Arlette Flemish Ministry of Culture, Youth, Sports and Media 
Torra Alberto  Archivo de la  Corona de Aragón (Barcelona) 
Torres Martín María Delegación de la Junta de Andalucía en Bruselas van Iersel Rob  Dutch Permanent Representation van Rijckevorsel L.  Europa Nostra Van Rompaey Sara Order of Architects Belgium 
Vandewattyne Claude Communauté française, Belgique 
Victor Stephane Représentation de l'Ile-de-France à Bruxelles  Walazyc Anne-Sophie Cabinet du Secrétaire d' Etat à la Région de Bruxelles-Capitale 
Wert Carlos Sitio Español de Patrimoni o Europeo Residencia de 
Estudiantes 
 
EN 51   EN Wittling  Isabelle  Representation of the state of Saarland (Germany) at the EU 
Zhang Li Mission of the People's Republic of China to the European 
Communities  
 
 
EN 52   EN ANNEX 2: 
       
MEETING SUMMARY 
EHL MEMBER STATES' EXPERTS MEETING 
24 JUNE 2009  
 
 
 
EN 53   EN  
 EUROPEAN COMMISSION 
Directorate-General for Education and Culture 
 
Culture, Multilingualism and Communication 
"Culture" programme and actions  
EUROPEAN HERITAGE LABEL (EHL)  MEMBER STATES ' EXPERTS MEETING  
 BRUSSELS , 24 JUNE 2009 
SUMMARY  OF THE  MEETING 
PRESENTATION OF THE MAIN STEPS OF THE IMPACT ASSESSMENT AND 
OBJECTIVES OF THE MEETING 
Ms Odile Quintin, Director General of DG Educa tion and Culture, opened the meeting and briefly 
recalled the origins of the Label, as an intergove rnmental initiative and the Council Conclusions of 
November 2008 inviting the Commission to submit to it "an appropriate proposal for the creation of a European Heritage Label by the European Uni on and specifying the practical procedures for the 
implementation of the project.". She then informed the participants on the main steps of the impact 
assessment which was currently underway and which included a public consultation (online 
consultation, stakeholder meeting and current  meeting). She announced that the Commission 
envisaged presenting its draft proposal at the begi nning of 2010, during th e Spanish Presidency. 
She restated that the Commission would take into account the achievements of the intergovernmental 
phase of the Label in the impact assessment and in the preparation of the Commission's proposal. 
However she also underlined that with the adoption of the Council conclusions, the Label entered into 
a new phase and that the Commission and the 27 Member States would now have to determine 
together what the new forms of the Label should be in order to make it as ef fective and attractive as 
possible. 
Ms Quintin made clear that, throughout the cons ultation phase a broad consensus emerged concerning 
the general orientations of the future Label. Ho wever, two important questions still raised some 
concerns concerning the practical details of the implementation of the label and needed further 
discussion: how to ensure that the number of site s awarded the European Heritage Label remained 
reasonable and representative and how to keep th e administrative arrangements for the future 
European Heritage Label light and flexible at nati onal and European level? The current meeting would 
therefore focus on those two issues.  She invited MS experts to inte rvene freely and frankly in the 
discussion, to test a range of ideas in order to find the most suitable solutions. 
PRESENTATION OF THE FIRST RESULTS OF THE PUBLIC CONSULTATION 
Mr Jean-Philippe Gammel, European Commission, presented the key messages received through the 
online public consultation (attached). He then brie fly related feedback from the stakeholder meeting 
held on 10 June, where the key messages had echoed t hose of the on-line consultation, with a stronger 
focus on the practical arrangements for the implementa tion of the Label. This had been greatly helped 
by the presence of Icomos (consultative body for Unesco, in charge of the instruction of applications 
for the World Heritage List), the European Institute of Cultural Routes (in charge of the instruction of 
applications for the Council of Europe's Cultural Routes) and Europa Nostra (managing the European 
Union Prize for Cultural Heritage). They all agreed  that the scope of EHL would not overlap existing 
initiatives and put forward concrete proposals to implement it in a flexible way. 
 
EN 54   EN The number of sites to be awarded per country an d the way of selecting the sites seemed to be the 
most complex issues. The Member States actually  implementing the intergovernmental European 
Heritage Label were in favour of keeping a two le vel selection process starting with a pre-selection at 
national level. Civil society organisations were more  in favour of an open, single stage competition at 
European level without any quotas of sites per country.  
OPEN DISCUSSION ON: 
How to ensure that the number of sites awarded the European Heritage Label remains reasonable 
and representative? 
How to keep the administrative arrangements for the future European Heritage Label light and 
flexible at national and European level? 
As proposed by Ms Quintin at the beginning of the meeting, it was agreed to take together the two 
points in the agenda, as they partially overlapped.  The two questions guided the interventions, which 
had been prepared on the basis of two discussion pape rs (attached) received in advance by participants 
and presenting a detailed set of implementation issues. 
ES thanked the Commission for its readiness to take EHL forward. It highlighted the dual nature - 
political and technical – of selection issues. As thre e levels of power were involved (local, national, 
European) ES feared that a selection only at EU le vel would undermine the political dimension and be 
detrimental to smaller or more peripheral sites. Other examples of combined selection procedures at national and EU level were available, for instance in  the education field. A maximum number of sites 
should be set to ensure quality as well as a quota of sites per country. ES proposed a rotation 
procedure, with 9 MS entitled to apply each year  for a maximum of 3 Labels per country. Quality 
should be the main criterion to decide to award th e Label. Although some costs were inevitable, it 
should be remembered that there would also  be benefits, especially from an awareness-
raising/educational point of view. ES strongly r ecommended to learning from the experience of the 
Unesco scheme in order not to repeat the same mi stakes: procedures should stay as light as possible. 
IT proposed to take inspiration from a national prac tice in place to facilitate applications to the 
UNESCO World Heritage List: a committee set in pl ace to disseminate information, provide guidance 
and “filter out” applications. This same Committee al so provided follow-up after selection of a site. IT 
proposed a two-phase selection, with national pre-sel ection managed by a national authority on the 
basis of common criteria set at European level. Fi nal selection should be mana ged by a panel of EU 
experts. IT would leave the number of Labels open. As for duration, the Label should be permanent in 
order to enable sites to invest in sustainable ac tivities. National monitoring should be foreseen. Priority 
should be given to sites with a broad access to the public and with a transnational character. 
CZ called for a system similar to the one for the Euro pean Capitals of Culture. Each MS should be left 
free to define what European added value meant na tionally. CZ was in favour of a rotation system, 
with each MS applying every fourth year, in order not to inflate the number of Labels. Monitoring 
would be ensured at national level. The attr ibution of the Label should be permanent. 
AT favoured an open selection procedure (in two phases) on a rotation base, with no set number of 
Labels. EHL should remain a voluntary initiative, leavi ng MS free to decide whether to participate. As 
for the duration, Labels should be temporary, but renewals could be allowed. Costs should be as 
limited as possible, both for the selection pr ocedure and for the sites themselves.  
The AT representative welcomed the EHL as a wa y of highlighting the richness of common EU 
heritage. He recalled that the EU dimension shou ld be ensured consistently: common guidelines and 
selection forms were much needed AT commented that  communication efforts were needed in order to 
raise the EHL profile. 
PL was in favour of a two-phase selection with no national quotas. The European panel should be 
composed by recognised EU cultural experts. Rotati on was an option that could be considered, but it 
could involve imbalances between MS who had alr eady implemented the intergovernmental Label and 
those who did not. It might be introduced in a sec ond phase only. Labels should be permanent, but 
 
