Report from the Commission on subsidiarity and proportionality (15th Report on Better Lawmaking, 2007)
Date: 2008-09-26
Institutions: European Commission
Subjects: activity report, application of EU law, operation of the Institutions, principle of proportionality, principle of subsidiarity

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COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 26.9.2008 
COM(2008) 586 final 

REPORT FROM THE COMMISSION 

ON SUBSIDIARITY AND PROPORTIONALITY  

(15th report on Better Lawmaking, 2007) 

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REPORT FROM THE COMMISSION 

ON SUBSIDIARITY AND PROPORTIONALITY  

(15th report on Better Lawmaking, 2007) 

1. Introduction 

This  is  the  15th  annual  review  of  the  application  of  the  principles  of  subsidiarity  and 
proportionality  which  the  Commission  presents  to  the  European  Council  and  the  European 
Parliament  in  line  with  the  protocol  annexed  to  the  Treaty  establishing  the  European 
Community. Unlike the reviews for the previous three years, this review does not cover the 
wider issues of better regulation as these were addressed in the Second Strategic Review of 
Better Regulation in the European Union1. 

The  review  also  highlights  two  developments  in  2007  which  have  an  impact  on  how 
subsidiarity and proportionality are applied. First the establishment of the Impact Assessment 
Board which has led to reinforced scrutiny of subsidiarity and proportionality in Commission 
impact assessments; and secondly, the agreement on a new Treaty which – if ratified – would 
give  an  important  new  role  to  national  parliaments  in  assessing  how  the  two  principles  are 
applied. 

2. The legal and institutional framework 

2.1 The principles of subsidiarity and proportionality 

The general definitions of subsidiarity and proportionality are found in paragraphs 2 and 3 of 
Article  5  of  the  Treaty  establishing  the  European  Community  (TEC).  Protocol  30  of  the 
Treaty provides further details on how the two principles should be applied. 

Subsidiarity is a guiding principle for defining the boundary between Member State and EU 
responsibilities - that is, who should act? If the Community has exclusive competence in the 
area concerned, there is no doubt about who should act, and subsidiarity does not apply. If the 
Community and the Member States share the competence, the principle clearly establishes a 
presumption  in  favour  of  decentralisation.  The  Community  should  only  take  action  if  the 
objectives cannot be achieved sufficiently by the Member States (necessity test) and if they 
can be better achieved by the Community (value-added test or compared effectiveness). 

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COM(2008) 32, 30.01.08 

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Subsidiarity is a dynamic concept, any assessment of which will evolve over time. It allows 
Community  action  within  the  limits  of  its  powers  to  be  expanded  where  circumstances  so 
require, and conversely, it means that Community action should be restricted or discontinued 
where it no longer meets the subsidiarity test.2  

Proportionality  is  a  guiding  principle  when  defining  how  the  Union  should  exercise  its 
competences, both exclusive and shared (what should be the form and nature of EU action?). 
Both  Article  5  TEC  and  the  Protocol  provide  that  the  action  should  not  go  beyond  what  is 
necessary  to  achieve  the  objectives  of  the  Treaty.  Any  decision  must  favour  the  least 
demanding option. 

2.2 Modes of application, opportunity for comments, and ex-post control 

All  institutions  of  the  Union  have  to  comply  with  both  principles  when  exercising  their 
powers.  Specific  obligations  have  been  set  out  in  the  Protocol  and  in  the  Inter-Institutional 
Agreement  of  1993  on  subsidiarity3.  Some  of  the  key  elements  are  summarised  here,  while 
the changes that the Treaty of Lisbon would introduce are presented in section 4.1. 

The Commission must: consult widely before proposing legislation; state in the explanatory 
memorandum  for  each  legislative  proposal  the  reasons  for  concluding  that  the  proposal 
complies with subsidiarity and proportionality; and take into account the burden falling on the 
Community,  national  governments,  local  authorities,  economic  operators  and  citizens.  As 
explained in section 3.1, the Commission's impact assessment system is helping to ensure that 
subsidiarity and proportionality are rigorously analysed for all major proposals. 

The European Parliament and Council must provide a justification regarding subsidiarity if an 
amendment  they  make  affects  the  scope  of  Community  action4.  If  the  consultation  or 
cooperation  procedure  applies,  the  Council  has  to  inform  Parliament  of  its  position  on  the 
application of subsidiarity and proportionality in a statement of reasons5.  

