Communication from the Commission to the European Parliament and the Council - The financial perspectives of the Office for Harmonisation in the Internal Market (Trade Marks and Designs)
Date: 2006-12-22
Institutions: European Commission
Subjects: European Union Intellectual Property Office, administration of the Institutions, budget, management accounting

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 22.12.2006 
COM(2006) 865 final 

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT AND THE COUNCIL  

THE FINANCIAL PERSPECTIVES OF THE OFFICE FOR HARMONISATION IN 
THE INTERNAL MARKET (TRADE MARKS AND DESIGNS) 

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COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT AND THE COUNCIL  

THE FINANCIAL PERSPECTIVES OF THE OFFICE FOR HARMONISATION IN 
THE INTERNAL MARKET (TRADE MARKS AND DESIGNS) 

1. 

INTRODUCTION 

The  Office  for  Harmonisation  in  the  Internal  Market  (Trade  Marks  and  Designs)1  is 
responsible for registering Community trade marks and Community designs. OHIM became 
operational in 1996. Since then more than 200,000 companies from all over the world have 
turned to the Office, located in Alicante, in order to obtain EU-wide protection for their trade 
marks and designs.  

This Communication is about the long-term management of the financing of the OHIM. As a 
self-financing  EU  agency  with  a  budget  independent  from  the  Community  budget,  OHIM's 
budget is subject to the requirement that the revenue and expenditure in the budget shall be 
balanced. The budget of OHIM is mainly funded by the fees that businesses have to pay for 
its services. These fees are established by the Commission through implementing regulations. 

OHIM  is  generating  substantial  cash  reserves  arising  from  several  causes  including  steadily 
rising  numbers  of  trade  mark  and  design  applications,  increased  productivity  and  improved 
efficiency of the Office, as well as growth in e-business. Despite recent fee reductions these 
cash  reserves  are  expected  to  grow  further  in  the  coming  years.  By  the  end  of  2005 
cumulative  cash  reserves  reached  more  then  €  130  million  and  cumulative  reserves  could 
easily reach € 375 million by the end of 2010.  

A  significant  annual  surplus  which  causes  structural  year-on-year  increases  in  the 
accumulated  cash  reserves  is  not  acceptable  in  the  long  run.  The  Commission  should  take 
action if revenues continually exceed the financial means that are needed to ensure the proper 
fulfilment  of  the  tasks  of  OHIM  and  reserves  become  structurally  disproportionate.  This 
Communication contains a concrete suggestion to guarantee that a reasonable equilibrium in 
the  budget  will  be  achieved  in  the  future  under  all  financial  circumstances.  A  regular  and 
automatic fees review should be applied both in circumstances of budget surpluses as well as 
in situations of budget shortages.  

The Commission believes  it is timely to consider a structural approach to OHIM's financial 
management.  OHIM  has  been  in  operation  for  more  then  ten  years,  during  which  it  has 
successfully managed major events such as the introduction of e-filing, the enlargement with 
ten new Member States in 2004 or the first round of trade mark renewals in 2005. It is now an 
opportune moment to stabilise budget practice. 

1 

Hereafter also referred to as "OHIM" or "the Office". 

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2. 

THE PERFORMANCE OF OHIM 

The OHIM was set up by the 1994 Community Trade Mark Regulation. A Community Trade 
Mark  is  an  industrial  property  title  which  gives  its  proprietor  a  right  valid  in  the  entire 
territory  of  the  EU.  Since  it  began  processing  trade  mark  applications  in  1996,  more  than 
330,000  trade  marks  have  been  registered.  In  2002,  the  Council  adopted  the  Community 
Design Regulation, creating a system of (registered and unregistered) Community designs for 
the  whole  of  the  EU.  Registration  of  Community  designs  began  in  2003  and  now  over 
180,000 designs have been successfully processed. 

These figures exceed even the most optimistic predictions made at the time that the relevant 
regulations were adopted by the Council of Ministers. They demonstrate the value to business 
of intellectual property rights which offer protection across the entire territory of the European 
Union as well as the success with which the Office has administered the system. Such unitary 
titles are a pillar of a broader EU strategy on intellectual property, which is at the heart of the 
EU’s Lisbon Strategy on growth and jobs. 