EN 55   EN subject to monitoring and there should a possibil ity of withdrawal in case the criteria were not 
respected . PL was in favour of the selection of transnational sites but drew attention to possible 
problems with sites which are common with third countries. PL commented that communication costs 
should not be disproportionate for EHL awarded sites. 
NL was in favour of national selections, based on common guidelines and criteria, especially to define 
the European dimension. It raised attention to the fact that the same number of Labels per MS would 
go against quality in smaller countries. If a limited nu mber was to be decided, it should be weighted 
upon the country size and population. NL would be against rotation as it did not seem to encourage transnational cooperation. 
LT supported an open competition, with no fixed quota per country. Nevertheless MS should be 
responsible for ensuring the quality and EU significan ce of the proposed sites. As for priorities, sites 
should have a strong transnational dimension and pr omote cross-border cooperation. It was in favour 
of awarding the Label for a limited time of 5-7 years, renewable upon monitoring of educational and 
communication activities in place. LT supported a permanent EU secretariat, with monitoring 
procedures at national level. Participation in EHL should be voluntary for each MS. 
FR thanked the Commission for the very comprehe nsive feedback on the consultation process and the 
focussed questions for discussion. FR agreed with  ES concerning a rotation principle (9 countries 
every third year), with a fixed number of Labels per country at every selection (with no difference 
between bigger and smaller countries)... It supported a selection at two levels (national and European) 
and agreed on the need for common criteria and gui delines. At European level, FR suggested the 
creation of a panel on the model of the European Ca pitals of Culture which should be supported by a 
consultative scientific committee. FR strongly supported the permanent nature of the Labels, is it took 
time to be set in place and should be based on long te rm strategies, but with monitoring. The European 
dimension should be strongly emphasised, as well as the networking among sites, in order to maximise 
awareness-raising of citizens. 
UK thanked the Commission for the consensual way it was steering the process. It agreed on keeping 
procedures light and on shifting EHL focus away from conservation and towards projects with a 
strong educational dimension. UK could support EHL as it was being currently developed. UK would 
be in favour of temporary designations, as it felt it  would be more appropriate for the nature of 
projects targeted by the Label, although it agreed th at it should be for a realistic duration. UK strongly 
reminded that as EHL should not insist on architect ural value; there would be no contradiction in 
awarding temporary labels, as they would be devoted mainly to the communication activities 
implemented. 
SE did not have yet an established position, but was inclined at the current time to favour an open 
competition, but could accept rotation between Member St ates. It stressed the n eed for very clear EU 
criteria and guidelines, with a special focus on th e EU dimension and the educational value. EHL 
should remain voluntary for Member States. Thema tic criteria could also be proposed to promote 
cooperation among countries. As for sel ection procedures: the most effici ent would be to allow sites to 
apply directly to a European panel, but this wa y the local and national involvement would be lost. 
Sites should not be inward looking but promot e access and cooperation across borders. The Label 
should be either permanent with a possibility of withdrawal, or temporary but long-term with the 
possibility for renewal. 
FI would welcome a maximum number of Labels per year at EU level, with no national quotas, but 
with a rotation process. This would minimize the selec tion workload at national level. As for length, 
FI was in favour of temporary Labels, in order to avoid heavy monitoring. It would also support 
thematic priorities. 
BE emphasised the transnational aspect of sites de signation. BE warned that, as the definition of 
heritage was evolving, including modern, contemporar y, etc. a closed number of perennial sites did 
not seem to be adapted. A national committee s hould be set in place, supported by an expert 
committee: it would be in charge of pre-selection a nd monitoring. For the final selection, BE would be 
in favour of a European panel made up of recognised  experts. The number of sites per country should 
 
EN 56   EN be linked to the frequency of calls (for instance three every year per country plus a number of 
transnational sites). Rotations would not help tran snational cooperation. Monitoring should be done 
nationally and upon two negative monitoring opinions  for example, the Label could be withdrawn. 
The mechanism of a “passive list” could be a way of documenting the history of the Label: 
intergovernmental sites and those no longer matc hing Label criteria could be put on the list.  
DE was in favour of a two-phase open procedure (n ational and European), with no national quotas. 
Nevertheless there should be no mo re than 10-15 labels per year, fa vouring transnational applications. 
Final decision should be taken by the Council of Culture Ministers, on the basis of the recommendations of the European panel. The Label should be permanent, but  could be withdrawn; 
alternatively, it could be temporary but renewable. As  for the secretariat, DE invited to consider the 
most cost effective solution which might be an ex ternal solution such as th e EAC executive agency or 
a third body like Europa Nostra for example. 
DK although initially not in favour of EHL, could agree with the current focus, especially with the aim 
of raising awareness of young people of common EU history. DK thought that a European panel was 
essential to guarantee the European dimension. It supported a country rotati on, with no fixed number 
of Labels. The Label should be perm anent, with periodic monitoring and with a strong transnational 
focus. 
LUX recommended fixing very detailed criteria and pr iorities. In a first phase there should not be 
limits per country. All applications should be su bmitted to a European panel. In a second phase a 
rotation system could be envisaged. The Label s hould be permanent as it highlighted a permanent 
value. Regular monitoring should be set in place w ith a possibility of withdrawal of the Label. 
HU was in favour of a two-phase selection procedure, with very stringent criteria, especially on the 
European dimension. There should be a pre-selection at national level, but the final selection should be 
European and made by an independent jury. HU would favour no rotation and no fixed number. 
Thematic priorities could be set in place to better focus applications. 
MT pleaded for an open call, with no set number pe r country but stringent criteria and transnational 
value. The Label should permanent, but monito red and with the possibility of withdrawal. 
EL proposed a two-phase selection, with pre-selecti on at national level and selection made by an EU 
independent expert committee. EL was not in favour of setting a fixed num ber of Labels, at least in the 
first phase, but quality criteria should be stringent and with a transnational dimension. Labels should 
be permanent. 
SI agreed on two-phase selection with common stringent  criteria and no fixed quotas. Special priority 
should be given to transnational nominations. Labels should be perm anent or alternatively, firstly 
temporary (during a trial phase) rather than permanent. 
SK was in favour of an open competition in two ph ases, with a permanent secretariat. Labels should 
be permanent with monitoring. 
Conclusions by the European Commission 
Mr Vladimir Šucha thanked the participants for the very constructive and frank debate, based on 
mutual trust and invited them to send in detailed position pa pers, if they so wished.  He underlined the 
many challenging questions which remained open ei ther because there were still divergences between 
Member States on certain issues or, more strikingl y, because the positions expressed by some of the 
Member States were not entirely free of contradictions , namely: how to reconcile the wish to have an 
open competition at European level with the w ill to keep a pre-selection at national level ? 
• how to foster the selection of transnational s ites while setting quotas of sites per country ? 
• how to keep the administrative arrangements light and flexible despite a selection at two levels 
and the involvement of the Council of Ministers in the designation procedure? 
• how to strengthen the role of the European panel of experts without jeopardising local 
involvement ? 
 
EN 57   EN • how to ensure the excellence of the Label and the relevance and quality of the selected sites 
without any limitations on the numbe r of Labels awarded each year? 
Mr Šucha concluded by saying that the Commission would nevertheless take up these challenges and 
was confident it would find reasonable solutions , on the basis of the common willingness of the 
Member States to develop the EHL. 
 
EN 58   EN  
Member States' expert s meeting 24 June 2009 
List of participants 
 
AUSTRIA 
 
Mr Norbert Riedl 
Head of Unit for EU cultural affairs  Federal Ministry for Education, Arts and Culture  Ms Heidemarie Meissnitzer Counsellor for Cultural Affairs Permanent Representation of Austria to the EU  
 
BELGIUM 
 
Ms Arlette Thys 
International Cultural Heritage  Flemish Ministry of Cultur e, Youth, Sports and Media 
 Mr Claude Vandewattyne Direction Générale de la Culture Ministère de la Communauté Française    
BULGARIA  
   
Ms Dolya Yordanova Architect, Chief Expert Directorate “European Union a nd International Cooperation”  
Ministry of Culture of the Republic of Bulgaria  
 
CYPRUS    
 Mr Kyriakos Costeas    
Education and Culture Attaché Permanent Representation of Cyprus to the EU 
 
 CZECH REPUBLIC  
Ms Jaromira Mizerova 
Head of EU Unit Ministry of Culture   
 
EN 59   EN  
Mr Zdenek P říhoda 
Expert - EU Unit Ministry of Culture   
DENMARK  
 
Mr Michael Lauenborg 
Head of Section  Heritage Agency of Denmark   
ESTONIA 
 
Mr Anton Pärn    
Undersecretary of Cultural Heritage Estonian Ministry of Culture   
FINLAND 
 
Ms Päivi Salonen  
Counsellor for Cultural Affairs Division for Cultural Policy 
Ministry of Education 
  
FRANCE 
 
Mr Bruno Favel  
Chef de la mission européenne et internationale  Direction de l'architecture et du patrimoine Ministère de la culture et de la communication 
 Mr France Quémarec  Direction de l'architecture et du patrimoine  Ministère de la culture et de la communication 
 Ms Claire-Lyse Chambron  Département des affaires européennes et internationales Ministère de la culture et de la communication 
 Mr Henri d'Almeida  Département des affaires européennes et internationales Ministère de la culture et de la communication 
  
 
 
