Special Report No 10/2009 #Information provision and promotion measures for agricultural products
Date: 2009-06-11
Institutions: European Court of Auditors
Subjects: EU control, EU financing, agricultural product, information policy, management audit, sales promotion, trade promotion

EUROPEAN COURT 
OF AUDITORS

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INFORMATION PROVISION 
AND PROMOTION MEASURES 
FOR AGRICULTURAL PRODUCTS

EN

 
 
 
 
Special Report No 10  

 2009

INFORMATION PROVISION 
AND PROMOTION MEASURES 
FOR AGRICULTURAL PRODUCTS

(pursuant to Article 248(4), second subparagraph, of the EC Treaty)

EUROPEAN COURT OF AUDITORS

2

EUROPEAN COURT OF AUDITORS
12, rue Alcide De Gasperi
1615 Luxembourg
LUXEMBOURG

Tel.: +352 4398-45410
Fax: +352 4398-46410
E-mail: euraud@eca.europa.eu
Internet: http://www.eca.europa.eu

Special Report No 10  

 2009

More information on the European Union is available on the Internet (http://europa.eu).

Cataloguing data can be found at the end of this publication.

Luxembourg: Publications Office of the European Union, 2009

ISBN 978-92-9207-362-6

doi:10.2865/50551

© European Communities, 2009

Reproduction is authorised provided the source is acknowledged.

Special Report No 10/2009 — Information provision and promotion measures for agricultural products

Printed in Belgium

TABLE OF CONTENTS

3

Paragraph

I–XI 

1–10 

1–4 
5–7 
8–10 

GLOSSARY

EXECUTIVE SUMMARY

INTRODUCTION

GENERAL FRAMEWORK
RECENT INFORMATION PROVISION AND PROMOTION MEASURES
OVERALL IMPRESSION OF THE MANAGEMENT SYSTEM

11–15 

AUDIT SCOPE AND APPROACH

16–52 

16–29 

16–18 
19–23 
24–29 

30–40 

31–33 
34–40 

41–52 

41–43 
44–46 
47–52 

OBSERVATIONS

THE IMPACT OF THE POLICY IS CURRENTLY DIFFICULT TO MEASURE

OBJECTIVES AND PERFORMANCE INDICATORS
LIMITS OF EXPECTED IMPACT OF THE POLICY
DIFFICULTY OF EVALUATING THE IMPACT OF THE VARIOUS PROGRAMMES

 THE DEGREE OF RIGOUR AND SELECTIVITY IN THE APPROVAL OF PROPOSALS FOR PROGRAMMES 
HAS BEEN IMPROVED BUT STILL NEEDS TO BE CONSOLIDATED

PRESELECTION BY MEMBER STATES OF PROPOSALS FOR PROGRAMMES
INCREASED STRICTNESS ON THE PART OF THE COMMISSION

THE CHECKS IN PLACE CONCERNING THE IMPLEMENTATION OF THE PROGRAMMES STILL NEED IMPROVING

SELECTION OF THE IMPLEMENTING BODIES
MONITORING OF EXPENDITURE STEPPED UP BY THE COMMISSION
PERSISTENT WEAKNESSES IN THE CHECKS BY SOME MEMBER STATES

53–57 

CONCLUSIONS AND RECOMMENDATIONS

ANNEX I  —  SUMMARY OF THE REGULATIONS IN FORCE DURING THE PERIOD AUDITED
ANNEX II  — 

 LIST OF THE THEMES, PRODUCTS AND COUNTRIES THAT MAY BE COVERED BY THE ELIGIBLE MEASURES

REPLY OF THE COMMISSION

Special Report No 10/2009 — Information provision and promotion measures for agricultural products

 
 
 
 
4

Special Report No 10/2009 — Information provision and promotion measures for agricultural products

GLOSSARY

5

Countries that can be covered by the measures: If a non-Community country is targeted, 
it must be on the list of eligible third countries or areas to be drawn up by the Commission 
in accordance with Article 4 of Regulation (EC) No 3/2008.

This list is currently shown in Annex II to Regulation (EC) No 501/2008.

Guidelines: For promotion on the internal market, the Commission must adopt guidelines to 
be followed defining the strategy for the proposed programmes for each of the selected sec-
tors or products; these guidelines must provide general indications concerning the objectives 
and targets to be reached, the themes, the types of measures, the duration of programmes 
and the indicative distribution of the Community’s financial contribution. Currently, these 
guidelines are set out in Annex I to Commission Regulation (EC) No 501/2008 (OJ L 147, 
6.6.2008, p. 3) and the indicative budget is shown in Annex III to this regulation.

For  promotion  in  third  countries,  the  Commission  may  adopt  guidelines  for  each  of  the 
selected sectors or products.

Implementing body: After inviting competitive offers by all appropriate means, the pro-
posing organisation shall select the bodies responsible for implementing the programmes 
(Article 11 of Regulation (EC) No 3/2008).

These are typically communication and advertising agencies.

Monitoring group:  The  programmes  are  monitored  by  a  monitoring  group,  comprising 
representatives  of  the  Commission,  the  Member  States  concerned  and  the  proposing 
organisations.

Programme: The various information and promotion measures for agricultural products 
shall be implemented as part of an information and promotion programme (Article 1 of 
Regulation (EC) No 3/2008).

Proposing organisation: This term designates the ‘organisations responsible for imple-
menting information and promotion measures’ defined in Article 6 of Council Regulation 
(EC) No 3/2008 (OJ L 3, 5.1.2008, p. 1). These are the trade and/or inter-trade organisation(s) 
representing the sector(s) concerned in one or more Member States or at Community level 
which draw up proposals for information and promotion programmes.

Themes and products which may be covered by the measures: The themes and products 
which may be covered by a co-financed programme are defined in general in Article 3 of 
Regulation (EC) No 3/2008. Within this framework, the Commission draws up lists of the 
eligible themes and products which are revised every two years. These lists are currently to 
be found in Annexes I and II to Regulation (EC) No 501/2008.

Special Report No 10/2009 — Information provision and promotion measures for agricultural products

6

EXECUTIVE 
REPLY OF THE 
SUMMARY
COMMISSION

V.
The Court also found that the impact of the 
p o l i c y ,   a l t h o u g h   i t   i s   p r o b a b l y   p o s i t i v e ,   i s 
a t   p r e s e n t   d i f f i c u l t   t o   m e a s u r e .   T h e r e   a r e 
no  specific  objectives  based  on  an  explicit 
strategy  which  can  serve  as  a  yardstick  for 
e v a l u a t i n g   t h e   e f f e c t i v e n e s s   o f   t h e   p o l i c y . 
Defining  a  specific  strategy  and  objectives 
therefore seems a precondition for defining 
suitable indicators, which are lacking at the 
m o m e n t .   T h e   i m p a c t   t o   b e   e x p e c t e d   f r o m 
t h e   p r o m o t i o n   s c h e m e   i s   n e v e r t h e l e s s   c i r -
cumscribed from the start by a budget that 
is  relatively  modest  in  relation  to  the  large 
number of products and geographical areas 
to  be  covered  and  the  lack  of  an  adequate 
p r o c e d u r e   f o r   e n s u r i n g   c o m p l e m e n t a r i t y 
with the various national or private promo-
t i o n   m e a s u r e s .   F i n a l l y ,   a l t h o u g h   t h e   i n f o r -
m a t i o n   a v a i l a b l e   e n c o u r a g e s   e x p e c t a t i o n s 
of  a  positive  impact,  the  limitations  of  this 
information make it difficult to measure the 
individual  effectiveness  of  the  co-financed 
programmes,  and  indeed  the  overall  effec-
tiveness of the policy.

VI.
T h e   C o u r t   t h e r e f o r e   r e c o m m e n d s   t h a t   t h e 
policy objectives be specified, whilst at the 
s a m e   t i m e   e n s u r i n g   t h a t   t h e   s t a t e d   a m b i -
tions and the budgets that are committed are 
consistent with each other. These objectives 
should be expressed as ‘SMART’ objectives, 
so that suitable performance indicators can 
b e   d e f i n e d   a n d   m o n i t o r e d .   A   f o r m a l   p r o -
c e d u r e   f o r   c o n s u l t i n g   a l l   t h e   s t a k e h o l d e r s 
s h o u l d   b e   i n t r o d u c e d   f o r   t h e   w h o l e   p r o -
cess, from defining the strategy through to 
i m p l e m e n t i n g   t h e   p r o c e d u r e s   t h a t   e n s u r e 
c o m p l e m e n t a r i t y   w i t h   t h e   v a r i o u s   p r o m o -
tion measures that already exist.

I.
T h e   E u r o p e a n   U n i o n   h a s   i m p l e m e n t e d   a n d 
c o - f i n a n c e d   p r o m o t i o n   m e a s u r e s   f o r   a g r i -
c u l t u r a l   p r o d u c t s   s i n c e   t h e   b e g i n n i n g   o f 
the  1980s.  From  1999  on,  the  various  exist-
i n g   a r r a n g e m e n t s   w e r e   b r o u g h t   t o g e t h e r 
into  a  common  scheme  for  all  the  products 
c o n c e r n e d .   T h e s e   p r o m o t i o n   m e a s u r e s   a r e 
m a i n l y   p r o g r a m m e s   o f   b e t w e e n   o n e   a n d 
t h r e e   y e a r s   c o - f i n a n c e d   u p   t o   a   m a x i m u m 
of 50 % by the European Union and destined 
b o t h   f o r   t h e   i n t e r n a l   m a r k e t   a n d   f o r   t h i r d 
countries.

II.
The Commission is currently making a thor-
o u g h   r e v i e w   o f   t h e   s c h e m e .   I n   p a r t i c u l a r , 
this could result in a significant increase in 
the information and promotion budget.

III.
T h e   C o u r t ’ s   a u d i t   c o n c e r n e d   t h e   e f f e c t i v e -
ness  of  the  information  provision  and  pro-
motion  measures  and  the  regularity  of  the 
expenditure earmarked for this purpose. The 
audit was carried out at the Commission and 
in the three Member States principally con-
cerned by the scheme.

IV.
The Court found that the Commission had for 
s o m e   y e a r s   b e e n   m a k i n g   i m p r o v e m e n t s   t o 
the management and control arrangements 
f o r   e x p e n d i t u r e   c o n n e c t e d   w i t h   i n f o r m a -
tion  provision  and  promotion  measures  for 
agricultural products. Through this process, 
positive results have already been obtained 
in some areas but it still needs to be further 
consolidated and expanded.

Special Report No 10/2009 — Information provision and promotion measures for agricultural products

7

EXECUTIVE 
REPLY OF THE 
SUMMARY
COMMISSION

X.
T h e   C o u r t   r e c o m m e n d s   t h a t   c h e c k s   o n   t h e 
selection of implementing bodies should be 
stepped up and that the control weaknesses 
i d e n t i f i e d   i n   o n e   M e m b e r   S t a t e   s h o u l d   b e 
followed up so as to ensure speedy improve-
ment in these shortcomings.

XI.
W h e n   c o n s i d e r i n g   t h e   p o t e n t i a l   i m p a c t   o f 
t h e   r e c o m m e n d a t i o n s   m a d e   i n   t h i s   r e p o r t , 
the  size  of  the  budget  devoted  to  the  pro-
motion  arrangements  needs  to  be  borne  in 
mind. The Commission is currently making a 
thorough review of this scheme. This could 
i n   p a r t i c u l a r   l e a d   t o   a   p r o p o s a l   t o   s i g n i f i -
c a n t l y   i n c r e a s e   t h e   i n f o r m a t i o n   a n d   p r o -
m o t i o n   b u d g e t .   F o r   t h a t   r e a s o n ,   t h e   C o u r t 
r e c o m m e n d s   t h a t   t h e s e   i m p r o v e m e n t s   b e 
made as soon as possible.

VII.
In  the  absence  of  a  useful  measure  of  their 
impact, the anticipated effectiveness of the 
m e a s u r e s   r e s t s   i n   l a r g e   p a r t   o n   a   s u i t a b l e 
selection of programmes proposed. Although 
control by the Member States remains some-
times  too  limited  in  this  area,  the  Commis-
sion has become much more demanding and 
s e l e c t i v e .   T h i s   i m p r o v e m e n t   n e v e r t h e l e s s 
needs to be confirmed.

VIII.
T h e   C o u r t   t h e r e f o r e   r e c o m m e n d s   t h a t   t h e 
improvements  currently  being  made  to  the 
C o m m i s s i o n ’ s   s e l e c t i o n   p r o c e d u r e   s h o u l d 
b e   c o n t i n u e d ,   e s p e c i a l l y   a s   r e g a r d s   t h e 
requirement for information on the expected 
i m p a c t   o f   t h e   p r o g r a m m e   a n d   t h e   m a n n e r 
i n   w h i c h   i t   w i l l   b e   m e a s u r e d ,   a n d   t h a t   t h e 
Member States should continue to increase 
t h e i r   s e l e c t i v i t y ,   a m o n g s t   o t h e r   t h i n g s   b y 
verifying information as to the relevance of 
the proposals.

IX.
T h e   c h e c k s   m a d e   o n   t h e   s e l e c t i o n   o f   t h e 
implementing bodies, which have a key role 
to  play  in  programme  implementation,  are 
t o o   l i m i t e d .   T h e   C o m m i s s i o n ’ s   s u b s e q u e n t 
m o n i t o r i n g   o f   e x p e n d i t u r e ,   o n   t h e   o t h e r 
h a n d ,   h a s   b e e n   s t e p p e d   u p .   B y   c o n t r a s t , 
s i g n i f i c a n t   c o n t r o l   w e a k n e s s e s ,   w h i c h   h a d 
b e e n   r e p e a t e d l y   i d e n t i f i e d   o v e r   t h e   l a s t 
f e w   y e a r s ,   s t i l l   p e r s i s t   i n   S p a i n   a n d   I t a l y . 
A l t h o u g h   a c t i o n   h a s   f i n a l l y   b e e n   t a k e n   i n 
t h e s e   t w o   M e m b e r   S t a t e s   i n   a n   a t t e m p t   t o 
c o r r e c t   t h e s e   s h o r t c o m i n g s ,   a t   t h e   t i m e   o f 
the audit it was still too early to say whether 
t h e s e   c h a n g e s   h a d   b e e n   e f f e c t i v e ,   s o   t h i s 
will have to be confirmed in the future.