Trade  marks  and  designs  are  essential  marketing  tools  for  modern  business  in  the  internal 
market.  Businesses  throughout  the  Union  and  beyond  can  now  rely  on  an  efficient 
organisation to provide timely and effective protection of some of their most valuable assets. 
In  a  world  of  increasing  consumer  sophistication,  branding  supported  by  trade  marks  and 
designs  can  assist  businesses  of  all  sizes  in  their  quest  for  innovation  and  entry  into  new 
markets. 

The  unexpected  success  and  the  ever-increasing  demands  for  its  services  have  created 
significant  challenges  for  the  OHIM  system.  However,  in  recent  years  the  Office  has  been 
able  to  improve  its  performance  considerably.  OHIM  sets  itself  ambitious  goals  for  service 
and  the  management  of  quality  of  its  operations.  It  has  put  in  place  a  programme  aimed  at 
increasing  productivity  and  improving  efficiency  by  simplifying  procedures,  streamlining 
working  methods,  reducing  bureaucracy,  implementing  strong  financial  management,  and 
introducing the most advanced information technology tools and resources.  

An important  trend  in the  process  of  filing has been the introduction of e-business in 2002. 
Users can now obtain considerable fees discounts if applications and renewals are performed 
electronically  following  reductions  in  these  fees  made  at  the  end  of  2005.  E-business  has 
financial benefits for users and it allows quality improvements such as more accurate capture 
of data, which also ultimately benefits users. The increasing importance of e-business in the 
Office must be welcomed.  

On  1  October  2004  the  EC  acceded  to  the  Madrid  Protocol  concerning  the  international 
registration  of  trade  marks.  The  Madrid  Protocol  offers  businesses  a  simple  process  for 
applying for trade mark rights in 67 countries outside the European Community in one single 
international application filed at the Office. The Community is currently preparing accession 
to the Geneva Act for a similar exercise in the field of international registrations of designs. 

In  2005  the  cooperation  between  OHIM  and  the  national  offices  of  the  Member  States 
intensified. The OHIM decided to dedicate more resources to financing partnerships and joint 
projects  with  national  offices.  The  Office  compensates  them  for  contributions  made  and 
services  provided  regarding  the  operation  of  the  Community  Trade  Mark  system.  It  is 
expected that  the  partnership will benefit the users of both the Community and the national 
systems of trade marks and designs.  

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These  users  evaluate  the  overall  output  of  OHIM  positively.  The  recognition  of  the 
stakeholders  was  confirmed  by  a  large  scale  Users  Satisfaction  Survey  conducted  by  an 
independent  research  company.  People  and  businesses  who  had  been  directly  using  the 
Community Trade Mark and/or the Community Designs systems between January 2004 and 
June  2005  were  extensively  polled.  The  full  results  were  published  in  March  2006.2  They 
show a good level of global satisfaction from both IP agents and IP right holders, even though 
the survey also identified areas for improvement. The Office takes the outcome seriously and 
continues to invest in improving its services.3 

3. 

THE DEVELOPMENT OF OHIM'S FINANCES 

3.1. 

The budget and the fees structure of OHIM 

OHIM's  income  consists  mainly  of  fees  that  users  have  to  pay  in  relation  to  registration  of 
trade  marks  and  designs.  The  Community  Trade  Mark  Regulation  contains  the  clear 
requirement that the revenue and expenditure in the budget shall be balanced.4 In other words, 
OHIM  enjoys  budgetary  autonomy  to  the  extent  that  it  should  not  need  a  subsidy  from  the 
Community to balance its budget. 

The fees that users of the system pay to OHIM are laid down in two implementing regulations 
established  by  the  Commission:  the  Community  Trade  Mark  Fee  Regulation  and  the 
Community  Designs  Fee  Regulation.  Such  fees  include  the  application,  registration  and 
renewal  fees  paid  by  the  trade  mark/design  proprietor,  the  opposition  fee  (only  for  trade 
marks)  or  the  cancellation  fee  paid  by  the  third  party  raising  an  opposition  or  cancellation 
action  and  the  appeal  fee  paid  by  the  party  appealing  an  OHIM  decision  to  the  Boards  of 
Appeal. However, around 90% of the OHIM's income comes from just three of these fees: the 
Community Trade Mark application, registration and renewal fees. According to Article 139 
(2) of the Community Trade Mark Regulation, the size of these Community Trade Mark fees 
must  be  fixed  to  ensure  that  the  subsequent  revenue  is  in  principle  sufficient  to  balance 
OHIM's budget. 