 
EN 60   EN  
 GERMANY   
Mr Dr. Werner von Trützschler 
Leiter der Abteilung für Kultur, Kunst und Kirchenangelegenheiten Kultusministerium Thueringen   Mr Dr. Friedrich Röhrs Botschaftsrat Europäische Kulturpolitik Permanent Representation of Germany to the EU   
GREECE 
 
Ms Marioanna Louka   
Archaelogist General Directorate of Antiqui ties and Cultural Heritage 
Hellenic Ministry of Culture    
HUNGARY 
 
Mr László Mihalyfi 
Directeur du Département de la Protection du Pa trimoine culturel et de la Coordination 
Ministry of Education and Culture 
 Mr Aron Balázs Permanent representation of Hungary to the EU     
IRELAND  
  
Mr Dermot Burke Director of Heritage Services Office of Public Works    Mr Caoimhin OCiaruain  Permanent representation of Ireland to the EU 
 
 ITALY  
Mr Patrizio Fondi 
Conseiller Diplomatique Ministère du Patrimoine et des Affaires Culturelles   Ms Leila Nista   Ministère du Patrimoine et des Affaires Culturelles  
 
EN 61   EN  
 
 LATVIA  
Ms Agnese Rupenheite- Čodare 
Cultural Heritage Policy Unit State Inspection for Heritage Protection   
LITHUANIA 
 
Ms Vida Graziene  
Attaché for Culture Permanent Representation of Lithuania to the EU   
LUXEMBURG 
 
Mr Alex Langini  
Chargé de Mission Ministère de la Culture   
MALTA 
 
Mr Kenneth Gambin   
Heritage Malta Head Office   
NETHERLANDS 
 
Ms Arda Scholte 
Head of Unit - Policy Development Directorate Cultural Heritage,  Ministry of Education, Culture and Science  Mr Aart de Vries  Cultural Heritage Agency   
POLAND 
 
Ms Małgorzata Fokt-Willman  
Chief specialist  Monuments Preservation Department Polish Ministry of Culture and National Heritage  Ms Hanna J ędras  
Head of Unit 
 
EN 62   EN Department of International Relations 
Polish Ministry of Culture and National Heritage   
PORTUGAL 
 
Mr Joao De Almeida Filipe 
Portuguese Ministry of Culture       
ROMANIA 
 
Mr Mircea Angelescu   
Ministry of Culture, Religious Affairs and National Heritage 
  
SLOVAKIA 
 
Ms Lucia Pawlikova 
Permanent Representation of the Slovak Republic to the European Union   
SLOVENIA  
 
Mr Dusan Kramberger 
Secretary 
Directorate for Cultural Heritage Ministry of Culture   
SPAIN 
 
Mr Fernando Gómez Riesco  
Sous-directeur de la coopérat ion culturelle internationale 
Ministère de la culture    Ms Josefina López Service de la coopération culturelle multilatérale Ministère de la culture   Ms Pilar Barraca de Ramos  Sous-direction générale de la pr otection du patrimoine historique 
Ministère de la culture   
SWEDEN 
 
Mr Henrik Selin 
Permanent Representation of Sweden to the EU  
 
EN 63   EN  
UNITED KINGDOM 
 
Mr Harry Reeves  
Department of Culture, Media and Sport   
 
EN 64   EN  
 
EUROPEAN HERITAGE LABEL 
Member States' experts meeting 
Brussels, 24 June 2009 
 
Discussion papers 
 
Introduction:  
At its meeting on 20 November 2008, the Council of  the European Union (Education, Youth and 
Culture) adopted conclusions inviting the European  Commission 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."  
These conclusions give a fairly detailed basis for the European Commission for the preparation of its 
proposal. However, during the negotiations for the adoption of these conclusions, a number of issues 
were left open by the Member States for further analysis. 
The Impact Assessment and public consultation wh ich were launched by the European Commission, 
and which are still underway, have been very useful in helping to move forward on several of these 
issues. It transpires that there is  indeed broad consensus concerning the general orientations of the 
future Label. However, two importa nt questions still raise some concerns and need further discussion: 
how to ensure that the number of sites awarded th e European Heritage Labe l remains reasonable and 
representative and how to keep the administrative arrangements for the future European Heritage 
Label light and flexible at national and European level? The Member States experts' meeting offers an 
opportunity to make substantial progress on these issues. The following two discussion papers are 
aimed at contributing to the orientation of the discussions. 
  
 
EN 65   EN Discussion paper n°1: how to ensure that the num ber of sites awarded the European Heritage 
Label remains reasonable and representative? 
 
The Council conclusions mention as one of the main pr inciples of the future European Heritage Label 
that the project should be based on a "regular selection procedure […] covering a reasonable and representative number of sites each time" (section 3b). 
The need to keep the number of sites awarded the label reasonable has indeed been a major concern of 
Member States and of stakeholders during the negot iation phase for the adopti on of the conclusions as 
well as during the current public consultation process. It  is considered an essential condition to ensure 
the quality and credibility of the European Heritage Label, as well as to keep the initiative manageable 
both at national and European level. It also has implications for the very design of the selection 
process. However, beyond consensus on the fact th at the number should be reasonable, few concrete 
solutions have been proposed as to how th is should be implemented in practice. 
A first important question which still requires an  answer is what is actually a reasonable and 
representative number of sites? Once this is determined, practical arrangements for the implementation 
need to be designed. 
1. Shall the label be attributed on the basis of an  open competition or shall there be a reserved number 
of sites for each Member State?  
Two main options are possible for the attribution of the Label to the sites. The first is to have an open 
competition which does not take into account the nati onal origin of the candidate sites. Only the 
quality of the sites and the proposed programmes w ould be considered. Special attention could be 
given to sites with a strong transnational dime nsion. This solution would guarantee the overall 
excellence of the selected sites. The risk is that this could create an imba lance between the various 
Member States. However the advantage would be th at it would in many ways be better adapted to 
reality in the sense that it could better accommodate the fact that some countries have a greater pool of 
potential sites than others, due to their size and othe r factors. By avoiding systematic national quotas, 
it would also be easier to keep to a reasonable numbe r of sites. If this option were chosen, the number 
of sites per year to be selected would need to be defined.  
The other option is to have a reserved number of sites for each Member State according to a system 
close to the one implemented for th e European Capitals of Culture (i n this instance two Member States 
per year can host the title). In this case, should the sam e number of sites be attributed to each Member 
State or should the size of each country be cons idered, and if so, what should be the formula for 
deciding the number of sites? 
Should transnational sites be made a special prio rity? For example, should a parallel procedure be 
launched for a small number of transnational sites which could apply directly to the European level 
every year, thereby providing an added incentive for this kind of initiative?  
2. Is a system of rotation for th e selection of the sites the solution?  
One solution that came up during the consultation pro cess is to have a system of rotation between the 
Member States for the selection and attribution of the Label. For example, only one third or one fourth 
of the Member States would be allowed to propose sites in any given year. Such a rotation system would help to avoid the number of sites awarded th e Label increasing too fast, it would help to keep 
the selection procedure more manageable each y ear and it would considerably decrease the work 
burden at national level. 
 
EN 66   EN Would such a rotation system be an acceptable soluti on? If yes, what would be a reasonable time span 
between two selection rounds for a Member State? Three years, four years or five years? 
3. Shall the label be attributed to the sites for a limited period of time or on a permanent basis?  
Another idea which emerged during the negotiation process in the Council was to attribute the label 
for only a limited, but renewable, duration. The argum ents in favour of this solution were that this 
would be coherent with the fact th at this label is much more about the educational and cultural projects 
put forward by the sites (cf. 2b of the conclusions ) than about conservation or preservation, and that 
this would help to ensure its distinctiveness vis-à- vis other existing initiatives. On the other hand, it 
was also mentioned that the time period needed to be long enough, and renewable, for the sites to feel 
that the investment effort was justified. 
The label could thus be awarded for example for 5 or 6 years and after this period a Member State 
could choose to either propose the renewal of the sa me site for a new period or to propose a new site. 
The advantage here would be to keep control over the overall number of sites awarded the label and to 
ensure that the sites actually comp ly with the commitments they ha ve made. This idea appealed to 
many stakeholders during the consultation process. 
Would the attribution of the label for a limited period be acceptable or is such an option inconceivable 
in the heritage field where organisations are traditionally used to work in the long term? If yes, would it be conceivable to have two lists as was proposed by several stakeholders: one "active" list with the 
sites which currently hold the label and one "passive " list with the sites which held it in the past? 
In case the label is attributed on a permanent basis, how can it be ensured that the sites comply with 
commitments they may have made ten or twenty years earlier? The conclusions mention that the sites "could be subject to periodic review" (3f). What form should this review take if the label is attributed 
on a permanent basis? Should it be possible for the label to be withdrawn fro m certain sites? Under 
which conditions? 
 