Special Report No 10/2009 — Information provision and promotion measures for agricultural products

INTRODUCTION

8

1. 

2. 

3. 

4. 

GENERAL FRAMEWORK

The European Union has implemented and co-financed promotion meas-
ures for agricultural products since the beginning of the 1980s. Until 
1999 these measures were handled sector by sector, on the basis of a 
range of regulatory provisions specific to the various common market 
organisations (CMOs).

In 1999 these regulations were harmonised and replaced by a scheme 
combined in two Council regulations 1 which governed promotion in 
third  countries  and  promotion  on  the  internal  market  respectively. 
T h e s e   t w o   r e g u l a t i o n s   w e r e   t h e n   a m a l g a m a t e d   a t   t h e   b e g i n n i n g 
o f   2 0 0 8   i n t o   C o u n c i l   R e g u l a t i o n   ( E C )   N o   3 / 2 0 0 8 2,   w h i c h   i s   a   s i n g l e 
regulation  covering  all  policies  for  promoting  agricultural  products 
w i t h o u t   m o d i f i y i n g   s i g n i f i c a n t l y   t h e   c o n t e n t   o f   t h e   t w o   p r e v i o u s 
regulations.

According to the regulations now in force, the measures referred to must 
c o v e r   a   p e r i o d   o f   b e t w e e n   o n e   a n d   t h r e e   y e a r s   a n d   m a y   c o n s i s t   o f 
public relations, promotional or publicity actions, which must high-
light  the  advantages  of  EU  products,  especially  in  terms  of  quality, 
hygiene,  food  safety,  nutrition,  labelling,  animal  welfare  or  respect 
f o r   t h e   e n v i r o n m e n t .   A l s o   c o v e r e d   a r e   p a r t i c i p a t i n g   i n   e v e n t s   a n d 
f a i r s ,   i n f o r m a t i o n   c a m p a i g n s   o n   t h e   E U   s y s t e m   o f   p r o t e c t e d   d e s i g -
n a t i o n s   o f   o r i g i n   ( P D O ) ,   p r o t e c t e d   g e o g r a p h i c a l   i n d i c a t i o n s   ( P G I ) , 
t r a d i t i o n a l   s p e c i a l i t y   g u a r a n t e e d   ( T S G ) ,   q u a l i t y   w i n e s   p r o d u c e d   i n 
specified  regions  (‘quality  wines  psr’),  or  information  on  EU  quality 
and labelling systems and on organic farming. Regarding third coun-
tries, such measures may also include studies to find new markets.

Subject to specific exceptions, these programmes are financed up to a 
maximum of 50 % by the European Union, the remainder being paid 
b y   t h e   t r a d e   a n d / o r   i n t e r - t r a d e   o r g a n i s a t i o n s  t h a t   p r o p o s e d   t h e m 
(minimum 20 %) and by the Member States concerned.

1  Council Regulation (EC) 

No 2702/1999 of 

14 December 1999 on measures 

to provide information on, and 

to promote, agricultural products 

in third countries (OJ L 327, 

21.12.1999, p. 7) and Council 

Regulation (EC) No 2826/2000 

of 19 December 2000 on 

information and promotion 

actions for agricultural products 

on the internal market (OJ L 328, 

23.12.2000, p. 2).

2  Council Regulation (EC) 

No 3/2008 of 17 December 2007 

on information provision 

and promotion measures for 

agricultural products on the 

internal market and in third 

countries (OJ L 3, 5.1.2008, p. 1).
See Annex I for the sequence 

of the various implementing 

regulations in force during the 

period of the audit.

Special Report No 10/2009 — Information provision and promotion measures for agricultural products

 
 
 
 
9

RECENT INFORMATION PROVISION 
AND PROMOTION MEASURES

5. 

The annual budget appropriations for information provision and promo-
tion measures for agricultural products have risen strongly over the 
last  few  years,  from  17  million  euro  in  2002  to  50  million  euro  since 
2007 (see Graph 1).

6.  Most of the cost relates to the EU’s co-financing of programmes. Around 
200 programmes were running during the period 2007–08, involving 
23 different Member States, sometimes as part of ‘multi-country’ pro-
grammes co-financed by several Member States at the same time.

7. 

In response, amongst other things, to a request from MEPs, the Commis-
sion is currently making a thorough review of this scheme, mainly as 
regards third countries. This could in particular lead to a significant 
increase in the information and promotion budget, as well as giving 
priority to programmes targeting third countries.

G R A P H   1

A N N UA L   A P P R O P R I AT I O N   ( PAYM E N T S )   O N   I N F O R M AT I O N   P R O V I S I O N 
A N D   P R O M OT I O N   M E A S U R E S

o
r
u
e

f
o

s
n
o

i
l
l
i

M

60

50

40

30

20

10

0

2002

2003

2004

2005

2006

2007

2008

2009

Co-financed programmes

Direct payments

Source: General budgets of the European Union 2002–09.

Special Report No 10/2009 — Information provision and promotion measures for agricultural products

 
 
 
 
 
10

8. 

9. 

10. 

OVERALL IMPRESSION OF THE MANAGEMENT SYSTEM

The programmes are usually submitted by ‘proposing organisations’. 
Member  States,  having  assessed  proposals  for  programmes  for  con-
f o r m i t y   w i t h   t h e   r e g u l a t i o n ,   s u i t a b i l i t y   a n d   v a l u e   f o r   m o n e y ,   s e n d 
t h e   C o m m i s s i o n   t h o s e   w h i c h   t h e y   h a v e   a g r e e d   t o   c o - f i n a n c e .   T h e 
Commission, after examining the proposals and possibly requesting 
amendments, selects the programmes that are to be co-financed.

These programmes are then carried out by the ‘implementing bodies’. 
These  bodies  must  be  selected  by  the  proposing  organisation  after 
‘inviting  competitive  offers  by  all  appropriate  means’.  The  Member 
State  is  responsible  for  monitoring  the  conditions  under  which  the 
programmes  are  selected  and  for  informing  the  Commission  about 
this procedure.

Under the terms of shared management, the Member State is also respon-
sible for monitoring the proper implementation of the programmes, 
payments  to  beneficiaries  and  related  checks.  A  monitoring  group, 
presided over by the Member State concerned and including in prac-
tice a representative of the Commission, meets regularly to monitor 
the progress of the various programmes.

Source: Association 5 al día.

Special Report No 10/2009 — Information provision and promotion measures for agricultural products

 
 
 
AUDIT SCOPE AND APPROACH

11

11. 

12. 

The main reason behind this audit is that, although the budget devoted 
t o   i n f o r m a t i o n   p r o v i s i o n   a n d   p r o m o t i o n   m e a s u r e s   f o r   a g r i c u l t u r a l 
p r o d u c t s   i s   s t i l l   r e l a t i v e l y   m o d e s t ,   i t   h a s   b e e n   c o n s t a n t l y   g r o w i n g 
over the last few years. Moreover, it could be further enlarged in the 
future, particularly as promotion measures are included in the ‘Green 
Box’  for  WTO  negotiations.  Indeed,  a  request  along  these  lines  was 
made by the European Parliament at the end of 2007 3.

3  See the explanatory 

memorandum of the ‘Report 

on the proposal for a Council 

Regulation on the information 

provision and promotion measures 

for agricultural products on the 

internal market and in third 

countries (COM(2007) 268 — 

C6-0203/2007 — 2007/0095(CNS))’.

The Court’s audit concerned the effectiveness of the information provi-
sion and promotion measures and the regularity of the expenditure. 
The audit questions were as follows:

(a) 

Does  the  system  of  management  and  monitoring  in  place  allow 
the  Commission  to  demonstrate  or  measure  the  effectiveness  of 
the measures?

(b) 

Does  the  system  of  management  and  monitoring  in  place  make 
it  possible  to  obtain  reasonable  assurance  that  programmes  are 
s e l e c t e d   i n   a   r e g u l a r ,   t r a n s p a r e n t   m a n n e r   a n d   o n   t h e   b a s i s   o f 
relevant criteria and information?

(c) 

Does the system of management and monitoring in place make it 
possible  to  obtain  reasonable  assurance  as  to  the  legality/regu-
larity of the expenditure?

13. 

The audit was carried out between June and October 2008 at the Com-
mission  and  in  Spain,  France  and  Italy.  As  shown  in  Graph  2,  these 
three countries are three of the five main Member States concerned 
by  the  scheme.  They  represent  nearly  45  %  of  the  expenditure  and 
Italy is the largest beneficiary.

Special Report No 10/2009 — Information provision and promotion measures for agricultural products

 
 
 
12

14. 

15. 

The  audit  mainly  concerned  the  period  from  2006  to  the  end  of  the 
first half of 2008. Since the promotion programmes are multiannual, 
reviewing  the  programmes  selected  in  this  period  sometimes  led  to 
an examination of earlier documentation.

The audit approach consisted of assessing the procedures established 
by the Commission and Member States for implementing the policy. 
T h e   a u d i t   w o r k   w a s   b a s e d   m a i n l y   o n   a n a l y s i s ,   d o c u m e n t a t i o n   a n d 
evaluation  of  the  procedures  and  systems  implemented  during  the 
main stages by:

 —

 —

the Commission (selection of programmes, monitoring and check-
ing of expenditure, monitoring of implementation and impact of 
the programmes); and

t h e   M e m b e r   S t a t e s   ( c a l l s   f o r   p r o p o s a l s ,   p r e s e l e c t i o n   o f   p r o -
grammes, checking the selection of implementing bodies, manage-
ment  and  monitoring  of  the  implementation  of  the  programmes 
and payments made).

The auditors’ work also included a visit to at least one proposing organi-
sation  which  was  a  beneficiary  of  the  policy  in  each  Member  State, 
and also to its implementing body.

G R A P H   2

M A I N   B E N E F I C I A RY   M E M B E R   S TAT E S   ( 2007 – 08 )

Other

Germany

Greece

Source: European Commission.

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Spain

France

Italy

 
 
 
 
OBSERVATIONS

13

THE IMPACT OF THE POLICY IS CURRENTLY 
DIFFICULT TO MEASURE

OBJECTIVES AND PERFORMANCE INDICATORS

16. 

17. 

18. 

The stated objective of the information provision and promotion meas-
u r e s   f o r   a g r i c u l t u r a l   p r o d u c t s   i s   t o   p r o m o t e   E u r o p e a n   a g r i c u l t u r a l 
p r o d u c t s .   H o w e v e r ,   t h e   c u r r e n t   a r r a n g e m e n t s   r e s u l t   f r o m   m e r g i n g 
t h e   e a r l i e r   s c h e m e s   f r o m   t h e   v a r i o u s   C M O s   w i t h o u t   s e t t i n g   o u t   a n 
overall strategy or defining ‘SMART’ 4 objectives.

In  the  absence  of  ‘SMART’  objectives  resulting  from  a  clear  strategy 
and by which the effectiveness of the policy could be evaluated, the 
indicators  monitored  and  circulated  by  the  Commission  (see  Box  1) 
are  simply  ‘participation’  statistics  and  do  not  measure  the  results 
or impact of the policy.

4  Article 27(3) of Council 

Regulation (EC, Euratom) 

No 1605/2002 of 25 June 2002 

on the Financial Regulation 

applicable to the general budget 

of the European Communities 

(OJ L 248, 16.9.2002, p. 1) provides 

that: ‘Specific, measurable, 

achievable, relevant and timed 

[SMART] objectives shall be set for 

all sectors of activity covered by 

the budget’.

Statistics such as these are not satisfactory as they are, but defining 
more suitable indicators seems difficult, pending a better definition 
of the objectives.

B O X   1

S TAT I S T I C S   M O N I TO R E D   BY  T H E   CO M M I S S I O N

• 

• 

• 

Number of products involved.

Number of countries or geographic areas covered.

Number of programme proposals submitted to the Commission and acceptance rate.

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LIMITS OF EXPECTED IMPACT OF THE POLICY

Despite strong growth since 2002, the Community budget devoted to 
information provision and promotion measures is still relatively small 
in relation to the large number of products, geographical areas and 
s u b j e c t s   t o   b e   c o v e r e d .   I n   f a c t   t h e   C o m m i s s i o n ’ s   g u i d e l i n e s   c o v e r 
most  of  agricultural  production  and  a  list  of  countries  correspond-
i n g   t o   m o s t   o f   t h e   w o r l d   m a r k e t   ( s e e   A n n e x   I I ) .   I n   a d d i t i o n ,   t h e r e 
are  many  PDOs,  PGIs  and  other  quality  labels  which  are  suitable  for 
promotion measures. Given these objectives, a comparison between 
the promotion expenditure of other national or private stakeholders 
confirms that the sums committed are rather modest (see Box 2).

Taking into account this limited budget, the measures being taken can-
not on their own have a significant impact on the objectives.

19. 

20. 

B O X   2

P U T T I N G  T H E   E U ’S   B U D G E T   F O R   I N F O R M AT I O N   A N D   P R O M OT I O N 
I N TO   P E R S P E C T I V E

EU’s budget for information and promotion

• 

• 

• 

2002: 17 million euro.

2005: 32 million euro.

2008: 50 million euro.

Examples of other promotion budgets

• 

• 

• 

The Swiss federal budget alone provided 36 million euro of assistance to promote sales of various 
Swiss agricultural products in 2008 and the same sort of expenditure also exists in the cantons.

The promotion budget of the Interprofessional Council of Bordeaux wine
du Vin de Bordeaux, CIVB) was more than 21 million euro in 2008.