The expenditure in the first few years of the Office’s operations was dominated by the need to 
invest in the infrastructure of the Office, and to recruit sufficient staff to deal with the higher 
than expected level of applications. Revenues grew rapidly until 2000, after which there were 
two years of falls until a pattern of growth became re-established.  

By the end of 2004, OHIM had accumulated significant cash reserves of around € 105 million 
as  measured  by  current  assets  less  current  liabilities,  and  projections  showed  a  continuing 
annual surplus.5 As a consequence, various fees were reduced by approximately 20% in 2005 

2 
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to 

of 

the 

User 

results 

OHIM's 

response 

See http://oami.europa.eu/en/office/survey05.htm.  
See 
http://oami.europa.eu/en/office/pdf/USS_Response.pdf.  
See  Article  134  (2)  of  Council  Regulation  (EC)  No  40/94  of  20  December  1993  on  the  Community 
trade mark, as most recently amended by Council Regulation (EC) No 422/2004 of 19 February 2004, 
OJ L 70, 9.3.2004, p. 1. 
The annual surplus results from a single budget exercise. However the (accumulated) surpluses are not a 
good guide to how much free cash exists. Some of the accumulated surplus is not available as free cash, 
for  example,  because  it  has  been  invested  in  fixed  assets  such  as  buildings.  This  Communication 
therefore  uses  the  notion  of  "cash  reserves"  in  order  to  measure  the  free  cash.  The  cash  reserves 
represents the current assets less the current liabilities. 

Satisfactory 

Survey 

at 

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in  the  first  revision  of  the  Community  Trade  Mark  fees  system  since  the  creation  of  the 
Office.6  

3.2. 

Recent developments affecting OHIM's budget 

The fees reform for trade marks came into effect in October 2005. The main features were a 
reduction in the application  and  registration fees; the introduction  of a discount for  e-filing, 
and  a  reduction  of  renewal  fees.  It  was  estimated  that  the  reduction  of  fees  would  save 
business  between  €  37  and  €  40  million  a  year,  but  the  real  savings  have  turned  out  to  be 
much higher. In 2006 alone industry is expected to save around € 55 million because of the 
2005 fees discounts.7 

In addition, two other recent developments have had an effect on OHIM's budget. Firstly, the 
level  of  applications  and  renewals  are  higher  than  initially  predicted.  This  global  increase 
reflects a general trend in most parts of the world. Secondly, 2005 was the first full year of 
applications coming through WIPO under the Madrid Protocol. In 2005, OHIM received, in 
cash  terms,  about  €  9  million  of  fees  for  international  applications  in  the  framework  of  the 
Madrid Protocol. 

The first experiences with the fee reform show that the package of fee changes certainly had a 
moderating  influence  on  the  revenues.  But  it  is  also  true  that  despite  the  fee  reduction,  the 
cash  reserves  for  2006  will  still  be  higher,  adding  further  to  the  accumulated  cash  reserves. 
For the financial year 2005 alone the surplus stood at € 41.5 million out of a total budget of € 
162.8 million. The total cash reserves reached € 132 million by the end of 2005. Estimates for 
the budget year 2006 predict a surplus of € 50 million out of a total income of € 179 million.8 
The budget is therefore clearly out of balance and needs to be equalized again. 

Finally,  it  should  be  noted  that  the  increasing  number  of  design  registrations  is  also 
contributing  to  the  budget  cash  reserves,  although  to  a  much  lesser  extent.  In  2005,  the 
revenues of designs constituted less than 10% of the income generated by Community Trade 
Mark fees.  

3.3. 

Budgetary predictions for the future 

It is expected that with an unchanged fees policy, the budget's imbalance will increase even 
more  in  the  future.  In  any  credible  scenario,  cash  reserves  will  continue  to  grow  on  a 
cumulative basis.  

