Commission staff working document - Impact Assessment - Accompanying document to the Proposal for a Decision of the European Parliament and of the Council establishing a European Union action for the European Heritage Label {COM(2010) 76 final} {SEC(2010) 198}
Date: 2010-03-09
Institutions: European Commission
Subjects: EU policy, European citizenship, cultural heritage, cultural policy, heritage protection, impact study, public awareness campaign, quality label

EN 

EN 

   EN 

 
 
EUROPEAN COMMISSION 

Brussels, 9.3.2010 
SEC(2010) 197 

COMMISSION STAFF WORKING DOCUMENT 

IMPACT ASSESSMENT 

Accompanying document to the 

Proposal for a 

DECISION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

establishing a European Union action for the European Heritage Label 

{COM(2010) 76 final} 
{SEC(2010) 198} 

EN 

1 

   EN 

 
 
  
 
 
 
 
 
 
 
 
TABLE OF CONTENTS 

Modifications following the opinion of the Impact Assessment Board..................................... 5 

1. 

Section 1: Procedural issues and context setting ......................................................... 5 

1.1. 

General context ............................................................................................................ 5 

1.1.1.  Political background .................................................................................................... 5 

1.1.2.  The Council conclusions .............................................................................................. 6 

1.2. 

Consultation of interested parties................................................................................. 9 

1.2.1. 

Internal consultations ................................................................................................... 9 

1.2.2.  Consultation of stakeholders and European citizens.................................................. 10 

1.2.2.1  Online consultation .................................................................................................... 10 

1.2.2.2  Consultation meeting ................................................................................................. 11 

1.2.3.  Consultation meeting with MS experts ...................................................................... 13 

1.2.4.  External services ........................................................................................................ 14 

2. 

Section 2: Problem definition .................................................................................... 15 

2.1. 

Problem ...................................................................................................................... 15 

2.1.1.  The problem in 2005 when the intergovernmental EHL was conceived ................... 15 

2.1.2.  The problem today ..................................................................................................... 16 

2.2. 

Baseline Scenario: the existing intergovernmental EHL ........................................... 17 

2.2.1  Rationale, objectives and procedures of the intergovernmental EHL........................ 17 

2.2.2 

The weaknesses of the current intergovernmental EHL ............................................ 18 

2.3. 

Legal basis and subsidiarity ....................................................................................... 20 

3. 

3.1. 

3.2. 

3.3. 

3.4. 

3.5. 

4. 

4.1. 

4.2. 

Section 3: Objectives ................................................................................................. 20 

General objectives...................................................................................................... 22 

Intermediate objectives .............................................................................................. 22 

Specific objectives ..................................................................................................... 22 

Operational objectives................................................................................................ 23 

Consistency of these objectives with other EU policies ............................................ 23 

Section 4: Policy options............................................................................................ 24 

Policy options not retained for analysis ..................................................................... 24 

Options retained for analysis...................................................................................... 24 

EN 

2 

   EN 

 
4.2.1.  Option 1: Status quo (baseline scenario).................................................................... 25 

4.2.2.  Option 2: Status quo plus limited EU financial support ............................................ 25 

4.2.3.  Option 3: The EHL becomes a EU initiative through a decision by the Council and 

the Parliament ............................................................................................................ 25 

5. 

5.1. 

5.2. 

5.3. 

5.4. 

6. 

6.1. 

6.2. 

6.3. 

6.4. 

6.5. 

6.6. 

6.7. 

7. 

7.1. 

7.2. 

Section 5: Analysis of impacts................................................................................... 26 

Development of the framework of impacts................................................................ 26 

The chain of effects.................................................................................................... 27 

Quantification versus qualitative analysis.................................................................. 27 

The likely impacts of the various policy options ....................................................... 28 

Section 6: Comparing the options .............................................................................. 30 

Criteria for comparing the options ............................................................................. 30 

Comparison of the options against effectiveness, efficiency and coherence criteria. 31 

Option 1: Status quo (baseline scenario).................................................................... 33 

Option 2: Status quo plus limited EU financial support ............................................ 33 

Option 3: The EHL becomes a EU initiative through a decision by the Council and 
the Parliament ............................................................................................................ 33 

Administrative arrangements and financial impacts .................................................. 35 

Preferred policy option............................................................................................... 37 

Section 7: Monitoring and evaluation ........................................................................ 40 

The monitoring of the labelled sites........................................................................... 40 

The evaluation of the EHL programme as a whole.................................................... 40 

Annex 1: ................................................................................................................................... 42 

Annex 2: ................................................................................................................................... 52 

Annex 3: ................................................................................................................................... 69 

Annex 4: ................................................................................................................................... 74 

Annex 5: ................................................................................................................................... 78 

Annex 6: ................................................................................................................................... 83 

Annex 7: ................................................................................................................................... 89 

EN 

3 

   EN 

 
List of main abbreviations 

EU: European Union 

EHL: European Heritage Label 

IA: Impact assessment 

MS: Member States 

Disclaimer: This IA report commits only the Commission's services involved in its 
preparation. The text is prepared as a basis for discussion and does not prejudge the final form 
of any decision to be taken by the Commission 

Lead DG: DG EAC 

Other involved services: SG, SJ, DG ELARG, DG ENTR, DG INFSO, DG MARE 

EN 

4 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Modifications following the opinion of the Impact Assessment Board 

The draft IA report was discussed with the Impact Assessment Board in a meeting on 
25  November  2009.  Following  this  meeting  and  the  opinion  of  the  Impact 
Assessment Board, several changes have been made to the report. 

Further information on the selection criteria that will be used to award the EHL has 
been provided. The added value of the EHL and the difference with other initiatives 
in the field of cultural heritage have been clarified. The proposed solutions to foster 
the participation of transnational sites have been specified. The objectives have been 
redefined in order to clarify the level of ambition of the initiative and to improve the 
coherence with the criteria that were used to compare the options. The report is also 
more specific about the costs of the initiative for the EU, but also at national level. It 
clarifies  why  the  option  of  the  attribution  of  the  label  on  a  temporary  basis  was 
dropped without further analysis. Finally, it specifies that the participation of MS in 
the EHL would be on a voluntary basis. 

Some  further  changes  which  were  not  discussed  in  the  Impact  Assessment  Board 
meeting and were not included in the Board's opinion, but which were mentioned in 
the  Impact  Assessment  Quality  Checklist  have  been  made.  These  changes  concern 
mostly the various tables and annexes of the IA report. 

Finally,  the  report  has  been  slightly  adapted  in  order  to  take  into  account  the  entry 
into force of the Treaty of Lisbon on 1 December 2009. The legal basis for the EHL 
is now article 167 of the Treaty on the Functioning of the European Union, and the 
references  to  the  European  Community  have  transformed  into  references  to  the 
European Union. 

1. 

SECTION 1: PROCEDURAL ISSUES AND CONTEXT SETTING 

1.1. 

General context 

1.1.1. Political background 

The original concept for a "European Heritage Label (EHL)" was first proposed by 
the French Minister of Culture at the time, Renaud Donnedieu de Vabres as part of 
the response to the growing gap between the citizens and Europe, in particular young 
people.  

The  scheme  was  subsequently  launched  in  April  2006  as  an  intergovernmental 
initiative  under  the  leadership  of  France,  Spain  and  Hungary,  with  the  aim  to 
"strengthen the support of European citizens for a shared European identity based on 
democratic values and human rights and to foster a sense of belonging to a common 
cultural  space".  All  European  States  that  wished  to  were  invited  to  put  forward 
cultural  heritage  sites  that  were  symbolic  of  Europe's  identity  and  to  promote  their 
European dimension. Rules of procedure for the EHL, as well as criteria for selection 
and  an  application  form,  were  adopted  and  the  initiative  was  formally  launched  in 
March  2007  to  coincide  with  the  50th  Anniversary  of  the  Treaty  of  Rome  when  a 
first  series  of  sites  was  awarded  the  EHL.  From  the  beginnings,  the  official 

EN 

5 

   EN 

 
 
 
documents  of  the  intergovernmental  initiative  stated  that  "the  ultimate  objective  of 
the EHL is to become a Community action". To this date, a total of 64 sites located 
in  17  EU  MS  as  well  as  in  Switzerland  have  obtained  the  label1.  At  first  the 
secretariat was being carried out by France and currently by the Spanish Ministry of 
Culture. The intergovernmental EHL is analysed in detail in section 2.2. 

The  European  Parliament  supported  the  development  of  the  EHL,  first  in  its 
resolution  of  29  November  2007  on  a  Renewed  EU  Tourism  Policy:  Towards  a 
stronger partnership for European Tourism (2006/2129(INI)) where it proposes "that 
support be given for the creation of a European Heritage label aimed at highlighting 
the  European  dimension  of  the  EU’s  sites  and  monuments"  and  subsequently  in  its 
resolution of 10 April 2008 on a European agenda for culture in a globalising world 
(2007/2211(INI))  in  which  it  underlines  "that  a  European  heritage  label  should  be 
established  with  a  view  to  emphasising  the  European  dimension  of  cultural  goods, 
monuments,  memorial  sites,  and  places  of  remembrance,  which  all  bear  witness  to 
Europe’s history and heritage". 

On  20 November 2008,  the  Council  of  Ministers  of  the  European  Union  adopted 
conclusions  inviting  the  European  Commission  to  submit  to  it  "an  appropriate 
proposal for the creation of a European Heritage Label by the European Union and 
specifying the practical procedures for the implementation of the project."  

An  IA  roadmap  was  prepared  in  February  2009.  Because  of  the  specificity  of  the 
agenda planning and of the preparation of the work programme for 2010 due to the 
arrival  of  a  new  College  of  Commissioners,  this  roadmap  was  not  published.  It 
served  however  as  a  communication  tool,  notably  with  the  Inter  Service  Steering 
Group and the external consultant. 

1.1.2. The Council conclusions 

As mentioned above, right from the start, the ultimate objective of the EHL was to 
become a EU action. The request of the MS to transform the intergovernmental EHL 
into a formal initiative of the EU came however very soon after the official launch of 
the  label.  The  reason  for  this  is  twofold.    Firstly,  several  MS  have  a  very  strong 
political interest in the EHL, including France which held the Presidency of the EU 
at  the  moment  of  the  adoption  of  the  conclusions  and  Spain  which  will  hold  the 
Presidency in the first semester of 2010. Secondly, after the initial wave of labelling, 
it  quickly  became  evident  that  the  EHL  is  an  initiative  which  is  difficult  to 
implement effectively and, as we will see in detail in section 2.2. of this report, the 
present  procedures  and  practical  arrangements  of  the  EHL  are  far  from  being 
optimal.  

The  Council  conclusions  were  an  essential  element  in  our  reflexion  because  the 
negotiations  which  led  to  the  adoption  of  these  conclusions  gave  the  MS  a  first 
opportunity to express their individual opinions on the EHL and on the added value 
of EU involvement, and because the final text gives a detailed view of their common 
expectations concerning the new EHL. Although the Commission retains freedom in 

1 

The list of these sites is in Anex 4. 

EN 

6 

   EN 

 
 
                                                 
its  right  of  initiative,  the  Council  conclusions  are  an  important  political  backdrop 
which cannot be ignored.  

The  conclusions  take  into  consideration  the  main  provisions  of  the  existing 
intergovernmental  EHL  and  emphasize  the  importance  of  raising  the  awareness  of 
young people of a shared European cultural heritage and hence the need to promote 
their  access  to  this  shared  heritage.  According  to  the  conclusions,  the  creation  of  a 
EHL  by  the  EU  which  would  aim  to  emphasize  Europe's  common  history  in  a 
concrete  way  by  enhancing  the  European  dimension  of  its  cultural  heritage  could 
contribute: 

(cid:190)  to enhancing the value and raising the profile of Member States' heritage and 

that of the shared cultural heritage, 

(cid:190)   to increasing knowledge and appreciation among citizens of their history and 

their shared yet diverse cultural heritage, 

(cid:190)  to  artistic,  cultural  and  historical  education  and,  in  so  doing,  to  stepping  up 

intercultural dialogue, especially among young people,  

(cid:190)  to  the  economic  attractiveness  and  sustainable  development  of  regions,  in 

particular through cultural tourism,  

(cid:190)  to the sharing of experiences and exchange of best practices across Europe as 

regards the enhancement of its cultural heritage, 

(cid:190)  more generally, to the promotion of democratic values and human rights that 

form the foundation of European integration and European citizenship. 

It is important to underline that the economic dimension of the EHL was not taken 
into account in the intergovernmental initiative. 

One of the main concerns of the MS during the negotiations was to avoid duplication 
with existing initiatives such as the UNESCO World Heritage List and the Council of 
Europe's  "European  Cultural  Routes"  and  to  seek  synergies  and  complementarities 
instead.  It  was  therefore  stated  very  clearly  during  the  discussions  that  the  added 
value of the EHL should be based (1) on the contribution made by the selected sites 
to European history and culture, (2) on a clear educational dimension reaching out to 
citizens,  and  (3)  on  the  networking  of  the  sites.  It  has  become  clear  during  the 
negotiations  that  the  main  focus  of  the  EHL  must  be  the  interpretation  and  the 
promotion  of  the  sites  and  not  on  conservation  and  protection.  It  is  also  very 
important  that  the  EHL,  unlike  other  existing  initiatives,  should  not  be  awarded  on 
the  basis  of  the  aesthetic  value  of  a  site,  for  example  its  natural  beauty  or 
architectural quality, but strictly on the basis of its symbolic value, in other words on 
the  basis  of  what  it  represents  or  stands for  in  the  common  history  of  Europe.  The 
options which have been tested all take into account this essential starting point. 

 While  the  EHL  is  considered  as  a  particularly  important  initiative  by  several  MS, 
notably those which are at the origin of the intergovernmental initiative, some other 
MS  were  more  hesitant  about  the  added  value  of  this  label  and  the  actual  need  to 
make  it  a  formal  EU  initiative.  Therefore,  before  the  adoption  of  the  Council 

EN 

7 

   EN 

 
conclusions there was a consensus between the MS that the new "communautarised" 
initiative  should  have  very  limited  consequences  both  on  the  EU  budget  and  on 
national budgets and that the participation of MS should be on a voluntary basis.   

