Commission working document - Reducing administrative burdens in the European Union 2007 progress - Report and 2008 outlook {COM(2008) 32 final} {COM(2008) 33 final}
Date: 2008-01-30
Institutions: European Commission
Subjects: European Union, administrative formalities, application of EU law, operating cost, overheads, report

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 30.1.2008 
COM(2008) 35 final 

COMMISSION WORKING DOCUMENT 

Reducing administrative burdens in the European Union  
2007 progress report and 2008 outlook 

{COM(2008) 32 final} 
{COM(2008) 33 final} 

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COMMISSION WORKING DOCUMENT 

Reducing administrative burdens in the European Union  
2007 progress report and 2008 outlook 

1. 

INTRODUCTION 

Unnecessary  administrative  burdens  hamper  growth  and  inhibit  innovation.  Removing  them 
will allow companies to spend more time on core business activities, thereby increase labour 
efficiency,  which  will  benefit  productivity  and  reduce  production  costs.  It  is  therefore  an 
important objective of the Growth and Jobs Strategy 

In  January  2007,  the  Commission  presented  an  ambitious  Action  Programme  aimed  at 
reducing  administrative  burdens  on  businesses  in  the  EU  by  25%  in  20121.  The  Action 
Programme  was  endorsed  by  the  Spring  European  Council  in  March  20072.  The  Council 
specifically  agreed  to  the  joint  reduction  target  and  invited  Member  States  to  “set  national 
targets of comparable ambition”3. 
This Working Document accompanies the Second Strategic Review on Better Regulation4. It 
details progress achieved in 2007 and the outlook for 2008.  

2. 

MAPPING,  MEASURING  AND  REDUCING  ADMINISTRATIVE  BURDENS  SET  BY 
EUROPEAN LEGISLATION 

The  Action  Programme  demonstrates  in  concrete  terms  the  way  in  which  the  Commission 
intends to work with Member States and stakeholders towards the 2012 milestone. Its aim is 
to  measure  costs  imposed  by  information  obligations  put  on  business  and  suppress 
unnecessary requirements. This will improve the efficiency of legislation without jeopardizing 
the purpose of the legislation in case.  

A key part of the Action Programme consists of a large-scale measurement of administrative 
costs  incurred  by  businesses  in  meeting  legal  obligations  to  provide  information.  This 
baseline  measurement  covers  obligations  stemming  from  Community  legislation  and  from 
national  measures  transposing  that  legislation.  The  methodology  used  is  based  on  the  so-
called ‘EU Standard Cost Model’, inspired by different variants of the Standard Cost Model 
(SCM) currently used in 15 Member States5. 

The  EU  measurement  focuses  on  the  most  burdensome  information  obligations  in  thirteen 
selected priority areas: 

(a) 

(b) 

(c) 

Agriculture and agricultural subsidies 

Annual Accounts/Company law 

Cohesion policy 

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COM(2007) 23. 
Presidency conclusions of the Brussels European Council (7/8 March 2007), p. 10 - 
http://www.consilium.europa.eu/ueDocs/cms_Data/docs/pressData/en/ec/93135.pdf. 
For details on See Annex 1. 
COM(2008) 32. 
The  Commission  participated  to  the  work  organised  by  the  Standard  Cost  Model  Network 
(http://www.administrative-burdens.com/). 

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(d) 

(e) 

(f) 

(g) 

(h) 

(i) 

(j) 

(k) 

(l) 

Environment 

Financial services 

Fisheries 

Food safety 

Pharmaceutical legislation 

Public procurement 

Statistics 

Tax law (VAT) 

Transport  

(m)  Working environment/employment relations 

These  priority  areas  were  selected  on  the  basis  of  a  2006  pilot  study,  comparing 
measurements  done  in  CZ,  DK,  NL  and  UK,  as  well  as  information  provided  by  Member 
States and stakeholders6. 

The  Commission  –  like  most  of  the  national  Member  States  embarking  on  such  exercise  –
hired  in  July  2007  a  large  consortium  of  consultants  to  help  mapping  and  measuring 
information obligations. 

The scope and depth of the programme is unprecedented at EU level. More than 40 pieces of 
legislation  in  the  13  priority  areas  –  believed  to  account  for  over  80%  of  administrative 
burdens  of  EU  origin7  –  are  under  review8.  Identifying  several  hundreds  of  information 
obligations, determining the types of activities required, groups concerned and the time they 
need for each action is a tremendous work. Conducting such an assessment simultaneously in 
all 27 Member States is even more demanding. This explains why substantial resources have 
been allocated to this exercise (approx. € 20 million). 

Work  is  progressing  in  line  with  the  initial  schedule.  All  EU  information  obligations 
concerned  have  been  identified  and  described  ("mapped")  in  2007.  The  review  of  their 
transposition  in  all  Member  States  followed  suit,  in  cooperation  with  the  so-called  "Single 
Points  of  Contact"  appointed  by  the  members  of  the  High  Level  of  National  Regulatory 
Experts9.  The  main  task  of  the  “Single  Points  of  Contact”  is  to  ensure  that  the  cooperation 
between  the  Commission  and  its  consultants  on  the  one  hand  and  Member  States 
administrations  on  the  other  is  facilitated.  This  is  an  important  responsibility  since  it 
significantly  contributes  to  methodological  consistency  and  better  comparability  of  results 
across all countries10. National contact points receive regular updates about the progress of the 

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the 

(SEC(2007)  84  and 

the  Action  Programme 

Impact  Assessment  accompanying 

“Pilot project on administrative burdens”, WIFO-CEPS, October 2006. 
See 
http://ec.europa.eu/enterprise/admin-burdens-reduction/admin_burdens_en.htm). 
As  announced  in  the  Action  Programme  (p.  19),  the  administrative  burden  related  to  Council 
Regulation (EC) No 1782/2003 (single payment scheme for farmers, part of the Common Agriculture 
Policy)  has  been  measured  in  a  separate  study.  That  study  has  been  completed  in  October  2007  and 
presents ideas for simplification in this area (“Study to assess the administrative burden on farms arising 
from the CAP” http://ec.europa.eu/agriculture/analysis/external/burden/exec_sum_en.pdf). 
Set up in February 2006 to advise the Commission on better regulation issues, this Group consists of 
high  level  governmental  experts  from  all  Member  States  (Commission  Decision  2006/210/EC  of  28 
February 2006). 
A  first  meeting  convening  all  contact  points  was  organised  on  23  November  2007,  and  two  further 
meetings are planned for the first part of 2008. 