By  far  the  biggest  determinant  of  future  revenue  is  the  volume  of  Community  Trade  Mark 
applications. The Annex contains calculations with alternative scenarios. Estimates are based 

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Commission Regulation (EC) No 1042/2005 of 29 June 2005 amending Regulation (EC) No 2869/95 
on the fees payable to the Office for Harmonization in the Internal Market (Trade Marks and Designs), 
OJ  L  172,  5.7.2005,  p.  22.  See  for  the  present  fees  for  designs  Commission  Regulation  (EC)  No 
2246/2002 of 16 December 2002 on the fees payable to the Office for the Harmonization in the Internal 
Market (Trade Marks and Designs) in respect of the registration of Community designs, OJ L 341 of 
17.12.2002, p. 54.  
For the budget year 2006, the total savings from the reduction of application and registration of fees are 
estimated to be some € 20 million; the effect on the renewal fees is calculated to be some € 28.5 million 
and the impact of the e-filing discount is estimated to be a further € 4.5 million. The combined effect for 
the additional class fees would be an extra € 2 million saving. 
Estimate 1 October 2006. 

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on a low scenario with 60,000 annual Community Trade Mark applications, on a mid scenario 
with 75,000 applications, and on a high scenario with 90,000 applications. 

According  to  the  estimates  based  on  the  most  realistic  mid-scenario  of  75,000  annual 
Community Trade Mark applications, and a renewal rate at 60%, the total income could reach 
nearly € 200 million in 2010 and over € 230 million in 2016. This would cause the cumulative 
cash reserves to reach the impressive amount of about € 375 million by the end of 2010 and 
nearly € 700 million by the end of 2016.  

Even with a low estimate of 60,000 annual Community Trade Mark applications (the Office 
received 64,000 applications in 2005) the structural cash reserves would be more then € 300 
million by 2010. The same conclusion can be drawn with a moderate estimate of a renewal 
rate of 40% instead of 60% (present renewal rate for whole 2006 estimated at around 63%), in 
which scenario the expected cash reserves would rise to more then € 330 million by 2010. 

The following two graphics show the estimated cumulative cash reserves for the period 2006-
2016, compared to the established cash reserves which have been accumulated over the period 
2000-2005 (all numbers below are given in € million and are based on a renewal rate at 60%). 

900

800

700

600

€mio 
500

400

300

200

100
0 

Evolution of Cumulative Surplus

Low Scenario

Mid Scenario

High Scenario

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

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4. 

A STRUCTURAL SOLUTION TO GUARANTEE A BALANCED BUDGET  

4.1. 

A high quality trade mark registration system in Europe 

As  has  been  stated  before,  the  increasing  annual  OHIM  surplus  makes  the  budget 
disproportionate which is not consistent with the principle enshrined in Article 139 (2) of the 
Community  Trade  Mark  Regulation  that  the  size  of  fees  must  to  ensure  that  revenue  is 
sufficient to balance the budget. The Commission is of the opinion that a structural solution is 
necessary. However, such approach should be closely linked to an outstanding performance of 
the Office. 

As  a  preliminary  remark,  it  should  be  emphasised  that  OHIM  administers  its  budget  in 
accordance  with  sound  budgetary  and  accounting  principles  and  under  supervision  of  the 
OHIM  Budget  Committee  and  the  Court  of  Auditors.  These  include,  for  example,  the 
principle of prudence (profits are only entered into the accounts when they are realised by the 
end  of  the  year  whereas  foreseeable  risks  and  contingent  liabilities  are  entered  into  the 
accounts as soon as they arise), the principle of sound financial management and the principle 
of transparency. It is important to stress that the cash reserves are calculated and administered 
on  the  basis  of  the  same  principles,  and  that  OHIM  also  handles  the  estimation  of  future 
predictions in a prudent and accountable manner. 

The  Commission  believes  that  part  of  the  cash  reserves  can  be  absorbed  to  finance  the 
challenges  that  OHIM  is  facing  in  the  operational  field.  Notwithstanding  the  fact  that  the 
recent  Users  Survey  showed  an  overall  satisfaction  with  the  performance  of  OHIM,  the 
Commission understands that more work still needs to be done. The initiatives of the Office to 
improve performance in a group of areas indicated in the survey must therefore be welcomed. 
This work should lead to greater clarity, consistency and completeness of decisions taken in 
Alicante,  simpler  administrative  procedures  and  increasing  processing  speed  in  key  parts  of 
the Office's operations. Such further quality improvement most likely requires more financial 
investment.  