 (Conseil Interprofessionnel 

The Italian authorities plan expenditure in 2013 of more than 100 million euro just for the promo-
tion of Italian wine.

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21. 

22. 

To achieve these objectives, these programmes ought at least, in accord-
a n c e   w i t h   t h e   r e c i t a l s   o f   R e g u l a t i o n   ( E C )   N o   3 / 2 0 0 8   ( s e e   Box  3) ,   t o 
b e   p a r t   o f   t h e   w i d e r   f r a m e w o r k   o f   n a t i o n a l   a n d   p r i v a t e   m e a s u r e s , 
particularly through the notion of complementarity or the multiplier 
effect.

There is, however, no instrument for guaranteeing or measuring, on the 
one hand, consistency or complementarity with the various national 
and  private  promotion  policies,  or,  on  the  other  hand,  a  ‘multiplier 
e f f e c t   o n   n a t i o n a l   a n d   p r i v a t e   i n i t i a t i v e s ’ .   M o r e o v e r ,   t h e   C o m m i s -
sion does not yet have full or reliable information about the various 
budgets or similar measures implemented in each Member State.

Source: Fancy Food Show (New York, July 2006).

B O X   3

E X T R AC T S   F R O M  T H E   S E CO N D   A N D   F O U R T H   R E C I TA L S 
O F   R E G U L AT I O N   ( E C )   N O  3/2008

• 

• 

• 

‘[…] to develop an overall, coherent information and promotion policy […]

‘Such a policy usefully supplements and reinforces the schemes run by Member States […].’

‘Such action, by helping to open up new markets in third countries, is also likely to have a multiplier 
effect on national and private initiatives.’

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23. 

24. 

25. 

The available evaluation reports 5, while recognising that Community 
c o - f i n a n c i n g   m a y   w e l l   h a v e   g e n e r a t e d   s o m e   p o s i t i v e   e f f e c t s ,   a l s o 
underlined the absence of a coordination mechanism and the limited 
synergies or aspects of complementarity (see Box 4).

DIFFICULTY OF EVALUATING THE IMPACT 
OF THE VARIOUS PROGRAMMES

The Court’s auditors examined a sample of 30 programmes completed in 
the period 2006–07 in order to establish to what extent the available 
activity  reports  provided  for  in  the  regulations 6  allow  the  Commis-
sion to demonstrate or measure the individual impact of the various 
programmes.

This examination showed that the Commission does not have a formal 
procedure  for  analysing  these  reports.  The  cases  examined  did  not 
always show signs of such analysis and some of them did not contain 
all the reports or other requisite items.

5  The Commission ordered seven 

external evaluations during 

the period 2006–07 on various 

subjects or geographic areas. 

These evaluations were based 

inter alia on examining samples 

of programmes implemented with 

effect from 2002 or 2003.

6  Articles 13 and 14 of 

Commission Regulation (EC) 

No 1071/2005 (OJ L 179, 

11.7.2005, p. 1) and Articles 14 

and 15 of Commission Regulation 

(EC) No 1346/2005 (OJ L 212, 

17.8.2005, p. 16) provide for the 

preparation by beneficiaries of 

reports containing inter alia ‘a 

summary of the work carried out 

and an evaluation of the results 

obtained […]’.

B O X   4

E X T R AC T S   F R O M   E VA LUAT I O N   R E P O R T S   O N  T H E   L I M I T S 
O F   CO O R D I N AT I O N   A N D   S YN E R G I E S

• 

• 

• 

‘The regulations do not provide clear and explicit incentives for promoting synergies between co-
financed programmes, whether within a single country or between countries. The same was observed 
of synergies between co-financed programmes and MS or private sector programmes.’

‘The regulations and programme documents do not refer to how synergies can be brought about 
and there is no evidence that any of the campaigns have promoted cooperation at EU level. […] 
No synergies or specific coordination mechanisms have been identified between co-financed pro-
grammes […].’

‘Only  the  national  authorities  and  proposing  organisations  are  able  to  ensure  complementarity 
between European, national and private promotion initiatives. Whilst redundant aspects and contra-
dictions had been avoided, few synergies could be identified […] The diversity of the programmes 
being supported does not promote complementarity between European programmes.’

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26. 

In  most  cases 7  the  ‘summary  of  the  work  carried  out’  is  sufficiently 
detailed  to  understand  the  way  in  which  the  money  was  spent  and 
what measures were carried out, and to ensure that these were con-
sistent with the promotion objective. By contrast, although the audi-
tors could see an improvement, the quality of available information 
on ‘the evaluation of the results obtained’ is still less than satisfactory 
(see Box 5):

(a) 

A l m o s t   a l l   t h e   r e p o r t s   c o n t a i n   a   q u a l i t a t i v e   a s s e s s m e n t   o f   t h e 
impact but, in most cases, it is not documented or even properly 
argued  and  therefore  it  is  not  actually  possible  to  evaluate  the 
impact of the measures.

7  Six examples were found in the 

sample that was examined where 

the auditors considered that this 

was not the case.

B O X   5

EXAMPLE OF A NON-DOCUMENTED QUALITATIVE APPRAISAL 
IN ONE OF THE ACTIVITY REPORTS EXAMINED

The ‘Evaluation of the project’s impact’ section of one report that was examined stated ‘Even though 
we do not have completely exact indicators, we can assure you with absolute confidence and in all 
conscience that the three-year campaign conducted by the XX company has achieved excellent results, 
which are on a par with or even better than those forecast in the approved programme […]’.

EXAMPLE OF AN INDICATOR NOT DIRECTLY CORRESPONDING 
TO THE AIMS SET BY THE PROGRAMME

One programme had as its objective to inform consumers about the specific qualities of PDO dairy 
products. Although the implementation report states the number of contacts achieved by the various 
measures, it does not contain any analysis of the impact of these contacts on the level of information 
to consumers.

Conversely,  an  analysis  of  this  kind  did  form  part  of  the  implementation  report  for  a  ‘Poultrymeat’ 
programme that was examined.

EXAMPLE OF INDICATORS ANNOUNCED BY THE PROGRAMMES BUT NOT FOLLOWED UP

One ‘Fruit and vegetables’ programme set specific objectives (‘to achieve average fruit and vegetable 
consumption of 6,2 portions per day and per person’; ‘to achieve an average level of consumption of 
four apples per week per person’; ‘kiwis: to achieve a 60 % market penetration rate’) and even stated 
‘The progress made in achieving these objectives will be monitored annually’.

But  the  reports  that  were  examined  did  not  contain  any  indicator  corresponding  to  this  planned 
monitoring.

One  ‘Wine’  programme  was  forecasting  10  million  contacts,  but  the  corresponding  reports  did  not 
contain any monitoring of this indicator.

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(b) 

Most reports contain quantitative indicators but these are mostly 
of  the  type  ‘number  of  contacts  generated’.  Although  this  type 
o f   i n d i c a t o r   c a n   c o n t r i b u t e   t o   t h e   e v a l u a t i o n   o f   t h e   i m p a c t   o f 
t h e   m e a s u r e s ,   i t   i s   o f t e n   i n s u f f i c i e n t   w h e n   i t   c o m e s   t o   t h e   r e a l 
objectives of programmes designed to increase sales or improve 
consumer knowledge.

(c) 

Certain reports
announced when the programme was approved.

8 do not contain the impact indicators which were 

8  Three examples were found in 

the sample that was examined.

27. 

28. 

The Court’s observation concerning the difficulty of evaluating the impact 
of the various programmes on the basis of the information available 
is in part borne out by the various evaluations that have already been 
mentioned.

The fact is that, whilst most of the evaluations conclude that the vari-
o u s   m e a s u r e s   d o   h a v e   a   p o s i t i v e   i m p a c t   ( s e e   p a r a g r a p h   2 9 ) ,   t h e y 
emphasise  that  effectiveness  is  in  general  not  measured  or  is  hard 
to  measure  and  that  it  is,  for  example,  difficult  to  establish  a  direct 
link  between  the  programmes  and  any  changes  in  sales  or  demand 
that  may  be  observed.  The  difficulty  of  measuring  the  efficiency  of 
programmes (cost–impact ratio) is also pointed out (see Box 6).

B O X   6

E X T R AC T S   F R O M   E VA LUAT I O N   R E P O R T S   I L LU S T R AT I N G   L I M I TAT I O N S 
O N   M E A S U R I N G   E F F E C T I V E N E S S

• 

• 

• 

‘Currently no conclusion is possible on cost 
versus impacts of measures or actions for the majority of 
programmes. [...] no causality link between I & P programmes and evolution of Community demand 
for F & V can be provided, and it is not easy to establish the link with demand for F & V in general, 
owing to the influence on demand of many external factors.’

‘The methods used for assessing the cost–output ratio are often subjective (unreliable and probably 
biased) and lack rigour […] the absence of detailed quantitative data during implementation impedes 
sound judgment on the efficiency of specific actions or of the cost versus impact relationship of the 
programmes […] no in-depth evaluations providing information on the TGs reached, the results or 
the impact of the programmes.’

‘There is an overall lack of measurement of the effectiveness of the measures in terms of improvement 
of the image of the Community products and themes and of the demand for organic products. More-
over, there is a lack of norms against which the trends in these respects could be benchmarked.’

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29. 

Nevertheless, despite these difficulties, these evaluations conclude that 
the  various  measures  do  have  a  positive  impact,  chiefly  in  terms  of 
image  or  the  development  of  professional  contacts  for  third  coun-
tries. In general, the cost-effectiveness ratio of the various measures 
is  even  favourably  viewed  in  comparison  with  the  standards  of  the 
sector, in particular as regards the internal market.

THE DEGREE OF RIGOUR AND SELECTIVITY 
IN THE APPROVAL OF PROPOSALS FOR PROGRAMMES 
HAS BEEN IMPROVED BUT STILL NEEDS 
TO BE CONSOLIDATED

30.  Where there are no objectives and indicators enabling the impact of the 
policy  to  be  ascertained  and  measured,  the  scheme’s  effectiveness 
d e p e n d s   t o   a   l a r g e   e x t e n t   o n   r e l e v a n t   p r o g r a m m e s   b e i n g   s e l e c t e d 
for co-financing.

PRESELECTION BY MEMBER STATES OF PROPOSALS 
FOR PROGRAMMES

31. 

Under the regulation, the Member States evaluate the proposals for 
programmes for their conformity with the rules, their suitability and 
their ‘value for money’ and forward to the Commission the proposals 
that they agree to co-finance.

B O X   7

P R O P O R T I O N   O F   P R O P O S A L S  VA L I DAT E D   BY  T H E   M E M B E R   S TAT E S 
T H AT  W E R E   CO N S I D E R E D   I N E L I G I B L E   BY  T H E   CO M M I S S I O N

Out of the sample of 30 proposals forwarded by the Member States in 2007 examined at the Commis-
sion, 10 had been rejected by the Commission on the grounds of ineligibility.

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32. 

33. 

Until recently, however, many Member States were forwarding the bulk of 
the proposals they had received after having carried out only limited 
preselection work. This lack of selectivity was reflected, for example, 
i n   v e r y   f e w   p r o p o s a l s   n o t   b e i n g   f o r w a r d e d   t o   t h e   C o m m i s s i o n ,   o r 
a g a i n   i n   t h e   l a r g e   n u m b e r   o f   p r o p o s a l s   f o r w a r d e d   b y   t h e   M e m b e r 
States that were in the end rejected by the Commission because they 
were  ineligible  (see  Box  7).  Furthermore,  in  making  their  appraisal, 
the Member States sometimes use the data supplied by the proposing 
organisations without these data having been adequately verified.

To encourage the Member States to be more selective, the Commission 
has gradually been laying down criteria to be applied when evaluating 
proposals for programmes. These specify the level of detail expected 
in  the  proposals  and  the  type  of  checks  to  be  carried  out,  and  indi-
cate a number of success factors that have been culled in particular 
from the conclusions of the various evaluation exercises mentioned 
above.  This  process  is  still  under  way,  however,  and  therefore  only 
time will tell how effective it actually is.

B O X   8

A P P R O V E D   P R O G R A M M E S  T H AT   CO U L D   N OT   B E   I M P L E M E N T E D

Of the 81 programmes closed during the 2006–07 period (approved between 2003 and 2006), there were 
17 for which the rate of implementation was less than 70 % of the original budget, including 11 where 
the rate was less than 40 %.

In Italy one programme had been discontinued after one year, with less than 20 % of the budget having 
been spent, because from the very outset the planned measures had come up against legal problems 
in the target third countries.

In Spain, the implementation rate for the largest programme ever approved had been only 34 % of 
the initial budget because the association, for lack of the necessary resources, suffered a financing 
problem.

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34. 

35. 

INCREASED STRICTNESS ON THE PART OF THE COMMISSION

An ex post review by the auditors shows that a significant number of the 
programmes approved by the Commission during the period 2003–05 
were  not  carried  through  to  the  end,  calling  into  question  whether 
it  was  appropriate  to  have  selected  them.  The  audit  in  the  Member 
S t a t e s   b r o u g h t   t o   l i g h t   s e v e r a l   c a s e s   w h e r e   t h e   r e a s o n s   f o r   t h e s e 
failures could most probably have been anticipated from the outset 
if the Member States or the Commission had been more thorough in 
their scrutiny of the proposals (see Box 8).

The Court nevertheless finds that the Commission’s level of selectivity 
in  approving  proposals  has  improved  markedly  since  the  early  days 
o f   t h i s   s c h e m e :   t h e   r a t e   o f   a p p r o v a l   h a s   t h u s   f a l l e n   f r o m   1 0 0   %   i n 
2001–02 to less than 50 % in the period 2006–08, whilst the number 
of proposals received has increased (see Graph 3).

G R A P H   3

N U M B E R   O F   P R O G R A M M E S   A P P R O V E D / R E J E C T E D   BY  T H E   CO M M I S S I O N

150

125

100

75

50

25

0

2001

2002

2003

2004

2005

2006

2007

2008

Approved

Rejected

Source: European Commission.