In  order  to  improve  the  implementation  of  the  EHL,  the  conclusions  dedicate  a 
considerable attention to the procedures and the practical arrangements of the future 
Label. The MS could reach an agreement on a number of principles:  

(cid:190)  The selection of sites should be on a regular basis and based on criteria that 

are common, clear and transparent; 

(cid:190)  The selection should be carried out initially at national and then at European 

level based on expert assessment; 

(cid:190)  The  number  of  sites  covered  each  time  should  be  reasonable  and 

representative; 

(cid:190)  The  administrative  arrangements  should  be  flexible  and  streamlined,  in 

compliance with the subsidiarity principle; 

(cid:190)  Recipients  should  be  required  to  comply  with  undertakings  they  have  given 

and could be subject to periodic review; 

(cid:190)  Sites already awarded the Label under the intergovernmental initiative should 

be taken into account and their status defined; 

(cid:190)  The  initiative  could  draw  on  existing  EU  funding,  without  prejudice  to  the 

support policies conducted by each of the Member States; 

(cid:190)  The initiative could also be open to third countries participating in the EU's 
Culture  Programme  as  there  was  an  assumption  that  the  costs  for  these 
countries might be covered by the programme. 

At  the  same  time,  a  number  of  questions  were  also  left  open  for  further  analysis 
during  the  negotiations  and  the  MS  underlined  that  they  expect  the  Commission  to 
come forward with concrete proposals. These questions which can be summarised as 
follows became a central element of the subsequent consultation process: 

(cid:190)  What precisely is a reasonable and representative number of sites? 

(cid:190)  Shall the label be attributed to the sites for a limited period of time or on a 

permanent basis? 

(cid:190)  Shall the label be attributed on the basis of an open competition or shall there 

be a reserved quota of sites for each MS? 

(cid:190)  In  the  event  of  a  quota  system,  how  to  determine  the  number  of  sites  per 
country and should a system of rotation between the MS be implemented in 
order to keep control over the total number of labelled sites and to help keep 
the selection and monitoring procedures manageable? 

EN 

8 

   EN 

 
(cid:190)  How to articulate the national level and the European level for the selection 
and monitoring procedures in order to ensure an homogeneous application of 
the rules while respecting the principle of subsidiarity? 

The MS were unanimous that new common, clear and transparent criteria and their 
proper application were essential for the renewed EHL. These criteria were discussed 
at  great  length  during  the  negotiations  and  the  main  elements  were  included  in  the 
conclusions.  Several  considerations  were  taken  into  account.  Firstly,  the  need  to 
ensure  that  there  will  be  no  overlap  with  other  existing  initiatives  in  the  field  of 
cultural heritage and to guarantee the added value of the EHL. Secondly, the need to 
ensure that the criteria will be efficient and unambiguous and at the same time that 
they  will  maintain  a  degree  of  flexibility  in  accordance  with  the  principle  of 
subsidiarity, respecting the multitude and diversity of potential sites, and the reality 
that the evaluation of the sites will inevitably have a subjective element. The national 
and  European  selection  panels  therefore  need  to  have  some  discretion  and  the 
experience  of  the  European  Capitals  of  Culture  was  mentioned  as  a  source  of 
inspiration.  Finally,  it  will  be  important  to  adapt  the  level  of  requirements  for  the 
management of the sites to the specificity of each site. A very diverse range of sites 
can potentially be awarded the label: whereas ambitious educational, information or 
promotion  activities  could  be  feasible  from  prestigious  sites  with  a  strong  touristic 
potential, the criteria might well be met in a more modest way in the case of smaller 
sites with a strong symbolic value. 

Because of the lengthy negotiations which already took place in the Council on the 
criteria  and  the  limited  room  for  manoeuvre  on  this  matter,  and  because  the  main 
challenge  for  the  EHL  will  be  the  proper  application  of  these  criteria  through  an 
effective process, it has been decided to present the criteria in greater detail in annex 
3 to this report and to limit the current IA to a discussion of the label's administrative 
arrangements. 

1.2. 

Consultation of interested parties 

Broad consultation has been undertaken in order to understand the various views on 
the EHL and to obtain necessary evidence. The consultation process started in March 
2009 and was carried out in different stages for which all the required Commission 
consultation  standards  were  applied.  The  results  of  the  different  elements  of  the 
consultation  are  summarized  below  and  were  duly  taken  into  account  for  the 
subsequent steps of our analysis. 

1.2.1. Internal consultations 

The existing Inter-service Group for Culture met three times for the IA of the EHL. 
At  the  first  meeting  on  9  March  2009  the  general  context  of  the  EHL  and  the 
roadmap for the IA were discussed. The objective of the second meeting on 29 June 
was  to  present  the  main  results  of  the  public  consultation.  The  aim  of  the  third 
meeting  on  19  October  was  to  discuss  the  first  draft  of  the  present  IA  report.  The 
comments of the group were taken into account for the finalisation of the report. 

 In  addition  to  colleagues  from  various  departments  of  DG  EAC,  representatives 
from SG, SJ, DG ELARG, DG ENTR, DG INFSO and DG MARE participated in at 
least one of the meetings. DG COMP, DG RTD, AIDCO, BEPA and ESTAT while 

EN 

9 

   EN 

 
 
not present at the meetings have asked to be kept informed about the various steps of 
the process. DG BUDG, DG AGRI, DG COMM, DG DEV, DG EMPL, DG ENV, 
DG  JLS,  DG  MARKT,  DG  RELEX,  DG  REGIO,  DG  TAXUD  and  DG  TRADE 
were invited but did not participate in the process. 

1.2.2.  Consultation of stakeholders and European citizens 

1.2.2.1 

Online consultation 

An  online  consultation  was  held  between  20  March  to  15  May  2009,  to  gather 
comments  from  the  public.  This  consultation  was  carried  out  with  the  help  of  the 
Interactive  Policy  Making  tool  and  was  accessible  in  six  languages.  We  received  a 
total  of  226  answers.  72%  of  the  answers  were  from  individuals,  17%from 
organisations and 11%from public authorities. However caution needs to be applied 
when interpreting these figures as it was apparent in some answers that some smaller 
organisations  preferred  to  answer  as  individuals  in  order  to  avoid  the  burden  of 
registering in the Register of Interest Representatives. 

The  consultation  consisted  of  18  questions.  Some  of  these  questions  were  single 
choice  questions  and  enabled  a  quantitative  analysis  to  be  made.  Other  questions 
were  open  questions  intended  for  a  qualitative  analysis.  The  statistics  displayed 
below  are  simply  meant  to  indicate  the  general  trends  within  the  consultation.  The 
sample  is  of  course  limited,  making  it  difficult  to  draw  general  conclusions  at  the 
European level. 

The main results of the online consultation were the following2: 

(cid:190)  Only  42%  of 

the  participants  had  previously  heard  about 

the 
intergovernmental  EHL.  This  low  percentage  is  surprising  given  that  the 
majority of participants in the consultation had a pre-existing interest in the 
cultural heritage field. 

(cid:190)  89%  believe  that  the  EHL  can  contribute  to  a  greater  sense  of  belonging  to 

the EU.  

(cid:190)  90% believe that the involvement of the EU will bring an added value to the 

EHL.  

(cid:190)  Concerning  the  potential  impacts  of  the  EHL,  the  following  elements  were 
mentioned: a greater sense of common belonging, the promotion of European 
values,  a  higher  profile  for  cultural  heritage,  the  strong  educational  value 
especially  for  young  people,  and  economic  development  notably  through 
tourism. 

(cid:190)  The  following  challenges  and  risks  were  mentioned:  the  potentially  limited 
impacts  of  the  initiative,  heavy  bureaucracy,  the  costs,  a  risk  of  duplication 
with  the  UNESCO  World  Heritage  List  or  the  Council  of  Europe  Cultural 
Routes or the lack of clarity concerning the objectives and selection criteria 

2 

The full report can be consulted at the following link: 
http://ec.europa.eu/culture/our-programmes-and-actions/doc/consultation_analysis_report_160709.pdf 

EN 

10 

   EN 

 
 
 
                                                 
 
which was considered as the main weakness of the current intergovernmental 
initiative. It is very important to note that these perceived risks and challenges 
were mostly expressed in answers which were generally positive to the EHL. 
The  11%  of  answers  mentioned  above  which  were  negative  concerning  the 
EHL  and  the  10%  of  answers  which  were  negative  concerning  the 
involvement  of  the  EU  were  either  not  explained  or  did  not  enable  any 
general trends to be drawn.  

(cid:190)  The expected benefits from EU involvement are the following: a strengthened 
legitimacy  and  credibility  for  the  EHL,  clearer  and  more  transparent 
objectives  and  criteria,  greater  impact  of  the  Label  due  to  a  permanent 
secretariat, 
countries, 
networking of sites, and better visibility of the EHL. 

coordination  between  participating 

improved 

(cid:190)  The originality of the EHL compared to other existing initiatives in the field 
of heritage should be based on: its strong European dimension, its educational 
dimension, the fact that the symbolic value of sites is more important than the 
aesthetic  dimension,  the  fact  that  pedagogic  and  cultural  programmes  are  at 
the  core  of  the  initiative  rather  than  conservation,  and  the  added  value 
obtained from the networking of sites. 

(cid:190)  Opinions  were  quite  divided  concerning  the  question  of  whether  the  EHL 
should  be  attributed  on  a  permanent  basis  (54%)  or  for  a  limited  duration 
(46%).  It  is  interesting  to  note  that  those  who  were  in  favour  of  a  limited 
duration generally considered that this period should be renewable and those 
who  were  in  favour  of  a  permanent  attribution  underlined  the  need  for  a 
strong  monitoring  system  and  ensuring  the  possibility  of  withdrawing  the 
label if the sites no longer comply with the criteria. 

(cid:190)  Opinions  were  also  divided  concerning  national  quotas  and  the  number  of 
sites  which  should  be  attributed  to  each  country.  A  significant  number  of 
participants  underlined  that  any  quota  set  in  advance  would  end  up  being 
artificial and arbitrary and preferred instead an open competition at European 
level  which  does  not  take  into  account  the  national  origin  of  the  candidate 
sites.  

1.2.2.2 

Consultation meeting 

On 10 June 2009, a consultation meeting took place in Brussels3. This meeting was 
open to all interested individuals and organisations, rather than a pre-selected set of 
stakeholders. 71 participants registered including representatives of key international 
and national organisations active in the field of heritage, public authorities (national, 
regional  and  local  level),  heritage  sites  which  had  been  awarded  the  EHL  in  the 
framework of the intergovernmental initiative, academics and students. 

The  meeting  was  very  constructive  and  generally  positive  for  the  EHL.  The 
discussions  were  framed  around  the  same  questions  as  the  online  consultation  and 
confirmed  its  main  results.  The  same  trends  emerged  concerning  the  potential 

3 

The report of this meeting is in Annex 1. 

EN 

11 

   EN 

 
 
                                                 
impacts  of  the  EHL,  its  originality  or  the  added  value  of  EU  intervention,  and  the 
same divisions appeared concerning the practical arrangements for the initiative. 

Five elements need to be underlined: 

(cid:190)  Representatives of the French Ministry of Culture which was at the origin at 
the EHL and of the Spanish Ministry of Culture which currently carries out 
the  secretariat  of  the  intergovernmental  initiative  chose  to  take  part  in  the 
meeting,  and  on  multiple  occasions  during  the  day  the  other  participants 
made use of that to ask them for precisions concerning the actual objectives 
and procedures of the intergovernmental initiative. This was evidence of how 
little  the  current  intergovernmental  label  is  known,  even  by  the  main 
stakeholders in the heritage sector.  

(cid:190)  There  was  general  consensus  that  the EHL  has  a  value  of  its  own  and  does 
not  overlap  with  other  existing  initiatives,  such  as  the  UNESCO  World 
Heritage  List,  the  Council  of  Europe  Cultural  Routes  or  the  EU  Prize  for 
Cultural Heritage / Europa Nostra Awards. This was clearly confirmed by the 
representatives  of  ICOMOS  (consultative  body  for  the  UNESCO  World 
Heritage List), the European Institute of Cultural Routes and Europa Nostra 
which were present at the meeting. Nevertheless it demonstrated that clearer 
communication would be needed to clarify the differences, especially for the 
general  public  (concerning  the  other  initiatives  in  the  field  of  cultural 
heritage, see also annex 7). 

(cid:190)  Opinions were clearly divided concerning the selection procedures to award 
the label. On the one hand, several representatives from civil society were in 
favour of an open competition at European level only in order to encourage 
the  application  of  transnational  sites,  to  ensure  that  the  selection  would  be 
based on quality alone and to keep the practical arrangements light. They also 
underlined that some MS had a greater pool of relevant sites than others. On 
the other hand, representatives of national authorities insisted on the need to 
have a selection first at national and then only at European level. In their view 
this would be the only way to deliver a fair geographical distribution of labels 
across  the  EU  and  thus  to  ensure  the  continuing  participation  and 
commitment  of  MS  in  the  initiative,  and  the  possibility  to  reach  as  large  a 
number of citizens as possible. 

(cid:190)  In a first stage, opinions  were also divided concerning the attribution  of the 
EHL  on  a  permanent  basis  or  for  a  limited  duration.  Some  representatives 
from civil society were in favour of a limited duration because this would be 
more  effective  in  terms  of  keeping  control  over  the  overall  number  of  sites 
and ensuring that the labelled sites continue to comply with the criteria and 
remain active. In contrast, managers of heritage sites were totally opposed to 
a  limited  duration  because  this  would  be  counter-cultural  for  the  heritage 
sector which is used to working on a long-term basis and because this would 
undermine  the  incentives  for  sites  to  invest  in  their  development.  They 
expressed their concern that such a decision would be felt by the sector as a 
very  awkward  decision  imposed  by  "Brussels".  The  site  managers  were 
supported  by  the  representatives  of  national  authorities  who  also  underlined 
that the EHL would be awarded mainly on the basis of the symbolic value of 

EN 

12 

   EN 

 
sites  and  that  this  symbolic  would  not  diminish  over  time.  Over  the  debate, 
several  civil  society  organisations,  notably  Europa  Nostra,  changed  their 
positions and a very clear consensus emerged amongst all the participants that 
the best solution would be the attribution of the EHL on a permanent basis, 
but  with  a  strong  monitoring  procedure  and  the  possibility  to  withdraw  the 
label.   