Furthermore,  the  Commission  wishes  to  highlight  the  importance  of  joint  partnerships 
between OHIM and the offices of the Member States for the efficient performance of, and the 
effective  interaction  between  the  Community  and  national  trade  mark  systems.  Intensive 
cooperation  programmes  are  being  developed  and  executed  in  areas  such  as  training, 
information technologies (IT), promotion and information services. To the extent necessary, 
more  financial  resources  could  be  made  available  to  facilitate  and  develop  such  technical 
cooperation partnerships. 

Nevertheless, taking into account the principles of good management and accounting, prudent 
additional  investments  in  the  operational  area  and  in  the  cooperation  partnerships  will  only 
have a relatively minor impact on the significant growth in cash reserves which is estimated 
for the coming ten years.  

4.2. 

Further fee reforms  

The Commission is of the opinion that in the current situation of an ever increasing surplus 
and therefore a disproportionate level of cash reserves the inevitable solution is to reduce fee 
levels further. Keeping fees low is an appealing option because it would make the Community 
Trade Mark financially even more attractive for companies, in particular for SME´s from all 
over the EU and abroad.  

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However,  experience  shows  that  the  reduction  of  fees  under  the  current  common  rules  and 
practices  is  not  an  easy  exercise.  The  fee  setting  is  governed  by  the  so-called  "comitology" 
procedure and the negotiations in the Community Trade Mark Fees Committee leading to the 
revision  of  the  Commission  Regulation  on  the  fees  payable  to  the  OHIM  in  2005  were 
difficult  due  to  divergent  views  on  the  destination  of  the  cash  reserves  and  on  the  most 
appropriate levels of the various fees. The level of reduction finally agreed was not sufficient 
to balance the budget.  

In  the  light  of  the  preceding  considerations,  it  is  appropriate  to  find  a  streamlined  and 
structural  approach  to  guarantee  a  flow  of  revenues  proportionate  to  the  estimated 
expenditure.  The  Commission  therefore  proposes  to  introduce  a  method  of  regular 
review  of  the  fees  based  on  the  Office's  financial  perspectives  and  to  manage  the  cash 
reserves in accordance with a pre-determined formula. The basis of the revision would be 
the  financial  statistics  of  the  Office,  produced  in  the  usual  manner,  including  an  indication 
from the Office of the expected amount of cash reserves for the next period.  

The formula should focus on trade mark fees only. As is indicated before, budget imbalances 
are almost entirely due to the revenues generated by the registration of the Community Trade 
Marks. The relatively short period of experience with the Community Design system would 
be another argument not to include the design fees in the formula for the time being.  

The introduction of a method of regular review of the trade mark fees has clear advantages.  

Firstly, the financial autonomy of the Office will be safeguarded. On the one hand, structural 
deficits  that  risk  entailing  the  consumption  of  the  reserves  and  a  need  for  subsidies  can  be 
avoided. On the other hand, excessive accumulation of reserves can be avoided; a necessity in 
order to guarantee a reasonable balance between revenue and expenditure.  

Secondly,  the  use  of  such  formula  would  better  reflect  the  costs  for  the  users  of  the  OHIM 
system. Even though a number of elements have to be taken into account when determining 
fees, the amount charged to the users should reflect the cost of the service rendered.  

Thirdly, the introduction of a formula for handling and absorbing future surpluses or deficits 
by  way  of  an  automatic  link  to  fees  does  not  as  such  seem  to  present  particular  technical 
difficulties.  The  Community  Trade  Mark  Regulation  states  that  the  fees  regulations  shall 
determine in particular the amounts of fees and the ways in which they are to be paid.9 The 
Commission  will  propose  to  amend  the  Commission  Fees  Regulation  by  "comitology"  as 
provided for in the Community Trade Mark Regulation. Provided there is an agreed approach 
on the calculation of the change – which may be a reduction or an increase - at policy level, 
these rules could include a formula on the basis of which the fees would be regularly revised 
in order to ensure that a reasonable equilibrium in the budget will be achieved. 

4.3.  Main features of the proposed method of regular fees review 

An automatic review and adjustment of the fees on the basis of OHIM's financial perspectives 
should be carried out respecting some basic conditions. The Commission intends to propose a 
method for regular review which should be based on the following presumptions. 