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36. 

37. 

Further to this analysis, the Court’s auditors selected a sample of 30 pro-
p o s a l s   a p p r o v e d   ( 1 5 )   o r   r e j e c t e d   ( 1 5 )   o v e r   t h e   p e r i o d   2 0 0 6 – 0 7   i n 
o r d e r   t o   r e v i e w   t h e   a v a i l a b l e   d o c u m e n t a t i o n   o n   t h e   c h o i c e s   t h a t 
were made.

9  One or the other of these two 

points was thus found in three 

cases in the sample that was 

examined.

The auditors’ examination of this sample first of all showed that, since 
2006, the selection process had been carried out by means of a proper, 
formal  procedure  that  on  the  whole  was  well  documented.  Certain 
improvements still need to be made, however:

(a) 

T h e   p r o c e d u r e   b e i n g   u s e d   d o e s   n o t   e n a b l e   a l l   t h e   p r o p o s a l s 
received to be compared one with another on the basis of a uni-
form set of objective criteria. The Commission thus does not itself 
apply  a  principle  which  it  requires  the  Member  States  to  follow 
when making their preselection.

(b) 

T h e   e x a m i n a t i o n   a l s o   s h o w e d   t h a t ,   w h e n   c a s e   f i l e s   a r e   b e i n g 
appraised,  there  is  not  always  a  sufficiently  formal  approach  to 
following up the problems that are identified and any replies that 
are received. Some proposals may thus be rejected without a suf-
ficiently  formal  record  being  made  of  the  unsatisfactory  nature 
o f   t h e   r e p l i e s   r e c e i v e d ,   a n d   o t h e r   p r o p o s a l s   m a y   b e   a p p r o v e d 
without the replies received being documented 9, thus laying the 
final choice open to risk. New instructions directly addressing this 
point were, however, issued in the course of the audit.

B O X   9

E X T R AC T S   O F   O B J E C T I V E S   F R O M  T H E   P R O G R A M M E S   E X A M I N E D

An ‘Organic farming’ programme set out the following general objectives:

‘[…] to inform and interest the general public and, above all, the casual consumer. The main objectives 
are: to increase the level of knowledge about the specific characteristics and benefits; to help increase 
consumption of organic products; to make the logos better known.’

A ‘Dairy products’ programme set objectives such as ‘to change eating habits’ and ‘to introduce more 
dairy products into young people’s diets’.

In both cases, no quantitative objectives were specified nor was there any stocktaking of the situation 
at the outset.

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38. 

39. 

At the same time, the Commission became considerably more demand-
ing  concerning  the  details  that  had  to  be  provided  in  the  proposals 
for programmes. Nevertheless, there are still weaknesses as regards 
the  information  that  is  required  on  the  expected  impact  of  the  pro-
grammes and the manner in which it will be measured. Indeed, most 
o f   t h e   a p p r o v e d   p r o p o s a l s   t h a t   w e r e   e x a m i n e d   d i d   n o t   l a y   d o w n 
satisfactory  objectives  and/or  indicators  for  measuring  programme 
i m p a c t   ( s e e   B o x   9 ) .   T h i s   o b s e r v a t i o n   o n   t h e   p r o g r a m m e s   i s   c l o s e l y 
a k i n   t o   t h e   o b s e r v a t i o n   a l r e a d y   m a d e   a s   r e g a r d s   p o l i c y ,   f o r   w h i c h 
i t   w a s   f o u n d   ( s e e   p a r a g r a p h s   1 6   t o   1 8 )   t h a t   t h e r e   w e r e   n o   s p e c i f i c 
objectives or suitable indicators.

The fact is that, just as for the policy as a whole, the effectiveness of each 
of  the  programmes  is  difficult  to  measure  if  precise  objectives  and 
indicators have not been defined in advance in the light of a clearly 
established initial situation.

40.  Moreover, some of the evaluation reports mentioned above have already 
p o i n t e d   o u t   s h o r t c o m i n g s   r e l a t i n g   t o   t h e   l a c k   o f   a   s t r a t e g y   a n d 
s p e c i f i c ,   m e a s u r a b l e   o b j e c t i v e s   f o r   t h e   v a r i o u s   p r o g r a m m e s   ( s e e 
Box 10).

B O X   1 0

E X T R AC T S   F R O M   E VA LUAT I O N   R E P O R T S   CO N C E R N I N G   S H O R TCO M I N G S 
I N   P R O G R A M M E S   I N  T E R M S   O F   D E F I N I N G   A   S T R AT E G Y 
A N D   S P E C I F I C ,  M E A S U R A B L E   O B J E C T I V E S

• 

• 

‘The programmes of the sample are in line with the regulations. […] They have however some design 
shortcomings in the sense that objectives are rarely quantified and are not structured hierarchically; 
furthermore the underlying strategies are poorly described.’

‘[…] formulation of the programmes’ objectives by the proposing organisation appears in many cases 
like a formal exercise rather than a real attempt to design an appropriate strategy.’

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THE CHECKS IN PLACE CONCERNING 
THE IMPLEMENTATION OF THE PROGRAMMES 
STILL NEED IMPROVING

SELECTION OF THE IMPLEMENTING BODIES

41. 

42. 

The implementing body plays a key role in carrying out the programme, 
s o   t h a t   a n y   w e a k n e s s   i n   c h e c k i n g   t h e   w a y   i t   i s   s e l e c t e d   i s   l i k e l y   t o 
have  an  effect  on  whether  the  programme  is  regular,  effective  and 
economic.  This  risk  is  all  the  greater  when  the  proposing  organisa-
tions’ minimum co-financing share is low and so the direct financial 
s t a k e s   i n v o l v e d   f o r   t h e   b e n e f i c i a r i e s   w h o   s e l e c t   t h e   i m p l e m e n t i n g 
body are limited.

It is basically up to the Member State to check the way in which the 
proposing organisation selects the implementing body. The checking 
procedures in use in the three Member States visited, and especially in 
Spain and Italy, however, were not sufficiently formal and systematic 
to make it possible to ascertain whether the choice did indeed result 
from actually ‘inviting competitive offers by all appropriate means’. 
F o r   a   f o u r t h   M e m b e r   S t a t e ,   t h e   C o u r t   a l s o   f o u n d   a   c a s e   w h e r e   t h e 
information  available  showed  that  the  proposing  organisation  had 
not complied with the terms of selection to which it had committed 
itself and raised questions as to the transparency of the final choice. 
Not one of these points had, however, been previously detected.

B O X   1 1

I L LU S T R AT I O N   O F  T H E   CO N D I T I O N S   F O R   S E L E C T I N G   S O M E   I M P L E M E N T I N G   B O D I E S

In Italy, the average period of time noted by the auditors between the call for proposals being sent to 
possible service providers and the final selection of the implementing body was less than 10 working 
days.

Spanish legislation lays down a standard time limit of 15 days for the receipt of tenders from service 
providers as part of a public call for tenders.

For several of the programmes examined in the various Member States, the implementing body had 
been selected on the basis of examining one single service tender.

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25

10  For example, a two-year 

programme starting on 17 April 

of year N will have its expenditure 

approved for the two periods 

running from 17 April N to 

16 April N + 1 (Year 1) and from 

17 April N + 1 to 16 April N + 2 

(Year 2); these are periods which 

coincide neither with the EAGF 

financial years nor with those of 

the other programmes.

43. 

44. 

45. 

As regards the procedures for selecting the service provider, very tight 
deadlines for invitations to tender were in some cases noted, which 
could hinder the presentation of tenders under proper conditions. In 
certain cases, the service provider may even be selected on the basis 
of a single tender received (see Box 11).

MONITORING OF EXPENDITURE STEPPED UP 
BY THE COMMISSION

For the last two years the Commission has been introducing or strength-
ening procedures and tools for its day-to-day monitoring of Member 
States’ programmes and payment claims. This has enabled it to detect 
and  start  rectifying  a  number  of  administrative  anomalies  that  pre-
viously  existed:  more  systematic  acquisition  of  the  case  documents 
required  by  the  regulations,  administrative  closure  of  programmes 
completed several years ago, detection of errors that have led some 
M e m b e r   S t a t e s   t o   c h a r g e   t o   c e r t a i n   p r o g r a m m e s   p a y m e n t   c l a i m s 
higher than the amounts approved.

Despite the progress that has been made, the tools in place are still 
undergoing  improvement,  which  is  why  some  residual  problems  of 
the type described in the previous paragraph were still being uncov-
ered during the audit. Furthermore, the principle of approving annual 
b u d g e t s   o n   t h e   b a s i s   o f   t h e   a n n i v e r s a r y   d a t e   s p e c i f i c   t o   e a c h   p r o -
gramme 10 hampers effective (budgetary) year-by-year checks on the 
booked expenditure.

B O X   1 2

E X A M P L E S   O F   S U B J E C T I V E   E L E M E N T S  TO   B E  TA K E N   I N TO   ACCO U N T 
I N  T H E   N AT U R E   O F  T H E   M E S S AG E S

One ‘Poultry’ programme used promotion material that provided the information stipulated by the 
regulations, but most of the expenditure incurred had been devoted to radio or television advertising 
spots which bore no relation to ‘the intrinsic qualities of the product concerned or its characteristics’ 
or to the objectives and main messages of the ‘poultrymeat’ guidelines.

Two  successive  ‘Wine’  programmes  presented  slogans  and  visual  advertisements  which  had  highly 
commercial connotations and had nothing to do with ‘the intrinsic qualities of the product concerned 
or its characteristics’.

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26

As regards the actual content of the programmes, the eligibility condi-
tions specified in the regulations are sometimes subject to interpre-
tation. In particular, the regulations 11 stipulate that ‘all information 
and/or promotion messages […] shall be based on the intrinsic quali-
ties of the product concerned or its characteristics’ and this criterion 
leaves  great  scope  for  interpretation.  It  is  therefore  sometimes  dif-
ficult to strike an acceptable balance between messages that directly 
satisfy the criteria of the regulation and more commercial promotion 
techniques (see Box 12).

11  Article 4 of Regulations (EC) 

No 1071/2005 and (EC) 

No 1346/2005.

PERSISTENT WEAKNESSES IN THE CHECKS 
BY SOME MEMBER STATES

The audits performed in Spain and Italy enabled the Court to follow up 
t h e   m a n a g e m e n t   a n d   c o n t r o l   p r o b l e m s   w h i c h   h a d   b e e n   i d e n t i f i e d 
by the Commission for several years and had already led to financial 
corrections being made as a result of procedures initiated in 2005. In 
both Member States it was apparent that the administrative practices 
still did not suffice to ensure that the management and control of the 
programmes  met  the  regulatory  requirements.  Shortcomings  of  the 
same kind as those identified by the Commission in 2005 (significant 
weaknesses  in  checks,  failure  to  abide  by  the  time  limits  stipulated 
i n   t h e   r e g u l a t i o n s ,   c a s e s   o f   t h e   m a x i m u m   C o m m u n i t y   c o n t r i b u t i o n 
of 50 % being exceeded) were found in particular.

In Spain, the administrative verification tasks were not carried out in 
a   s u f f i c i e n t l y   w e l l - d o c u m e n t e d   m a n n e r   t o   b e   r e c o g n i s e d   a n d   t h e 
deadlines were often exceeded. The Spanish authorities themselves 
had found on several occasions that the system of checks in place to 
date  was  not  able  to  guarantee  that  the  expenditure  complied  with 
the regulations.

In Italy, the checks required by the Community regulations were often 
not  carried  out  by  the  authorities  and  the  administrative  practices 
did  not  ensure  that  payments  were  made  within  acceptable  periods 
o f   t i m e .   I n t e r n a l   c o n t r o l   w e a k n e s s e s   w e r e   f o u n d   a t   t h e   p r o p o s i n g 
organisations and at the implementing bodies as regards their ability 
to  ensure  the  traceability  of  expenditure  and  a  satisfactory  level  of 
information provision.

46. 

47. 

48. 

49. 

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27

50. 

51. 

52. 

In both these countries it was also found that the effectiveness of the 
checks could be further curtailed in cases where considerable use was 
made of subcontractors or intermediaries. In some of these cases, the 
C o u r t ’ s   a u d i t o r s   w e r e   n o t   g i v e n   a c c e s s   t o   a l l   t h e   s u p p o r t i n g   d o c u -
ments they asked for.

In both Spain and Italy, action had just been taken, however, to address 
the problems that had been found for more than four years. Neverthe-
less,  at  the  time  of  the  audit  it  was  still  too  early  to  verify  whether 
these  changes  had  been  effective  and  so  this  will  therefore  have  to 
be ascertained in the future.

The audit conducted in France found practices which, whilst still requir-
i n g   i m p r o v e m e n t   o r   s y s t e m a t i c   a p p l i c a t i o n   i n   s o m e   r e s p e c t s ,   w e r e 
much more in keeping with expected practice.

Source: Centre d'Information des Viandes (CIV).

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CONCLUSIONS AND 
RECOMMENDATIONS

28

53. 

54. 

The Commission has for some years been improving the management and 
c o n t r o l   a r r a n g e m e n t s   f o r   e x p e n d i t u r e   c o n n e c t e d   w i t h   i n f o r m a t i o n 
provision and promotion measures for agricultural products. Through 
t h i s   p r o c e s s ,   p o s i t i v e   r e s u l t s   h a v e   a l r e a d y   b e e n   o b t a i n e d   i n   s o m e 
areas  but  it  still  needs  to  be  further  consolidated  and  expanded,  in 
particular with the prospect of the budget devoted to these arrange-
ments being increased.