 
EN 67   EN Discussion paper n°2:  how to keep the administrative  arrangements for the future 
European Heritage Label light and flexib le at national and European level? 
The Council conclusions mention that the Europe an Heritage Label shou ld keep "flexible and 
streamline administrative arrangements in complian ce with the principle of subsidiarity." (3b) 
This was indeed a central element in the ne gotiations for the adoption of the conclusions. 
Without a strong commitment to keep the costs limited both at national and European level and a strong commitment to avoid all unnece ssary bureaucracy, no agreement could have 
been reached between the Member States. This same concern has been expressed on 
numerous occasions during the consultation process and several stakeholders have underlined the importance of also taking in to account the potential hidden  costs (including for example 
self-generating bidding processes)  or potential inflation of the workload which might only 
become apparent after several years.    
An appropriate division of tasks between na tional and EU level will be one of the main 
challenges for the future label. There is genera l consensus that subsidia rity should remain the 
key principle and that th e EU should intervene only where it  can bring a clea r added value to 
the initiative. Concerning the selection procedur es for example, the conclusions mention that 
the selection procedure should be  carried out initially at na tional level and then only at 
European level. 
The main tasks for the Member States would thus be to organise the first stage of the selection 
procedure and the regular monitoring of all the sites awarded the label on their territory in 
order to ensure that they comply with undertak ings they have given. The main tasks of the 
Commission would be to ensure the homogeneous  application of the criteria by all the 
Member States, to guarantee the continuity of the la bel through a permanen t secretariat, to 
support the work of the group of European expe rts in charge of the second stage of the 
selection and monitoring procedur es, to facilitate networking activities and to ensure the 
visibility of the label, for example through a common portal or website. 
1.Which practical arrangements at European level?
 
The permanent secretariat w ould replace the current revolving secretariat of the 
intergovernmental label and its core tasks woul d be the general coordination of the label and 
provision of support for the Europe an experts panel. This secretar iat should remain  as light as 
possible. 
Concerning the financial implications at European  level, in addition to the secretariat of the 
label, the costs should be limited to funding the work of the European experts, some 
networking activities between the sites and a website.  
2. Which practical arrangem ents at national level?  
In accordance with the subsidiarity principle, the practical arrangements at Member State 
level should remain as flexible as possible in order to be tailored to  national circumstances. 
However, how can it be ensured that this flex ibility will not harm the overall quality and 
prestige of the label and that each Member St ate will respect the common rules and criteria? 
Participation in the label will be on a voluntary basis. Each Member State which decides to 
participate will have to commit itself to the effective organisation of the selection and 
 
EN 68   EN monitoring procedures at national level. How can it be ensured that the workload associated 
with these procedures can be kept under control?  
The financial obligations linked to the label at a national level should be limited to the 
practical organisation of these procedures. Any other expenses linked to the label, either 
during the bidding phase for the a ttribution of the label or dur ing the implementation of the 
educational and cultural programmes on the site s should be left to the free decision of 
Member States and should not create formal obligations for them. Ho w can potential hidden 
costs of the label be avoided (for example, expensive self-generati ng bidding processes)?  
Although the Council conclusions re fer to a first selection occu rring at national level, the 
consultation leads us to believe that this will in  fact be a rather expe nsive approach and more 
difficult to prevent unexpected costs arising both  for Member States and the sites themselves. 
Another more cost-effective solution which came up during the consultation would be to 
leave the sites themselves to a pply directly to an independent expert organising body recruited 
by the European Commission (see also questio n 1 above), which would design a simple 
procedure and simple application form. This w ould have the advantage of taking away the 
organising burden and its associated costs at the national level. Would such a solution be 
conceivable? 
 
__________ 
 
 
EN 69   EN ANNEX 3:  
    
CRITERIA FOR THE SELECTION OF THE SITES 
 
EN 70   EN  
The first question which needs to be raised concerning the criteria is which type of 
heritage should be eligible for the attri bution of the EHL. This question was debated 
in the Council during the preparation of  the conclusions. After long and complex 
negotiations, MS agreed on a list insp ired by various UNESCO and Council of 
Europe conventions. This list includes: "monu ments, natural or urban sites, cultural 
lanscapes and places of remembrance, as well as cultural goods and intangible heritage attached to a place, including c ontemporary heritage". The complexity of the 
negotiations between the MS leaves littl e room for manoeuvre. During the Inter-
service group meetings, DG MARE and DG INFSO requested the addition of 
"cultural objects" to the list in order to ensu re that traditional ships or film heritage 
were also covered by the defi nition as far as they were linked to a physical site. 
Further to the question of the type of he ritage which should be eligible, a set of 
criteria was designed for the actual selection of the candidate sites.  These criteria are 
largely inspired by the Council conclusions  in which the MS made a number of 
proposals. These proposals were then discussed and re-evaluated during the 
consultation process and they were then further developed by the Commission. Two 
main concerns were taken into account. Firstly, to ensure that there will be no 
overlap with other existing initiatives in th e field of cultural heritage and reinforce 
the added value of the EHL. Secondly, to li nk these criteria as much as possible to 
the objectives of the EHL, especially to the operational objectives and to the activities that should be implemented by th e sites in order to contribute to the 
specific, intermediate and general objectiv es. The criteria are listed below and are 
divided into three categories linked to th e European dimension of the sites, the 
quality of the projects they submit and the quality of the management proposed. 
1. European dimension 
Candidates for the label shall have a symbolic value for Europe's identity and shall 
have played a key ro le in the history and the building of Europe. The sites shall 
therefore justify: 
¾ their cross-border or pan-European natu re: the past and present influence and 
attraction of a candidate site must  go beyond the national borders of a 
Member State; 
¾ and/or the place and role of a site in European history and European 
integration, and its links with key European  events or personalities, as well as 
with cultural, artistic, political, social, scientific or technol ogical movements ; 
¾ and/or the place and role of a site in the development and promotion of 
common values such as freedom, democracy, respect for human rights, cultural diversity, tolerance and solidarity that underpin European integration. 
These criteria are not cumulative. Each site must justify that it fits into one of the 
criteria as a pre-c ondition for being selected. The st rong European dimension and the 
symbolic value of sites are essential elements for the originality of the EHL compared to other initiatives, notably the UNESCO World Heritage List. The three 
criteria are built mainly on elements which are present in the Council conclusions 
 
EN 71   EN and were discussed at length by the MS in th is context. Some room for interpretation 
was deliberately left open, firstly for reas ons of subsidiarity as there are some 
differences in interpretation between MS, a nd secondly in order not to close the door 
to highly original sites which might have  a strong potential and are difficult to 
foresee. The selection panels at national and / or EU level will therefore have an essential role to play in evaluating if th e European dimension and the symbolic value 
of a site are strong enough and if the site is relevant in the light of the objectives of 
the EHL. Inspiration should be drawn from  the experience of managing the European 
Capitals of Culture, which have a degree of flexibility in the criteria, and which is 
recognised as necessary for such  an event in the light of European diversity in this 
area. 
2. Quality of the project submitted 
Candidates for the label shall submit a project which promotes their European 
dimension and commits them to all the following elements: 
¾ raising awareness on the European signi ficance of the site, in particular 
through appropriate information activ ities, signage and staff training; 
¾ organising educational activities, esp ecially for young people, which increase 
the understanding of the common history of Europe and of its shared yet 
diverse heritage and which strengthen  the sense of belonging to a common 
space; 
¾ promoting multilingualism by using several languages of the European 
Union; 
¾ taking part in the activities of netw orks of sites awar ded the European 
Heritage Label in order to exchange experiences and initiate common projects; 
¾ raising the profile and the attractivene ss of the site on a European scale, 
notably through the use of modern technologies. 
¾ The organisation of  artistic and cultu ral activities (for example events, 
festivals, residencies) which foster the mobility of European artists and collections, stimulate inte rcultural dialogue and en courage linkage between 
heritage and contemporary creation a nd creativity are welcomed whenever 
the specificity of the site allows it. 
These criteria are cumulative except for the last indent whic h will depend on the 
"physical" capacity of a site to actually or ganise such artistic and cultural activities. 
They derive directly from the operational objectives of the EHL and will therefore contribute concretely and pr ogressively to the achieve ment of the higher level 
objectives. These elements are all derive d from the Council conclusions and are 
essential to ensuring the adde d value of the label and to achieving its objectives, so 
that the sites actively reach out to and e ducate citizens, rather than simply limiting 
themselves, for example, to a plaque placed on a building. 
 