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programme and are in particular invited to provide feedback on national data collected at each 
stage  of  the  operations.  The  Commission  is  grateful  for  the  efforts  already  undertaken  but 
underlines  that  an  even  bigger  contribution  will  be  required  in  2008  to  ensure  that  the 
demanding timetable of the Action Programme can be met.  

Figure 1: Project overview – Modules and calendar 

Module 1 

Mapping of EU legislation 
Pilot Project on Company Law 
Other Priority Areas 

Module 2 

Mapping of transposition measures in MS 
Pilot Project on Company Law 

Other Priority Areas 

Completed  
(end October 07) 

Completed  
(end December 07)

Completed  
(end October 07) 

In process
(mid February 08)

Module 3 

Module 4 

Module 5 

Measurement by interviewing companies 
Pilot Project on Company Law(cid:198) started in November 
Other Priority Areas (cid:198) to start March 2008 

In process
(mid February 08)

To be completed in 
Autumn’ 2008 

Drafting reduction recommendations 
Communication of the results.  
National events (cid:198) started in Jan 2008 
EU Conference 24 June 2008 

On-going 
throughout 
project 
Concentration 
late 2008

In 2008, businesses will be interviewed throughout the EU to assess the amount of time and 
money they spend as a result of these requirements. This should be completed in the summer 
of 2008.  

The  Action  Programme  will  show  in  particular  which  Member  States  have  decided  to  go 
beyond what is strictly required by Community law and at what cost. Comparison on such a 
scale is unprecedented and will help identify best practices in terms of transposition. Specific 
recommendations for large scale reduction measures will follow.  

For the 42 pieces of legislation examined, 344 EU Information Obligations have been mapped 
and the largest number has been found in the priority areas Annual Accounts / Company law 
(75 IOs) and Food Safety (64 IOs)11. 

Suggestions for suppressing unnecessary administrative burdens are collected throughout the 
Programme and processed by the Commission on a continuous basis, together with those sent 
by the Member States12 and by respondents to the online consultation (see below). This will 
lead to proposals being tabled throughout the year. Wherevever possible, and in line with its 

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12 

For a detailed account of the number of EU IOs identified in each priority area, see Annex 1. 
The  Commission  received  in  2007  a  number  of  specific  suggestions  from  the  Danish,  Slovene  and 
British governments as well as from other public authorities including the Bavarian executive. It also 
benefited from advice given by the High Level Group of National Regulatory Experts. 

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2006-2010 e-Commission strategy13 as well as with its i-2010 strategy14 for e-Governments in 
Europe, the Commission will pursue the reduction of administrative burdens by promoting the 
resort to information and communication technologies. 

2.1. 

First results for the pilot Priority Area: Company Law 

The mapping and measurement of one of the most wide-ranging priority areas – company law 
/ annual accounts – is carried out ahead of the other priority areas15. Evidence from Member 
State measurement exercises indicates that this is an important area with significant burdens: 
early  action,  therefore,  holds  out  the  potential  for  significant  benefits  to  be  obtained  at  an 
early stage. The Commission will be in a position to table proposals in this field before the 
summer of 2008. Certain reporting requirements concerning divisions and mergers could be 
considered as not necessary any more.  

Mapping of EU information obligations (IOs) for company law started in early August 2007 
and was finalized in October, followed by the mapping of national IOs finalized in November. 
Single  Points  of  Contacts  gave  feedback  on  the  results  of  the  national  mapping16  and 
measurement started in December 2007. Measurement will be finalized in early 2008, so that 
preliminary results will be available by February 2008. A final evaluation of the measurement 
results and a list of recommendations for reduction measures will be available by the end of 
March 2008. 

The  two  first  phases  (mapping  at  EU  and  national  levels)  painted  the  picture  of  a  highly 
complex area and the total burdens in this priority area are expected to be significant. Eight 
directives were identified as particularly burdensome and as dating back to the early years of 
the  European  Communities  so  that  they  are  likely  to  contain  a  number  of  IOs  which,  from 
today’s  point  of  view,  seem  outdated,  excessive  or  duplicative.  Overall,  the  eight  directives 
contain  75  information  obligations,  such  as  the  requirement  for  companies  to  establish  and 
publish their annual accounts or the obligation for merging companies to draw up a detailed 
written  report  explaining  the  draft  terms  of  merger  and  setting  out  the  legal  and  economic 
grounds for them. 

The 75 EU information obligations can be linked to more than 2 000 transposition provisions 
in the 27 Member States. There seem to be considerable differences between Member States 
concerning  the  extent  to  which  additional  requirements  concerning  content,  target  group  or 
frequency of the IO have been added to the requirements contained in the EU IOs. 

Although currently only very preliminary results of the measurement are available, it seems 
likely  that  the  highest  costs  (not  necessarily  the  highest  burden)  will  be  found  in  the 
information  obligations  concerning  the  drawing  up  and  the  auditing  of  annual  accounts  and 
consolidated accounts as foreseen in the Fourth and Seventh company law Directives17. 