The Court has found that the system in place does not make it possible 
to gauge the effectiveness of the measure. The impact of the policy, 
although it is probably positive, is currently difficult to measure, one 
of the contributory factors being that there are no specific objectives 
based on an explicit strategy which can serve as a yardstick for evalu-
ating the effectiveness of the policy and monitoring the appropriate 
indicators (see paragraphs 16 to 18). The impact to be expected from 
t h e   p r o m o t i o n   s c h e m e   i s   n e v e r t h e l e s s   c i r c u m s c r i b e d   b y   a   b u d g e t 
that is relatively modest in relation to the large number of products 
a n d   g e o g r a p h i c a l   a r e a s   t o   b e   c o v e r e d   a n d   t h e   l a c k   o f   a n   a d e q u a t e 
p r o c e d u r e   f o r   e n s u r i n g   c o m p l e m e n t a r i t y   w i t h   t h e   v a r i o u s   n a t i o n a l 
or private promotion measures (see paragraphs 19 to 23). The Court 
therefore expresses the following recommendations regarding these 
points:

(a) 

The policy objectives need to be specified whilst at the same time 
e n s u r i n g   t h a t   t h e   s t a t e d   a m b i t i o n s   a r e   c o m m e n s u r a t e   w i t h   t h e 
budgets that have been committed.

(b) 

These objectives should be expressed as ‘SMART’ objectives so that 
suitable performance indicators can be defined and monitored.

(c) 

A formal procedure for consulting all the stakeholders should be 
introduced  so  as  to  ensure  that,  during  the  whole  process,  from 
defining  the  strategy  through  to  implementing  the  procedures, 
there  is  complementarity  with  the  various  promotion  measures 
that  already  exist.  With  this  in  mind,  the  Commission  should  in 
particular encourage the Member States to systematically notify 
it of the various promotion aids and measures in use nationally.

55. 

As regards selecting the programmes to be co-financed, the Commis-
sion’s selectivity has considerably increased in recent years (see para-
graphs  34  to  38).  This  progress  nevertheless  needs  to  be  continued 
both at the Commission (see paragraphs 37 to 40) and in the Member 
S t a t e s   ( s e e   p a r a g r a p h s   3 1   t o   3 3 ) .   T h e   C o u r t   t h u s   h a s   t h e   f o l l o w i n g 
recommendations:

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29

(a) 

T h e   i m p r o v e m e n t s   c u r r e n t l y   b e i n g   m a d e   t o   t h e   C o m m i s s i o n ’ s 
selection  procedure  should  be  continued,  especially  as  regards 
the  requirement  for  information  on  the  expected  impact  of  the 
programme and the manner in which it will be measured.

(b) 

The Member States should continue to increase their selectivity, 
amongst other things by verifying information as to the relevance 
of the proposals.

56. 

As regards the implementation of the programmes and the legality/
regularity  of  the  expenditure,  the  checks  made  on  the  selection  of 
the implementing bodies, which have a key role to play, are still too 
limited (see paragraphs 41 to 43). The Commission’s subsequent moni-
toring of expenditure has indeed been stepped up (see paragraphs 44 
to 46), but significant control weaknesses persist in certain Member 
States (see paragraphs 47 to 52). The Court therefore makes the fol-
lowing recommendations:

(a) 

Checks on the selection of implementing bodies should be stepped 
up.

(b) 

C o n t r o l   w e a k n e s s e s   i d e n t i f i e d   i n   o n e   M e m b e r   S t a t e   s h o u l d 
b e   f o l l o w e d   u p   s o   a s   t o   e n s u r e   s p e e d y   i m p r o v e m e n t   i n   t h e s e 
shortcomings.

57.  When considering the impact to be expected from implementing the 
Court’s recommendations, the size of the budget devoted to the pro-
m o t i o n   a r r a n g e m e n t s   n e e d s   t o   b e   b o r n e   i n   m i n d .   T h e   C o m m i s s i o n 
is  currently  making  a  thorough  review  of  this  scheme.  This  could  in 
particular lead to a proposal to significantly increase the information 
and promotion budget. For that reason, the Court recommends that 
these improvements be made as soon as possible.

This report was adopted by the Court of Auditors in Luxembourg at its 
meeting of 11 June 2009.

For the Court of Auditors

Vítor Manuel da Silva Caldeira
President

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30

A N N E X   I

S U M M A RY   O F  T H E   R E G U L AT I O N S   I N   F O R C E   D U R I N G  T H E   P E R I O D   AU D I T E D

Type of 
measure

Internal 
market

2008

Third countries

Council

Commission

Council Regulation (EC) No 3/2008 
of 17 December 2007 on information 
provision and promotion measures for 
agricultural products on the internal 
market and in third countries
(OJ L 3, 5.1.2008, p. 1)

NB: amalgamation of the two previous 
regulations without any change in the 
content.

Commission Regulation (EC) 
No 501/2008 of 5 June 2008 laying 
down detailed rules for the application 
of Council Regulation (EC) No 3/2008 
on information provision and 
promotion measures for agricultural 
products on the internal market and 
in third countries (OJ L 147, 6.6.2008, 
p. 3)

Before 2008

Internal 
market

Council Regulation (EC) 
No 2826/2000 of 19 December 
2000 on information and promotion 
actions for agricultural products 
on the internal market
(OJ L 328, 23.12.2000, p. 2)

(Amended by Council Regulation (EC) 
No 2060/2004 (OJ L 357, 2.12.2004, 
p. 3) and by Council Regulation (EC) 
No 1182/2007 (OJ L 273, 17.10.2007, 
p. 1))

Third countries

Council Regulation (EC) 
No 2702/1999 of 14 December 1999 
on measures to provide information 
on, and to promote, agricultural 
products in third countries 
(OJ L 327, 21.12.1999, p. 7)

(Amended by Council Regulation (EC) 
No 2060/2004)

Commission Regulation (EC) 
No 1071/2005 of 1 July 2005 laying 
down detailed rules for applying 
Council Regulation (EC) No 2826/2000 
on information and promotion actions 
for agricultural products on the 
internal market (OJ L 179, 11.7.2005, 
p. 1)

Commission Regulation (EC) 
No 94/2002 of 18 January 2002 laying 
down detailed rules for applying 
Council Regulation (EC) No 2826/2000 
on information and promotion actions 
for agricultural products on the 
internal market (OJ L 17, 19.1.2002, 
p. 20)

Commission Regulation (EC) 
No 1346/2005 of 16 August 2005 
laying down detailed rules for the 
application of Council Regulation 
(EC) No 2702/1999 on measures 
to provide information on, and to 
promote, agricultural products in third 
countries (OJ L 212, 17.8.2005, p. 16)

Commission Regulation (EC) 
No 2879/2000 of 28 December 2000 
laying down detailed rules for applying 
Council Regulation (EC) No 2702/1999 
on measures to provide information 
on, and to promote, agricultural 
products in third countries (OJ L 333, 
29.12.2000, p. 63)

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31

A N N E X   I I

L I S T   O F  T H E  T H E M E S ,  P R O D U C T S   A N D   CO U N T R I E S  T H AT   M AY   B E   CO V E R E D 
BY  T H E   E L I G I B L E   M E A S U R E S

L I S T   O F  T H E  T H E M E S   A N D   P R O D U C T S   CO N C E R N E D   O N  T H E   I N T E R N A L   M A R K E T

(Source: Annex I to Regulation (EC) No 1071/2005)

• 
• 
• 
• 
• 
• 
• 
• 

• 
• 
• 
• 
• 

• 
• 

Fresh fruit and vegetables
Processed fruit and vegetables
Fibre flax
Live plants and products of ornamental horticulture
Olive oil and table olives
Seed oils
Milk and milk products
Fresh,  chilled  or  frozen  meat,  produced  in  accordance  with  a  Community  or  national  quality 
scheme
Marking of eggs for human consumption
Honey and beekeeping products
Quality wines psr, table wines with a geographical indication
Graphic symbol for the most remote regions as laid down in agricultural legislation
Protected designation(s) of origin (PDO), protected geographical indication(s) (PGI) and traditional 
speciality(ies) guaranteed (TSG)
Organic farming
Poultrymeat

L I S T   O F  T H I R D - CO U N T RY   M A R K E T S   I N  W H I C H   P R O M OT I O N A L   M E A S U R E S 
M AY   B E   C A R R I E D   O U T

(Source: Annex to Regulation (EC) No 1346/2005)

A.  COUNTRIES
• 
Australia
• 
Bosnia and Herzegovina
• 
Bulgaria
• 
China
• 
Croatia
• 
Former Yugoslav Republic of Macedonia
• 
India
• 
Japan
• 
New Zealand
• 
Norway
• 
Romania
• 
Russia
• 
Serbia and Montenegro, including Kosovo
• 
South Africa
• 
South Korea
• 
Switzerland
• 
Turkey
• 
Ukraine

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A N N E X   I I

B.  GEOGRAPHICAL AREAS
• 
• 
• 
• 
• 

North Africa
North America
Latin America
South-East Asia
Middle East

L I S T   O F   P R O D U C T S  W H I C H   M AY   B E   CO V E R E D   BY   P R O M OT I O N A L   M E A S U R E S 
I N  T H I R D   CO U N T R I E S

(Source: Annex to Regulation (EC) No 1346/2005)

• 
• 
• 
• 
• 
• 
• 
• 
• 
• 
• 

• 

Fresh, chilled and frozen beef, veal and pigmeat; food preparations based on these products
Quality poultrymeat
Milk products
Olive oil and table olives
Table wines with a geographical indication. Quality wines psr
Spirit drinks with a geographical indication or a reserved traditional description
Fresh and processed fruit and vegetables
Products processed from cereals and rice
Fibre flax
Live plants and products of ornamental horticulture
Products benefiting from a protected designation of origin (PDO), a protected geographical indica-
tion (PGI) or a traditional speciality guaranteed (TSG)
Organic farming products

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REPLY OF THE 
REPLY OF THE 
COMMISSION
COMMISSION

SUMMARY

I.
Since 1999, the European Union has pursued 
a n   o v e r a l l   a n d   c o h e r e n t   i n f o r m a t i o n   a n d 
promotion  policy  for  agricultural  products 
a n d   p r o d u c t i o n   m e t h o d s   a n d   a g r i c u l t u r a l -
b a s e d   f o o d   p r o d u c t s .   T h e   i n f o r m a t i o n   a n d 
promotion  campaigns  which  it  co-finances 
may  take  place  either  inside  or  outside  the 
EU.

V.
With a view to sound management and in an 
attempt  to  improve  implementation  of  this 
policy, the Commission requested a total of 
e i g h t   e x t e r n a l   e v a l u a t i o n   s t u d i e s   b e t w e e n 
2006 and 2008 and drew a number of conclu-
sions and operational recommendations.

These  eight  studies  to  evaluate  promotion 
programmes in both the internal market and 
non-member  countries  and  the  two  accom-
panying summaries highlighted the positive 
impact  of  these  programmes  in  relation  to 
the  objectives  set  out  below  (see  point  28) 
and the importance of the policy.

C o u n c i l   R e g u l a t i o n   ( E C )   N o   3 / 2 0 0 8   l a y s 
down the objective of developing an overall, 
coherent information and promotion policy. 
The  regulation  sets  four  clear  objectives  in 
the fourth recital:

 —

to usefully supplement and reinforce the 
schemes run by Member States;

 —

t o   b o o s t   p r o d u c t   i m a g e   i n   t h e   e y e s   o f 
c o n s u m e r s   i n   t h e   C o m m u n i t y   a n d   i n 
non-member  countries,  in  particular  as 
regards the quality, nutritional value and 
safety of foodstuffs and the methods of 
production;

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34

REPLY OF THE 
COMMISSION

VII.
T h e   p r o m o t i o n   p r o g r a m m e s   h a v e   h a d   a n d 
c o n t i n u e   t o   h a v e   a   t a n g i b l e   i m p a c t   o n   t h e 
p r o m o t i o n   o f   E u r o p e a n   a g r i c u l t u r a l   p r o d -
ucts, as shown by the eight evaluation stud-
ies requested by the Commission.

A lack of selectivity and control by the Mem-
ber States at the preselection stage results in 
ineffective programmes being presented to 
the  Commission.  However,  the  Commission 
departments’ rigorous approach in applying 
t h e   r e g u l a t i o n 2  m a k e s   i t   v e r y   u n l i k e l y   t h a t 
this type of programme would be selected.

The Commission would ask the Member States 
to increase the standards of evaluation and 
selection for programme proposals.

VIII.
To ensure that improvements continue, par-
ticularly as regards requirements concerning 
information  on  the  expected  impact  of  the 
programme  and  the  way  in  which  it  will  be 
measured, the Commission has produced the 
following three documents:

 —

g u i d e l i n e s   t o   b e   c o n s i d e r e d   w h e n 
a s s e s s i n g   a n d   m a n a g i n g   p a r t -
f i n a n c i n g   p r o g r a m m e s   f o r   p r o m o t -
i n g   C o m m u n i t y   a g r i c u l t u r a l   p r o d u c t s 
(AGRI/60787/2007);

 —

t h e   d o c u m e n t   o n   e v a l u a t i o n   m a t t e r s 
(AGRI/63454/2007);

 —

a   s t a n d a r d   e v a l u a t i o n   g r i d ,   a l l o w i n g 
t h e   C o m m i s s i o n   t o   o b j e c t i v e l y   a s s e s s 
and  quantify  the  evaluation  of  the  pro-
grammes (AGRI/64046/2008).

2  Article 11(2) of Regulation (EC) No 501/2008.

 —

to help to open up new markets in non-
member countries;

 —

t o   h a v e   a   m u l t i p l i e r   e f f e c t   o n   n a t i o n a l 
and private initiatives.

S i m i l a r l y ,   A n n e x   I   t o   C o m m i s s i o n   R e g u l a -
tion (EC) No 501/2008 also sets appropriate 
s p e c i f i c   o b j e c t i v e s   f o r   e a c h   o f   t h e   v a r i o u s 
products concerned.

A s   r e g a r d s   t h e   m o d e s t   b u d g e t ,   i t   s h o u l d 
b e   r e m e m b e r e d   t h a t   i t   i s   i n t e n d e d   o n l y   t o 
s u p p l e m e n t   a n d   r e i n f o r c e   s c h e m e s   r u n   b y 
Member States, in line with the principle of 
subsidiarity.