The  European  Economic  and  Social  Committee  and  the  Committee  of  the  Regions  express 
their views either when they are consulted or in own-initiative opinions. The ‘Conference of 
European  Community  Affairs  Committees’  (COSAC)  can  also  express  an  opinion  on  the 
application of the principle of subsidiarity6.  

Since  September  2006,  the  Commission  has  transmitted  new  legislative  proposals  to  the 
national  parliaments  inviting  them  to  react.  Although  this  exchange  is  much  wider  in  scope 
than  the  application  of  the  principles  of  subsidiarity  and  proportionality,  many  of  the 
comments received from national parliaments relate to these principles. 

Finally, the Court of Justice and the Court of First Instance can review the legality of acts of 
the institutions for compliance with the principle of subsidiarity.  

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Article 3 of the Protocol 
Adopted 17.11.93, OJ C 329, 06.12.93, p. 132. 
Section 2, point 3 of the Inter-Institutional Agreement on subsidiarity of 1993. 
Article 12 of the Protocol. 
Point 6 of the Protocol on the role of national parliaments in the European Union, Treaty of Amsterdam. 

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3. Application of the principles by the Commission in 2007 

3.1 Impact Assessments and the Impact Assessment Board 

Consideration  of  subsidiarity  and  proportionality  is  part  of  the  Commission's  daily  work  of 
developing  new  policy  initiatives,  but  the  development  of  impact  assessments  has  added  an 
extra  layer  of  focused  scrutiny.  The  Commission’s  impact  assessment  system  is  helping  to 
facilitate better-informed decision making throughout the legislative process. It improves the 
quality of proposals by ensuring that initiatives are based on transparent evidence, stakeholder 
input,  and  a  thorough  and  integrated  analysis  of  the  economic,  social  and  environmental 
impacts  of  different  ways  of  addressing  a  problem.  An  analysis  of  subsidiarity  and 
proportionality is a key aspect of this approach.  

While  impact  assessment  has  become  embedded  in  the  working  practices  and  decision-
making of the Commission, the institution is committed to improving the system even further. 
A  key  development  was  the  creation  of  the  Impact  Assessment  Board  (IAB)  in  November 
2006 to provide independent quality support and control for impact assessments prepared by 
Commission  services.7  The  IAB's  opinions  are  formally  integrated  into  the  Commission’s 
internal  decision-making,  from  inter-departmental  consultation  to  the  final  adoption  by  the 
College.  They  are  also  available  to  the  other  institutions  and  the  general  public,  once  the 
corresponding  Commission  initiative  is  adopted.  In  its  opinions,  the  IAB  frequently 
recommends substantial improvements to core elements of the impact assessments, including 
on subsidiarity and proportionality. Some examples are provided in Section 3.28. 

On the basis of the IAB's work and of an external evaluation of the impact assessment system, 
the  Commission  has  decided  to  make  more  operational  the  guidance  it  provides  on  the 
analysis of subsidiarity and proportionality in the revised Impact Assessment Guidelines to be 
adopted  in  the  second  half  of  2008.  The  Guidelines  will  contain  explicit  questions,  closely 
based on protocol 30 of the Treaty establishing the European Community, which each impact 
assessment will have to address. The revised Guidelines will also reinforce the message that, 
while impact assessments typically examine problems that can be addressed by action at EU-
level, they must take into account the fact that the problems and the measures taken to address 
them, may have different effects in different Member States and regions of the Union9.  

These  changes  will  help  to  ensure  that  the  Commission  provides  a  more  rigorous  and 
transparent analysis and justification of its proposals than ever before. This is essential given 
the increased role that national parliaments will play if the Lisbon Treaty enters into force.  

3.2 Examples of how the Commission applied the principles  

This section illustrates how the Commission has examined subsidiarity and proportionality in 
its impact assessments, reorienting or abandoning its proposals as a result.  