Early mapping and measurement of company law provided furthermore an opportunity to test 
the  latest  methodological  and  IT  developments  before  embarking  on  the  fully-fledged 
measurement exercise in the other priority areas. Methodological issues raised by the work on 
the pilot priority area concerned for example EU provisions explicitly giving Member States 

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See http://ec.europa.eu/dgs/informatics/ecomm/index_en.htm. 
See http://ec.europa.eu/information_society/eeurope/i2010/index_en.htm. 
An earlier measurement exercise was also performed in a specific field of the financial services priority 
area (the so-called large exposure regime), enabling the Commission to table proposals in late 2008. 
See previous section. 
Council Directive 78/660/EEC of 25 July 1978 (4th Directive) and Council Directive 83/349/EEC of 13 
June 1983 (7th Directive). 

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the possibility to create/or not create national IOs and EU provisions that do not contain an IO 
but which may lead to the creation of national IOs. 

3. 

FAST TRACK ACTIONS TO REDUCE ADMINISTRATIVE BURDENS 

A key part of the Action Programme consists of a large-scale measurement of administrative 
burdens  in  2007-8,  to  be  followed  by  major  simplification  proposals.  However,  in  order  to 
produce  concrete  results  in  the  short  term,  the  Action  Programme  also  includes  immediate 
measures that are likely to generate significant benefits through technical changes in existing 
rules.  Because  of  the  nature  of  the  changes  required,  these  measures  can  be  adopted  fairly 
quickly. They are therefore called ‘Fast Track Actions’ (FTA).  

Ten FTA were tabled in 2007 with estimated savings of € 1,3 billion for EU businesses. The 
Commission intends to present in 2008 a similar number of FTA.  

It  is  the  Commission’s  intention  to  continue  presenting  reduction  proposals  along  two 
pathways:  technical  changes  should  follow  fast  track  procedures  where  the  legislators  are 
asked  to  agree  to  assign  priority  to  a  swift  adoption.  At  the  same  time,  more  substantial 
changes will be included in the Simplification Rolling Programme18. 

3.1. 

The first 10 ‘Fast Track Actions’ 

In  January  2007,  the  Commission  announced  its  intention  to  present  10  ‘Fast  Track 
Actions’19. The European Council of March 2007 specifically called on the Council and the 
EP  to  “give  special  priority  to  the  measures  for  immediate  action  set  out  in  the  action 
programme (...), with a view to their adoption as soon as possible in 2007”. 

These Fast Track Actions came under three categories: 

•  4 executive measures to be adopted by the Commission (comitology procedure) 
•  1 omnibus package made of 2 legislative proposals covering 3 actions20  

•  3 stand-alone legislative proposals 

As  an  example,  the  proposal  dealing  with  Directives  under  the  omnibus  package  aimed  at 
removing unnecessary burdens for public limited liability companies involved in mergers or 
divisions. It basically stated that companies should not be forced to order costly expert reports 
unless there is a demand for such reports among shareholders.  
All in all, as of 31 December 2007, 5 of the 10 actions have been formally adopted21. These 
represent  total  savings  of  approximately  € 500  million  in  administrative  burdens.  The  4 
executive  measures  were  adopted  by  the  Commission  in  a  time  frame  of  approximately  six 
months. The legislative proposal described in the previous paragraph has been agreed under 

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21 

See COM(2008) 33. 
COM(2007) 23, Annex III. 
An omnibus package combines a number of revisions that concern different acts and possibly different 
sectors,  but  that  share  the  same  (technical)  nature  and  purpose  (i.e.  suppressing  unnecessary 
administrative burdens). Insofar as a Regulation can only be revised by a Regulation and a Directive by 
a Directive, the Commission presented one omnibus package made of two proposals (one per type of 
act). 
For detailed description of the state of play as of 31 December 2007, see Annex 3. 

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co-decision  in  record  time22.  The  European  Parliament  and  Council  are  likely  to  adopt  the 
remaining proposals during the first months of 2008. 

Generally speaking, the 'omnibus' approach has the great advantage of making clear that the 
objective of a proposal is not to modify the substance of the legislation concerned, but to cut 
unnecessary administrative burdens quickly. Even if the relative novelty of this approach must 
be taken into account, it should be supported in the future. 

In order to better process technical administrative burdens reduction measures, Parliament and 
Council should put in place a specific - fast track – adoption procedure. This will be necessary 
to  ensure  that  a  significant  number  of  reduction  proposals  can  be  taken  forward  in  200923. 
Avoiding  delays  in  the  adoption  of  these  proposals  is  crucial  if  the  EU  is  to  succeed  in 
reaching its 25% reduction objective by 2012. 

3.2. 

Possible new Fast Track Actions 

Upon  completion  of  its  internal  evaluation  and  consultation  procedures  the  Commission 
intends  to  present  new  fast  track  actions  in  2008.  Problems  at  the  origin  of  unnecessary 
administrative  burdens  were  identified  on  the  basis  of  internal  review  and  suggestions 
received  from  stakeholders  and  Member  States’  experts.  Problems  that  could  be  quickly 
solved through technical measures include: 

•  Operators  who  reprocess  some  agricultural  products  are  eligible  for  production  refunds 
under certain conditions; when refunds go beyond a set threshold these operators have to 
meet additional administrative requirements aimed at preventing speculative reprocessing; 
in a number of cases, these requirements seem to apply even when there is no speculative 
risk. 

•  Some notification requirements for non-road mobile machinery such as locomotives seem 
to impose many duties on manufacturers while their added value has not been proved after 
years of implementation. 

•  Manufacturers  of  certain  radio  equipments  are  exposed  to  significant  costs  linked  to  the 
obligation  to  notify  their  intention  to  place  their  product  on  the  market  to  the  national 
authorities  of  each  Member  State  concerned;  this  and  the  fact  that  the  information  to  be 
provided varies from one Member state to another appear to cause unnecessary burdens. 