VI.
The four objectives set out in Council Regu-
l a t i o n   ( E C )   N o   3 / 2 0 0 8   a n d   t h o s e   s e t   o u t   i n 
Commission Regulation (EC) No 501/2008 are 
c o n s i d e r e d   b y   t h e   C o m m i s s i o n   a s   ‘ S M A R T ’ 
o b j e c t i v e s   w h i c h   s h o u l d   b e   p u r s u e d   i n   a l l 
the programmes.

T h e   C o m m i s s i o n   a l s o   b a s e s   i t s   a p p r o a c h 
o n   t h e   e i g h t   e x t e r n a l   e v a l u a t i o n s   o n   p r o -
m o t i o n   p o l i c y   w h i c h   a r e   u n d e r   w a y .   D o c u -
m e n t   A G R I / 6 3 4 5 4 / 2 0 0 7   w a s   a d o p t e d   a n d 
distributed  on  2  October  2007  to  the  Mem-
ber  States  to  evaluate  the  results  which  all 
future programmes should achieve.

T h e   C o m m i s s i o n   i s   a l r e a d y   i n   r e g u l a r   c o n -
t a c t   w i t h   a l l   t h e   s t a k e h o l d e r s   i n v o l v e d   i n 
p r o m o t i o n   p o l i c y   t h r o u g h   t h e   ‘ P r o m o t i o n 
of  agricultural  products’  advisory  group.  It 
responds  to  requests  from  working  groups, 
conferences and seminars organised by the 
m a i n   s t a k e h o l d e r s .   I t   a l s o   p l a y s   a n   a c t i v e 
part  in  the  work  of  the  various  monitoring 
g r o u p s . 1  T h e   c u r r e n t   d i s c u s s i o n   w i t h i n   t h e 
Commission on the promotion of agricultural 
products  will  doubtlessly  provide  a  further 
contribution.

1  These groups are provided for by Article 12(1) of 

Regulation (EC) No 3/2008.

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REPLY OF THE 
COMMISSION

OBSERVATIONS

16.
C o u n c i l   R e g u l a t i o n   ( E C )   N o   3 / 2 0 0 8   l a y s 
down the objective of developing an overall, 
coherent information and promotion policy. 
The  regulation  sets  four  clear  objectives  in 
t h e   f o u r t h   r e c i t a l   w h i c h   t h e   C o m m i s s i o n 
considers to be ‘SMART’:

 —

to usefully supplement and reinforce the 
schemes run by Member States;

 —

t o   b o o s t   p r o d u c t   i m a g e   i n   t h e   e y e s   o f 
c o n s u m e r s   i n   t h e   C o m m u n i t y   a n d   i n 
non-member  countries,  in  particular  as 
regards the quality, nutritional value and 
safety of foodstuffs and the methods of 
production;

 —

to help to open up new markets in non-
member countries;

 —

t o   h a v e   a   m u l t i p l i e r   e f f e c t   o n   n a t i o n a l 
and private initiatives.

Similarly, Annex I to Commission Regulation 
(EC) No 501/2008 also lays down appropriate 
specific objectives for the internal market for 
each of the various products concerned.

17.
T h e   C o m m i s s i o n   a l s o   b a s e s   i t s   a p p r o a c h 
o n   t h e   e i g h t   e x t e r n a l   e v a l u a t i o n s   o n   p r o -
m o t i o n   p o l i c y   w h i c h   a r e   u n d e r   w a y .   D o c u -
m e n t   A G R I / 6 3 4 5 4 / 2 0 0 7   w a s   a d o p t e d   a n d 
distributed  on  2  October  2007  to  the  Mem-
ber  States  to  evaluate  the  results  which  all 
future programmes should achieve.

IX.
With  regard  to  the  recurring  weaknesses  in 
Spain and Italy, following the investigations 
by the Commission in 2004 and 2005 which 
led to substantial financial corrections, the 
Commission  launched  follow-up  investiga-
tions in 2007 and 2008. A third on-the-spot 
investigation is planned in Italy in 2009.

T h e   C o m m i s s i o n   h a s   c a r r i e d   o u t   a u d i t s   i n 
Spain and Italy for all in respect of the finan-
cial years covered by the measure since 2003 
and in respect of these countries’ decentral-
ised management up to now. The corrective 
measures  adopted  by  these  Member  States 
have  also  been  examined  in  the  framework 
of clearance of accounts investigations.

T h e   C o u r t ’ s   o b s e r v a t i o n s   w i l l   a l s o   b e 
taken  into  account  during  the  clearance  of 
accounts.

X.
C h e c k s   o n   t h e   s e l e c t i o n   o f   i m p l e m e n t i n g 
b o d i e s   h a v e   b e e n   p a r t i c u l a r l y   s t e p p e d   u p 
f o r   t h o s e   s e l e c t e d   a f t e r   a d o p t i o n   o f   t h e 
Commission’s  decision  on  the  programmes 
accepted.

T h e   m a n u a l   o f   p r o c e d u r e s   f o r   m o n i t o r i n g 
programmes now provides for tighter checks 
on the documentation submitted by Member 
S t a t e s   c o n c e r n i n g   n a t i o n a l   s e l e c t i o n   p r o -
cedures (points 1.4 and 2).

XI.
O n c e   t h e   i n t e r n a l   d i s c u s s i o n   o n   t h e   s t r a t -
egy for the EU co-financed promotion policy 
h a s   b e e n   c o m p l e t e d ,   t h e   C o m m i s s i o n   w i l l 
a p p l y   t h e   o p e r a t i o n a l   g u i d e l i n e s   b a s e d   o n 
its conclusions.

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20.
Since  the  beginning  of  this  promotion  and 
i n f o r m a t i o n   p o l i c y   ( 1 9 9 9 ) ,   s e v e r a l   p r o f e s -
sional  organisations  representing  products 
and sectors have noted a definite impact of 
t h e i r   a c t i o n   o n   a c h i e v i n g   o b j e c t i v e s .   T h i s 
can be verified in the eight evaluation stud-
ies requested by the Commission.

22.–23.
T h e   C o m m i s s i o n   i s   a w a r e   o f   t h e   d e f i c i e n -
cies pointed out by the Court and mentioned 
i n   t h e   e v a l u a t i o n   s t u d i e s .   D i s c u s s i o n s   a r e 
ongoing within the Commission to improve 
t h e   d e f i n i t i o n   a n d   i m p l e m e n t a t i o n   o f   t h e 
programmes with regard to the synergy and 
c o m p l e m e n t a r i t y   o f   p r o m o t i o n   c a m p a i g n s 
and to address other problems raised by the 
external evaluators.

The promotion and information programmes 
are co-financed by the proposing organisa-
tions, the Member States and the European 
U n i o n .   U n d e r   A r t i c l e   9   o f   R e g u l a t i o n   ( E C ) 
No 501/2008, it is the responsibility of Mem-
ber States to ensure consistency with other 
programmes  and  initiatives  as  part  of  their 
d u t y   t o   s e e   t h a t   t h e   s e l e c t e d   p r o g r a m m e s 
are satisfactorily implemented.

Reply to Box 4
First and second indents
Article 8 of Council Regulation (EC) No 3/2008 
provides that the Commission must give pri-
o r i t y   t o   p r o g r a m m e s   p r o p o s e d   b y   s e v e r a l 
M e m b e r   S t a t e s   a n d   t h a t   t h e   C o m m i s s i o n 
w i l l   c o n t i n u e   t o   e n c o u r a g e   r e p r e s e n t a -
t i v e   p r o f e s s i o n a l   o r g a n i s a t i o n s   t o   s u b m i t 
‘ m u l t i - c o u n t r y ’   p r o g r a m m e s   a n d   s y n e r g y 
generators.

18.
D o c u m e n t   A G R I / 6 3 4 5 4 / 2 0 0 7 ,   d r a w n   u p   b y 
t h e   C o m m i s s i o n   o n   t h e   b a s i s   o f   e x t e r n a l 
evaluation studies, covers five main topics. 3 
The  systematic  application  of  indicators  to 
a l l   p r o g r a m m e s   a p p r o v e d   b y   t h e   C o m m i s -
sion will help to better harmonise the whole 
of the promotion policy and to increase the 
measurability of the objectives pursued.

19.
T h e   f a c t   t h a t   t h e   C o m m u n i t y   b u d g e t   f o r 
p r o m o t i o n   a n d   i n f o r m a t i o n   m e a s u r e s   i s 
relatively  modest  is  justified  in  part  by  the 
fact that its purpose is only to usefully sup-
p l e m e n t   a n d   r e i n f o r c e   t h e   s c h e m e s   r u n   b y 
Member States.

The promotion and information programmes 
are co-financed by the proposing organisa-
t i o n s ,   t h e   M e m b e r   S t a t e s   a n d   t h e   E U .   T h i s 
system of co-financing is an effective method 
of making the stakeholders accountable and 
of beneficially applying the principle of sub-
sidiarity to this policy.

General reply to Box 2
T h e   p r o p o s e d   c o m p a r i s o n   s h o u l d   t a k e 
account  of  the  fact  that  the  objectives  and 
m e c h a n i s m s   o f   t h e   a b o v e   p r o m o t i o n   p r o -
g r a m m e s   a r e   n o t   c o m p a r a b l e   t o   t h o s e   o f 
Community promotion policy.

3  Coherence between the implemented measures and 

the objectives of the regulation; actions and information 

channels used and their cost-effectiveness; coverage and 

content of the programmes; impact and effectiveness of the 

measures; and complementarities between programmes 

submitted by the Member States and programmes 

submitted by the professional organisations.

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26.
These  problems  were  detected  after  analy-
sis  of  the  first  external  evaluations  studies 
requested by the Commission.

To resolve them, the Commission issued all 
t h e   M e m b e r   S t a t e s   w i t h   a   s e r i e s   o f   i n d i c a -
tors  on  2  October  2007  to  assess  all  future 
promotion programmes 5.

(a)
T h e   i m p a c t   o f   t h e   a c t i o n   t a k e n   c a n   b e 
g a u g e d   f r o m   t h e   p r o g r a m m e s   a p p r o v e d 
from December 2008.

Most of the programmes taken as examples 
b y   t h e   C o u r t   o f   A u d i t o r s   a r e   p r o g r a m m e s 
s e l e c t e d   b e f o r e   2 0 0 5 .   T h e s e   p r o g r a m m e s 
have not therefore been subject to the vari-
ous  improvements  which  were  made  to  the 
current rules. 6

(b)
See reply to point 26.

(c)
The  comments  made  by  the  Court  of  Audi-
tors were already taken into account by the 
C o m m i s s i o n   o n   2   O c t o b e r   2 0 0 7 .   T h e   n e w 
provisions in the manual of procedures cover 
this aspect and greater attention will be paid 
from  now  on  to  the  analysis  of  information 
received from the Member States.

5  Document No AGRI/63454/2007.

Third indent
A working party was specifically set up at the 
meeting of the advisory group on promotion 
on 12 January 2009 to achieve more synergy 
b e t w e e n   p r o g r a m m e s .   T h i s   w o r k i n g   p a r t y 
could consist of representative professional 
organisations at European level and of rep-
resentatives of the Member States.

25.
The  vast  majority  of  the  programmes  taken 
as examples by the Court of Auditors are pro-
grammes selected by Member States before 
2005. These programmes have not therefore 
b e e n   s u b j e c t   t o   t h e   v a r i o u s   i m p r o v e m e n t s 
made to the current rules. 4 Even before the 
Court of Auditors’ audit was announced, the 
Commission had drawn the attention of the 
Member States to all the documents, includ-
ing reports, which had to be examined.

A f t e r   i n t e r n a l   s c r u t i n y   b y   t h e   C o m m i s s i o n , 
the manual of procedures for the administra-
tors  examining  the  programmes  was  tight-
ened up even more rigorously than the Court 
had recommended.

T h e   n e w   p r o v i s i o n s   s e t   o u t   i n   t h i s   m a n u a l 
p a y   p a r t i c u l a r   a t t e n t i o n   t o   a n a l y s i n g   t h e 
r e s p o n s e s   r e c e i v e d   f r o m   M e m b e r   S t a t e s 
c o n c e r n i n g   p r o m o t i o n   m a t e r i a l   f o r   p r o d -
u c t s ,   q u a r t e r l y   a n d   a n n u a l   r e p o r t s ,   a n n u a l 
a n d   f i n a l   e v a l u a t i o n s ,   c o n t r a c t s ,   ‘ t e m p l a t e 
a c t i o n s ’ ,   i n t e r m e d i a t e   a n d   f i n a l   p a y m e n t s 
and webpages.

4  After documents AGRI/60787/2007 and AGRI/63454/2007 

6  Documents AGRI/60787/2007 and AGRI/63454/2007.

were drawn up.