 
EN 72   EN 3. Quality of the management proposed 
Candidates for the label shall submit a management plan which commits them to all 
the following elements: 
¾ ensuring the sound management of the site; 
¾ ensuring the protection of the site and its  transmission to future generations in 
accordance with the relevant protection regimes; 
¾ ensuring the quality of the reception facilities such as the historical 
presentation, the visitors in formation, the signage, etc. 
¾ ensuring access for the widest po ssible public, notably through site 
adaptations or staff training; 
¾ according special attention to young peopl e, in particular by allowing them 
privileged access to the site; 
¾ undertaking the promotion of s ites as tourist destinations; 
¾ developing a coherent and comp rehensive communication strategy 
highlighting the European dimension of the site; 
¾ ensuring the management plan is as e nvironmentally friendly as possible in 
order to limit potential negative impacts of tourism. 
These criteria are also cumulative and de rive from the operational objectives of the 
EHL. The quality of management was a co ncern expressed notably by the MS which 
do not yet participate in the intergovernmental initiative and was therefore included in the Council conclusions. Furthermore, it is essential for ensuring the effective 
implementation of the key elements of the project, mentioned above. 
Two remarks need to be made concerning th e criteria in the last two categories and 
the fact that they are cumu lative. The first is that al though these criteria may look 
very ambitious, many potential sites for th e EHL do already fulfil a number of them 
and will therefore only have to make limited adjustments and investments. This is 
notably a lesson learnt from the analysis ECOTEC made from the sites which were 
already awarded the label in th e intergovernmental initiative
12. The second is that a 
very diverse range of sites can potentially be awarded the label. If we take the list of 
the intergovernmental EHL, the Robert Schumann house in Scy-Chazelles is very different from the Acropolis in Athens, a nd the Gdansk shipyards are very different 
from the Franja Hospital at Dolenji Novaki in Slovenia. The level of requirements for each criterion will therefore vary considerably from one site to another and must 
be adapted to the specificity of each site . In the case of some prestigious sites, 
ambitious educational, information or prom otion activities can be  expected, whereas 
for smaller sites with a strong symbolic va lue, the criteria can  be met in a more 
modest way. Here too, the national and / or European selection panels will have an 
                                                
 
12 See ECOTEC report: http://ec.europa.eu/dgs/e ducation_culture/evalreports/index_en.htm  
 
EN 73   EN essential role to play by evaluating what  is relevant and appropriate for each 
candidate site. 
For the reasons mentioned above, it is also very difficult to estimate the costs of 
participating in the EHL for a site. Each criteria in the last two categories may 
potentially ask for investments from a site a nd have costs. But this will vary greatly 
from one site to another and on what is already in place. Quantification is not 
therefore possible. 
It needs to be repeated in this context th at participation of the MS and the sites will 
be voluntary, so none of the costs will be "imposed". On the other hand, one of the benefits for the sites is that  it may of course open the door for them to sources of 
national funding. 
 
EN 74   EN  
ANNEX 4:  
    
LIST OF THE COUNTRIES PARTICIPATING IN THE  
INTERGOVERNMENTAL EUROPEAN HERITAGE LABEL 
AND OF THE SELECTED SITES 
(OCTOBER 2009)
 
EN 75   EN  
COUNTRY SITE 
Palace of the Prince-Bishops at Liege 
Stoneware of Raeren (German Community) 
Archaeological site of Ename BELGIUM 
Archaeological site of Coudenberg 
Archaeological site of  Debelt 
Memorial Vassil Lesvki 
Historic town of Rousse BULGARIA 
Boris Christoff Music Centre 
Fortifications of Nicosia 
Castle of Kolossi 
Site of Kourion CYPRUS 
Circuit of 6 churches with Byzantine and post Byzantine frescos, 
Troodos 
Castle of Kynzvart 
Zlín, town of Tomas Bat'a 
Vítkovice coal mine at Ostrava CZECH 
REPUBLIC 
Memorial of Antonin Dvorak at Vysoka 
Cluny Abbey 
House of Robert Schumann, near Metz FRANCE 
Pope's Palace Court, Avignon 
 
Acrópolis, Athens 
Knossos Palace 
Archaeological site of Poliochne GREECE 
Byzantine site of Monemvasia 
Royal castle of Esztergom 
Szigetvar fortress 
The Reformed college and great church at Debrecen HUNGARY 
Royal palace of Visegrád 
Birthplaces of Rossini, Puccini and Verdi ITALY 
Birthplace of Gasperi 
 
EN 76   EN COUNTRY SITE 
Ventotene Island 
Capitole Place in Roma 
Historic centre of Riga 
Rundale Palace LATVIA 
Town of Kuldiga 
Mikalojus Konstantinas Ciurlionis' works 
Historical centre of  Kaunas 
Zemaitija (lowlands) region and the Hill of Crosses LITHUANIA 
Museum of Genocide Victims (1940-41) at Vilnius 
MALTA Catacombs of Rabat 
 
Gdansk Shipyards 
Hill of Lech at Gniezno (Cathedral, church, palaces, museum) 
Cathedral St Wenceslas and Stanislas, Krakow  POLAND 
Town of Lublin 
Braga cathedral 
Convent of Jesus at Setubal 
General library of the University of Coimbra PORTUGAL 
Abolition of the death penalty 
Archaeological site of Istria 
Cantacuzino Palace at Bucarest 
Roman Athenaeum at Bucarest ROMANIA 
Park Brancusi at Targu Jiu 
Pre Romanesque Ecclesiastical Architecture, St Margaret church, 
Kopcany 
The Castle of Červený Kame ň SLOVAKIA 
The Barrow of General Milan Rastislav Štefánik at Bradlo 
Memorial church of the Holy Spirit at Javorca 
Franja Hospital at Dolenji Novaki SLOVENIA 
Zale Cemetery at Ljubljana 
Crown Aragon Archive 
Yuste Royal Monastery SPAIN 
Cap Finisterre  
 
EN 77   EN COUNTRY SITE 
Students Residence, Madrid 
Cathedral St Peter in Geneva 
Castle of La Sarraz SWITZERLAND 
Hospice of St Gotthard 
 
 
EN 78   EN ANNEX 5:  
 
 
 
 
TABLE 1 
COMPARISON OF THE OP TIONS IN TERMS OF 
LIKELY IMPACTS COMPARED  TO BASELINE OPTION 
 
EN 79   ENTable 1:  Comparison of options in terms of likely impacts compared to the baseline option  
Option 3: EU initiative…  
 
Option Option 1: 
Status quo Option 2: 
Status quo 
plus EU 
funding ..with MS 
selection 
(a) ..with EU 
level 
selection 
(b) .. with MS 
pre-
selection 
and EU 
level 
approval (c)  
Assessment 
KEY: 
=  baseline or equivalent to baseline                        + to +++ minor to major improvement compared to baseline                         - to --- minor to major worsening compared to baseline 
SOCIAL/SOCIETAL IMPACTS 
Increased access to 
cultural heritage 
resources = + ++ ++ +++ This effect is most likely to be felt for under-d eveloped sites for whom th e Label offers a more 
substantial opportunity for profile-raising and in creased visitor numbers. There might be some 
improvement under option 2 due to improvements in visibility and profile (see table 2). Access 
is likely to be most improved under option 3 on account of enhanced management plans and 
improved monitoring. MS involvement in option 3c would enhance this further. 
Increased access to 
heritage for young 
people = (+) + ++ +++ There might be some improvement under option 2 in light of the likely general effects on 
access.  Access is likely to be improved under option 3 on acc ount of enhanced management 
plans and improved monitoring. Option 3 provides for enhanced opportunities to link 
heritage/culture with education (and thereby young people) through an integrated approach 
from the Commission via DG EAC. 3(c) would ensure MS inter- (or intra-) ministry 
engagement (between educa tion and culture domains). 
Increased interest in 
and knowledge of 
common European 
heritage = (+) + ++ ++ This impact assumes that as a consequence of visiting a labelled site individuals will increase 
their interest in and knowledge of common Eur opean heritage.  Achieving this will depend on 
sites realising a number of obligations includ ing effectively communicating their European 
aspects. Improvements agains t the baseline would be real ised through better central 
coordination and emphasis on commonalities, expressed through activity at labelled sites and 
higher profile/access to informa tion pertaining to the EHL from central (web based) sources. 
Such benefits would most likely be realised under option 3 and especially where there is a 
strong EU tier (3b and 3c).  Some benefits  might be achieved through option 2 where there 
may be a slight improvement in the European dimension (see table 2) 
 