•  Information  provided  by  a  large  number  of  small  enterprises  on  goods  they  import  from 
other  Member  States  (Intrastat)  seem  to  bring  little  added-value  in  terms  of  statistical 
accuracy, while imposing significant burden on these enterprises. 

•  Changes subsequent to the placing of medicines on the EU market have to follow complex 
rules  and  mobilise  substantial  resources  from  companies;  this  is  in  particular  true  for 
changes  in  their  packaging  or  in  the  address  of  the  manufacturer;  while  regulating 
variations is essential to ensure that patients are properly informed, some modalities could 
be unduly burdensome. 

•  Difference  in  definitions  for  “volatile  organic  compounds”  creates  some  confusion  and 

complicates reporting for no obvious reason. 

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Parliament and the Council reached a political agreement only four months later. Formal adoption by 
the Council took place on 22 October 2007. 
With  new  European  elections  scheduled  for  June  2009,  the  European  Parliament  announced  that  it 
would not consider new legislative initiatives after March/April 2009. In view of previous changes of 
legislature, normal legislative work might not be back to full speed before November 2009. 

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•  Fishing vessels of 24 meters in length and more are subjected to surveys every four years 
according to some obligations and every five years according to others; these differences in 
inspection frequency may put excessive burdens on owners.  

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Particular attention has been paid to Company Law, one of the most important area in terms 
of administrative burdens. The following difficulties were identified: 

•  Certain  publication  requirements  concerning  company  particulars  appear  to  be  outdated 

considering the development of electronic communication. 

•  Specific  translation  and  documentation  modalities  when  registering  a  branch  seem  to  be 

too burdensome. 

•  Having  to  explain  the  formation  of  expenses  and  the  breakdown  of  net  turnover  in  the 

notes to the accounts (disclosure requirements) seems excessive for SMEs. 

The  Commission  will  also  seek  the  opinion  of  the  newly  established  High  Level  Group  of 
Independent  Stakeholders  on  Administrative  Burdens  before  finalising  the  list  of  2008  Fast 
Track Actions. 

4. 

CONSULTATION WITH STAKEHOLDERS 

Reducing  burdens  is  not  something  the  Union  can  or  should  do  on  its  own.  Community 
legislation  indeed  is  mostly  implemented  at  Member  State  level  and  affects  businesses  and 
citizens.  The  Action  Programme  therefore  needs  outside  expertise,  so  that  the  concrete 
experience of stakeholders is fully taken into account. 

Stakeholder involvement is structured around three pillars:  

•  An online consultation in 22 EU official languages 

•  Local workshops with businesses in Member States. 

•  The High Level Group of Independent Stakeholders on Administrative Burdens 

These pillars ensure continuous input from stakeholders all over Europe and transparency in 
the implementation of the Action Programme as announced in January 200724. Moreover, in a 
number of areas (e.g. agriculture), consultation with Member States' experts and stakeholders 
is facilitated via sectoral expert or advisory groups. 

4.1. 

Online stakeholder consultation  

On 21 September 2007, the Commission launched a website, building on best practice from 
similar web sites in some Member States, intended at collecting suggestions from businesses 
and  citizens  to  reduce  administrative  burdens  in  EC  legislation  throughout  the  Action 
Programme. The website is available in 22 official EU languages at 
http://ec.europa.eu/enterprise/admin-burdens-reduction/index_en.htm  

Building on best practices at Member State level, the Online Consultation was created for the 
purpose  of  giving  EU  businesses  the  possibility  to  voice  their  concerns  directly  to  the 
European Commission. The website is designed  to collect specific information on problems 
and concrete suggestions related to administrative burdens.  

An  outline  of  the  submissions  received  so  far  is  presented  in  Annex  5.  The  first  quarterly 
report presenting them will be released in January 2008 on  
http://ec.europa.eu/enterprise/admin-burdens-reduction/reports_en.htm  and,  given  that  they 
often cover also national measures, will also be discussed intensively with Member States. 

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COM(2007) 23. 

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4.2.  Workshops in the Member States 

During the first half of 2008, workshops and conferences will be held with businesses from all 
Member  States  in  order  to  raise  awareness  about  the  Programme  and  obtain  comments  or 
suggestions.  Another  round  of  events  will  be  organised  at  the  end  of  2008  and  beyond  to 
disseminate  results.  More  information  on  those  initiatives  will  be  available  on  the 
Commission website dedicated to administrative burdens25. 

4.3. 

The High Level Group of Independent Stakeholders on Administrative Burdens 

The  Commission  decided  on  31  August  2007  the  creation  of  the  High  Level  Group  of 
Independent  Stakeholders  on  Administrative  Burdens  (HLG)26.  This  Group  has  a  three  year 
mandate27 and will be funded as part of a pilot project funded thanks to an amendment to the 
EU budget voted by the European Parliament.  

On 13 September 2007, the Commission appointed Dr Stoiber, the former Minister President 
of  Bavaria,  to  chair  the  High  Level  Group  because  of  his  long-standing  efforts  to  improve 
legislation  in  Bavaria,  Germany  and  Europe.  The  Commission  invited  EU  representative 
organisations  to  nominate  candidates.  After  careful  consideration  and  in  depth  consultation 
with  Dr  Stoiber,  the  Commission  appointed  the  remaining  14  members  of  the  Group  on  23 
November.  They  include  the  leaders  of  several  bodies  responsible  for  fighting  red  tape  at 
member  state  level,  representatives  from  the  worlds  of  industry,  small  and  medium  sized 
enterprises  (SMEs)  and  environmental  and  consumer  organisations,  all  having  first  hand 
experience in Better Regulation28.  

The HLG will advise the Commission on the implementation of the Action Programme and 
make  recommendations  on  administrative  burdens  measures.  Its  constitutive  meeting  took 
place  on  17  January  2008.  The  Commission  will  fully  take  these  recommendations  into 
account before presenting its proposals aimed at reducing administrative burdens. 