Two proposals in the area of company law were stopped in 2007 on the basis of the analysis 
in the impact assessments. The first concerned a possible Recommendation on proportionality 
between  capital  and  control  in  listed  companies.  The  impact  assessment  concluded  that,  in 

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"Enhancing quality support and control for Commission Impact Assessments - The Impact Assessment 
Board" - SEC(2006) 1457.  
For an overview of the IAB's first year of operation SEC(2008)120, 30.01.08.  
http://ec.europa.eu/governance/impact/key_en.htm 

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terms of proportionality, it was not clear that a Directive or a Recommendation were the least 
onerous  ways  to  reduce  the  risk  of  private  benefit  extraction  by  insiders  across  the  EU 
Member States. It concluded that the combination of market forces, Member State regulatory 
initiatives  and  the  existing  Community  legal  framework  were  sufficient  and  that,  in  the 
absence  of  empirical  evidence  on  the  existence  and  extent  of  shareholder  expropriation, 
adopting  further  measures  could  entail  a  risk  of  imposing  significant  costs  to  issuers  and 
controlling shareholders without proportional benefits.10 

The  second  company  law  case  concerned  a  proposal  for  a  Directive  on  the  cross  border 
transfer  of  registered  offices.  The  impact  assessment  concluded  that  the  effects  of  existing 
legislation  on  cross-border  mobility  (Directive  on  cross-border  mergers)  are  not  yet  known, 
and  that  the  issue  of  the  transfer  of  the  registered  office  might  be  clarified  by  the  Court  of 
Justice  in  the  near  future.  As  a  result,  the  assessment  concluded  that  a  Directive  was  not  a 
proportionate response to the problem, and that it would be more appropriate to wait until the 
impacts  of  those  developments  can  be  fully  assessed  and  the  need  and  scope  for  any  EU 
action better defined.11 

A number of initiatives were revised significantly as a response to the scrutiny of the Impact 
Assessment  Board.  For  example,  an  Initiative  on  the  quality  of  teacher  education12  became 
much more explicit on the possible supportive role of EU initiatives in the light of Member 
State  competence.  Likewise,  for  the  Action  plan  on  effective  consular  protection  in  third 
countries13, the need for EU action was carefully re-examined and a more modest approach 
proposed.  

The proposal for a Directive on the cross-border enforcement of sanctions in the field of road 
safety  originally  consisted  of  two  separate  parts:  the  first  to  set  up  an  efficient  cross-border 
enforcement  system  ensuring  that  all  speeding  violations  committed  in  a  Member  State  by 
drivers  from  another  Member  State  could  be  followed  up;  and  the  second  to  make  national 
road  safety  enforcement  practices  comply  with  certain  requirements  with  regard  to  the 
number of controls carried out and the follow-up to registered offences. In its opinion on the 
draft  impact  assessment,  the  IAB  asked  for  the  two  parts  of  the  proposal  to  be  clearly 
distinguished,  and  for  each  part  to  be  assessed  separately  in  terms  of  EU  added  value, 
proportionality and subsidiarity. In March 2008 the Commission adopted a proposal on only 
the  first  part  of  the  initial  draft,  having  dropped  the  part  on  requirements  for  national 
enforcement systems.14 

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SEC(2007) 1705. 
SEC(2007) 1707. 
COM(2007) 392 
COM(2007) 767 
COM(2008) 151 

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4. Application of the principles by other actors 

4.1 National parliaments 

If  ratified,  the  Treaty  of  Lisbon  would  lead  to  a  number  of  changes  in  the  role  of  national 
parliaments  in  EU  lawmaking.15  One  of  the  most  important  innovations  concerns  the 
introduction  of  ex  ante  political  control  and  ex  post  judicial  control  over  the  principle  of 
subsidiarity.  Ex  ante  political  control  would  be  provided  by  the  introduction  of  an  early 
warning mechanism. This would allow national parliaments to send a reasoned opinion when 
they  consider  that  a  European  legislative  proposal  does  not  comply  with  the  subsidiarity 
principle16. National parliaments would be informed systematically of all legislative proposals 
and, except in duly justified urgent cases, will have eight weeks in which to make their views 
known17.  Depending  on  the  number  of  responses  received  from  national  parliaments,  the 
Treaty would provide two mechanisms - the 'yellow card' and the 'orange card' - which lead to 
a  review  and  possible  withdrawal  of  the  proposal.  In  terms  of  ex-post  judicial  control,  the 
Treaty  would  contain  new  provisions  for  national  parliaments  and  the  Committee  of  the 
Regions  to  bring  suspected  violations  of  the  principle  of  subsidiarity  before  the  European 
Court of Justice.18 

In a procedure that is distinct from – though in some aspects similar to – this early warning 
mechanism, the Commission has been transmitting all new initiatives to national parliaments 
since 2006, and has put in place a procedure for replying to the opinions they produce19. By 
December 2007, the Commission had received 166 opinions from 25 national parliaments in 
19 Member States. These related to 86 Commission texts20.  