(cid:190)  With  regards  to  impacts,  there  was  a  consensus  amongst  participants  that 
these would be first and foremost political and educational impacts, in other 
words  social  impacts,  and  that  the  initiative  should  focus  mainly  on  these 
social impacts at the outset in order not to blur its message. There was also an 
interesting  view  expressed  that  the  social  impacts  should  actually  be 
expressed in terms of 'societal' impacts in order to emphasise that the primary 
effects  were  not  about  social  inequality  but  about  identities.  Opinions  were 
rather mixed about the potential economic impacts because a great variety of 
sites  can  potentially  be  awarded  the  label  and  their  touristic  appeal  will 
greatly depend on their nature, size or location. Furthermore, the contribution 
of the EHL will greatly depend on the prestige the label will acquire and thus 
on  its  quality  and  credibility,  and  this  was  considered  by  participants  as  a 
potential  benefit  more  likely  to  occur  in  the  long-term  (this  issue  will  be 
further discussed in section 3).  

1.2.3. Consultation meeting with MS experts 

On 24 June 2009, a meeting took place in Brussels with experts designated by the 27 
MS4. The concept of this meeting was different from the meeting with stakeholders 
and citizens. As mentioned above, the MS had already had the opportunity to express 
their  individual  opinions  on  the  EHL  during  the  negotiations  for  the  Council 
conclusions  and  the  adopted  text  gives  a  fairly  detailed  view  of  their  common 
expectations. However a number of issues concerning the practical arrangements of 
the future EHL were left open for further analysis. Therefore the aim of this meeting 
was twofold: (1) to inform the MS about the progresses of the IA and the first results 
of the consultation of stakeholders and citizens and (2) to make substantial progress 
on the questions which were still open. To this end, a discussion paper summarising 
the  main  issues  at  stake  and  proposing  general orientations for the  discussions  was 
sent to the participants two weeks before the meeting.  

The  27  MS  sent  experts  to  this  meeting  and  all  of  them,  including  the  MS  which 
were  more  reluctant  during  the  negotiations  for  the  adoption  of  the  conclusions, 
contributed  very  constructively  to  the  debate.  At  this  stage  it  is  likely  that  a  very 
large majority of the MS would join the new "communautarised" label. 

 A general consensus emerged between MS on several issues: 

(cid:190)  the  EHL  should  be  attributed  on  a  permanent  basis.  The  two  main  reasons 
expressed  by  the  27  MS  are  very  close  to  the  conclusions  which  emerged 
during the consultation meeting with the stakeholders: (1) the label seeks to 
denote  cultural  heritage  that  has  played  a  key  role  in  European  history  and 

4 

The report of this meeting is in Annex 2. 

EN 

13 

   EN 

 
 
                                                 
which therefore has a symbolic value which does not diminish over time, and 
(2)  it  would  be  more  likely  to  encourage sites to take  a  long term approach 
and  to  invest  in  their  development.  The  MS  also  agreed  that  the  permanent 
attribution  of  the  label  should  be  linked  to  strong  monitoring  and  review 
processes and the possibility to withdraw the label;  

(cid:190)  a  selection  procedure  at  European  level  only  –as  advocated  by  some 
stakeholders- is not acceptable for the MS.  They confirmed  their wish  for a 
two level approach. Several MS insisted that if the selection should take place 
at one level only, it should be the national level; 

(cid:190)  a  rotation  system  between  the  MS  is  an  acceptable  solution  to  keep  the 
number  of  sites  reasonable  and  to  facilitate  the  practical  arrangements 
(several MS suggested that a good compromise would be the participation of 
one third of the countries every year); 

(cid:190)  there  should  be  a  certain  element  of  competition  for  the  attribution  of  the 

label; 

(cid:190)  a permanent secretariat for the EHL is essential;  

(cid:190)  the  EHL  could  be  open  to  the  countries  participating  in  the  Culture 
programme, but as the implementation of the initiative is quite complex, it is 
wise  to  start  first  with  the  27  MS  before  thinking  about  enlarging  the 
initiative; 

(cid:190)  the application of transnational sites should be encouraged.  

However,  despite  the  progress  made  during  the  meeting,  certain  challenging 
questions remained open either because there were still divergences between MS (are 
national quotas needed? what is a reasonable number of labelled sites?) or, because 
the positions  expressed by some  of  the MS  were not entirely  free of contradictions 
(How to reconcile the wish to have an open competition at European level with the 
will  to  keep  a  pre-selection  at  national  level?  how  to  foster  the  selection  of 
transnational  sites  while  setting  quotas  of  sites  per  country?  how  to  ensure  the 
excellence of the EHL and the relevance and quality of the selected sites without any 
limitations on the number of labels awarded each year?)  

1.2.4. External services 

Although  most  of  the  work  has  been  conducted  in-house,  and  was  based  on  the 
consultation steps described above, some support services to assist the Commission 
in  the  preparation  of  the  IA  have  been  asked  from  ECOTEC  as  part  of  a  DG 
Education and Culture framework contract with this consultant. 

The main tasks requested of ECOTEC were: (1) to identify and analyse the existing 
literature  and  data  in  the  field  (2)  to  evaluate  the  strengths  and  weaknesses  of  the 
current  intergovernmental  EHL  (3)  to  analyse  other  international  cultural  and 
heritage  schemes,  as  well  as  other  EU  labels,  in  order  to  limit  risks  of  overlap  and 
learn any lessons (4) to assist the Commission in the analysis of the answers to the 
online  consultation  and  (5)  to  provide  the  Commission  with  additional  expertise 

EN 

14 

   EN 

 
 
concerning the identification of the potential impacts of the EHL, the comparison of 
the  options  and  the  definition  of  monitoring  and  evaluation  indicators.  The  main 
results  of  ECOTEC's  work  are  summarized  in  a  report5.  Sections  5,  6  and  7  of  the 
present  report  prepared  by  the  services  of  the  Commission  draws  many  elements 
form ECOTEC's support services. 

The  regular  meetings  and  exchanges  with  ECOTEC  experts'  also  provided  the 
Commission  with  a  good  opportunity  to  test  and  to  fine  tune  its  own  ideas 
concerning the objectives of the EHL, the policy options and the development of the 
preferred option. 

2. 

SECTION 2: PROBLEM DEFINITION 

2.1. 

Problem 

2.1.1. The problem in 2005 when the intergovernmental EHL was conceived 

As mentioned in the previous section, the concept of the EHL was born as one of the 
responses  to  the  problem  of  the  existing  gap  between  the  EU  and  its  citizens  and 
between  the  reality  of  European  integration  and  people's  perceptions.  This  gap  is 
linked to an important extent to a lack of knowledge of the history of Europe, of the 
role of the EU and of the functioning of its institutions.  

The  aim  of  the  EHL  was  to  use  the  potential  of  cultural  heritage  to  strengthen 
European  citizens'  sense  of  belonging  to  Europe  and  promote  a  sense  of  European 
identity.  It  is  important  to  note  that  right  from  the  start,  it  was  clear  that  the  EHL 
alone could not fill the gap between citizens and the EU. It was meant more modestly 
to  be  one  contribution  alongside  other  initiatives  aimed  at  addressing  the  same 
problem such as for example the "Plan D for Democracy, Dialogue and Debate" or 
"Communicating  Europe  in  Partnership"  of  DG  Communication  or  the  Europe  for 
Citizens programme.  

This  leads  us  to  a  second  level  of  the  problem  which  is  that  the  reading  or 
interpretation of cultural heritage in Europe, including of the most symbolic sites of 
our shared heritage, is still to a very large extent  a  national reading. The European 
dimension  of  our  common  heritage  is  insufficiently  highlighted  and  its  potential  to 
stimulate  intercultural  dialogue  is  insufficiently  exploited.  This  situation  has  been 
the 
clearly  acknowledged  by 
intergovernmental EHL and this initiative aimed to tackle this problem by identifying 
and designating sites which have played a key role in building and uniting Europe, 
promoting a European reading of these sites, developing their educational potential, 
and fostering the exchange of experience and of best practices.  

the  Ministers  of  Culture  who 

launched 

The launch of the intergovernmental EHL was backed by a statistical survey carried 
out  in  five  MS  (Finland,  France,  Germany,  Hungary  and  Italy)  in  March  2007  by 
IPSOS  for  the  French  Ministry  of  Culture6.  This  survey  showed  that  60  %  of  the 
respondents believed that shared cultural heritage could contribute to a greater sense 

5 
6 

The full report can be consulted on:http://ec.europa.eu/dgs/education_culture/evalreports/index_en.htm  
http://www.culture.gouv.fr/culture/actualites/index-labeleurope.html 

EN 

15 

   EN 

 
 
                                                 
of  belonging  to  Europe  (85%  in  Italy,  76%  in  France,  but  only  11%  in  Hungary). 
However, the definition  of  what national heritage is and what European heritage is 
varied  considerably  from  one  country  to  another,  and  49%  of  the  respondents 
believed  that  European  cultural  heritage  is  merely  the  addition  of  the  national 
heritage of European countries, while only 45% believed in the existence of a truly 
common cultural heritage shared by the inhabitants of the European Union. It is also 
interesting  to  note  that  Hungary,  the  only  new  Member  State  participating  in  this 
Survey, had a much more hesitant approach towards the common heritage of Europe 
than  the  other  participating  countries:  5%  only  of  the  Hungarian  respondents 
believed  that  their  national  cultural  heritage  "is  completely  a  part"  of  European 
cultural heritage (52% in Italy, average 28%),   59% believed that Europe represents 
a risk for Hungary's own identity (13% in Italy, average 34%), and 29% only of the 
Hungarian  respondents  answered  that  they  were  more  interested  in  the  cultural 
heritage of other EU MS  than a few years ago (51% in Germany, average 44%). 

A Eurobarometer survey on cultural values in Europe carried out for DG Education 
and  Culture  in  September  20077  confirmed  the  overall  tendencies  of  the  IPSOS 
survey. The aim of this survey was to measure public opinion on culture and values 
in  Europe  and  to  form  an  initial  insight  into  the  ways  in  which  citizens  think  and 
behave in this area, as well as to provide benchmarks against which future evolutions 
can be tracked. The survey was carried out by TNS Opinion & Social, interviewing 
26,755  citizens  in  the  27  MS.  53%  of  respondents  agreed  with  the  statement  that 
Europe  is  too  diverse  to  speak  of  a  common  European  culture  (38%  disagreed), 
however  77%  agreed  that  the  richness  of  Europe's  culture  comes  from  the  history 
shared  by  its  countries.  The  Eurobarometer  also  showed  that  respondents  are  as 
likely to be interested in arts and culture in the rest of the world as in other European 
countries (13-14% being very interested and 43% fairly interested). The survey also 
asked  people  about  the  ways  in  which  Europeans  could  be  assisted  to  get  to  know 
one  another  better:  22%  answered  support  to  heritage  compared  to  56%  who 
answered  teaching  of  foreign  languages  or  41%  mentioning  increased  student  and 
teacher exchange programmes like Erasmus. This shows us on the one hand that the 
ambitions of the EHL in bringing citizens closer to each other and closer to Europe 
should remain modest, and that the label will most probably not reach the same level 
of  impacts  in  this  respect  as  student  exchanges  or  language  learning.  On  the  other 
hand,  this  also  suggests  that  the  potential  role  of  heritage  in  developing  mutual 
understanding is not sufficiently recognised and exploited and that there is room for 
improvement. 

2.1.2. The problem today 

In 2009, four years after the concept of the EHL was born, it is obvious that the gap 
between citizens and the EU still exists. This has been demonstrated recently by the 
disappointing  turnout  in  the  European  elections  in  June  2009.  This  has  also  been 
demonstrated  by  a  number  of  Eurobarometer  surveys  such  as  for  example  the 
Eurobarometer 70 published in December 2008 which shows that the perception of 
the image of the EU has not improved over the past few years. On the contrary the 

7 

http://ec.europa.eu/dgs/education_culture/publ/pdf/culture/barometer_en.pdf 

EN 

16 

   EN 

 
 
                                                 
number  of  Europeans  who  have  a  positive  image  of  the  EU  (45%)  is  at  its  lowest 
level since the autumn of 20058. 

At  the  second  level  of  the  problem,  it  is  also  clear  that  the  EHL  did  not  achieve 
concrete results so far despite the attribution of the Label to 64 sites since 20079. The 
European  dimension  of  our  common  heritage  is  still  very  insufficiently  highlighted 
and its potential insufficiently exploited.  This is due in part to the fact that the EHL 
is  only  very  recent  and  that  the  problem  it  seeks  to  address  is  complex  and  deep-
rooted.  It  would  probably  have  been  surprising  to  find  any  major  shift  so  quickly. 
But this is due also to the fact that the EHL is still very far from having reached its 
full  potential  and  its  implementation  shows  many  deficiencies  which  need  to 
addressed as we will see in the next section, notably concerning the educational and 
networking aspects10. 

2.2. 

Baseline Scenario: the existing intergovernmental EHL 

2.2.1  Rationale, objectives and procedures of the intergovernmental EHL 

The rationale behind the intergovernmental EHL as described in the introduction to 
the EHL adopted by the participating countries on 25 January 2007 is that "Cultural 
heritage forms an integral part of our European identity and of our shared values and 
principles.  Today’s  European  culture  is  based  on  a  history  of  border  crossing 
exchange  and  dialogue,  of  interaction  and  transfer  of  people  and  values,  of  ideas, 
artistic  movements  and  works  of  art.  The  EHL  was  designed  to  promote  the 
transnational European dimension of cultural property, monuments, natural or urban 
sites,  tangible  and  intangible,  contemporary  and  traditional  heritage  and  sites  that 
have played a key role in building and uniting Europe." 