EN 80   ENOption 3: EU initiative…  
 
Option Option 1: 
Status quo Option 2: 
Status quo 
plus EU 
funding ..with MS 
selection 
(a) ..with EU 
level 
selection 
(b) .. with MS 
pre-
selection 
and EU 
level 
approval (c)  
Assessment 
Increased 
understanding of 
European  cultural 
diversity = = + +++ ++ This impact assumes that individuals will have an increased understanding of European 
cultural diversity on account of inte racting with labelled sites.  EU intervention might be better 
able to emphasise such cultural diversity aspects.  This impact is likely to flow most directly 
through an emphasis upon the transnational aspects of the Label. Option 3(b) provides an 
enhanced opportunity to co-ordinate and emphasise this as a priority. 
Increase in 
intercultural dialogue = = + + + This effect goes a step beyond impacts on the k nowledge and understanding of individuals and 
assumes that as a result of increases in these area s there will be greater levels of intercultural 
dialogue.  This is therefore a long-term term effect and would be more difficult to achieve than 
other effects since it would involve more complex activities – especially transnationality - and 
might not be inherent to all sites. EU intervention would be  better able to emphasise 
intercultural dialogue through the secretariat and by co-ordinating ev ents, networking etc. 
Greater sense of 
belonging to the 
European Union = = (+) (+) (+) Strong evidence from across many fields of rese arch makes the link between cultural identity 
and heritage. But any impacts the Label mi ght make on sense of belonging would be 
considerably affected by other factors and would be realised only in the long term.  Again, it 
goes a step beyond raised levels of knowledge and understanding.  Howe ver, the key aim of 
the EHL to increase a sense of belonging to Eur ope (and the EU) would be enhanced by EU 
involvement and the coordination and encourag ement of this level of activity aimed 
specifically at emphasising the European aspects of the Label. 
 
Stronger participation 
in the democratic 
process = = = = = This would be an indirect effect of the La bel, would be highly dependent on many other 
factors, and could be realised  only in the long-term; however, the relation between democratic 
participation and a sense of belonging or ow nership is evidenced in research and the 
assumption then is that citizens will be enc ouraged to participate as they understand the 
European dimensions of their own cultural heri tage. For New Member States this may be of 
particular importance as they seek gr eater integration with 'old' Europe.  
 
 
 
EN 81   ENOption 3: EU initiative…  
 
Option Option 1: 
Status quo Option 2: 
Status quo 
plus EU 
funding ..with MS 
selection 
(a) ..with EU 
level 
selection 
(b) .. with MS 
pre-
selection 
and EU 
level 
approval (c)  
Assessment 
ECONOMIC IMPACTS 
Positive effects on the 
local tourism industry, 
including number of 
people employed = = (+) (+) (++) Direct economic benefits through increased visitor numbers are unlikely to be major effect of 
the EHL in a first stage, especially in establishe d tourist sites with alr eady high visitor figures.  
Rather, EHL is likely to impact most on the quali ty of the visitor experience and in developing 
and enhancing their understanding of the site fro m a European perspective.  Nonetheless there 
are likely to be positive effects on local and regional tourism through the greater publicity and 
potentially the attraction of new visitors attract ed via networked activity, which are likely to be 
greater under a EU initiative for th e reasons set out in Table 2. Some additional employment is 
likely to be generated directly and indire ctly at sites and downstream through service 
industries, especially if the EHL acquires a st rong credibility and prestige. Option 3c might 
have the strongest impact in th e long term because it ensures best mix between the quality of 
the selected sites and the fair distribution of labels across MS. 
Development of links 
with cultural and 
creative industries = = (+) (+) (+) Impacts here as a direct result of the EHL are likely to be minimal in a first stage.  But option 3 
could potentially place a greater emphasis upon integration with creative industries, 
particularly on site and through networked events  and activities. Improve ments on this impact 
may also flow from better links to  other EU policies and programmes. 
Development of 
innovation and 
creativity = = (+) (+) (+) Direct impacts as a result of EHL are likely to be marginal.  However, option 3 could provide 
greater priority for integrating innovative tech niques for promoting the EHL on sites, and 
through networking, particularly emphasising the use of Information and Communication 
Technologies.  Improvements might also be de rived from closer links to other policies and 
programmes of the EU. 
 
ENVIRONMENTAL IMPACTS 
Negative effects 
linked to over-
development of 
tourism = = + + + Effects are highly variable due to locality-dep endent nature of this impact. However, the 
enhanced monitoring capa city offered by option 3 would enable a greater emphasis and more 
resource to be placed upon amel ioration and monitoring of impa cts, with management plans 
and sustainable development objectives inco rporated into monitoring and evaluation. 
 
EN 82   ENOption 3: EU initiative…  
 
Option Option 1: 
Status quo Option 2: 
Status quo 
plus EU 
funding ..with MS 
selection 
(a) ..with EU 
level 
selection 
(b) .. with MS 
pre-
selection 
and EU 
level 
approval (c)  
Assessment 
Protection of cultural 
heritage = = + = + The label may be regarded as an extra 'lay er' of conservation/prot ection – although clearly 
there is no legal basis or intent for this to be so. However, as an unint ended 'side effect', the 
raising of the profile of some sites from a her itage perspective should be regarded as a positive 
effect.  This should be a little  bit stronger under options 3a and 3c which would ensure a 
greater ownershi p by the MS. 
 
EN 83   EN  
 
ANNEX 6:  
   
 
TABLE 2 
COMPARISON OF THE OPTIONS AGAINST 
EFFECTIVENESS, EFFICIENCY  AND COHERENCE CRITERIA 
 
EN 84   ENTable 2:  Comparison of the opt ions against effectiveness, e fficiency and coherence criteria 
Option 3: EU initiative…  
 
Option Option 1: 
Status quo Option 2: 
Status quo 
plus EU 
funding ..with MS 
selection 
(a) ..with EU level 
selection (b) .. with MS pre-
selection and EU 
level selection (c)  
 
Assessment 
KEY: 
=  baseline or equivalent to baseline                        + to +++ minor to major improvement compared to baseline                         - to --- minor to major worsening compared to baseline  
EFFECTIVENESS 
Representativeness  
 = = +  - + Transforming the EHL into a EU action would probably increase the 
number of MS participating in the initiative. EU level selection alone, 
without reference to the nationality of a site (option 3b), carries the risk 
that it would favour countries with  well-developed cultural heritage 
sectors who are more used and be tter able to make high quality 
applications, irrespective of the actual merit of a site. Some countries 
might therefore be under-represented. 
European dimension – 
significance of sites 
 = (+) + +++ ++ Under the intergovernmental initiative, Labelled sites have varied in their 
European significance and the way in which they have sought to make it 
clear, yet this is central to developing European citizens' understanding of 
their common yet diverse cultural her itage.  In general, improvements 
would be possible through better ma rketing and networking. Additional 
funding alone (option 2) might have  a marginal positive effect on the 
priority accorded to the European significance of sites, provided it were 
used to support expert meetings.  More substantial gains would be likely 
if an EU level secretariat were in pl ace (option 3), since it would be more 
possible to ensure that this dimension were given priority.  This would be 
especially so if there was some form  of EU level selection (options 3b 
and 3c).  EU level selection alone would be most likely to stress the 
European dimension (option 3b). 
Transnationality and 
networking 
 = + + +++ ++ Funding to support networking would achieve some improvement on this 
dimension (option 2). It is also impor tant to facilitate the selection of 
"transnational sites" which thus depe nd simultaneously from several MS.  
If MS selection were to predominate (option 2 or 3a) this would still be 
difficult..  The transnational dimens ion could be better emphasised if 
there were to be some form of EU level selection process (options 3b and 
3c), and especially if MS level sel ection were to be removed altogether 
(option 3b).  There is also experien ce in the Commission about how best 
to ensure exchanges of good practice and build partnerships.  The EU 
 
EN 85   ENOption 3: EU initiative…  
 
Option Option 1: 
Status quo Option 2: 
Status quo 
plus EU 
funding ..with MS 
selection 
(a) ..with EU level 
selection (b) .. with MS pre-
selection and EU 
level selection (c)  
 