Subsidiarity and proportionality have been important themes in the issues raised by national 
parliaments. For example:  

•  The  German  Bundesrat  was  of  the  view  that  the  proposal  on  the  framework  for  soil 
protection21  did  not  respect  the  principle  of  subsidiarity,  while  the  French  Senate  was  of 
the  opinion  that  there  was  insufficient  information  on  the  costs  of  the  provisions  on  soil 
contamination to verify whether the proportionality principle was respected. As indicated 
in  section  4.2,  the  proposal  was  subject  to  active  discussions  on  subsidiarity  and 
proportionality in both the European Parliament and Council.  

•  Both the French Senate and German Bundesrat also expressed doubts on the need for the 
proposal on the safety of road infrastructures22. In the European Parliament views differed: 

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Protocols Nº1 and 2 
This  concerns:  proposals  of  the  Commission;  initiatives  of  a  group  of  Member  States  (cf.  penal 
cooperation);  initiatives  of  the  European  Parliament;  requests  of  the  European  Court  of  Justice; 
recommendations  of  the  European  Central  Bank;  and  requests  of  the  European  Investment  Bank  for 
adoption of a European legislative act. 
Article 4 of the Protocol on the Role of national Parliaments in the European Union.  
Article 8 of the Protocol on the application of the principles of subsidiarity and proportionality 
"A Citizens' Agenda - Delivering Results For Europe", COM(2006) 211. 
Annex 1 provides a more detailed overview of the opinions. 
COM(2006)232 
COM(2006)569 

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a  majority  of  Members  wanted  the  Commission  to  be  more  ambitious,  while  others 
opposed it on the grounds of subsidiarity.  

•  The French Senate expressed the view that the Commission had not justified its proposal 
on the reform of the fruit and vegetable market23 from the point of view of subsidiarity and 
proportionality.  In  the  debate  in  Council,  the  Commission  modified  and  completed  the 
recital of the text to make it more explicit on these points.  

•  On  the  Green  Paper  on  Tobacco24,  the  Folketing  (DK)  and  the  Riksdag  (SE)  raised  the 
issue of subsidiarity and expressed a preference for these issues to be dealt with at national 
level.  

It  should  be  noted  that  35  opinions  were  produced  in  the  framework  of  two  co-ordinated 
exercises on  subsidiarity  led by  COSAC and launched at the end of 2006. In 2007 COSAC 
launched a further exercise of this type, focusing on the Framework Decision of the Council 
on  the  fight  against  terrorism25.  By  the  end  of  January  2008,  29  assemblies  out  of  40  had 
participated in the exercise.  The exercise was designed to simulate the procedures proposed 
under the Treaty of Lisbon, although in the event the thresholds triggering action would not 
have been met. The House of Commons opposed the proposal on the grounds of subsidiarity, 
while  the  Bundestag  opposed  it  on  the  grounds  of  proportionality.  Several  chambers 
considered  that  the  arguments  for  subsidiarity  were  insufficient.  All  of  the  chambers 
questioned the value added of Union action compared to action by the Council of Europe.  

4.2 European Parliament and Council  

The European Parliament and the Council raised the issues of subsidiarity and proportionality 
on a number of occasions. 

In  the  discussions  on  the  Marine  Strategy  Framework  Directive,  the  Parliament  in  first 
reading  amended  the  Commission's  proposal  by  introducing  a  more  stringent  and  legally 
binding  obligation  of  result.  Certain  Member  States  subsequently  argued  that  the  main 
objective  of  the  Directive  as  amended  by  the  Parliament  ('to  achieve  or  maintain  good 
environmental  status  of  the  marine  environment')  might  raise  a  problem  in  terms  of 
proportionality.  These  Member  States  were  concerned  that  the  implementation  of  the 
Framework Directive could in certain situations lead to disproportionate costs, and requested 
a clause to address this. The European Parliament in second reading agreed a new text on the 
objective ('shall take the necessary measures to achieve') and also stated that subject to certain 
conditions  Member  States  do  not  have  to  take  specific  measures  where  the  costs  would  be 
disproportionate  taking  into  account  the  risks  to  the  marine  environment..  Some  Member 
States  were  of  the  opinion  that  the  agreed  safeguard  on  costs  was  itself  disproportionately 
cautious  and  for  this  reason  abstained  at  Council  to  express  their  opinion  that  it  had  been 
unnecessarily weakened.  