The introduction to the EHL outlines the central objectives of the initiative which are 
"to strengthen the support of European citizens for a shared European identity based 
on  democratic  values  and  human  rights,  and  to  foster  a  sense  of  belonging  to  a 
common  cultural  space".  The  intergovernmental  EHL  also  aims  "to  encourage 
people’s  understanding  of,  and  respect  and  support  for,  their  heritage  and  it 
represents a means of protecting and promoting our cultural heritage, with the aim of 
identifying and passing on that heritage to future generations". 

In order to achieve these objectives, participating countries and labelled sites have to 
undertake  education  and  information  activities  to  promote  the  European  dimension 
of  heritage,  as  well  as  artistic  and  cultural  activities  to  foster  synergies  between 
heritage and contemporary creation and creativity. They have to ensure the quality of 
facilities, notably accessibility for all members of the public. The establishment of a 
dynamic network of labelled sites is also foreseen. 

Rules  of  procedure  for  the  EHL  were  adopted  on  25  January  2007.  If  the  main 
responsibility for the selection of sites and the implementation of the label remains at 

8 
9 
10 

http://ec.europa.eu/public_opinion/archives/eb/eb70/eb70_first_en.pdf 
The list of these sites is in Annex 4. 
An  evaluation  of  the  intergovernmental  EHL  was  carried  out  by  ECOTEC  (see  Section  2.2.2).  The 
results are part of the ECOTEC report: 
http://ec.europa.eu/dgs/education_culture/evalreports/index_en.htm 

EN 

17 

   EN 

 
 
                                                 
 
national  level,  the  creation  of  a  European  heritage  committee  composed  of  the 
Ministries of Culture or their representatives (supported if necessary by consultative 
bodies) is foreseen. The role of this committee is to seek a consensus on the sites pre-
selected at national level and to take the final decision on the attribution of the Label, 
as well as to establish a quality charter and to adopt the rules for the implementation 
of the EHL. A withdrawal clause is included to enable the exclusion from the list of 
sites  which  do  not  respect  the  rules  and  conditions.  A  transitional  clause  mentions 
that in a first stage each country can designate a maximum of 4 sites. 

2.2.2  The weaknesses of the current intergovernmental EHL 

The weaknesses of the current EHL became evident as soon as the Commission started 
to look into this initiative. To name just two examples:  

(cid:190)  Up  to  the  beginning  of  2009,  absolutely  no  structured  information  on  the 
EHL was available on the internet. Some bits and pieces such as speeches or 
press  releases  were  scattered  on  a  variety  of  sites,  but  it  was  almost 
impossible  for  an  interested  individual  or  organisation  to  assemble  these 
elements  into  coherent  and  reliable  information.  The  situation  started  to 
evolve  in  March  2009  when  the  Spanish  Ministry  of  Culture  launched  the 
first  web-pages  dedicated  to  the  EHL.  These  web  pages  are  however  rather 
difficult to locate for the general public because they are embedded within the 
Ministry's  website.  They  were  also  initially  accessible  only  in  Spanish,  and 
the  pages  are  now  gradually  being  translated  into  other  languages.  This  is 
without any doubt one of the reasons why there is not much awareness of the 
existence  of  the  EHL,  and  why  even  the  main  stakeholders  in  the  field  of 
cultural  heritage  do  not  have  a  clear  understanding  of  its  precise  objectives 
and  procedures,  as  was  demonstrated  by  the  various  steps  of  the  public 
consultation. 

(cid:190)  As mentioned earlier, 64 sites in 18 countries have been awarded the label so 
far,  but  no  database  with  the  names  and  contact  details  of  all  the  site 
managers exists. To this date, it was not possible for the Spanish Ministry to 
collect the necessary data from the participating countries, which also means 
that the secretariat of the EHL cannot get directly in touch with the managers 
of the 64 sites. 

A  more  detailed  evaluation  of  the  strength  and  weaknesses  of  the  initiative  was 
carried  out  by  ECOTEC  as  part  of  their  support  services  and  confirmed  the  first 
impressions.  This  evaluation  was  based  on  a  close  examination  of  all  the  official 
documents of the intergovernmental initiative (rules of procedure, application forms, 
etc…),  interviews  with  Ministry  officials,  interviews  with  stakeholders,  interviews 
and questionnaires sent to site managers and site visits.  

The  main  findings  of  the  evaluation  of  the  intergovernmental  EHL  can  be 
summarized as follows: 

(cid:190)  The  lack  of  clear  and  transparent  objectives  and  procedures  is  the  main 
criticism  that  was  made  to  the  EHL  during  the  negotiations  for  the  Council 
conclusions and during the public consultation.  A deeper examination shows 
that  the  label  actually  has  fairly  ambitious  and  coherent  objectives,  even  if 

EN 

18 

   EN 

 
 
they  leave  too  much  room  for  diverging  interpretations,  and  that  rules  of 
procedures  were  established  to  try  to  reach  these  objectives.  The  main 
problem is that to this date these rules of procedures were either not applied 
or insufficiently applied. 

(cid:190)  Despite all the enthusiasm and good will shown by the current secretariat of 
the  initiative  whose  activities  are  performed  counting  on  support  from  the 
Spanish Ministry of Culture alone, the present form of revolving secretariat is 
not an optimal form of organisation for a complex initiative such as this. The 
lack of continuity does not enable a long term-approach to be developed and 
the building up of the necessary expertise. 

(cid:190)  So far, the sites have been selected independently by participating countries 
and  the  interpretation  and  application  of  the  selection  criteria  varied 
considerably from one country to another. The European committee foreseen 
in the rules of procedures was never established and as a result there was no 
overseeing body to take the final decision on the attribution of the Label and 
to  ensure  the  quality  of  the  process  in  all  regards.  As  a  consequence,  the 
nature  of  the  selected  sites,  their  relevance,  and  their  activities  are  rather 
disparate and in some cases difficult to comprehend.  

(cid:190)  With  the  present  organisation,  there  is  no  means,  via  the  secretariat,  to  be 
assured  that  sites  gaining  the  label  are  maintained  to  any  quality  levels 
indicated  in  their  original  application,  or  are  undertaking  activities  in  line 
with the label to a degree of quality which reflects the merit associated with 
the label. 

(cid:190)  The  educational  aspects  are  regarded  as  fundamental  by  the  institutional 
stakeholders and the site managers interviewed by ECOTEC, and some sites 
have  developed  interesting  programmes,  however  there  is  no  evidence  that 
these programmes have evolved since the attribution of the label or that the 
European dimension has been strengthened. 

(cid:190)  The  networking  between  sites  has  limited  itself  so  far  to  one  meeting 
organised by the French Presidency of the EU in Avignon in December 2008 
which  brought  together  representatives  from  the  first  set  of  labelled  sites. 
Little real progress has been made in promoting the transnational dimension 
of the EHL. 

(cid:190)  Concerning  promotion  and  communication,  as  mentioned  before,  except  for 
the  web-pages  recently  developed  by  the  Spanish  Ministry  of  Culture  very 
little has been done to effectively promote the EHL at a transnational level, 
neither for the heritage and culture community, nor for the general public. At 
national level, there is no evidence of an effective promotion of the EHL by 
the  Ministries.  At  the  level  of  the  64  labelled  sites,  42  have  a  website  and 
only 8 actually display the EHL logo as part of their web-pages. 

(cid:190)  The EHL has achieved few concrete results so far, and since the initial wave 
of  labelling  there  has  been  little  forward  momentum  with  the  initiative.  In 
order  to  make  an  impact,  the  EHL  needs  to  take  a  qualitative  step  forward. 

EN 

19 

   EN 

 
This  means  at  minimum  implementing  the  current  rules  and  procedures, 
before addressing all their limitations.  

2.2.4  How would the problem evolve, all things being equal?  

In the event that no action is taken by the EU, the most probable scenario is that the 
EHL  would  continue  as  an  intergovernmental  initiative,  even  if  several  MS  have 
raised  their  concern  that  under  the  present  revolving  secretariat  of  the  EHL  the 
durability of the initiative is far from being ensured. After France in the initial phase 
and now Spain, no other MS has volunteered so far to take over the secretariat. Spain 
already drew attention to the burden created by the current situation and underlined 
that such a revolving secretariat could only be a transitional solution while waiting 
for the creation of a permanent secretariat. 

If the EHL continues as an intergovernmental initiative, the initiative needs to take a 
qualitative step forward in order to achieve concrete results and to make an impact. 
However,  at  the  present  moment,  there  is  absolutely  no  sign  that  the  countries 
participating  in  the  intergovernmental  EHL  are  ready  to  take  a  more  proactive 
approach without EU involvement. Therefore, the chances are very high that at best 
the  intergovernmental  approach  will  continue  with  a  very  low  profile  and  with  no 
significant results.  

2.3. 

Legal basis and subsidiarity 

The  legal  basis  for  this  initiative  can  be  found  in  article  167  of  the  Treaty  on  the 
Functioning  of  the  European  Union.  This  article  gives  the  EU  the  mandate  to 
"contribute to the flowering of the cultures of the MS, while respecting their national 
and regional diversity and at the same time bringing the common cultural heritage to 
the  fore".  The  EU  shall  also  encourage  "cooperation  between  MS"  in  the  field  of 
culture and "if necessary, support and supplement their action". In accordance, with 
the Council conclusions, the participation of the MS would be on a voluntary basis. 
EU involvement in the EHL is expected to reinforce coordination between MS and 
thus to contribute to the development and the application of new common, clear and 
transparent selection criteria, as well as new selection and monitoring procedures for 
the EHL, thereby ensuring the relevance of the sites in the light of the objectives. The 
results of the evaluation of the current EHL mentioned above demonstrated that this 
could  not  be  achieved  with  the  intergovernmental  arrangements.  Other  expected 
benefits of EU action are increasing the number of MS participating in the initiative, 
fostering the participation of transnational sites and resolving the problems linked to 
the present revolving secretariat. According to the MS, this should help to improve 
the  value  of  the  initiative  in  order  to  ensure  the  quality,  credibility  and  long-term 
success of the EHL. 

3. 

SECTION 3: OBJECTIVES 

 The  proposed  objectives  for  the  renewed  EHL  derive  from  the  objectives  of  the 
current intergovernmental initiative and from the Council conclusions which adapted 
and  refined  some  of  these  original  objectives,  but  they  were  re-evaluated  and 
redefined  in  order  notably  to  ensure  that  they  are  sufficiently  specific,  realistic  and 
measurable, in other words that they are "SMART" enough. 

EN 

20 

   EN 

 
As already mentioned, the problem described in section 2.1.1 is a broad and complex 
problem which cannot and will not be solved by the EHL alone. Different initiatives 
address this issue in complementary ways. Therefore it has been decided to propose 
four levels of objectives for the EHL: 

(cid:190)  At a very basic level, the operational objectives refer to the improvements of 
the  practical  arrangements  which  are  needed  in  order  to  address  the 
deficiencies  of  the  current  intergovernmental  label,  as  well  as  to  the  actual 
activities  which  should  be  implemented  by  the  labelled  sites.  Output 
indicators  would  thus  help  to  verify  that  sites  receiving  the  Label  have  met 
the  obligations  they  agreed  to  undertake  when  they  made  their  application 
and were selected.  

(cid:190)  The  specific  objectives  relate  to  the  direct  improvements  that  sites  – 
individually and collectively - would be intended to deliver as a result of their 
activities  linked  to  the  EHL  designation  or  that  the  new  practical 
arrangements would be intended to deliver. Hence result indicators would go 
beyond simply cataloguing what was done to look at its direct effects.   

(cid:190)  The intermediate objectives are the highest level of impact that the EHL can 
achieve on its own. They refer to the impacts of the EHL on individuals and 
on  heritage  as  a  whole.  At  this  level,  the  impacts  can  be  measured  and  /  or 
assessed with a degree of certainty with intermediate impact indicators. 

(cid:190)  The general objectives reflect the overall ambition of the EHL and link it into 
the  wider  EU  policy  agenda.  These  goals  are  subject  to  many  complex 
influences  and  whilst  the  EHL  can  make  some  contribution  to  their 
achievement, separating out and measuring that effect would be enormously 
difficult.  It  is  important  to  repeat  once  again  that  the  ambitions  of  the  EHL 
concerning  these  general  objectives  are  modest  and  that  the  contribution  of 
the  label  will  certainly  not  reach  the  same  level  of  impacts  as  for  example 
student exchanges or language learning. 

 It  should  be  noted  that  the  economic  dimension  of  the  EHL,  notably  linked  to 
tourism,  has  been  included  only  through  specific  and  operational  objectives 
related mainly to the marketing and the promotion of the sites. This is due to a 
number of factors. Firstly, as mentioned earlier, during the consultation process 
many stakeholders insisted that the primary effects of the EHL will be and should 
be social ones and they warned that stressing the economic objectives too much 
might  blur  the  message  of  what  the  label  is  trying  to  achieve.  The  EHL  may 
stimulate tourism and associated gains, but it is most appropriate to see these as 
secondary, indirect benefits.  

Secondly,  one  of  the  specificities  of  the  EHL  is  that  the  symbolic  value  of  the 
sites and their European significance is more important than their aesthetic value. 
As a result, a great diversity of sites can possibly be awarded the label, some with 
a  potential  for  touristic  "mass  appeal",  others  with  less,  some  which  already 
attract  numerous  visitors  before  being  labelled,  and  others  which  are  basically 
unknown. As a result it is almost impossible to set common economic objectives 
to be reached by all the sites without distorting the central aim of the label.  