Assessment 
also has strong potential to act as an 'honest broker' (legitimacy). 
Visibility, profile and access 
 = + ++ ++ +++ High visibility and profile are important  for raising awareness of the sites 
and for opening up access. The lo w visibility from which the 
intergovernmental EHL has suffere d might be improved through the 
extra funding available under option 2.  But leaving the secretariat 
function at MS level means that th e effectiveness of publicity and 
marketing activities will depend upon the competences of a particular 
ministry to effectively commissi on these activities on a pan-European 
level.  Visibility would be improved by being a fu ll EU initiative (option 
3), able to benefit directly from be ing able to use the EC's established 
media channels and experience in this  area (e.g. through European Years, 
ECOC, EU Prize for Cultural Heritage / Europa Nostra Awards) ); and 
access would be more likely to be en hanced by ensuring compliance with 
this objective.  Profile would also stand to benefit through the 
involvement of a tier of EU level se lection which would be more likely to 
be perceived as expert and independent (options 3b and 3c).  Having both 
MS and EU involvement would be mo st likely to ensure high visibility 
and profile since marketing and public ity could take place at both levels, 
as used in the European Years to good effect. Access would probably 
also benefit through improved sharing of good practice through close MS 
involvement. 
Artistic, cultural and historical 
education = = + ++ ++ Additional funding for central activitie s (option 2) would be unlikely to 
lever improvements in sites' educa tional activities.  Making the EHL a 
EU initiative (option 3) could deliver  improvements if greater emphasis 
were to be placed upon this component  through selection and subsequent 
enforcement, which would be st rongest under options 3b and 3c. 
Programmes of cultural 
activities = = + ++ ++ Extra funding alone (option 2) w ould not have any effect on the 
effectiveness of sites' cultural programme.  Greater stress could be placed 
on this element through the more rigorous selection processes possible 
under a EU initiative, especially under options 3b and 3c. 
EFFICIENCY 
Selection processes = = + ++ +++ Whilst selection criteria were establis hed for the interg overnmental EHL, 
the selection process has not always b een transparent, and there has been 
much scope for national interpretation of the criteria. Additional funding 
 
EN 86   ENOption 3: EU initiative…  
 
Option Option 1: 
Status quo Option 2: 
Status quo 
plus EU 
funding ..with MS 
selection 
(a) ..with EU level 
selection (b) .. with MS pre-
selection and EU 
level selection (c)  
 
Assessment 
for the status quo model (option 2) would be unlikely to impact upon this 
to any significant degree. Making the EHL a EU initiative (option 3) 
would have the effect of increasing the transparency of the process and 
the clarity with which the criteria ar e applied.  Selection at EU level 
(options 3b and 3c) would in particular help to ensure that criteria are 
consistently applied.  However, it is  important that MS commitment is 
maintained (as in option 3c), not l east because (a) the complex processes 
through which European identity will be realised need to involve both 
European level and national interpreta tions of culture and history; (b) 
there is a need to ensure a fair distribution of sites across MS (see 
'Representativeness' criterion above); and (c) MS represent an important 
resource and infrastructure. MS commitment would be jeopardised under 
option 3b. 
 
Delivery and compliance 
(monitoring and QA) = (+) ++ + +++ Additional funding for the status quo option (option 2) might make 
monitoring (which has not taken place under the intergovernmental EHL) 
possible on the part of the secretariat but establishing and maintaining 
systems would still depend on the e xpertise available within a given 
ministry. 
A EU initiative (option 3) in contrast w ould be more likely to be able to 
use expertise available to the Commission to set up and maintain the 
necessary systems and would not be s ubject to having to transfer systems 
periodically, as would be the case with a revolving ministry-based 
secretariat.  However, centralising responsibility for monitoring and QA 
processes at EU level which would be necessary if there were solely EU 
level selection (option 3b) would pr obably be too remote (and hence less 
efficient) and would also load additional administration onto the  
secretariat.  Critically, it would carry a significant risk of losing 
commitment at MS level to their sites and thus disengagement of the 
ministries  (and their agencies) who should maintain the key relationship 
with sites in this regard. At the same  time, there would be value in having 
some form of review at EU level wh ich is independent of each MS, e.g. 
the expert panel to check that oblig ations have been fulfilled after 3 
years. This would suggest that the best model would be a clear 
distribution of functions between MS and EU levels (option 3c). 
 
EN 87   ENOption 3: EU initiative…  
 
Option Option 1: 
Status quo Option 2: 
Status quo 
plus EU 
funding ..with MS 
selection 
(a) ..with EU level 
selection (b) .. with MS pre-
selection and EU 
level selection (c)  
 
Assessment 
Administrative arrangements 
at EU and MS level = - - -- --- The administrative burden would increase under all of the options 
compared to the baseline.  Under option 3a the administrative burden 
would be largely shared across MS, whereas under 3b a significant 
burden would fall on the central secr etariat in organising selection, 
monitoring etc. Administration would probably be most substantial under 
option 3c where it would be necessary to ensure close integration 
between the MS and EU selection processes, requiring significant 
communication and liaison functions.   
Financial impacts for the EU = - -- --- -- Although all of the options would ha ve very limited impacts on the EU 
budget,  the financial implications fo r the EU need to be taken into 
account. In addition to the funding of some networking and 
communication activities (option 2), op tion 3 would also imply the costs 
of the secretariat which would be provided by the Commission. The 
financial implications are therefore related to the scale of the 
administrative tasks required from the EU level and thus would be 
greater under options 3b than under options 3a and 3c where more tasks 
would be shared between EU and MS level. 
Communication with other 
international bodies = + ++ +++ +++ A secretariat at MS level (option 2) w ould be unlikely to be able to open 
up the same quality of communication with other international bodies 
than a secretariat at EU level.  Credibility in those communications 
would be increased where the EU has a role in selection (options 3b and 
3c). 
COHERENCE 
Limitation of trade-offs across 
social, economic and 
environmental domains = = + + + The social and economic success of sites (greater access, more tourism) 
is likely to lead to negative enviro nmental effects under whichever option 
is pursued. However, the magnitude of the trade-off may be positively 
affected by incorporating mana gement plans and sustainable 
development objectives into selec tion and monitoring requirements. 
Synergies and 
complementarities with other 
initiatives = = ++ +++ +++ An EU-level secretariat (option 3) offers much greater prospect of 
realising such synergies and compleme ntarities than where the secretariat 
rests with the MS (options 1 and 2) since communication channels and 
joint working are al ready established (e.g. with the Council of Europe on 
Heritage Days).  The credibility of th e EU with other bodies is probably 
greatest where there is some form of EU-level selection (options 3b and 
 
EN 88   ENOption 3: EU initiative…  
 
Option Option 1: 
Status quo Option 2: 
Status quo 
plus EU 
funding ..with MS 
selection 
(a) ..with EU level 
selection (b) .. with MS pre-
selection and EU 
level selection (c)  
 
Assessment 
3c) 
Participation of third countries 
in Culture programme  = = +++ +++ +++ Even if it is quite likel y that the EHL will commence with the EU 27 and 
that the participation of third coun tries would be considered only in a 
second stage after a first evaluation, this is much more likely to be 
facilitated effectively where the secretariat is provided by the 
Commission (option 3).  It is unlikely that there would be much 
difference between the sub-options under option 3. 
 
EN 89   EN ANNEX 7: 
       