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28.–29.
The  importance  and  the  positive  impact  of 
t h i s   p o l i c y   c a n   b e   e a s i l y   i l l u s t r a t e d   u s i n g 
p a s s a g e s   f r o m   t h e   a b o v e   e v a l u a t i o n s ,   f o r 
example:

’ E U   c o - f u n d i n g   e n a b l e s   p r o p o s i n g   o r g a n i -
s a t i o n s   t o   c o n d u c t   a m b i t i o u s ,   l a r g e - s c a l e 
p r o g r a m m e s   a d d r e s s i n g   a   w i d e   a u d i e n c e 
w i t h   e x p e c t e d   h i g h   i m p a c t   [ . . . ] .   W i t h o u t 
EU  co-funding,  some  campaigns  would  not 
have been implemented’, and ‘EU co-funding 
produces multiplier effects, mainly by facili-
tating  implementation  of  other  campaigns 
and [...] by promoting cooperation between 
Member States at EU level’. 9

A n o t h e r   p a s s a g e   s t a t e s   t h a t :   ‘ A s   a   c o n s e -
q u e n c e   o f   t h e s e   c a m p a i g n s ,   t h e   i m a g e   ( o f 
the promoted products) has improved among 
opinion  leaders  and  the  general  public  has 
b e e n   m a d e   f a m i l i a r   w i t h   a   w i d e r   r a n g e   o f 
products  than  before’  and  ‘EU  co-financing 
h a s   b e e n   a   c l e a r   i n c e n t i v e   f o r   p r o f e s s i o n -
a l s   t o   j o i n   f o r c e s   a n d   f o r   i m p r o v i n g   s e c t o r 
integration  [...].  In  particular,  small  produ-
cers  felt  encouraged  to  organise  their  own 
p r o m o t i o n   c a m p a i g n s   o u t s i d e   t h e i r   r e g i o n 
of production.’ 10

Moreover, ‘[...] They also state that, without 
co-financing, the programmes either would 
n o t   h a v e   t a k e n   p l a c e   o r   w o u l d   h a v e   b e e n 
much smaller.’ 11

9  Fruit and vegetables sector, November 2007.

General reply to Box 5
Most of the programmes taken as examples 
b y   t h e   C o u r t   o f   A u d i t o r s   a r e   p r o g r a m m e s 
s e l e c t e d   b e f o r e   2 0 0 5 .   T h e s e   p r o g r a m m e s 
have not therefore been subject to the vari-
ous  improvements  which  were  made  to  the 
current rules. 7

T h e   C o m m i s s i o n   d e t e c t e d   t h e s e   p r o b l e m s 
following analysis of the reports submitted 
b y   t h e   M e m b e r   S t a t e s   a n d   a c t e d   i m m e d i -
a t e l y   t o   r e s o l v e   t h e m ,   w h i l e   a t   t h e   s a m e 
time respecting the principle of subsidiarity 
applicable to this policy. 8

Moreover, the new provisions in the manual 
of  procedures  stipulate  that  greater  atten-
tion must be paid from now on to the analy-
sis of information received from the Member 
States.

Example of an indicator not directly 
corresponding to the aims set 
by the programme
T h e   n e w   p r o v i s i o n s   i n   t h e   C o m m i s s i o n ’ s 
manual of procedures stipulate that greater 
attention  must  be  paid  from  now  on  to  the 
a n a l y s i s   o f   i n f o r m a t i o n   r e c e i v e d   f r o m   t h e 
Member States.

Example of indicators announced 
by the programmes but not followed up
T h e   n e w   p r o v i s i o n s   i n   t h e   m a n u a l   o f   p r o -
cedures stipulate that greater attention must 
be paid from now on to the analysis of infor-
mation received from the Member States.

7  Documents AGRI/60787/2007 and AGRI/63454/2007.

10  Wine sector, April 2007.

8  This is why, when the Promotion of Agricultural 

11  Organic products sector, November 2006.

Products Committee met on 2 October 2007, document 

AGRI/63454/2007 was distributed to all the Member States 

to help them to select programmes more efficiently and 

evaluate the effectiveness of the programmes they manage, 

check and co-finance. In this regard, please see also 

point 17 above.

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M o r e o v e r ,   e v e n   b e f o r e   t h e   s t a r t   o f   t h e 
C o u r t   o f   A u d i t o r s ’   a u d i t   ( o n   4   A p r i l   2 0 0 8 ) 
a n d   b e f o r e   t h e   e n d   o f   t h e   c y c l e   o f   t h e 
e x t e r n a l   e v a l u a t i o n   s t u d i e s   r e q u e s t e d   b y 
t h e   C o m m i s s i o n   ( i n   D e c e m b e r   2 0 0 8 ) ,   t h e 
C o m m i s s i o n   h a d   a l r e a d y   d r a w n   u p   d o c u -
ment  AGRI/63454/2007  on  matters  relating 
t o   e v a l u a t i o n   o n   t h e   b a s i s   o f   t h e   c o n c l u -
s i o n s   a n d   r e c o m m e n d a t i o n s   c o n t a i n e d   i n 
the evalu ation studies available.

Reply to Box 6
 —

With regard to fruit and vegetables, the 
d e t a i l e d   g u i d e l i n e s   i n   R e g u l a t i o n   ( E C ) 
No 501/2008 12 show that the aims of the 
Community  information  and  promotion 
policy are much broader and more com-
p l e x ,   a n d   c e r t a i n l y   g o   b e y o n d   s i m p l y 
quantifying consumption.

 The ‘Food Dudes’ programme, which was 
awarded the World Health Organisation 
p r i z e   i n   2 0 0 6   f o r   i t s   e f f o r t s   t o   c o m b a t 
c h i l d   o b e s i t y ,   s h o u l d   b e   m e n t i o n e d   a s 
a n   o b v i o u s   e x a m p l e   o f   t h e   m u l t i p l e , 
c o m p l e x   d i m e n s i o n   o f   t h e   c o - f i n a n c e d 
programmes.

12  The guidelines in Regulation (EC) No 501/2008 state that 

the main aims of the information programmes co-financed 

in the fruit and vegetable sector are ‘to improve the image 

of the products as being “fresh” and “natural”, encourage 

their regular consumption and bring down the average age 

of consumers. The latter may be attained by encouraging 

young people, and in particular children and adolescents 

in educational establishments, to consume the products 

concerned’.

 —

T h e   C o m m i s s i o n   p r o p o s e d   r e m e d i e s 
t o   t h e   c r i t i c i s m   i s s u e d   b y   t h e   e x t e r n a l 
evaluation firms as and when it received 
their reports.

 The Commission focused in particular on 
the methods used to evaluate the cost–
impact ratio based on the evaluation of 
the internal market programmes 13.

 The monitoring system has been consid-
e r a b l y   i m p r o v e d   a n d   w h e n   i t   r e c e i v e s 
the annual reports for each programme, 
t h e   C o m m i s s i o n   p a y s   s p e c i a l   a t t e n t i o n 
to the Member States’ evaluation of the 
measures introduced.

 —

T h e   C o m m i s s i o n   p r o p o s e d   r e m e d i e s 
t o   t h e   c r i t i c i s m   i s s u e d   b y   t h e   e x t e r n a l 
evaluation firms as and when it received 
their reports.

30.
I t   w i l l   b e   p o s s i b l e   t o   g a u g e   t h e   i m p a c t   o f 
the measures on the programmes approved 
as of December 2008.

See reply to point 26(a).

32.
Because of the Member States’ lack of selec-
t i v i t y   a n d   c o n t r o l   d u r i n g   t h e   p r e s e l e c t i o n 
process, a number of ineffective programmes 
a r e   p r e s e n t e d   t o   t h e   C o m m i s s i o n .   N e v e r -
theless, the Commission’s rigorous applica-
tion  of  the  regulation 14  considerably  limits 
t h e   r i s k   o f   t h i s   t y p e   o f   p r o g r a m m e   b e i n g 
selected by the Commission.

  As for processed fruit and vegetables, the guidelines 

in Regulation (EC) No 501/2008 state that the main 

13  Dated 15 February 2009.

objectives of the co-financed information programmes are 

to modernise ‘the image of the product’ and make it more 

14  Article 11(2) of Regulation (EC) No 501/2008.

youthful, ‘giving the information needed to encourage 

consumption’.

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Reply to Box 8 as a whole
Some of the programmes not carried through 
to the end complied perfectly with the selec-
tion criteria defined by the various Member 
S t a t e s   w h e n   t h e y   c o m m u n i c a t e d   t h e   p r o -
grammes  to  the  Commission.  Based  on  the 
documents sent by the Member States — in 
p a r t i c u l a r   t h e   i d e n t i f i c a t i o n   s h e e t   —   t h e 
Commission  did  not  find  sufficient  reasons 
for  rejecting  these  programmes,  bearing  in 
mind the rules applicable.

S o m e   o f   t h e   p r o b l e m s   r a i s e d   b y   t h e   C o u r t 
c o n c e r n   u n f o r e s e e n   p r o b l e m s   w h i c h   c o u l d 
not have been anticipated when the Member 
States selected the programmes or when the 
Commission approved them.

H o w e v e r ,   i t   m u s t   b e   s t r e s s e d   t h a t   m o s t   o f 
the  Court’s  comments  refer  to  programmes 
that  have  already  ended.  The  current  aver-
age rate of completion of programmes since 
the start of the measure is 85 %.

This increase in the rate of implementation 
is due mainly to the new provisions and tools 
i n t r o d u c e d   b y   t h e   C o m m i s s i o n   t o   m o n i t o r 
programmes from June 2006 on, in particular 
the IT monitoring programme MPP (manage-
ment promotion programme) and the stand-
ard forms given to Member States to ensure 
regu lar  communication  of  the  measures  to 
be implemented and the related payments.

37.
(a)
Since 7 November 2008, the Commission has 
developed a uniform evaluation grid 15, form-
ing part of the manual of procedures. Using 
this grid, the Commission is able to evaluate 
all the programmes objectively.

15  Document AGRI/64046/2008.

The  Commission  is  making  an  effort  to  get 
M e m b e r   S t a t e s   t o   r a i s e   t h e i r   s t a n d a r d s   i n 
t e r m s   o f   e v a l u a t i o n   a n d   s e l e c t i o n   o f   p r o -
gramme proposals.

r e f e r s  

33.
T h e   C o u r t  
t o   d o c u m e n t 
A G R I / 6 3 4 5 4 / 2 0 0 7   o f   2   O c t o b e r   2 0 0 7 .   S i n c e 
then,  programmes  have  been  evaluated  on 
the basis of the criteria set out in this docu-
ment, among other things.

A s   a l r e a d y   s t a t e d   i n   p o i n t   1 8 ,   d o c u m e n t 
A G R I / 6 3 4 5 4 / 2 0 0 7 ,   d r a w n   u p   b y   t h e   C o m -
mission  on  the  basis  of  the  findings  in  the 
e x t e r n a l   e v a l u a t i o n   r e p o r t s ,   c o v e r s   c o h e r -
e n c e   b e t w e e n   t h e   i m p l e m e n t e d   m e a s u r e s 
and the objectives of the regulation, actions 
a n d   i n f o r m a t i o n   c h a n n e l s   u s e d   a n d   t h e i r 
c o s t - e f f e c t i v e n e s s ,   c o v e r a g e   a n d   c o n t e n t 
o f   t h e   p r o g r a m m e s ,   i m p a c t   a n d   e f f e c t i v e -
n e s s   o f   t h e   m e a s u r e s ,   a n d   c o m p l e m e n t a r i -
ties between programmes submitted by the 
Member  States  and  programmes  submitted 
by professional organisations.

This process entered into force in 2009 when 
the Commission selected the internal market 
p r o g r a m m e s ;   t h e   p r o g r a m m e s   p r e s e l e c t e d 
by Member States were sent to the Commis-
sion on 15 February 2009.

34.
On 5 September 2006 the Commission carried 
out a thorough check of all the programmes 
running at that date. It noticed at that time 
t h a t   a   s i g n i f i c a n t   n u m b e r   o f   p r o g r a m m e s 
had not been carried through to the end. It 
t o o k   i m m e d i a t e   a c t i o n   w i t h   r e s p e c t   t o   t h e 
M e m b e r   S t a t e s   a n d   i n t r o d u c e d   t h e   c o r r e c -
tive measures required.

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REPLY OF THE 
COMMISSION

The Commission considers that its rigorous 
s e l e c t i o n   p r o c e d u r e s   f o r   t h e   p r o g r a m m e s 
l i m i t   t h e   r i s k   t h a t   a   w e a k n e s s   i n   c h e c k i n g 
t h e   s e l e c t i o n   o f   i m p l e m e n t i n g   b o d i e s   i s 
likely  to  have  an  effect  on  whether  the  co-
f i n a n c e d   p r o g r a m m e   i s   r e g u l a r ,   e f f e c t i v e 
and economic.

42.
I n   t h e   s p e c i f i c   c a s e   o f   i m p l e m e n t i n g   b o d -
i e s   c h o s e n   a f t e r   t h e   a d o p t i o n   o f   t h e   C o m -
m i s s i o n ’ s   d e c i s i o n ,   p o i n t s   1 . 4   a n d   2   o f   t h e 
manual  of  procedures  now  applicable  have 
reinforced the monitoring of the implement-
ing body selection procedure since Member 
States  must  forward  to  the  Commission  all 
documents concerning this procedure.

43.–44.
When  the  Commission  is  selecting  the  pro-
g r a m m e s ,   i t   c h e c k s   t h a t   t h e   i m p l e m e n t i n g 
bodies  were  subjected  to  competitive  ten-
dering procedures. This is one of the points 
on the checklist for officials entrusted with 
checking the eligibility of proposals.

D u r i n g   i t s   i n v e s t i g a t i o n s ,   t h e   C o m m i s s i o n 
u n c o v e r e d   i r r e g u l a r i t i e s   i n   t h e   t e n d e r i n g 
p r o c e d u r e s   f o r   i m p l e m e n t i n g   b o d i e s .   I n 
accordance with the principle of subsidiarity, 
Member States must ensure compliance with 
the requirements in the regulation concern-
ing  a  competitive  procedure.  The  Commis-
sion  has  imposed  a  financial  correction  on 
Member  States  which  have  been  found  not 
to comply with these provisions.

(b)
As acknowledged by the Court, new instruc-
tions concerning the follow-up to problems 
i d e n t i f i e d   a n d   a n y   r e p l i e s   r e c e i v e d   b y   t h e 
Member States became the formal procedure 
following the audit of 2 October 2008.

38.
T h e r e   i s   s t i l l   s o m e   r o o m   f o r   i m p r o v e m e n t 
a s   r e g a r d s   d e f i n i n g   a n d   i m p l e m e n t i n g   t h e 
promotion programmes 16.

See reply to point 17.

39.
T h e   e f f e c t i v e n e s s   o f   t h e   i n f o r m a t i o n   a n d 
promotion programmes has been evaluated 
on the basis of the new evaluation grid since 
15 February 2009.