EN 

21 

   EN 

 
Thirdly, the capacity of the EHL to have a significant impact on the number of 
visitors  to  a  site  will  depend  greatly  on  the  quality  and  the  credibility  the  label 
will acquire and thus on the prestige it will develop. This is a process which will 
take  a  number  of  years.  It  would  therefore  seem  more  appropriate  to  consider 
building in more ambitious economic objectives at a later stage after evaluation 
of the initial functioning of the initiative.  

This  should  however  not  prevent  the  MS  and  sites  wishing  to  exploit  the 
economic  dimension  of  the  EHL  more  actively  to  do  so  already  in  the  initial 
stage. 

3.1. 

General objectives 

(cid:190)  Strengthen  European  citizens'  sense  of  belonging  to  the  European  Union 
based  on  shared  elements  of  history  and  cultural  heritage,  as  well  as  an 
appreciation of diversity. 

(cid:190)  Strengthen intercultural dialogue 

3.2. 

Intermediate objectives 

(cid:190)  Enhance the value and profile of  sites  which have played a key role in the 

history and the building of the European Union  

(cid:190)  Increase European citizens' understanding of the building of Europe, and their 
common yet diverse cultural heritage, especially related to democratic values 
and human rights that underpin European integration 

3.3. 

Specific objectives 

(cid:190)  Develop sites' European significance 

(cid:190)  Raise young people's awareness of their common cultural heritage 

(cid:190)  Facilitate  sharing  of  experiences  and  exchanges  of  best  practice  across 

Europe 

(cid:190)  Increase  access  to  heritage  sites  for  all  members  of  the  public,  especially 

young people 

(cid:190)  Increase  intercultural  dialogue,  especially  among  young  people,  through 

artistic, cultural and historical education 

(cid:190)  Foster  synergies  between  cultural  heritage  and  contemporary  creation  and 

creativity 

(cid:190)  Contribute  to  the  attractiveness  and  the  sustainable  development  of  the 

regions 

EN 

22 

   EN 

 
 
3.4. 

Operational objectives 

a) Practical arrangements for the EHL 

(cid:190)  Ensure  the  application  of  common,  clear  and  transparent    criteria  for  the 

selection of the sites 

(cid:190)  Foster a fair distribution of labels across the European Union  

(cid:190)  Introduce a monitoring procedure to ensure that the labelled sites respect their 

commitments 

(cid:190)  Improve  the  complementarity  with  other  initiatives  in  the  field  of  cultural 
heritage,  notably  through  good  communication  with  relevant    international 
bodies 

(cid:190)  Ensure  that  the  practical  arrangements  remain  light  and  flexible  for  the  EU 

and the MS 

(cid:190)  Increase the visibility at European level, notably through the development of 

a website 

(cid:190)  Develop transnational networks of sites to develop their European profile and 

exchange 

b) Activities of the labelled sites 

(cid:190)  Develop  the  European  dimension  of  sites  through  appropriate  information 

activities and multilingual signage 

(cid:190)  Develop programmes of educational activities 

(cid:190)  Undertake  marketing  and  promotion  of  sites  as  tourist  destinations  locally, 

nationally and at European level 

(cid:190)  Develop  access  to  sites  through  site  adaptations,  visitor  tools,  staff  training, 

privileged access for the young public 

(cid:190)  Develop  programmes  of  cultural  activities:  events,  festivals,  artist-in-

residence schemes, etc 

3.5. 

Consistency of these objectives with other EU policies 

These objectives will help  to meet  the challenges mentioned  in  section 2 alongside 
other  initiatives  aimed  at  filling  the  gap  between  citizens  and  the  EU  such  as  the 
various EC initiatives in the field of information and communication. 

They will contribute to the objectives of the European agenda for culture which are 
notably to foster cultural diversity and intercultural dialogue and to promote culture 
as  catalyst  for  creativity.  They  are  also  fully  in  line  with  the  goals  of  the  new  EU 
strategy for youth to improve access and full participation of young people in society 
and  to  foster  solidarity  between  youth  and  society,  as  well  as  with  other  DG 

EN 

23 

   EN 

 
Education and Culture policies and programmes such as Lifelong Learning or Europe 
for Citizens. 

They  are  consistent  with  the  activities  in  the  field  of  heritage  and  tourism  of  other 
services  of  the  Commission  such  as  DG  Information  Society  and  Media,  DG 
Maritime Affairs and Fisheries, DG Regional Policy or DG Enterprise and Industry. 

They  are  also  related  to  the  Integrated  Guidelines  for  Growth  and  Jobs  2008-10 
which  continue  to  emphasise  the  need  to  strengthen  territorial  and  social  cohesion, 
not  least  as  a  consequence  of  the  development  of  large  volumes  of  cross-border 
migration  or  to  the  Renewed  Social  Agenda  which  aims  to  develop  cohesive  and 
inclusive societies. 

4. 

SECTION 4: POLICY OPTIONS 

In  order  to  achieve  the  objectives  of  the  EHL,  a  wide  range  of  policy  options  was 
considered.  These  options  were  then  narrowed  down  through  an  initial  screening 
taking into account the technical constraints of the EHL. Options which appeared to 
be completely unrealistic or unfeasible were excluded from further analysis. 

4.1. 

Policy options not retained for analysis 

The  Council  conclusions  mention  that  the  new  EHL  should  keep  "flexible  and 
streamline  administrative  arrangements  in  compliance  with  the  principle  of 
subsidiarity." This was indeed a central element in the negotiations for the adoption 
of  the  conclusions.  Without  a  strong  commitment  to  keep  the  costs  limited  both  at 
national  and  European  level  and  a  strong  commitment  to  avoid  all  unnecessary 
bureaucracy,  no  agreement  could  have  been  reached  between  the  MS.  This  same 
concern was also expressed on numerous occasions during the consultation process 
and  it  has  been  reinforced  by  the  current  context  of  financial  and  economic  crisis 
which makes it highly unlikely that much funding will be available either at national 
or European level for the EHL in the coming years. 

In  light  of  these  factors  we  excluded  an  option  which  would  have  involved 
continuing the EHL as an intergovernmental initiative but with significant financial 
support from the EU to develop sites and the networking between them, as well as an 
option  which  would  have  involved  transforming  the  EHL  into  a  EU  initiative  with 
significant financial support to the sites. 

 Because  of  the  very  clear  consensus  which  emerged  during  the  consultation  phase 
(see sections 1.2.2. and 1.2.3.), all the retained options are based on the attribution of 
the EHL on a permanent basis with a strong monitoring procedure and the possibility 
to  withdraw  the  label.  Options  based  on  the  attribution  of  the  EHL  for  a  limited 
duration were considered as un-realistic because of the reticence of a vast majority of 
MS and were therefore excluded from further analysis.  

4.2. 

Options retained for analysis 

Flowing  out  of  the  screening  process  mentioned  above,  three  main  options  were 
developed, with one of the options containing three sub-options.  All of these options 

EN 

24 

   EN 

 
would  have  very  limited  impacts  on  the  EU  budget.  All  of  them  also  respect  the 
principles of subsidiarity and proportionality. 

4.2.1. Option 1: Status quo (baseline scenario) 

The  EHL  continues  as  an  intergovernmental  initiative  with  a  secretariat  hosted  by 
participating  countries  on  a  revolving  basis  (unfunded  by  the  EU)  and  without  any 
EU action. This is the baseline option against which the other options are tested.   

4.2.2. Option 2: Status quo plus limited EU financial support   

The EHL continues as an intergovernmental initiative with limited financial support 
from the EU budget to support part of the running costs of the secretariat, part of the 
communication costs, expert meetings and networking. Funding would have to come 
from  either  the  current  or  future  Culture  programme.  With  this  option,  no  new 
legislation as such is needed, although it might be necessary to take into account the 
specificity  of  the  EHL  while  preparing  the  legal  base  of  the  future  Culture 
programme 

4.2.3. Option 3: The EHL becomes a EU initiative through a decision by the Council 
and the Parliament  

This decision would specify the objectives and the rules of the new Label, define the 
common selection criteria, set up the selection and monitoring procedures and share 
clearly  the  tasks  and  responsibilities  between  the  MS  and  the  Commission.    A 
secretariat  would  be  provided  by  the  Commission.  Some  limited  financial  support 
would be provided to assist the transnational networking of the sites, either through 
calls  for  proposals  or  by  the  direct  organisation  of  expert  meetings  by  the 
Commission. The Commission would also be responsible for the communication and 
the visibility of the EHL at European level. Three sub-options are possible according 
to  the  various  selection  and  monitoring  procedures  that  came  up  during  the 
consultation phase: 

(cid:190)  3(a)  Selection  of  sites  is  undertaken  by  the  MS  against  common,  clear  and 
transparent  criteria.    Each  year  the  MS  put  forward  sites  up  to  a  maximum 
number and according to country quotas which could be on a rotating basis.  
The  sites  are  then  validated  by  the  EU.  Monitoring  is  a  MS  responsibility. 
The function of the Commission is to ensure a good coordination between the 
MS and the smooth running of the procedures and the practical arrangements. 

(cid:190)  3(b) Sites are selected through an open selection process which does not take 
into account the national origin of the candidate sites by an expert committee 
at European level.  A limited number of Labels could be awarded each year.  
Monitoring functions would also be undertaken at EU level. 

(cid:190)  3(c)  Sites  are  pre-selected  by  MS  and  then  subject  to  final  selection  by  an 
independent panel at EU level.  MS nominations could be on a rotating basis. 
Monitoring is primarily a MS responsibility, but with supervision and review 
by the independent panel. 

EN 

25 

   EN 

 
 
 
 
5. 

SECTION 5: ANALYSIS OF IMPACTS 

5.1. 

Development of the framework of impacts 

In  order  to  undertake  the  impact  assessment  a  range  of  potential  impacts  were 
identified.  These  were  derived  from  consideration  of  a  number  of  sources:  from  a 
review  of  the  literature  relating  to  the  impact  of  culture  and  heritage;  from  an 
analysis  of  the  objectives  of  the  EHL;  and  from  the  comments  and  perspectives  of 
individuals, organisations and MS who participated in the consultation process. 

A  number  of  considerations  were  important  in  assembling  the  list  of  potential 
impacts and then determining the likely impact of the EHL. 

It is clear from the objectives of the EHL that the primary direct effects of the Label 
are likely to be social ones.  As already mentioned in section 1.2.2.2., the participants 
in  the  consultation  meeting  placed  particular  emphasis  on  the  political  and 
educational dimensions and they stressed that the EHL should be concerned mostly 
with  social  /  societal  changes.  A  majority  of  the  impacts  examined  in  table  1  are 
therefore social / societal impacts. 

Included in these social / societal impacts are the potential impacts on fundamental 
rights. As pointed out several times in the preceding sections of this report, European 
common values are at the core of the EHL and one of the foundation stones for the 
initiative  concerns  the  building  of  a  shared  European  identity  based  on  democratic 
values and human rights.  It should therefore be noted that the label is likely to have 
positive impacts (and certainly no negative ones) and thereby make a contribution to 
the objectives of the Charter of Fundamental Rights of the European Union. 

Concerning the economic benefits of the EHL, as discussed in section 3, they should 
rather be considered as secondary or indirect benefits in a first stage.  The potential 
impacts of the EHL on the local tourism industry have however been analysed. Some 
economic impacts are also possible in relation to innovation and creativity.  One of 
the  objectives  of  the  EHL  is  to  link  cultural  heritage  to  contemporary  cultural 
activities  and  creation.  Much  will  depend  here  on  individual  sites  and  their 
immediate local context, and on the extent to which active programmes of linking to 
creative  industries  and  artists  etc  are  built  into  sites'  projects  –  and  then  delivered.  
And  this  will  depend  in  part  on  the  extent  to  which  this  is  emphasised  during  the 
selection process. 

In relation to environmental impacts, these are unlikely in general to be substantial.  
There is a risk that tourist footfall could become a problem at some sites but as we 
have seen, this should remain limited in a first stage.  The EHL is also not primarily 
about conservation.  There are a number of accolades in that domain already (e.g. the 
UNESCO  World  Heritage  List  or  the  Europa  Nostra  Awards,  as  well  as  numerous 
designations  at  national  level)  and  whilst  the  EHL  may  secure  the  future  of  some 
sites for future generations that would otherwise not have been saved, it is important 
that it does not become seen as a Label for sites that could not secure one of these 
other designations. 

Finally, the EHL will have no negative impacts on third countries. On the contrary, if 
at some stage of its development the EHL opens up to third countries participating in 

EN 

26 

   EN 

 
the  Culture  programme  as  suggested  by  the  Council  conclusions,  the  potential 
benefits of the EHL will extend to these countries. 

5.2. 

The chain of effects 

The  most  direct  effects  of  the  Label  will  be  on  the  sites  themselves  and  then  on 
individual  citizens:  indeed  without  those  impacts  on  the  sites,  positive  impacts  on 
individuals will not be achieved.  Thus the primary effects should be on raising the 
European dimension and the profile of sites, and on increasing access, especially for 
young people.  Once such improvements are achieved we would then expect to see 
benefits  on  individuals  in  terms  of  increased  interest  in  and  understanding  of 
European heritage, and Europe's cultural diversity.   

Clearly  at  this  point  in  the  chain  of  effects,  however,  the  possibility  of  positive 
effects  starts  to  become  affected  by  many  other  factors.    The  ultimate  goal  of  the 
EHL is to change individual attitudes, and not just in terms of a person's view on this 
or that subject, but at a very deep-rooted level, namely their identity.  Not only is this 
a very complex area, but it raises an insurmountable difficulty in terms of attributing 
someone's  'change  of  mind'  to  the  EHL  or  indeed  to  any  other  single  effect.  
Compared  to  the  other  influences  on  someone's  identity,  a  visit  to  a  labelled  site 
clearly – in general – should not be counted as a major influence, although equally 
we cannot rule out the possibility that for any one individual a visit to certain sites 
could have a profound impact.  For this reason, it would be unrealistic to expect the 
EHL in general and in aggregate to have anything other than a modest effect in areas 
such as the level of a greater sense of belonging to the EU and intercultural dialogue.  
Still less would we then anticipate a strong effect on behaviour such as participation 
in the democratic process. 