In Council discussions on the Directive on the protection of soil in December 2007, an effort 
has been made to provide flexibility for Member States and reduce costs of implementing the 
Directive.  However,  certain  Member  States  continue  to  argue  that  soil  policy  is  a  national 
competence  and  that  the  proposal  does  not  respect  the  principles  of  subsidiarity  and 

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COM(2007)17 
COM(2007)27 
COM(2007)650 

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proportionality. While the Committee on Legal Affairs of the European Parliament adopted an 
opinion  rejecting  this  proposal  on  the  grounds  of  subsidiarity,  the  European  Parliament  did 
not follow this opinion.  

As noted in section 2.2, Council and the European Parliament should address subsidiarity and 
proportionality  when  proposing  an  amendment  that  affects  the  scope  of  Community  action. 
The  low  number  of  amendments  that  actually  does  so  reflects  wider  difficulties  for  the 
European  Parliament  and  the  Council  to  provide  impact  assessments  of  significant 
amendments that are proposed, especially when during political discussions they are changed, 
split, or combined before coming to a vote. The review of the "Common Approach for Impact 
Assessment"26 – which will take place in 2008 – provides an opportunity for the Council, the 
European  Parliament  and  the  Commission  to  discuss  ways  of  facilitating  the  assessment  of 
amendments. 

4.3 Committee of the Regions 

The  Committee  of  the  Regions  launched  an  interactive  Subsidiarity  Monitoring  Network  in 
March  2007,  building  on  test  phases  carried  out  in  2005  and  2006.  The  network  is  primarily 
aimed  at  local  and  regional  authorities,  but  EU  and  national  institutions  are  also  invited  to 
participate. The network is organised through an inter-active website27. Registered participants 
receive an email alert when compliance with the subsidiarity principle needs to be examined for 
a  new  policy  document  from  the  Commission.  The  time  for  submitting  comments  to  the 
Committee of the Regions (using a standardised electronic form) is approximately 6 weeks after 
the test has been announced on the network. This electronic platform will, among other things, 
help  the  European  Commission  and  the  Committee  of  the  Regions  to  implement  their  co-
operation agreement of November 2005, according to which they will identify priorities which 
need specific follow-up in the field of subsidiarity and proportionality. 

4.4 The Court of Justice 

2007  was  a  year  in  which  the  established  case-law  on  the  principles  of  subsidiarity  and 
proportionality was confirmed. The Court of First Instance (CFI) made interesting comments 
on subsidiarity, by way of obiter dicta in two cases, and further elaborated on the applicability 
of the principle of proportionality in the field of competiton law.  

In  Case  T-  374/04  Germany  v.  Commission28  the  CFI  linked  the  burden  of  proof  on  the 
Commission when it is exercising its supervisory powers under secondary legislation, to the 
principle  of  subsidiarity.  The  CFI  was  considering  a  challenge  from  Germany  to  the 
Commission's  decision  on  its  national  plan  for  the  allocation  of  greenhouse  gas  emission 
allowances,  in  which  the  Commission  rejected  rules  on  downwards  ex-post  adjustments 
proposed  by  Germany,  on  the  grounds  that  they  infringed  Directive  2003/87/EC.29  The  CFI 
examined the legality of the Commission's finding that Germany had infringed the criteria of the 
directive. In the course of its judgment, the CFI addressed the division of powers between the 
Commission  and  the  Member  States  in  this  area.  It  concluded  that,  where  there  is  no 
Community rule which prescribes clearly and precisely the form and methods which Member 
States must use to ensure the effectiveness of directives, it is for the Commission to prove to 

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Adopted under the 2003 Inter-institutional Agreement on Better Lawmaking. 
http://subsidiarity.cor.europa.eu  
Judgment of 07.11.07– not yet reported. 
Directive 2003/87/EC (O.J. 2003 L 275, pg. 32.) (Emissions Trading). 

