WRITTEN QUESTION P-2253/96 by Paul Rübig (PPE) to the Commission (26 July 1996)

Subject: Burden placed on SMEs by statistical surveys

The principle of cost-effectiveness in statistics - as laid down in Article 10 of the draft Council regulation on Community action in the field of statistics -requires that the amount of work and the costs arising from the production of statistics must be in proportion to the importance of the results sought. The burden on respondents is to be minimized.

At present, some regulations are placing an unacceptable burden on small and medium-sized enterprises (SMEs) and imposing costs on statistical offices which are not in any reasonable proportion to the foreseeable gain in information. The surveys also presuppose an unrealistic level of information among SMEs obliged to provide data. As a result, the excessive inclusion of SMEs does not improve the reliability of statistical findings and may in some cases undermine it where the results of high-quality surveys are merged with necessarily less well-founded estimates.

Will the Commission therefore take action to ensure that certain provisions of existing regulations - such as, in particular, the 90% rule prescribed by the Prodcom Regulation (EEC) No 3924/91 ((OJ L 374, 31.12.1991, p. 1. )) of 19 December 1991 - are amended so as to improve the application of the principle of cost-effectiveness?

What specific measures will the Commission take to ensure that future regulations do not include any provisions which might place an unacceptable burden on SMEs in connection with statistical surveys?

Will the Commission ensure that the principle of cost-effectiveness, and in particular the principle that the burden on respondents should be minimized, is reflected in all the manuals currently being prepared, e.g. in the form of corresponding thresholds?

Answer given by Mr de Silguy on behalf of the Commission (23 September 1996)

The introduction of the cost-benefit principle in the Commission's proposal on statistical activities mentioned in the question reflects the importance the Commission attaches to this subject.

The question suggests that some existing regulations impose excessive burdens on small and medium sized enterprises (SMEs) and excessive costs for the statistical offices. The Commission relies on information from the Member States on costs and burdens. A recent study carried out for the committee on statistical information in the economic and social spheres concluded that the total load on businesses of statistics is relatively small, less than 5% of the overall costs of all governmental administrative burdens. Typically the time spent on statistical returns for government is no more than 24 hours per year for SMEs and in total amounts to well under 0.1% of all working hours.

Many Member States, working in co-operation with industry representatives, inform enterprises in advance of the information that they will be asked to supply at the end of each reference period (month or year) in order that they can store information in an easily retrievable form. It is also stated that too great a demand for information is put on SMEs which leads to poor statistics. In order to avoid this, most Community legislation either foresees a reduction in the data request for small enterprises or permits each Member State to estimate data for smaller enterprises rather than to collect it. Hence, when it is believed that information cannot be collected from very small enterprises, they may be excluded or data may be estimated using statistical techniques.

The Honourable Member suggests that the Commission should modify some regulations. Of the regulations in force, there has been a great deal of discussion about the future form of Intrastat and this is still under review. In particular, the burden caused by this survey is being studied as it is included within the framework of the SLIM initiative. Any changes to this existing text, as with all new texts, will be subject to examination from the perspective of cost-benefit. With regard to the Prodcom Regulation (Regulation 3924/91 of 19 December 1991), the Commission does not feel it is necessary to modify the text at the present time. The 90% rule mentioned in the question allows sample surveys to be carried out in order to have data representative of the entire population, without requiring exhaustive surveys to be conducted. The result is that some 200,000 enterprises are surveyed under Prodcom while Intrastat forms are sent to approximately 370,000 enterprises.

A number of measures concerning simplification of Community legislation already have been taken, such as the improvements to the business impact assessment system and the follow-up given by the Commission to the recommendations of the Molitor group.

New measures foreseen under the Integrated programme for SMEs and the craft sector ((COM (96) 329 final. )) will include the implementation of the recently adopted guidelines for regulatory policy which will improve the quality of Community legislation and lead to better consultation of interested parties, including SME organisations. An improved, more pragmatic method for the implementation of cost-benefit evaluation is foreseen among the measures to be taken in the framework of the Third multi-annual programme for SMEs ((COM (96) 98 final. )). In addition, Eurostat has been trying to establish with the Member States the cost of the existing statistical system and the part of this that is due to the requirements of Community legislation.

The methodology manuals currently being drafted will not be legally binding. Hence, the Member States carrying out the surveys will be free to sample or to request a reduced set of information from certain enterprises (for example small ones). The use of sampling is encouraged by the Commission for enterprises of all sizes, contrary to previous practice.

The use of thresholds at the Community level is not always supported by the Commission in business statistics. The different sizes and structures of the Member States make comparisons of data collected using thresholds erroneous. The importance of enterprises below a threshold varies greatly between countries and sectors. The removal of thresholds and the use of samples across all sectors permits the estimation of figures that are truly comparable. The use of thresholds ignores the very real need of the Commission for information on small enterprises for its enterprise policy. Statistics from smaller enterprises are needed in order to ensure that the results do not only reflect reality in large multi-national enterprises.

The Commission is conscious of the difficulties that these data requests can cause SMEs and is committed to a concentration of its data requests on priority policy areas of the Union. The Commission is always open to new proposals to improve the balance between the need or data and the cost of supplying information.