5.3. 

Quantification versus qualitative analysis 

It has not been possible to make quantitative estimates of the likely impacts for the 
EHL.  No data is for example available from the sites which were awarded the EHL 
under  the  intergovernmental  initiative  that  would  enable  us  to  construct  reliable 
estimates of effects. Furthermore, if there is a growing literature on cultural heritage, 
most  of  the  evidence  about  the  socio-economic  benefits  of  heritage  is  of  a  very 
general  or  unquantified  nature.  The  literature  review  carried  out  by  ECOTEC  did 
help  to  understand  the  broad  types  of  impact  that  might  be  possible  and  the  likely 
balance  of  social,  economic  and  environmental  impacts,  but  it  did  not  help  with 
estimating  the  potential  magnitudes  of  any  effects  and  it  did  certainly  not  help  to 
understand the effect that a designation such as the EHL might have over and above 
the  impacts  that  would  be  taking  place  in  the  absence  of  the  designation.  Even  the 
most prestigious designations such as the UNESCO World Heritage List have been 
the  subject  of  very  few  detailed  studies  and  in  the  UNESCO's  own  words:  "the 
economic  impact  for  local  communities  when  a  site  is  inscribed  on  the  World 
Heritage List is still to be measured"11.  Consequently, the assessment of options is 
conducted  in  qualitative  and  comparative  terms.  In  the  following  section,  an 
assessment  is  made  of  each  option  in  terms  of  whether  it  would  lead  to  an 
improvement or deterioration in an impact. 

11 

http://unesdoc.unesco.org/images/0018/001809/180960m.pdf 

EN 

27 

   EN 

 
                                                 
With a view to measuring the impacts of the EHL in the future, section 7.2.  proposes 
a  set  of  indicators  for  the  evaluation  of  the  initiative  which  should  enable  also  a 
quantitative analysis of the Label. 

5.4. 

The likely impacts of the various policy options 

The summary table below presents a comparative assessment of the likely impact of 
the  EHL  under  the  different  options.  It  was  developed  in  close  cooperation  with 
ECOTEC and is based on the external expertise provided by the consultant. Against 
each impact an indication is given of the likely difference of each impact compared 
to the baseline. In the full table in annex 5, an explanation is also provided as to the 
assessment  made.    Naturally  these  differences  depend  on  a  chain  of  causality  that 
runs from the changes envisaged under each option and further discussion of this is 
provided  in  the  subsequent  section  that  deals  with  efficiency,  effectiveness  and 
coherence. 

EN 

28 

   EN 

 
Table 1:  Comparison of options in terms of likely impacts compared to the baseline option 

Option 2: 

Status quo plus 
EU funding 

Option 1: 

Status quo 

Option 3: EU initiative… 

..with MS 
selection 

..with EU level 
selection (b) 

(a) 

.. with MS pre-
selection and 
EU level 
approval (c) 

Option 

KEY: 

=  baseline or equivalent to baseline             + to +++ minor to major improvement compared to baseline    

 - to --- minor to major worsening compared to baseline 

SOCIAL/SOCIETAL IMPACTS 
cultural 
access 
Increased 
heritage resources 

to 

Increased  access  to  heritage  for 
young people 

and 
interest 
Increased 
knowledge  of  common  European 
heritage 

in 

Increased 
understanding 
European  cultural diversity 

of 

Increase in intercultural dialogue 

Greater  sense  of  belonging  to  the 
European Union 

Stronger  participation 
democratic process 

in 

the 

ECONOMIC IMPACTS 
the 
Positive  effects  on 
local 
tourism 
including 
industry, 
number of people employed 

Development 
cultural and creative industries 

links  with 

of 

Development  of  innovation  and 
creativity 

ENVIRONMENTAL IMPACTS 
Negative  effects  linked  to  over-
development of tourism 

Protection of cultural heritage 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

+ 

(+) 

(+) 

= 

= 

= 

= 

= 

= 

= 

= 

= 

++ 

+ 

+ 

+ 

+ 

(+) 

= 

(+) 

(+) 

(+) 

+ 

+ 

++ 

++ 

++ 

+++ 

+ 

(+) 

= 

(+) 

(+) 

(+) 

+ 

= 

+++ 

+++ 

++ 

++ 

+ 

(+) 

= 

(++) 

(+) 

(+) 

+ 

+ 

EN 

29 

   EN 

 
 
 
 
 
6. 

SECTION 6: COMPARING THE OPTIONS 

6.1. 

Criteria for comparing the options  

Having looked at the likely impacts of the different options we turn in this section to 
an  assessment  in  terms  of  three  main  criteria:  effectiveness,  efficiency  and 
coherence. However, within these general criteria there are a range of sub-criteria to 
consider. These derive from  the key features of the current EHL, from the Council 
conclusions,  from  the  consultation  process,  and  from  the  lessons  learnt  from  other 
labelling  and  award  schemes.    The  criteria  selected  are  shown  below  and  reflect 
closely all of the objectives proposed in section 3: 

Effectiveness 

(cid:190)  Representativeness – As mentioned above, it is important that the EHL is able 
to deliver a fair distribution of Labels across the EU Member States to ensure 
continuing  participation  and  commitment  in  the  development  of  a  shared 
European identity. 

(cid:190)  European  dimension,  significance  of  sites  –  It  is  essential  for  the  EHL  that 
interpretations  of  culture  and  history  are  balanced  with 

national 
interpretations of sites' European significance. 

(cid:190)  Transnationality and networking – This needs to be a key component of the 
EHL  if  it  is  to  realise  its  aspirations  to  build  a  shared  understanding  of 
European  cultural  heritage.  Inter  alia  it  will  enable  the  sharing  of  good 
practice, for example in relation to ways of improving access to sites. 

(cid:190)  Visibility and profile – Having a high profile will be important for the EHL 
as it seeks to impact on the attitudes and identities of Europeans, and is also 
central  to  improving  access,  especially  for  young  people,  where  new  and 
creative ways may need to be found to open up sites. 

(cid:190)  Artistic,  cultural  and  historical  education  –  Effective  programmes  of 
educational  activities  will  be  central  to  the  success  of  the  EHL  in 
promulgating  the  role  of  sites  in  European  culture  and  heritage  and 
demonstrating the importance of intercultural dialogue to the development of 
tolerance and understanding. 

(cid:190)  Programmes  of  cultural  activities  –  It  is  important  that  the  culture  and 
heritage of EHL sites do not ossify and that their relevance to contemporary 
life  is  demonstrated  through  links  to  contemporary  cultural  activities  and 
creativity.  Programmes of cultural activities will be an important means by 
which this can be achieved. 

EN 

30 

   EN 

 
 
 
 
Efficiency 

(cid:190)  Selection  processes  –  These  are  core  to  differentiating  the  options  and 
different  options  offer  different  combinations  of  advantages  and 
disadvantages. 

(cid:190)  Delivery  and  compliance  –  Options  are  likely  to  vary  in  their  ability  to 

implement effective monitoring and evaluation processes. 

(cid:190)  Administrative arrangements – It is important that whichever option is chosen 
the resulting administrative arrangements are 'flexible and streamlined/light'.  

(cid:190)  Financial effects – Related to the preceding point, consideration also needs to 
be given to the financial implications for the EU for each of the options. 

(cid:190)  Communication  with  other  international  bodies  –  Given  the  nature  of  the 
EHL  concept  and  the  existence  of  similar  schemes,  the  ability  to 
communicate  with  other  bodies  will  be  an  important  feature  of  the  Label 
going forward. 

Coherence 

(cid:190)  Limitations of trade-offs across social, economic and environmental domains 
– The economic impacts of sites, though likely to be limited (as discussed in 
the preceding impact assessment), may bring negative environmental effects, 
and  to  mitigate  these,  conservation  will  need  to  be  one  of  the  criteria  in 
awarding the Label.  It is important to assess the extent to which the options 
will affect this trade-off.   

(cid:190)  Synergies  and  complementarities  with  other  initiatives  –  Synergies  and 
complementarities  offer  the  prospect  of  increasing  the  impact  of  the  EHL. 
Some options may be more likely to offer them than others. 

(cid:190)  Participation  of  third  countries  in  the  Culture  programme  –  Although  such 
participation  is  likely  to  take  place  only  once  the  EHL  is  well  established, 
consideration  should  be  given  to  which  option  is  more  likely  to  deliver  this 
effectively and efficiently. 

In the following section each of the options is assessed against each of these criteria 
in terms of whether they would be likely to achieve an improvement or a worsening 
compared to the baseline position. 

6.2. 

Comparison  of  the  options  against  effectiveness,  efficiency  and  coherence 
criteria 

The  summary  table  below,  prepared  in  cooperation  with  ECOTEC,  presents  the 
scores  of  the  options.  The  full  table,  including  the  comments,  is  in  annex  6.

EN 

31 

   EN 

 
Table 2:  Comparison of the options against effectiveness, efficiency and coherence criteria 

Option 1: 

Option 2: 

Option 3: EU initiative… 

Status quo 

Status quo 
plus EU 
funding 

..with MS 
selection 

..with EU level 
selection (b) 

.. with MS pre-
selection and EU 
level selection (c) 

(a) 

Option 

KEY: 

=  baseline or equivalent to baseline             + to +++ minor to major improvement compared to baseline                         
- to --- minor to major worsening compared to baseline 

EFFECTIVENESS 

Representativeness  

European dimension – significance 
of sites 

Transnationality and networking 

Visibility, profile and access 

Artistic,  cultural  and  historical 
education 

Programmes of cultural activities 

EFFICIENCY 

Selection processes 

Delivery 
(monitoring and QA) 

and 

compliance 

Administrative  arrangements  at 
EU and MS level 

Financial impacts for the EU 

Communication 
international bodies 

with 

other 

COHERENCE 

Limitation  of 
social, 
economic 
environmental domains 

trade-offs  across 
and 

Synergies  and  complementarities 
with other initiatives 

Participation  of  third  countries  in 
Culture programme 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

= 

EN 

= 

(+) 

+ 

+ 

= 

= 

= 

(+) 

- 

- 

+ 

= 

= 

= 

32 

+  

+ 

+ 

++ 

+ 

+ 

+ 

++ 

- 

-- 

++ 

+ 

++ 

+++ 

- 

+++ 

+++ 

++ 

++ 

++ 

++ 

+ 

-- 

--- 

+ 

++ 

++ 

+++ 

++ 

++ 

+++ 

+++ 

--- 

-- 

+++ 

+++ 

+ 

+++ 

+++ 

+ 

+++ 

+++ 

   EN 

 
 
 
6.3. 

Option 1: Status quo (baseline scenario) 

As  already  mentioned  in  section  2.2.  and  illustrated  in  tables  1  and  2,  if  the  EHL 
continues as an intergovernmental initiative, it would need to take a qualitative step 
forward  in  order  to  reach  concrete  results  and  to  make  an  impact.  However,  at  the 
present  moment,  there  is  absolutely  no  sign  that  the  countries  participating  in  the 
intergovernmental  EHL  are  ready  to  take  a  more  proactive  approach.  On  the 
contrary, the adoption of the Council conclusions suggests that the MS are convinced 
that the EHL can only reach its full potential through the 'communautarisation' of the 
label. Without such a 'communautarisation', the chances are very high that at best the 
initiative will continue with a very low profile and with no significant results. Option 
1 would also imply that the Commission ignores the request made by the Council. 

6.4. 

Option 2: Status quo plus limited EU financial support   

Thanks  to  the  additional  funding,  this  option  is  likely  to  deliver  a  small  number  of 
effectiveness and efficiency improvements compared to the baseline scenario which 
would  feed  through  into  some  minor  improvements  on  a  limited  range  of  impacts.  
The  most  significant  effectiveness  and  efficiency  gains  are  likely  in  the  areas  of 
transnationality/networking,  and  visibility/profile  where  additional  funding  might 
facilitate an increase in relevant activity including marketing and promotion.  These 
improvements  might  then  feed  through  into  slight  improvements  in  individuals' 
access  to  cultural  heritage,  including  possibly  youth  access.    There  might  also  be 
some enhancement in the emphasis placed on the European significance of sites (e.g. 
through  support  to  expert  meetings)  which,  combined  with  the  increased  visibility 
and  profile  of  sites,  might  deliver  a  rise  in  interest  in  and  knowledge  of  common 
European  heritage.    However,  with  this  option  there  is  no  guarantee  that  the 
numerous  shortfalls  in  the  practical  arrangements  and  in  the  implementation  of  the 
initiative analysed in section 2.2.2. would be tackled effectively, and, as a result, that 
the  overall  quality  of  the  initiative  would  improve  significantly.  It  is  also  unlikely 
that this option would lever any significant benefits in terms of improved educational 
or  cultural  activity  programmes.  Option  2  (as  option  1)  would  finally  lack  the 
strengthened  legitimacy  and  credibility  that  comes  from  being  an  EU  initiative  and 
which was mentioned on numerous occasions during the public consultation. For all 
these reasons, it is very unlikely that the minor improvements that could be realised 
under option 2 would feed through into wider and deeper impacts. 

6.5. 