OTHER INTERNATIO NAL INITIATIVES 
IN THE FIELD OF CULTURAL HERITAGE 
 
EN 90   EN  
Besides the EHL a number of ot her international initiatives ex ist in the field of cultural 
heritage including notably the UNESCO Worl d Heritage List, the Council of Europe 
Cultural Routes or the EU Prize for Cultura l Heritage / Europa Nostra Awards. This 
has created confusion around the EHL, as well as some fears concerning possible 
overlaps. Therefore, the Comm ission asked ECOTEC as part of their support services 
to examine these different schemes. ECOTEC's  analysis demonstrated clearly that the 
EHL is very different from the other initiatives and that it has the potential to add value in terms of all three of its core elements: the European dimension, pedagogy and 
networking
13. 
The UNESCO World Heritage Convention was adopted in 1972. Once a country has 
ratified the Convention, it can nominate site s to be considered for inclusion on the 
World Heritage List. To date, 890 sites ar e listed: 689 cultural, 176 natural and 25 
mixed properties, in 148 stat es. There are four main differences between the EHL and 
the World Heritage List. The EHL focuses on si tes which have played a key role in the 
history and the building of Europe while  the UNESCO list designates sites of 
universal value. The EHL is not about the beau ty of a site or its architectural quality 
but about its symbolic value for European in tegration. To name just one example, the 
UNESCO designated the Kremlin and the Red Square in Moscow which has a 
wonderful architecture but was also the residence of Stalin, while the 
intergovernmental EHL designated the Gdan sk Shipyards which have a symbolic 
signification for the reunification of Europe. In contrast to the UNESCO list, the EHL 
is not about the conservation of sites, but about the activities they propose and their 
educational dimension, especially for young people. Finally, the EHL seeks to 
stimulate the networking of labelled s ites, as well as common projects. 
The Europa Nostra Awards began in 1978 and became the EU Prize for Cultural 
Heritage / Europa Nostra Awards in 2002 wh en Europa Nostra started to cooperate 
with the European Commission in the framework of the Culture programme14. In 
2009, 60 % of the budget of the Prize / Awards came from a EU grant (200 000 € for a 
333 333 € total budget). Each year awards are attribut ed in four categories: 
conservation, research, educa tion and dedicated services. In  contrast to the EHL, the 
Awards focus on the conservation of cultural heritage. They are one off prizes which 
recognize achievements afte r the fact, and unlike the EHL do not set in train 
development activities; nor are they de signations which can  be subsequently 
withdrawn if criteria are not met. Furtherm ore, the awarded achievements do not need 
to have a European narrative, but the pri ze seeks to highlight excellence at European 
level and promote exch ange of practice. 
The Cultural Routes programme was launche d by the Council of Europe in 1987. 25 
routes have been designated to date i nvolving approximately 30 000 towns and cities.  
The Mozart route for example is a network set up along 18 historic  routes taken by 
Mozart across ten countries. Technical s upport is provided to the routes by the 
European Institute of Cultural Routes in L uxembourg which currently benefits from an 
                                                 
13  See ECOTEC report: http://ec.europa.eu/dgs /education_culture/evalreports/index_en.htm  
14 Europa Nostra is the pan-European federation for cultural heritage.  It represents over 250 heritage 
NGOs in 45 countries across Europe, and works to recognise good practice among heritage projects. 
 
EN 91   EN EU operating grant in the framework of th e Culture programme for which it has to 
compete through an open call for proposals. In  terms of objectives, the Cultural Routes 
are probably the closest to the EHL as they also aim at raising awareness on a European cultural identity and European citizenship or at promoting intercultural dialogue. However the modus ope randi of the Routes is ve ry different to the EHL. 
Firstly, while the EHL concentrates mostly  on the 27 EU MS, the Cultural Routes are 
open to the 47 MS of the Council of Europe and over recent years, the focus of the 
initiative has been very much on the c ountries which are not in the EU. Secondly, 
while the EHL is attributed to individual sites which have to implement a number of very specific activities, the Cultural Routes concern very loose and very large thematic 
networks of sites that span several countri es and often simply signpost vis itors to 
towns and cultural attractions en route with  very little obligations for the sites 
themselves. Thirdly, while the EHL aims at promoting a European reading of symbolic sites of the building of Europe, th e objective of the thematic networks of the 
Cultural Routes is to illustrate the histor y of influences and exchanges across Europe, 
but the themes in themselves can sometime s have a limited European significance (the 
Routes of the Olive Tree, Parks and Gard ens, the Iron Route in the Pyrenees, …). 
As mentioned in section 1.2.2.2 of the IA report, the representatives of ICOMOS 
(consultative body for the UNESCO World Herita ge List), the European Institute of 
Cultural Routes and Europa Nostra who par ticipated in the consultation meeting all 
confirmed the added value of the EHL. Nevert heless, they also unde rlined that clearer 
communication would be needed to clarify the differences, especially for the general 
public. 
Communication between the intergovernmen tal EHL and the other initiatives has 
remained very limited so far, which has hi ndered the building of synergies. There is 
however a potential for cooperation. Firstl y, because the initia tives all reward 
excellence and stimulate improvements in the field of cultural heritage, but they cover 
different aspects of the domain (preserv ation, conservation, promotion, information, 
education…). Secondly, because the initia tives have very different geographical 
scopes. It is also possible that one specific site takes part or is rewarded by two or 
more initiatives for different aspects of its  work. So far, among the 64 sites of the 
intergovernmental label, 6 are also on the World Heritage List, 12 are part of Cultural 
Routes networks and 3 were rewarded by EU Prize for Cultural Heritage / Europa 
Nostra Awards. This is also a basis on which synergies could be developed.
 
EN 92   EN Profiles of other international initiati ves against key features of the EHL: 
 
Initiative European 
Heritage Label Council of 
Europe 
Cultural 
Routes EU Prize for 
Cultural Heritage / 
Europa Nostra 
Awards UNESCO World 
Heritage List 
Objectives 
Scope Identification and 
promotion of 
European 
dimension of 
cultural heritage Promotion of 
European 
heritage and 
culture Conservation of 
European heritage Preservation of 
global heritage 
Emphasises common – yet diverse 
– European heritage High High Low No 
Aims to develop stronger sense of 
European citizenship/belonging High High Low No 
Promotes use of cultural tourism as 
a tool in social and economic 
development High High Low Medium 
Targets needs of young people High High Medium Low 
Modus operandi 
General focus Individual  
heritage sites Development of 
routes based 
around themes 
that link cultural 
heritage sites Individual heritage 
sites Individual built 
heritage sites 
Trans-national dimension (e.g. 
networking between heritage sites) High High High Low 
Contains explicit pedagogical aspect High High High Low 
Scale 
 64 sites 
designated in 18 
countries 25 routes 
currently 
designated 
involving approx. 
30,000 towns 
and cities and 
174 NGOs Around 30 awards 
are made each year 
with up to six prizes 
being awarded the 
Grand Prize of €10k 
each 890 sites in 148 
countries 
 
 
EN 93   EN Heritage designations:  summary of  selection criteria and processes: 
 
   Council of Europe Cultural Routes 
Selection Criteria Selection processes 
The routes are to be centred on a theme, which, in 
order to qualify for the programme, must fulfil a 
series of criteria. 
Each theme or sub-theme is to be dealt with in a 
series of co-operation projects in specified priority 
fields of action.  
Project initiators must form a network so as to 
improve co-operation and poo l their experience. In 
order to be approved, these networks must in turn 
satisfy a number of criteria.  
A 2007 resolution of the Council of Europe presents 
all selection criteria : 
https://wcd.coe.int/ViewDoc.jsp?id=1194679   The certification is awarded by the Council of 
Europe committee responsible for the Cultural 
Routes programme on a proposal from the advisory 
committee. 
Networks must submit every three years an activity 
report to the Council of Europe. If some criteria are 
not fulfilled, a recommendation will be issued. If the 
recommendation is not followed within a year, the 
committee may withdraw the certification.  
 
 
  
                                                
 
15 International Council on Monuments and Sites. 
16 World Conservation Union. UNESCO World Heritage List 
Selection Criteria Selection processes 
Guidance for selection processes now 1000 pages 
long. To be included on the WH list, sites must be of 
outstanding universal value and meet at least one of 
the 10 criteria set out at:  
http://whc.unesco.org/pg.cfm?cid=57  
For example: 
 
1. To represent a masterpiece of human 
creative genius. 
2. To exhibit an important interchange of 
human values over a period of time. 
3. Unique/exceptional testimony to culture. 
4. Outstanding architecture, technology, 
landscape. Country proposes site – a) tentative list created, then 
b) formal proposal made. 
Evaluation of dossier by ICOMOS15 and IUCN16 
according to site type. 
On site evaluation – technical site report + Report 
by expert in the field. 
Expert panel discussion and recommendation to 
World Heritage Committee to: 
a. Put on list 
b. Return for further information 
c. Postpone 
d. Reject 
1.5 – 2 years for the process to complete. 
 
EN 94   EN    Europa Nostra Awards (sel ection procedure as  of 2010 call) 
Selection Criteria Selection processes 
Europa Nostra Awards are awarded in 4 categories 
(conservation, research, dedicated service and 
education/training/awarene ss-raising). Each of the 
four categories has its own selection criteria.  
http://www.europanostra.o rg/UPLOADS/FILS/HA20
10_call_conditions.pdf   
  
 Applicants from all European Countries*  must fill a 
dossier and submit it in French or English to Europa 
Nostra Secretariat 
A European Jury of independent experts designated 
by Europa Nostra select the award-winners. 3 out of 
4 categories are also assessed on location by a local 
expert prior to the Jury meeting. 
*only entries from countries that are part of the EU Culture 
programme are eligible for the monetary award