5. 

NATIONAL PROGRAMMES FOR REDUCING ADMINISTRATIVE BURDENS 

The  European  Council  of  March  2007  agreed  with  the  proposed  target  for  administrative 
burdens  of  EU  origin  and  invited  Member  States  to  set  “national  targets  of  comparable 
ambition  within  their  spheres  of  competence  by  2008”  29.  If  the  European  institutions  took 
steps to deliver on EU reduction (-25% of administrative burdens resulting from Community 
legislation and its national transposition by 2012), more has to be done at Member State level.  

As  of  December  2007,  6  Member  States  completed  a  baseline  measurement  of  information 
obligations  in  their  country  (AU,  CZ,  DK,  DE,  NL  and  UK).  A  number  of  other  Member 
States  have  conducted  partial  measurements  and/or  are  planning  to  embark  on  a  full-scale 
measurement.  

Twelve  Member  States  have  set  a  reduction  target,  most  having  opted  for  25%  i.e.  a 
comparably ambitious target to that set at the EU level30.  

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30 

http://ec.europa.eu/enterprise/admin-burdens-reduction/. 
Commission Decision 2007/623/EC of 31 August 2007 setting up the High Level Group of Independent 
Stakeholders on Administrative Burdens. 
The mandate and rules of procedure are available on: 
http://ec.europa.eu/enterprise/regulation/better_regulation/high_level_grou p_is_en_version.htm 
See Annex 6. 
Presidency conclusions of the Brussels European Council (7/8 March 2007), p.10. 
For details, see Annex 3: National targets for the reduction of administrative burdens as of end 2007. 

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6. 

NEXT STEPS 

The European Parliament and the Council are invited to:  

•  complete  decision  making  on  the  outstanding  fast  track  proposals  of  the  European 
Commission to reduce administrative burdens before the European Council in March 2008; 

•  give priority to the fast track proposals which the European Commission will make in 2008 
to reduce administrative burdens as well as to related simplification proposals which will 
significantly  contribute  to  the  reduction  of  administrative  burdens  in  areas  such  as 
agriculture, company law and financial services; 

•  put  in  place  appropriate  working  methods  to  speed  up  the  process  of  adoption  of 
simplification  measures  as  foreseen  in  the  2003  Inter-Institutional  Agreement  on  Better 
Lawmaking. 

Member States are invited to: 

•  submit their national targets ahead of the 2008 Spring European Council; 

•  take  into  account  the  findings  of  the  Action  Programme  when  reducing  burdens  flowing 

from the transposition and implementation of EU legislation. 

The  Commission  will  present  the  results  of  the  measurement  exercise  of  administrative 
burdens  by  the  end  of  2008 followed  by  a  number  of  further  proposals to  meet  the 
25% reduction  target.  In  addition,  as  announced  in  the  Action  Programme  in  January  2007, 
the Commission will set specific targets per sector in 200831. 

7. 

CONCLUSIONS 

The Action Programme is on track. Its implementation in 2007 highlighted a number of key 
issues. The active involvement of all stakeholders is a necessity. If businesses are to harvest 
the  full  benefits  of  a  large  scale  reduction  of  administrative  burdens,  it  is  essential  that 
Member  States  continue  their  efforts  at  national  level.  In  particular,  it  is  imperative  that 
Member States adopt national reduction targets of comparable ambition to the EU target by 
2008, as stated by the 2007 Spring European Council. Along the same line, the EU legislators 
should  bear  in  mind  the  European  Council’s  request  to  assign  priority  to  adopting  the  fast 
track actions presented by the European Commission.  

31 

Communication  from  the  Commission  to  the  Council,  the  European  Parliament,  the  European 
Economic and Social Committee and the Committee of the Regions, "Action Programme for Reducing 
Administrative Burdens in the European Union" - COM(2007) 23, 24.1.2007, p. 13. 

EN 

11 

   EN 

 
                                                 
Annex 1: Mapping of EU information Obligations – Preliminary results 

Priority Area and pieces of EU legislation 

Agriculture and agricultural subsidises 

-  Council Regulation (EC) 1782/2003 of 29 September 2003 establishing common rules for direct support schemes under the common agricultural policy and 

establishing certain support schemes for farmers 

-  Commission  Regulation  (EC)  No  1291/2000  of  9  June  2000  laying  down  common  detailed  rules  for  the  application  of  the  system  of  import  and  export 

licences and advance fixing certificates for agricultural products 

Annual Accounts/Company law 

- 

- 

First  Council Directive of 9 March 1968  on  co-ordination  of  safeguards  which, for  the  protection of  the  interests of  members  and  others,  are required by 
Member States of companies, with a view to making such safeguards equivalent throughout the Community (68/151/EEC) 

Second Council Directive of 13 December 1976 on coordination of safeguards which, for the protection of the interests of members and others, are required 
by Member States of companies (77/91/EEC) 

-  Third Council Directive of 9 October 1978 concerning mergers of public limited liability companies (78/855/EEC) 

- 

- 

- 

Fourth Council Directive of 25 July 1978 on the annual accounts of certain types of companies (78/660/EEC) 

Sixth Council Directive of 17 December 1982 concerning the division of public limited liability companies (82/891/EEC) 

Seventh Council Directive of 13 June 1983 on consolidated accounts (83/349/EEC) 

-  Eleventh Council Directive of 21 December 1989 concerning disclosure requirements in respect of branches opened in a Member State by certain types of 

company governed by the law of another State (89/666/EEC) 

-  Twelfth Council Directive of 21 December 1989 on single-member private limited-liability companies (89/667/EEC) 

Cohesion policy 

-  Council Regulation (EC) No 1260/1999 of 21 June 1999 laying down general provisions on the Structural Funds, as amended by Council Regulation (EC) No 