40.
The  Commission  is  aware  of  the  shortcom-
i n g s   m e n t i o n e d   i n   t h e   e v a l u a t i o n   r e p o r t s . 
I n t e r n a l   d i s c u s s i o n s   a r e   u n d e r   w a y   t o 
improve the implementation of programmes 
i n   t e r m s   o f   t h e   s y n e r g i e s   a n d   c o m p l e m e n -
t a r i t y   o f   p r o m o t i o n   m e a s u r e s ,   a n d   a l s o   i n 
r e l a t i o n   t o   o t h e r   p r o b l e m s   r a i s e d   b y   t h e 
external auditors.

41.
Member States are responsible for approving 
and  monitoring  the  selection  of  the  imple-
menting body 17.

16  Document AGRI/63454/2007 has come into force.

17  Recital 8 and Article 12 of Regulation (EC) No 501/2008.

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45.
I n t e r n a l   C o m m i s s i o n   d i s c u s s i o n s   a r e   i n 
progress  to  find  an  appropriate  solution  to 
ensure that each phase of a programme cor-
r e s p o n d s   t o   a n   E A G F   b u d g e t   y e a r   w i t h o u t 
making  the  system  too  rigid  or  excessively 
limiting  the  possibilities  for  implementing 
the programmes.

46. and boxes
Without prejudice to the correct application 
o f   t h e   p r i n c i p l e   o f   s u b s i d i a r i t y ,   t h e   C o m -
mission attaches particular attention to the 
messages  used  in  order  to  strike  a  fair  bal-
ance between the information and commer-
cial aspects of the promotion campaigns.

T h e   s e l e c t i o n   p r o c e d u r e   a p p l i e d 1 8  b y   t h e 
C o m m i s s i o n   e n s u r e s   u n i f o r m ,   i m p a r t i a l 
treatment of all the programmes.

D u r i n g   i t s   i n v e s t i g a t i o n s ,   t h e   C o m m i s s i o n 
i d e n t i f i e d   f a i l u r e s   t o   c o m p l y   w i t h   t h e   p r o -
visions on product promotion and informa-
tion in relation to the intrinsic quality of the 
products concerned or their characteristics. 
In accordance with the principle of subsidi-
a r i t y ,   M e m b e r   S t a t e s   m u s t   e n s u r e   t h a t   t h e 
criteria approved by the Commission regard-
ing promotional messages are satisfied. The 
C o m m i s s i o n   h a s   i m p o s e d   a   f i n a n c i a l   c o r -
rection on Member States which have been 
found not to comply with these provisions.

18  Appointment of a first and second reader for each 

programme, examination of all programmes by an 

evaluation committee and participation of external experts 

in the selection process.

42

REPLY OF THE 
COMMISSION

47.–52.
The  Commission  initiated  investigations  in 
2007 and 2008 following the significant cor-
r e c t i o n s   i m p o s e d   o n   S p a i n   a n d   I t a l y   a f t e r 
the 2005 investigations. Italy has again been 
subjected to a risk analysis by the Commis-
sion, and a third investigation (on-the-spot 
inspection) is scheduled for 2009 19 to cover 
e x p e n d i t u r e   i n   2 0 0 8   a n d   2 0 0 9 ,   a n d   s u b s e -
quent years if necessary.

For these two Member States, all the finan-
cial years covered by the measure since 2003 
and their decentralised management to date 
are audited by the Commission.

During  these  ongoing  audits  for  Italy 20  and 
Spain 21,  the  Commission  asked  these  Mem-
b e r   S t a t e s   t o   c o m m u n i c a t e   t h e   c o r r e c t i v e 
measures adopted, the inspection structures 
a n d   t h e   i n s t r u c t i o n s   g i v e n   t o   t h e   r e l e v a n t 
inspection bodies.

T h e   e x i s t e n c e   a n d   i m p a c t   o f   t h e   c h a n g e s 
a n n o u n c e d   b y   t h e s e   M e m b e r   S t a t e s   a r e 
c u r r e n t l y   b e i n g   a n a l y s e d   a s   p a r t   o f   t h e 
c u r r e n t   i n v e s t i g a t i o n s   f o r   t h e   c l e a r a n c e   o f 
accounts.

I n   a d d i t i o n   t o   t h e   c o r r e c t i o n s ,   t h e   C o m -
m i s s i o n   h a s   m a d e   r e c o m m e n d a t i o n s   t o 
t h e s e   M e m b e r   S t a t e s   t o   s t e p   u p   t h e i r   k e y 
i n s p e c t i o n s   a n d   t o   r e m e d y   w e a k n e s s e s   i n 
subcontracting.

E v e n   t h o u g h   t h e   C o m m i s s i o n   a g r e e s   w i t h 
the Court that France’s practices were much 
more  in  keeping  with  expected  practice,  it 
nevertheless points out that it sent a series 
of recommendations to France to have them 
improved.

The Court’s comments will also be taken into 
account for the clearance of accounts.

19  LA/2009/006/IT.

20  LA/2007/020/IT.

21  LA/2008/007/ES.

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REPLY OF THE 
COMMISSION

Moreover, Annex I to the Commission Regu-
lation 22  sets  specific  objectives  for  each  of 
the various products concerned. These goals 
are accompanied by an overview of the situ-
ation  which  led  to  the  organisation  of  pro-
m o t i o n   a n d   i n f o r m a t i o n   m e a s u r e s   f o r   t h e 
product  in  question,  the  target  groups,  the 
main  messages,  the  main  channels  and  the 
duration and scope of the programmes. The 
d i s c u s s i o n s   w h i c h   a r e   n o w   t a k i n g   p l a c e   a t 
the Commission will enable further improve-
ments to be made in this respect.

(b)
The four objectives set out in Council Regu-
l a t i o n   ( E C )   N o   3 / 2 0 0 8   a n d   t h o s e   s e t   o u t   i n 
Commission Regulation (EC) No 501/2008 are 
c o n s i d e r e d   b y   t h e   C o m m i s s i o n   a s   ‘ S M A R T ’ 
o b j e c t i v e s   w h i c h   s h o u l d   b e   p u r s u e d   i n   a l l 
of the programmes.

D o c u m e n t   A G R I / 6 3 4 5 4 / 2 0 0 7 ,   d r a w n   u p   b y 
the Commission on the basis of the findings 
i n   t h e   e x t e r n a l   e v a l u a t i o n   r e p o r t s ,   c o v e r s 
five main themes. Systematic application of 
indicators  in  all  the  programmes  approved 
by  the  Commission  would  make  it  possible 
to  harmonise  further  the  entire  promotion 
policy and enhance the measurability of the 
objectives pursued.

22  Commission Regulation (EC) No 501/2008 laying down 

detailed rules for the application of Council Regulation (EC) 

No 3/2008.

CONCLUSIONS AND 
RECOMMENDATIONS

54.
Since 1999, the European Union has pursued 
a n   o v e r a l l   a n d   c o h e r e n t   i n f o r m a t i o n   a n d 
promotion  policy  for  agricultural  products 
a n d   p r o d u c t i o n   m e t h o d s   a n d   a g r i c u l t u r a l -
b a s e d   f o o d   p r o d u c t s .   T h e   i n f o r m a t i o n   a n d 
promotion  campaigns  which  it  co-finances 
may take place either in the EU internal mar-
ket or in non-EU countries.

W i t h   a   v i e w   t o   s o u n d   m a n a g e m e n t   a n d   i n 
a n   a t t e m p t   t o   i m p r o v e   i m p l e m e n t a t i o n 
o f   t h i s   p o l i c y ,   t h e   C o m m i s s i o n   r e q u e s t e d 
e i g h t   e x t e r n a l   e v a l u a t i o n   r e p o r t s   b e t w e e n 
2 0 0 6   a n d   2 0 0 8   w h i c h   d e m o n s t r a t e d   t h e 
importance  of  the  mechanism  and  its  posi-
tive impact (see point 28). Conclusions and 
operational recommendations have already 
been identified.

T h e   e i g h t   s t u d i e s   t o   e v a l u a t e   t h e   i n f o r m a -
tion and promotion programmes and the two 
accompanying summaries requested by the 
Commission highlighted the positive impact 
of  the  promotion  programmes  for  the  four 
s p e c i f i c   s t r a t e g y   o b j e c t i v e s   s e t   o u t   i n   t h e 
regulations. As regards the modest budget, 
it should be remembered that it is intended 
only  to  supplement  and  reinforce  schemes 
run by the Member States.

(a)
The four objectives of the promotion policy 
set out in point V are clear.

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REPLY OF THE 
COMMISSION

Checks  are  carried  out  when  selecting  pro-
grammes  and  once  the  implementing  body 
has been chosen. Similar checks will be car-
r i e d   o u t   i n   t h e   s u b s e q u e n t   p h a s e   o f   s e l e c -
t i o n   o f   t h e   i m p l e m e n t i n g   b o d y   a n d   i n   t h e 
monitoring groups.

(a)
In  the  case  of  implementing  bodies  chosen 
after the adoption of the Commission’s deci-
sion, points 1.4 and 2 of the manual of pro-
cedures now applicable have reinforced the 
monitoring of the implementing body selec-
t i o n   p r o c e d u r e   s i n c e   M e m b e r   S t a t e s   m u s t 
f o r w a r d   t o   t h e   C o m m i s s i o n   a l l   d o c u m e n t s 
concerning this procedure.

(b)
The clearance of accounts department carries 
out permanent monitoring in those Member 
States whose inspections were found to have 
shortcomings leading to major financial cor-
rections by the Commission.

57.
Once  the  internal  discussions  on  the  strat-
egy  for  the  EU  co-financed  promotion  pol-
i c y   h a v e   b e e n   c o m p l e t e d ,   t h e   C o m m i s s i o n 
will apply the operational guidelines which 
emerge.

(c)
The Commission is already in regular contact 
w i t h   a l l   t h e   s t a k e h o l d e r s   i n v o l v e d   i n   p r o -
motion  policy  through  the  Advisory  Group 
o n   P r o m o t i o n   o f   A g r i c u l t u r a l   P r o d u c t s .   I t 
responds  to  requests  from  working  groups 
and takes part in conferences and seminars 
organised  by  the  main  stakeholders.  It  also 
plays an active part in the work of the vari-
ous monitoring groups 23.

The discussions which are now taking place 
a t   t h e   C o m m i s s i o n   w i l l   e n a b l e   f u r t h e r 
improvements to be made in this respect.

55.
(a)
T h e   C o m m i s s i o n   w i l l   c o n t i n u e   t o   i m p r o v e 
t h e   s e l e c t i o n   p r o c e d u r e   b y   p u t t i n g   t h e 
emphasis on good evaluation methodology 
in each programme, based closely on docu-
ment AGRI/63454/2007.

(b)
T h e   C o m m i s s i o n   a g r e e s   w i t h   t h e s e 
recommendations.

56.
T h e   C o m m i s s i o n   c o n s i d e r s   i t   v e r y   i m p o r -
t a n t   f o r   t h e   i m p l e m e n t i n g   b o d i e s   t o   c o m -
ply with the selection procedures, ensuring 
t h a t   A r t i c l e   1 1   o f   C o u n c i l   R e g u l a t i o n   ( E C ) 
No 3/2008 on tendering procedures is prop-
erly applied.

The Commission considers that its rigorous 
s e l e c t i o n   p r o c e d u r e s   f o r   t h e   p r o g r a m m e s 
l i m i t   t h e   r i s k   t h a t   a   w e a k n e s s   i n   c h e c k i n g 
t h e   s e l e c t i o n   o f   i m p l e m e n t i n g   b o d i e s   i s 
likely  to  have  an  effect  on  whether  the  co-
f i n a n c e d   p r o g r a m m e   i s   r e g u l a r ,   e f f e c t i v e 
and economic.

23  The establishment of these groups is provided for in 

Article 12(1) of Regulation (EC) No 3/2008.

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REPLY OF THE 
COMMISSION

Special Report No 10/2009 — Information provision and promotion measures for agricultural products

47

REPLY OF THE 
COMMISSION

European Court of Auditors

Special Report No 10/2009

Information provision and promotion measures for agricultural products

Luxembourg: Publications Office of the European Union

2009 — 44 pp. — 21 (cid:2) 29.7 cm

ISBN 978-92-9207-362-6

doi:10.2865/50551

Special Report No 10/2009 — Information provision and promotion measures for agricultural products

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I N  T H I S  R E P O R T,  T H E  CO U R T  A N A LYS E S  T H E  MA N AG E M E N T  O F 

THE  INFORMATION  PROVISION  AND  PROMOTION  MEASURES  FOR 

AGRICULTURAL PRODUCTS IN ORDER TO ASCERTAIN WHETHER THIS 

POLICY IS EFFEC TIVE AND WHETHER THE EXPENDITURE INVOLVED 

IS REGULAR.

THE  REPORT  FINDS  THAT  PROGRESS  IS  BEING  MADE  IN  THE  WAY 

THE SCHEME IS MANAGED, BUT HIGHLIGHTS OTHER ASPECTS STILL 

NEEDING IMPROVEMENT. THESE OBSERVATIONS FOCUS IN PARTICULAR 

ON THE DIFFICULTY OF MEASURING THE SCHEME'S IMPACT AND ON 

THE CONTROL WEAKNESSES IDENTIFIED IN SOME MEMBER STATES.

THE REPORT ACCORDINGLY MAKES A NUMBER OF RECOMMENDATIONS 

WHOSE IMPACT COULD BE ALL THE MORE SIGNIFICANT INSOFAR AS THE 

BUDGET DEVOTED TO THE INFORMATION PROVISION AND PROMOTION 

MEASURES FOR AGRICULTURAL PRODUCTS IS LIKELY TO INCREASE IF 

THE REVIEW CURRENTLY BEING MADE BY THE COMMISSION RESULTS 

IN THE LATTER MAKING A PROPOSAL ALONG THESE LINES.

EUROPEAN COURT OF AUDITORS

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