Option 3: The EHL becomes a EU initiative through a decision by the Council 
and the Parliament  

The most substantial improvements in impacts would be achieved by making the EHL 
a EU initiative. Within this broad option, the sub-option of MS selection with a EU 
secretariat (3a) would probably deliver less marked improvements across the range of 
impacts and the fewest effectiveness and efficiency gains.  This option 

EN 

33 

   EN 

 
 
would  involve  a  less  'active'  EU  level  which  would  probably  mean  less  emphasis 
placed  upon  and  ability  to  realise  in  particular  the  European  dimension,  as  well  as 
transnationality  and  networking,  or  less  likelihood  of  achieving  improvements  in 
education  and  cultural  activity  programmes.  It  would  also  make  it  less  likely  that 
visibility and profile could be raised to the same degree as with a stronger EU tier.  
As  regards  selection  processes,  transparency  and  clarity  would  probably  not  be  as 
strong as under sub-options 3b and 3c and it would not be as possible to ensure the 
consistent  application  of  criteria. 
the  EHL 
  The 
(communication with other international bodies and synergies and complementarities 
with  other  initiatives)  would  also  probably  be  weaker  under  sub-option  3a.    As  a 
consequence  of  these  weaknesses,  sub-option  3a  would  probably  not  deliver  the 
same level of improvements in impacts as could be achieved under 3b and 3c.  With 
weaker  visibility/profile  and  less  emphasis  on  the  European  dimension  and 
transnationality/networking,  this  sub-option  would  be  less  likely  to  increase  the 
numbers  of  individuals  accessing  cultural  heritage  and  especially  appreciating  its 
European aspects. 

international  aspects  of 

In  contrast,  more  active  EU  involvement  (sub-options  3b  and  3c)  would  be  more 
likely to deliver greater benefits on account of: being able to ensure a greater focus 
on  the  European  dimension,  on  transnationality  and  networking,  and  on  enhancing 
educational programmes and programmes of cultural activities; being better equipped 
in terms of marketing and promotion; and having an enhanced capability in relation 
to  monitoring  and  evaluation  and  adherence  to  quality  standards.      These  factors 
would  give  sub-options  3b  and  3c  the  propensity  to  drive  up  performance  across  a 
range of impacts, especially the social/societal ones.   

Naturally,  for  the  reasons  already  noted,  even  under  these  sub-options  the 
achievement of greater  economic impacts would  be difficult  at  the outset,  although 
some  minor  improvements  to  economic  impacts  would  be  possible  if  links  were 
made  to  other  areas  of  EU  policy  and  programmes  (in  the  areas  of  cultural  and 
creative  industries  and  innovation  and  creativity  for  example),  and  through 
networked activity in relation to tourism.  These would probably be realised over the 
longer  term.    Through  the  new  selection  criteria  and  the  enhanced  monitoring 
capacity that would be achievable under a EU initiative, some positive impact might 
be possible in relation to the attenuation of negative environmental effects linked to 
the development of tourism, but this is likely to be limited. 

If  we  compare  now  sub-options  3b  (selection  at  EU  level  only)  and  3c  (combined 
MS and EU level selection), sub-option 3c offers the prospect of the same or better 
level of improvement as 3b across all impacts, except the increased understanding of 
cultural  diversity  (Table  1).  In  relation  to  the  two  impacts  related  to  access,  sub-
option 3c is likely to deliver greater improvements by being better able to ensure that 
priority is accorded and delivered, not least through the commitment from and links 
between ministries that could be forged at national level. This was referred to very 
strongly  during  the  consultation  process.  In  relation  to  the  effectiveness  and 
efficiency criteria, sub-option 3c is also preferable on the basis that: 

(cid:190)  it  would  continue  to  ensure  a  fair  distribution  of  sites  across  Europe  and 
hence  be  more  likely  to  ensure  the  ownership  and  the  commitment  of  all 

EN 

34 

   EN 

 
Member States, even if this implies the equal treatment of all the MS while 
the pools of relevant sites may differ from one country to another;  

(cid:190)  it is likely to be more effective in relation to the visibility and profile of the 

EHL since both levels could be engaged in marketing and publicity; 

(cid:190)  it would be able to draw both on MS and EU resources in relation to selection 
and  monitoring,  whilst  ensuring  a  consistent  application  of  criteria  and  the 
engagement of all EU countries in the complex process of realising a shared 
sense of European identity; 

(cid:190)  it would realise the same improvements as the EU only model (3b) in relation 
to  the  criteria  related  to  communication  with  other  international  bodies  and 
coherence. 

6.6. 

Administrative arrangements and financial impacts 

Whilst sub-option 3c offers the advantages mentioned above, it is also necessary to 
take into account the extent to which administrative arrangements across the options 
and sub-options are 'flexible and streamlined'.  This requires us to take into account 
the fact that there is some trade-off between overall efficiency and effectiveness and 
the  burden  of  administration:  the  lightest  and  most  flexible  administration  is  not 
necessarily the most effective or efficient; balance is key. 

Option  1  would  have  no  impact  at  all  for  the  EU.  All  administrative  arrangements 
and costs remain at MS level. 

With option 2, the only involvement of the EU would be through a grant to support 
part  of  the running  costs of the secretariat, part of the communication costs, expert 
meetings  and  networking.  Funding  would  have  to  come  from  either  the  current  or 
future Culture programme. One basis to estimate the size of the grant for the EHL, 
could  be  the  current  EU  Prizes  for  heritage,  literature,  architecture  or  music  which 
cover  selection  procedures,  visibility  and  some  staffing  costs,  but  no  networking. 
These grants range from 200 000 € to 360 000 € for total budgets which range from 
333 333 € to 704 000 €. It needs to be pointed out that by definition grants consist of 
co-financing only, meaning that the recipient organisations must also put in resources 
of  their  own,  which  would  not  be  straightforward  with  an  intergovernmental 
arrangement.  It  also  needs  to  be  recalled  that  EU  grants  are  subject  to  open 
competition, which creates uncertainty and reduces the reliability of this option. 

With option 3, the administrative arrangements and the costs would be greater for the 
EU.  A  secretariat  would  be  provided  by  the  Commission.  Some  limited  financial 
support  would  be  provided  to  assist  the  transnational  networking  of  the  sites.  The 
Commission  would  also  be  responsible  for  the  communication  and  the  visibility  of 
the EHL at European level. On the basis of the experience of the European Capitals 
of Culture they can be estimated as follows for the 3 sub-options.  

EN 

35 

   EN 

 
 
 
 
Costs per year 

Sub-option 3a 

Sub-option 3b 

Sub-option 3c 

Secretariat 

1 staff member 

2 staff members 

2 staff members 

122 000 € 

244 000 € 

244 000 € 

Selection 

- 

400 000 € 

200 000 € 

Visibility 

250 000 € 

250 000 € 

250 000 € 

Networking 

300 000 € 

300 000 € 

300 000 € 

Total 

672 000 € 

1 114 000 € 

994 000 € 

The  costs  for  visibility  and  networking  would  remain  the  same  across  the  three 
options.  The  variations  are  linked  to  the  selection  procedure.  With  selection  at 
national level only (3a), there would be no costs at EU level and less staff needed in 
the secretariat. With selection at EU level only and thus without the filtering of the 
pre-selection  at  national  level,  the  number  of  applications  to  evaluate  by  the 
independent panel of experts would be much higher which would increase the linked 
costs. 

With option 3, the  only compulsory  expenses for a MS would be the costs of their 
own pre-selection (3c) or selection procedure (3a) and of the monitoring of the sites 
located on the national territory (3a and 3c). If a parallel is drawn with the European 
Capitals  of  Culture,  the  selection  process  in  MS  typically  occupies  one  member  of 
staff in the national ministries or organising bodies during the relevant period. Any 
additional  costs  would  be  a  national  matter.  Sub-option  3b  with  selection  and 
monitoring  at  EU  level  would  have  much  fewer  administrative  and  financial 
implications for the MS, but as seen in section 1.2.3., the MS were not in favour of 
this option during the consultation meeting and preferred a two level approach.  

It is very difficult to quantify the costs for the MS, as the nature and the size of the 
selection and monitoring procedures will greatly depend on the specificities of each 
MS. The needs will not be the same for a big MS with a large pool of potential sites, 
than for smaller MS with only a few potential sites. In accordance with the principle 
of  subsidiarity,  each  MS  should  also  have  the  possibility  to  establish  the  type  of 
selection or monitoring procedure which is the most adapted to the national context. 
A  flexible  approach  should  enable  each  MS  to  choose  the  most  cost-effective 
solution.  

As  a  conclusion,  option  3c  is  not  the  lightest  option  but,  as  we  have  shown  in  the 
previous sections, greater benefits would be realised across most of the criteria and 
hence greater cost-effectiveness would be achieved. Furthermore, the increase of the 
administrative and  financial  "burden"  is  not expected to be significant compared to 
the baseline or the other options, and it would be spread across the EU and MS. This 
option  would  also  have  the  advantage  of  having  greater  political  "buy  in"  or 

EN 

36 

   EN 

 
 
 
commitment by the MS, which would consequently make it more likely that the sites 
would be made a priority in accessing funding through national sources or nationally 
administered sources. 

6.7. 

Preferred policy option  

On  the  basis  of  the  assessment  above,  as  well  as  of  the  consultation  process,  the 
preferred  option  is  option  3c  (combined  MS  and  EU  level  selection).  With  this 
option,  the  EU  involvement  brings  a  clear  added  value  to  the  EHL  and  enables 
benefits  that  could  not  be  achieved  by  MS  acting  alone.  The  most  marked 
improvements  in  impacts  would  be  in  short-term  effects  where  there  would  be  a 
strong connection to the improvements in effectiveness and efficiency.  Direct effects 
on  factors  such  as  a  sense  of  belonging  to  the  EU,  intercultural  dialogue  and 
participation  in  the  democratic  process  remain  of  course  more  limited  since  such 
high  level  impacts  are  affected  by  a  vast  array  of  influences,  and,  as  discussed  in 
section 2, the EHL is only one initiative amongst many others. 

In order to work effectively and on the basis of the results of the IA and of the public 
consultation, the main features of the selected option should be the following: 

(cid:190)  An  overall  legal  framework  to  transform  the  EHL  into  a  EU  initiative 
provided by a Decision of the Council and Parliament.  This Decision would, 
inter alia, specify the objectives and rules governing the label, establish clear, 
common and transparent selection criteria, and specify the arrangements for 
monitoring  and  evaluation.  We  have  seen  in  section  2  that  the  present 
objectives and rules of the intergovernmental EHL leave too much room for 
diverging  interpretations  by  the  MS  and  this  has  harmed  to  the  overall 
coherence and quality of the label so far. It is also essential to ensure that all 
the future rules will de facto be applied, and that they will be applied evenly 
by all the participating MS.   

(cid:190)  The participation of the MS should be on a voluntary basis. 

(cid:190)  A clear division of responsibilities is needed between sites, MS and EU level 
in  terms  of  selection,  delivery,  and  monitoring  and  evaluation  in  order  to 
avoid  overlaps,  share  the  administrative  burden,  and  thus  ensure  that  the 
practical arrangements remain as light and flexible as possible.  

(cid:190)  In  order  to  emphasize  the  added  value  of  the  EHL  compared  to  other 
initiatives in the field of heritage such as the UNESCO World Heritage List,  
the Council of Europe Cultural Routes or the EU Prize for cultural heritage / 
Europa Nostra Awards, the criteria of the EHL should be based clearly on the 
symbolic value of sites for Europe's identity and the role they have played in 
the history and the building of Europe, on the quality of the programme they 
submit and on the quality of their management plan. A good communication 
between  the  EHL  and  the  other  initiatives  will  be  needed  in  order  to  foster 
synergies.  This  should  be  facilitated  notably  by  the  fact  that  both  the 
European Institute of Cultural Routes and Europa Nostra receive EU grants in 
the framework of the Culture programme. 

EN 

37 

   EN 

 
(cid:190)  In  a  first  stage,  the  pre-selection  of  the  sites  should  take  place  at  MS  level, 
and then in a second stage, the final selection should take place at EU level 
with  the  help  of  a  panel  of  independent  experts.  This  would  ensure  both  a 
robust application of criteria and the giving of appropriate prominence to the 
European dimension, whilst also preserving an equitable distribution of sites 
across the EU.  

(cid:190)  A pre-established rotation system with the participation of a limited number 
of  MS  each  year,  as  discussed  during  the  consultation  phase,  could  have 
helped to keep the number of sites and the administrative burden reasonable 
while ensuring the long-term commitment of all MS. However, a consultation 
of  the  Legal  Service  of  the  Commission  showed  that  this  solution  was  not 
applicable  for  reasons  of  discrimination  between  the  MS.  Therefore,  an 
alternative solution would be to give each MS the possibility to participate in 
the selection procedure each year, but after three successive years dedicated 
to  the  selection  of  new  sites,  each  fourth  year  would  be  reserved  for  the 
monitoring procedure. 

(cid:190)  This  two-stages  approach  needs  to  be  linked  to  national  quotas,  but  these 
quotas must keep a certain flexibility because some countries have a greater 
pool  of  potential  sites  than  others  and  all  MS  may  not  wish  to  propose  the 
same number of sites. It is also politically very sensitive to attribute different 
quotas to the MS. Therefore the best compromise seems to be to give to each 
MS the possibility to pre-select up to a maximum of two sites every year in 
which  a  selection  is  made.  These  national  quotas  will  keep  the  process 
manageable at European level by avoiding a too high number of applications 
from certain MS, while at the same time working as an incentive for all the 
voluntary MS to actually participate in the selection procedure.  

(cid:190)  A certain element of competition should also be kept between the sites at EU 
level for the purpose of ensuring the general quality of the sites and thereby 
the prestige and credibility of the initiative. The panel of independent experts 
should therefore have the possibility to choose between the sites pre-selected 
by a MS and should select a maximum of one site per MS. A special priority 
should be given by the panel to sites with a strong transnational dimension. 
This should be facilitated by the selection criteria in which the cross-border 
or pan-European nature of the sites will be clearly mentioned (see annex 3). 
Special  provisions  should  also  be  designed  to  enable  the  participation  of 
several sites located in different MS which gather around one specific theme 
to propose a single application, or the participation of single sites which are 
geographically  situated  on  the  territory  of  at  least  two  different  MS.  Such 
"transnational sites" should follow the same procedure as other sites for their 
application  and  should  be  pre-selected  by  one  of  the  concerned  MS. 
However, if the panel of independent experts judges that such "transnational 
sites" respect all the criteria, priority should be given to these sites during the 
final selection. 