1105/2003 of 26 May 2003 

Environment 

-  Directive 2003/105/EC of the European Parliament and of the Council of 16 December 2003 amending Council Directive 96/82/EC on the control of major-

accident hazards involving dangerous substances 

-  Regulation (EC) No 1013/2006 of the European Parliament and of the Council of 14 June 2006 on shipments of waste  

-  Council Directive 96/61/EC of 24 September 1996 concerning integrated pollution prevention and control (as amended by Regulation (EC) No 166/2006 of 
the  European Parliament  and  of  the  Council  of 18  January  2006  concerning  the  establishment  of  a  European Pollutant  Release  and Transfer  Register  and 
amending Council Directives 91/689/EEC and 96/61/EC) 

Number of 
EU IOs 

9 

(separate 
study 
completed) 

9 

75 

1 

32 

9 

7 

16 

2 

5 

3 

6 

6 

43 

7 

15 

5 

EN 

12 

EN 

 
  
-  Waste Electrical and Electronic Equipment (WEEE) directive 2002/96/EC 

-  Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000 on end-of life vehicles 

Financial services 

-  Directive  2006/48/EC  of  the  European  Parliament  and  of  the  Council  of  14  June  2006  relating  to  the  taking  up  and  pursuit  of  the  business  of  credit 

institutions 

-  Directive 2006/49/EC of the European Parliament and of the Council of 14 June 2006 on the capital adequacy of investment firms and credit institutions 

-  Directive 2002/83/EC of the European Parliament and of the Council of 5 November 2002 concerning life insurance 

Fisheries 

-  Council Regulation (EEC) No 2847/93 of 12 October 1993 establishing a control system applicable to the common fisheries policy 

Food safety 

-  Regulation (EC) No 1760/2000 of the European Parliament and of the Council of 17 July 2000 establishing a system for the identification and registration of 

bovine animals and regarding the labelling of beef and beef products and repealing Council Regulation (EC) No 820/97 

-  Council Regulation (EC) No 21/2004 of 17 December 2003 establishing a system for the identification and registration of ovine and caprine animals and 

amending Regulation (EC) No 1782/2003 and Directives 92/102/EEC and 64/432/EEC 

-  Directive 2000/13/EC of the European Parliament and of the Council of 20 March 2000 on the approximation of the laws of the Member States relating to the 

labelling, presentation and advertising of foodstuffs. 

-  Council Regulation (EC) 1/2005 Protection of animals during transport and related operations 

-  Regulation 1830/2003 GMOs - traceability rules require that operators have in place system to hold information for 5 years 

-  Council  Directive  2000_29  of  8  May  2000  on  protective  measures  against  the  introduction  into  the  Community  of  organisms  harmful  to  plants  or  plant 

products and against their spread within the Community 

-  Directive  98/6/EEC  of  the  European  Parliament  and  the  Council  of  16  February  1998  on  consumer  protection  in  the  indication  of  the  prices  of  products 

offered to consumers 

Pharmaceutical legislation 

-  Directive 2001/83/EC of the European Parliament and of the Council of 6 November 2001 on the Community code relating to medicinal products for human 

use  

-  Directive 2001/20/EC on the approximation of laws, regulations and administrative provisions of the Member States relating to the implementation of good 

clinical practice in the conduct of clinical trials on medicinal products for human use 

Public procurement 

-  Directive  2004/18/EC  of  the  European  Parliament  and  of  the  Council  of  31  March  2004  on  the  coordination  of  procedures  for  the  award  of  public  work 

contracts, public supply contracts and public service contracts 

9 

7 

44 

17 

11 

16 

12 

12 

64 

7 

5 

1 

16 

3 

31 

1 

35 

22 

13 

8 

4 

EN 

13 

EN 

 
  
-  Directive  2004/17/EC  of  the  European  Parliament  and  of  the  Council  coordinating  the  procurement  procedures  of  entities  operating  in  the  water,  energy, 
transport  and  postal  services  sectors  (including  Commission  Regulation  (EC)  No  1564/2005  of  7  September  2005  establishing  standard  forms  for  the 
publication of notices in the framework of public procurement procedures pursuant to that directive) 

Statistics 

-  Regulation (EC) 638/2004 of the European Parliament and of the Council of 31 March 2004 on Community Statistics relating to the trading of goods between 

Member States and repealing Council Regulation (EEC) No 3330/91 

-  Council Directive 2001/109/EC of the EP and Council on fruit trees 

-  Council Directive 93/23/EEC of 1 June 1993 on the statistical surveys to be carried out on pig production 

-  Council Directive 93/24/EEC of 1 June 1993 on the statistical surveys to be carried out on bovine animals 

-  Council Regulation (EEC N) 3924/91of 19 December 1991 on the establishment of a Community survey of industrial production 

-  Council Regulation (EC, Euratom) No 58/97 of 20 December 1996 concerning structural business statistics 

Tax law (VAT) 

-  Council Directive 2006/112/EC of 28 November 2006 on the Common system of value added tax 

Transport 

-  Regulation (EC) No 561/2006 of the European Parliament and of the Council of 15 March 2006 on the harmonisation of certain social legislation relating to 

road transport and amending Council Regulations (EEC) No 3821/85 and (EC) No 2135/98 and repealing Council Regulation (EEC) No 3820/85 

-  Directive  2004/49/EC  of  the  European  Parliament  and  of  the  Council  of  29  April  2004  on  safety  on  the  Community's  railways  and  amending  Council 
Directive 95/18/EC on the licensing of railway undertakings and Directive 2001/14/EC on the allocation of railway infrastructure capacity and the levying of 
charges for the use of railway infrastructure and safety certification 

Working environment/employment relations 

-  Council Directive 89/391/EEC of 12 June 1989 on the introduction of measures to encourage improvements in the safety and health of workers at work 