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the  required  legal  standard  that  the  instruments  used  by  the  Member  States  are  contrary  to 
Community law. It also concluded that when the EC and its Member States share competence 
in an area, it is for the Commission to prove the extent to which Member States' powers are 
limited. The Court finally concluded that the Commission had not proved to the requisite legal 
standard that the downwards ex-post adjustments were contrary to the objectives of the Treaty 
and annulled the relevant part of the decision. 

In  the  case  of  Minin  v.  Commission30  the  CFI  confirmed  the  reasoning  of  its  rulings  in  the 
Yusuf and Ayadi cases.31 This makes clear that the principle of subsidiarity does not apply with 
regard to economic sanctions against third countries. However, the CFI went on to state that 
even if the principle of subsidiarity did apply, it is "plain that the uniform implementation in 
the Member States of Security Council resolutions can be better achieved at Community level 
than at national level". 

In  the  case  of  Alrosa32  ,  the  CFI  applied  the  principle  of  proportionality  for  the  first  time  to 
decisions  under  Article  9  of  Regulation  1/200333  on  the  implementation  of  the  rules  on 
competition.  That  article  concerns  commitments  made  by  undertakings  and  made  binding  by 
the  Commission.  This  case  centered  on  a  trading  agreement,  notified  to  the  Commission, 
between  two  companies  operating  in  the  market  for  the  production  and  supply  of  rough 
diamonds. One of the companies made commitments to the Commission to stop all purchases 
from  the  other  party,  which  the  Commission  made  binding  in  an  Article  9  decision.  The 
second  company  challenged  the  decision  inter  alia  on  the  grounds  that  it  infringed  the 
principle  of  proportionality,  arguing  that  a  prohibition  of  all  supplies  to  the  other  party  was 
disproportionate.  The  CFI  confirmed  that,  although  Article  9  does  not  refer  explicitly  to 
proportionality, the Commission must comply with this principle as it is a general principle of 
Community  law.  It  concluded  that  the  complete  prohibition  of  all  commercial  relations 
infringed the principle of proportionality and annulled the decision.34 

5. Conclusions 

On the basis of the above analysis, three broad conclusions can be drawn. First, in 2007 each 
of the actors in the system, at national and European level, made a contribution to ensuring 
that  Community  proposals  are  scrutinised  to  ensure  consistency  with  subsidiarity  and 
proportionality.  The  evidence  is  that  this  functions  well.  Second,  the  process  of  scrutiny  is 
being  reinforced  in  a  number  of  ways:  in  the  Commission  through  reinforcement  of  the 
impact  assessment  system;  in  national  parliaments;  and  in  the  Committee  of  the  Regions. 
Third,  the  fact  that  national  parliaments  and  the  EU  institutions  have  raised  similar  issues 
shows a growing degree of consensus on what is meant by subsidiarity and proportionality in 
practice. The Commission will continue to follow these developments closely. 

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34 

Case T-362/04 Judgment of 31.01.07, ECR 2007 Page II-2003 
Case  T-306/01  Yusuf  and  Al  Barakaat  International  Foundation  v.  Council  [2005]  ECR  11-3533, 
paragraphs 112 to 116 and Case T-253/02 Ayadi v. Соипсil [2006] ECR II - 2139, paragraphs 87 to 89. 
T-170/06, Judgment of 11.07.07 not yet reported. 
O.J. 2003 L 1, pg.1. 
It has to be noted that the Commission is appealing this judgement. 

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Annex 1: Number of opinions received from national parliaments 

National chamber 

Opinions received 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

FR Sénat 

DE Bundesrat 

UK House of Lords 

SE Riksdag 

PT 

DK Folketing 

CZ Sénat 

IE (Joint EU Committee) 

NL (Both Houses) 

DE Bundestag 

LT Seimas 

FR Assemblée nationale 

BE Sénat 

UK House of Commons 

HU 

LUX 

EE Riigikogu 

CZ Chambre des députés 

IT Camera dei Deputati 

BE Chambre des Représentants 

PL Sejm 

PL Senat 

FI 

SI 

SK 

Total: 

40 

21 

18 

17 

13 

12 

11 

5 

3 

3 

3 

2 

2 

2 

2 

2 

2 

1 

1 

1 

1 

1 

1 

1 

1 

166 

EN 

10 

   EN