9 

See Article 139 (2) of Regulation (EC) No 40/94, as amended. 

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•  For  the  sake  of  legal  certainty  and  to  take  into  account  the  real  budgetary 
developments over a limited period of time, any necessary adjustment should take 
place on a regular basis (for example, on an annual basis).  

•  Once the estimated surplus (or shortage) has been defined, the basis of the review 
should be the three most important basic fees: the fees for application, registration 
and renewal of (individual) trade marks. The reduction or increase of these three 
fees should be proportionate to their relative weight.10 

•  The  automatic  regular  adjustments  should  not  take  effect  outside  a  fluctuation 

margin.  

•  OHIM's financial autonomy must be secured under all circumstances.  

5. 

CONCLUSION 

The Community Trade Mark Regulation obliges the OHIM budget to be in financial balance. 
With  an  unchanged  fees  policy  and  on  the  basis  of  realistic  predictions  of  future  annual 
Community Trade Mark applications and renewal rates, this will not be the case. Cumulative 
cash reserves could reach about € 375 million by the end of 2010 and nearly € 700 million by 
the end of 2016. There is therefore an urgent need for action in order to keep control of the 
cash reserves.  

The Commission has a specific responsibility because it is in charge of setting the fee levels. 
These  fees  should  be  fixed  at  such  a  level  as  to  ensure  that  the  revenues  are  in  principle 
sufficient  for  the  OHIM  budget  to  be  balanced.  To  choose  for  an  ad  hoc  approach  with  an 
occasional adjustment of fees may be a difficult route to follow as this may lead to long and 
repetitive  debates  in  "comitology"  context.  A  better  alternative  would  be  to  focus  on  a 
detailed and structural solution. It is therefore suggested to introduce a regular review of the 
budget situation in light of the best available knowledge of the evolving financial situation at 
OHIM,  making  use  of  a  standard  approach  in  which  the  most  important  fees  would  move 
upwards  or  downwards  as  necessary.  Following  political  agreement  on  this  approach,  such 
formula  should  be  applied,  for  example,  on  an  annual  basis.  The  formula  should  take  into 
account all relevant elements to guarantee a balanced and workable fee structure.  

The Commission believes that this is the appropriate moment to present a structural proposal 
in  order  to  avoid  disproportionate  OHIM  cash  reserves.  In  over  ten  years  since  its 
establishment,  OHIM  has  consistently  achieved  a  high  standard  of  Community  trade  mark 
registrations,  and  more  recently  in  the  registration  of  Community  designs.  Furthermore,  the 
Office  has  successfully  managed  some  major  events  with  important  financial  repercussions 
such as the introduction of e-filing, the enlargement with ten new Member States in 2004 and 
the first round of trade mark renewal fees in 2005. 

The pre-determined formula should not put at risk the OHIM's high level of performance nor 
should  it  prevent  an  optimum  cooperation  with  national  offices.  Neither  should  it  lead  to 
deficit situations in the future. Under all circumstances, the Office should be able to continue 

10 

The regular fees adjustment of the three main types of fees in accordance with a pre-determined formula 
does not exclude a reform of all the fees. Structural modifications may be necessary, for example, in the 
light of EU enlargement or following legislative amendments. 

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operating modern, efficient and effective registration systems for trade marks and designs in 
the interest of the users and the society as a whole.  

In light of the current budget surpluses at OHIM, the Commission wishes to act as quickly as 
possible  while  respecting  the  principles  of  good  governance.  The  Commission  intends  to 
present proposals for an amendment of the Commission's Fees Regulation in spring 2007. The 
proposals will be accompanied by a proportionate impact assessment.  

The  Commission  invites  the  Council  and  the  EP  to  submit  observations  on  the  proposed 
approach in this Communication. 

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ANNEX 

The  table  combines  a  number  of  presumptions  for  the  budgetary  predictions  in  the  period 
2006-2016 (all numbers are given in € million). The estimated hypothesis calculates 75,000 
applications per year, with alternatives of 60,000 and 90,000 annual applications. In the three 
options the Community trade mark renewal rate is fixed at a stable rate of 60% over the whole 
period. 

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