-  Directive 92/57/EEC of 24 June 1992 on the implementation of minimum safety and health requirements at temporary or mobile construction sites 

TOTAL 

4 

9 

1 

1 

2 

2 

1 

1 

25 

25 

8 

2 

6 

7 

4 

3 

344 

EN 

14 

EN 

 
  
 
Annex 2: State of play – Administrative Burdens measurement at Member State level 

a
i
r
t
s
u
A

Priority areas/Countries
Company Law
Statistics
Cohesion Policy
Financial services
Public Procurement
Food safety
Transport
Fisheries
Pharmaceuticals
Environment
Employment
Agriculture
VAT

Legend

i

m
u
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e
B

l

a
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B

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s
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C

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a

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a
M

s
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r
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t
e
N

d
n
a
o
P

l

l

a
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P

i

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e
v
o
S

l

i

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a
p
S

n
e
d
e
w
S

K
U

Full Baseline Measurement
Partial Measurement
No Measurement
Planned Measurement
No detailed information available

Belgium has done partial measurement in a number of unspecified areas. Cyprus, Greece, Luxembourg and Malta announced their intention to conduct 
partial measurements (to be determined). France announced that the mapping of all Information Obligations should be completed in March 2008. 

Full baseline measurement means that all information obligations in the sector have been identified and quantified. Partial measurement means that 
some legal texts in the sector have been identified and quantified. 

EN 

15 

EN 

 
  
 
Annex 3: National targets for the reduction of administrative burdens as of end 2007 

i

m
u
g
e
B

l

a
i
r
t
s
u
A

-25%

2010

a
i
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a
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B

l

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C

.
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F

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t
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g
r
u
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b
m
e
x
u
L

a
t
l
a
M

-20% -25% -25%

-25% -25% -25%

2010 2010 2012

2011 2011 2012

-25%

2012

d
n
a
o
P

l

l

a
g
u
t
r
o
P

i

a
n
a
m
o
R

s
d
n
a
l
r
e
h
t
e
N

-25%

2011

For the Netherlands, this is the second reduction of 25% in a row
For Slovenia, the target applies to selected priority areas

Target (%)

Deadline

Legend

i

a
k
a
v
o
S

l

i

a
n
e
v
o
S

l

i

n
a
p
S

n
e
d
e
w
S

K
U

-25% -25% -25% -25% -25%

2012 2010 2012 2010 2010

EN 

16 

EN 

 
  
 
Annex 4: Fast Track Actions presented in 2007 - State of play on 15 January 2008 

Areas 

Change pursued 

Proposal 

Status 

Executive measures 
Energy crops  
Commission regulation 1973/2004.  

Reduce reporting obligation for farmers 

Export Refunds for agricultural 
products  
Commission regulation 800/1999. 

Ease the requirements concerning the documentary proof to be 
delivered by operators in order to receive export refunds for 
exporting certain agricultural products. 

Statistics on the information 
society  
Regulation 808/2004. 

Hygiene on fishing vessels 
Regulation 853/2004. 
“Omnibus” package 
Company law  
Directives 78/855 and 82/891. 

Transport documents 
Regulation no. 11. 

HACCP, food hygiene 
Regulation 852/2004. 

Stand-alone proposals 
Statistics on farmers 
Directives 93/23, 93/24 and 93/25.  

Simplify ordinary and sector questionnaire in annual 
Commission Regulation, thus easing the administrative burdens 
for respondents. 

Remove unnecessary requirements for small fishing vessels. 

Remove the requirement of drawing up an independent expert 
report in the case of a merger or a division if all shareholders 
renounce to it. 

Remove outdated requirements (from 1960) to provide a series 
of information on tariffs, agreements, price deals and transport 
when transporting goods across national borders within the EU. 

Exempt micro-enterprises from certain HACCP (Hazard 
Analysis and Critical Control Point) requirements, thereby not 
imposing the same burdens on small bakers, grocery shops, 
market stalls etc. as on large supermarkets 

Proposal adopted on 
7/03. 
COM (2007) 91. 

Proposal adopted on 
7/03. 
COM (2007) 90. 

Proposal adopted on 
7/03. 
COM (2007) 90. 

Adopted. 
Regulation 270/2007 of 13/03/2007 

Adopted. 
Regulation 1001/2007 of 29/08/2007 

Adopted. 
Regulation 1243/2007 of 18/07/2007 

Adopted. 
Regulation 1243/2007 of 24/10/2007 

Adopted. 
Directive 2007/63/EC of 13/11/2007 

European Parliament: 1st reading adoption on 
15/01/2008.  
Council: ready for adoption. 

European Parliament: first exchange of views in 
committee in January 2008. 
Council: under discussion in working party. 

Simplify and reduce the frequency of agricultural statistics to 
once a year for surveys in member states with pig populations 
smaller than 3 million heads and cattle population smaller than 
1.5 million heads. 

Proposal adopted on 
22/03. 
COM (2007) 129 

European Parliament: principle approval. 
Council working party agreement expected early 
2008 

Road haulage  
Directive 96/26. 

Dangerous goods 
Directive 96/35.  

Introduce electronic register to enhance exchange of data and a 
simplified and standardized format for the Community licence, 
certified copies and the driver attestation. 

Proposal adopted on 
23/05. COM (2007) 263 
and COM (2007) 265 

Simplify the administrative procedures both for public 
authorities (EU or national) and for private bodies. 

Proposal adopted.  
COM (2006) 852 

European Parliament: 1st reading adoption expected 
in March 2008 
Council: under discussion in working party. 
European Parliament: 1st reading on 05/09. Council: 
principle approval in October 2007, formal 
agreement expected early 2008. 

Estimated 
benefit (€) 

38,680,000 

210,830,000 

45,960,000 

14,010,000 

194,910,000 

432,900,000 

100,000,000 
to 
140,000,000 

66,640,000 

44,300,000 

101,750,000 

EN 

17 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex 5: Administrative Burdens Reduction - Online consultation as of 15 January 2008 

Geographical origin of complaints and suggestions

Sector of activity

30

25

40

35

30

25

20

15

10

5

0

s
n
o
i
s
s
i
m
b
u
s

20

15

f
o
r
b
N

10

5

0

Other

Czech Republic
Bulgaria
Belgium
Denmark

Germany

Estonia

Greece

Spain

France

Ireland

Cultural and Recreational Services
Agriculture, Forestry and Fishing
Construction
Communication Services
Accommodation, Cafes and Restaurants

Education

Electricity, Gas and Water Supply
Health and Community Services
Finance and Insurance

Manufacturing

Mining

Property and Business Services
Personal Services

Retail Trade
Transport and Storage
Wholesale Trade

Organisational size

self-employed

1..9

10..49

50..249

250..499

500+

EN 

18 

Italy

Cyprus

Lithuania
Latvia
Luxembourg

Hungary

Malta
Netherlands

Austria

Poland

Portugal

Romania

Slovenia

Slovakia

Sweden
United Kingdom
Finland
other...

Country

Type of respondents

a citizen

a company

a national business association

a European business association

a non profit organisation

other

EN 

 
  
 
 
 
 
Annex  6:  Members  of  the  High  Level  Group  of  Independent  Stakeholders  on 
Administrative Burdens 

Dr Edmund Stoiber 
Chair  of  the  High  Level  Group  of  Independent  Stakeholders  on  Administrative  Burdens.  Former  Minister-
President of Bavaria. 

Mr Roland Berger  
CEO of Roland Berger Strategy Consultants GmbH. 

Mr Gabriel Côrte-Real Goucha  
General Counsel of the Mirpuri Investments Group (a group of companies in Portugal and abroad which includes 
airlines,  airport  management,  handling,  real  estates,  a  bank,  etc.).  Vice  President  for  Institutional  and 
International  Relations  of  PME  Portugal  (an  Association  of  SMEs).  Representative  of  PME  Portugal  in  the 
Commission for “Desformalização” of the Ministry of Justice. Nominated by European Small Business Alliance 
(ESBA). 

Ms Annika Fritsch  
Specialist taxes and corporate law and coordinator of Better Regulations at Företagarna, the Swedish Federation 
of  Private  Enterprises.  Nominated  by  European  Association  of  Craft,  Small  and  Medium-sized  Enterprises 
(UEAPME). 

Mr Rick Haythornthwaite  
Chairman  of  the  “Better  Regulation  Commission”  providing  independent  advice  to  the  UK  government,  from 
business  and  other  external  stakeholders,  about  new  regulatory  proposals  and  about  the  Government's  overall 
regulatory performance. 

Mr John Hontelez  
Secretary General of European Environmental Bureau (EEB), the largest european federation of environmental 
citizens  organisations  aiming  for  effective  european  environmental  and  sustainable  development  policies  and 
with an active role in Better Regulation, Impact Assessment, better enforcement and Lisbon Process. Nominated 
by European Environmental Bureau (EEB). 

Mr Riccardo Illy  
President of the Region Friuli-Venezia-Giulia and President of the Assembly of European Regions. 

Mr Robin Lindschoten  
Chairman of the Dutch Advisory Board on Administrative Burdens (Actal) since May 2000. 

Dr Johannes Ludewig  
Executive Director of the Community of European Railway and Infrastructure Companies (CER); Chairman of 
the  German  “Nationaler  Normenkontrollrat”  (National  Regulatory  Control  Council).  Nominated  by 
BusinessEurope. 

Mr Candido Mendez  
Secretary  General  of  the  UGT-E  (Unión  General  de  Trabajadores-  Espana)  and  former  President  of  ETUC. 
Nominated by European Trade Union Confederation (ETUC) 

Mr Jim Murray  
Director  of  BEUC,  the  European  Consumers  Organisation  (Brussels).  Previously  Director  of  the  Office  of 
Consumer  Affairs  and  Fair  Trade  in  Ireland.  Nominated  by  Bureau  Européen  des  Unions  de  Consommateurs 
(BEUC). 

Mr Pierre Pere Padrosa  
Vice  President  of  IRU  (International  Road  Transports  Union).  President  and  Vice  President  of  various 
Transports Federations. Nominated by International Road Transport Union (IRU). 

Mr Pekka Pesonen  
Secretary General of “Committee of Professional Agricultural Organisations in the European Union” (COPA) & 
“General  Confederation  of  Agricultural  Co-operatives  in  the  European  Union”  (COGECA).  State  Secretary  - 
Finnish Ministry of Agriculture and Forestry. Formerly dairy and livestock advisor in Brussels; employee with 
by Valio Ltd, Finnish dairy company. M.Sc.Agric. at Helsinki University. Nominated by Copa & Cogeca. 

Mr Jacques Potdevin  

EN 

19 

   EN 

 
Certified  public  accountant  and  auditor.  Chairman  of  Jacques  Potdevin  &  Associés  (JPA  Paris),  CEO  of  JPA 
International and JPA Consulting International (network of certified public accountants and auditors representing 
130  member  firms  in  41  countries).  Senior  lecturer  to  the  French  Business  School  HEC  (hautes  etudes 
commerciales). Nominated by European Federation of Accountants (FEE). 

Mr Pavel Telicka  
Director  of  “BXL  consulting”.  Senior  Advisor  at  European  Policy  Centre  (EPC).  Former  Commissioner 
nominated by the Czech Republic and co-responsible for the portfolio of Health and consumer protection with 
Commissioner David Byrne (in 2004). Nominated by European Policy Centre (EPC). 

EN 

20 

   EN