(cid:190)  The  label  should  be  attributed  on  a  permanent  basis  because  the  symbolic 
value  of  the  selected  sites  will  not  diminish  over  time  and  in  order  to 
encourage  sites  to  take  a  long  term  approach  and  to  invest  in  their 
development.  However,  in  order  to  maintain  the  quality  and  the  credibility 

EN 

38 

   EN 

 
also in the long term, a strong monitoring system is needed to ensure that the 
labelled  sites  respect  their  commitments,  as  well  as  the  possibility  to 
withdraw  the  label.  This  monitoring  should  also  take  place  first  at  national 
and then at European level. 

(cid:190)  The  consultation  process  has  shown  that  it  does  not  make  sense  to  try  to 
define what a "reasonable" number of labelled sites means numerically. Any 
number  would  be  arbitrary.  At  the  same  time,  it  became  clear  that  with  too 
few sites, there would be an inadequate geographical spread and it would be 
harder  to  reach  citizens  for  practical  geographical  reasons,  which  might 
undermine the initiative's objectives. Therefore, there should be no cap from 
the  outset  on  the  total  number  of  sites  which  will  be  awarded  the  EHL,  but 
the number of sites should increase slowly and progressively in order to keep 
the initiative manageable and to ensure its overall quality and credibility. The 
cap on the number of selected sites for each MS at each selection round will 
contribute to this. 

(cid:190)  Because  the  implementation  of  the  rules  of  the  EHL  will  be  a  complex 
process, the EU action should in a first stage start with the 27 MS. It could 
then in a second stage be enlarged to the third countries participating in the 
Culture  programme  if  the  practical  arrangements  prove  to  be  sufficiently 
strong and efficient. 

(cid:190)   The Commission should provide the permanent secretariat of the initiative in 
order to ensure a greater stability than under current arrangements and enable 
expertise  to  be  built  up.  This  solution  would  enable  to  draw  on  existing 
experience  such  as  for  example  in  the  framework  of  the  European  Capitals 
for culture or the EU Prize for Cultural Heritage / Europa Nostra Awards. It 
will however demand additional resources which need to be made available.  
In order to keep the practical arrangements as light and flexible as possible, 
tendering 
certain  administrative 
procedures.  

tasks  could  be  externalized 

through 

(cid:190)   Transitional  measures  need  to  be  taken  in  order  to  define  the  status  of  the 
sites which were awarded the EHL in the framework of the intergovernmental 
initiative. In order to ensure the overall coherence of the initiative, these sites 
will need to be re-assessed against the new criteria. 

(cid:190)  In  order  to  keep  the  impact  on  the  EU  budget  limited  without  harming  the 
overall quality of the initiative, funding at EU level should remain restricted 
to the costs of the secretariat, the costs of the European panel of experts, the 
visibility  of  the  initiative  at  European  level  and  some  networking  activities 
for  the  sites.  On  the  basis  of  the  experience  of  the  European  Capitals  of 
Culture,  this  should  not  exceed  a  maximum  of  1,5  million  Euros  a  year, 
including  the  additional  human  resources  needed  to  run  the  action  (one 
administrator and one assistant). 

(cid:190)  At  a  national  level,  the  only  compulsory  expenses  for  a  MS  would  be  the 
costs of their own pre-selection procedure and of the monitoring of the sites 
located  on  the  national  territory.  As  the  nature  and  the  size  of  the  selection 
and  monitoring  procedures  will  greatly  depend  on  the  specificities  of  each 

EN 

39 

   EN 

 
MS, the costs will vary from one MS to another. A flexible approach should 
enable  each  MS  to  choose  the  most  cost-effective  solution  according  to  the 
national context. Any additional costs would be a national matter. 

7. 

SECTION 7: MONITORING AND EVALUATION 

Monitoring and evaluation are crucial to ensure the effectiveness of the initiative, its 
credibility  and  its  prestige.  The  monitoring  and  evaluation  framework  of  the  EHL 
will comprise two elements which need to be distinguished: 

7.1. 

The monitoring of the labelled sites 

As already mentioned in the previous section, the aim here is to verify that labelled 
sites  have  met  the  obligations  they  agreed  to  undertake  when  they  made  their 
application and were selected. This monitoring will be under the responsibility of the 
MS  who  will  report  to  the  European  panel  every  4  years.  A  set  of  indicators  to  be 
taken  into  account  will  be  provided  by  the  Commission.  In  the  event  that  specific 
sites  no  longer  meet  their  obligations,  there  will  be  a  possibility  to  withdraw  the 
Label. 

7.2. 

The evaluation of the EHL programme as a whole 

This  evaluation  will  need  to  combine  a  focus  on  examining  both  the  processes 
involved in operating the programme and the actual cumulative impact of the EHL at 
programme  level.  The  aim  will  be  to  identify  in  which  respects  the  programme  is 
working  well,  where  there  is  room  for  improvement  and,  crucially,  how  this 
improvement  might  best  be  achieved  in  the  future.  The  monitoring  of  the  labelled 
sites  will  of  course  feed  into  this  evaluation.  The  evaluation  will  be  under  the 
responsibility  of  the  Commission  and  will  take  the  form  of  an  external  evaluation 
every 6 years. 

Concerning the effectiveness of the processes involved in operating the programme, 
the  annual  selection  process,  the  monitoring  and  evaluation  plan,  as  well  as  the 
communication  and  marketing  plan  should  be  taken  into  consideration.  Key 
indicators could include: 

(cid:190)  the number of sites selected annually;  

(cid:190)  the number and quality of the monitoring activities;  

(cid:190)  the number of promotional events held by EHL sites, the number of new EHL 

websites launched;   

(cid:190)  the networking and transnational initiatives established.  

impacts  and  outcomes  of 

the 
The 
operationalisation of the objectives described in section 3.  Key indicators should be 
defined  in  the  social,  economic  and  environmental  areas.  Social  indicators  could 
include:  

the  EHL  will  be  examined  against 

(cid:190)  numbers reporting that their interest in cultural heritage has increased; 

EN 

40 

   EN 

 
(cid:190)   numbers  saying  their  appreciation  of  common  European  history  has 

increased; 

(cid:190)   numbers of activities organised by the sites towards young people; 

(cid:190)   collaboration projects between EHL sites; 

(cid:190)   number  of  cultural  activities  created  or  activities  raising  the  awareness  on 

democratic values/human rights.  

Economic indicators could include:  

(cid:190)  number of direct or indirect jobs created;  

(cid:190)  number of jobs safeguarded;  

(cid:190)  increase in  visitors numbers;  

(cid:190)  number of partnerships projects between EHL sites and cultural and creative 

industries; 

(cid:190)   number  of  partnerships  projects  between  EHL  sites  and  local  business 
activities  or  leverage  effect  of  investment  on  heritage  on  private  and  public 
sources.  

Environmental indicators could include:  

(cid:190)  number of sustainable management plans adopted by the sites; 

(cid:190)   improved access to the sites with sustainable transport; 

(cid:190)   landscapes and historic environment conditions.  

Key  measurement  methods  for  these  indicators  could  include  visitors'  surveys,  site 
managers' surveys, focus groups, case studies or quantitative and qualitative analysis. 

EN 

41 

   EN 

 
ANNEX 1: 

MEETING SUMMARY 

EHL PUBLIC CONSULTATION MEETING 

10 JUNE 2009 

EN 

42 

   EN 

 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 
Directorate-General for Education and Culture 

Culture, Multilingualism and Communication 
"Culture" programme and actions 

EUROPEAN HERITAGE LABEL PUBLIC CONSULTATION MEETING 

10 June 2009 Charlemagne Building (Sicco Mansholt room), Rue de la Loi 170, Brussels 

SUMMARY OF THE MEETING 

The  meeting  was  open  to  all  interested  individuals  and  organisations.  71  participants  registered 
including  representatives  of  international  and  national  organisations  active  in  the  field  of  heritage, 
public authorities (national, regional and local level), heritage sites which were awarded the European 
Heritage Label in the framework of the intergovernmental initiative, academics and students. The list 
of participants is attached. 

After  the  opening  by  the  European  Commission  and  a  presentation  of  the  first  results  of  the  online 
consultation  on  the  European  Heritage  Label,  the  discussions  with  the  participants  were  centred 
around four questions: what are the potential impacts of a label in the field of cultural heritage? What 
is  the  added  value  of  the  European  Heritage  Label?  Which  role  for  the  European  Union  in  the 
European Heritage Label? How to implement the European Heritage Label effectively? 

1. 

OPENING BY THE EUROPEAN COMMISSION 

Ms Ann Branch, Head of the Culture Programme and Actions unit opened the meeting recalling that 
this  would  be  a  consultation  meeting,  organised  in  order  to  listen  to  stakeholders'  views  on  the 
European Heritage Label. 

She  highlighted  the  context  of  the  European  Heritage  Label:  its  beginnings  as  an  intergovernmental 
initiative, the call of the Council Conclusions of 2008 to make it a European Union initiative and the 
steps taken by the Commission in order to prepare its proposal to the Council and the Parliament: the 
online consultation, the current public consultation meeting and a similar meeting with Member States 
experts,  taking  place  on  24  June.  The  Commission  would  prepare  an  impact  assessment  report  to 
summarize  feedback  received  and  examine  the  advantages  and  disadvantages  of  different  ways  of 
implementing  the  Label.  This  report  would  accompany  the  Commission  proposal  on  the  European 
Heritage Label, foreseen by February 2010. 

PRESENTATION  OF  THE  FIRST  RESULTS  OF  THE  ONLINE 

2. 
CONSULTATION ON THE EUROPEAN HERITAGE LABEL 

Mr  Jean-Philippe  Gammel,  the  official  responsible  for  the  European  Heritage  Label  in  the 
Commission’s Culture Programme and Actions unit, presented the results of the online consultation, 
which ran from 20 March until 15 May and received 226 responses. The presentation is attached. 

OPEN  DISCUSSION:  WHAT  ARE  THE  POTENTIAL  IMPACTS  OF  A 

3. 
LABEL IN THE FIELD OF CULTURAL HERITAGE? 

Ms Branch invited comments, on the basis of the following questions: 

EN 

43 

   EN 

 
 
 
 
 
3.1.  What social impacts? 

Firstly, most participants commented that the main EHL impact would be political: EHL should build 
a bridge between the European project and the citizen, by exploiting the potential of common history 
and heritage, without fearing entering into controversial debates: European history was often complex 
and sometimes sensitive. 

EHL should be a way of affirming European identity within the EU, but also a way of promoting this 
identity and European values linked to it abroad. Secondly, participants wished to better focus social 
impacts by speaking of societal impact: EHL would not have a direct impact on social inclusion, but 
could  lead  to  a  better  integration  of  EU  citizens,  who  would  improve  their  capacities  to  seize 
opportunities  at  home  and  abroad  in  Europe.  Educational  impacts  should  also  be  mentioned  in  this 
section as EHL shall have a strong educational dimension, with programmes involving young people 
through schools, online learning or young tourists. 

3.2.  What economic impacts? 

Participants had mixed opinions on the economic impacts, which were considered to mainly relate to 
tourism.  Some  foresaw  an  increase  of  tourism  on  EHL  sites.  While  this  might  boost  local 
development, it was recommended to promote sustainable tourism on the basis of lessons learnt in the 
management  of  the  Unesco  World  Heritage  Sites.  Some  other  participants  found  it  difficult  to 
anticipate the impact on tourism, with the argument that the EHL sites were likely to be already well 
known. Nevertheless the quality of the cultural aspect of the visit should improve notably through a 
better  interpretation  of  the  sites,  and  it  was  hoped  that  this  would  lead  to  increasing  numbers  of 
targeted visitors, especially young people. In any case, although a raise in tourism was likely, it would 
take  time  to  have  a  real  impact.  The  example  of  tourist  packages  linked  to  Unesco  World  Heritage 
sites was mentioned. 

3.3.  What environmental impacts? 

Most  remarks  focussed  on  the  importance  of  promoting  sustainable  tourism  to  which  there  was  a 
reference in the Council conclusions. Although EHL did not aim at conservation, it should under no 
circumstances endanger the sites. Appropriate clauses should be included in the award criteria in order 
to ensure respect for the sites and their eco-systems.  

3.4.  How to maximize the positive impacts of the European Heritage Label? 

Participants were unanimous in indicating that a big communication effort would greatly increase the 
EHL impact, along with a strong educational dimension.  

A  clear  selection  framework,  publicised  over  Europe  would  be  of  great  help.  Attention  should  be 
given also to the extent to which the organisations managing the sites worked on promoting European 
values  and  history.  Networking  among  the  awarded  sites  through  Europe  would  also  increase  their 
impact. 

3.5.  Are there models of good practices to follow? 

Unesco's studies on impacts were referred too, along with the experience of some existing European 
Heritage Label sites and best practices from European Capitals of Culture. 

OPEN  DISCUSSION:  WHAT  IS  THE  ADDED  VALUE  OF  THE  EUROPEAN 

4. 
HERITAGE LABEL? 

Ms  Branch  introduced  the  topic  recalling  that  this  was  at  the  core  of  the  Council  Conclusions.  A 
preliminary  survey  to  compare  the  Label  with  other  existing  initiatives  had  been  undertaken  by  an 

EN 

44 

   EN 

 
external  consultant,  Ecotec,  providing  support  to  the  Commission  in  the  preparation  of  the  impact 
assessment report. The discussion was guided by the following key questions: 

4.1.  What  should  the  originality  of  this  Label  be,  taking  into  account  other  existing 
national or international initiatives in the field of cultural heritage? 

There  was  a  general  consensus  that  EHL  had  a  value  on  its  own  and  did  not  overlap  with  other 
existing  initiatives,  such  as  the  Unesco  World  Heritage  List,  the  Council  of  Europe  Cultural  Routes 
and the Europa Nostra awards. This was confirmed by the representatives of ICOMOS (consultative 
body for the UNESCO World Heritage List), the Institute of Cultural Routes and Europa Nostra which 
were  present  in  the  meeting.  Nevertheless  clear  communication  would  be  needed  to  clarify  the 
differences for the general public. 

Stakeholders  involved  in  the  Unesco  World  Heritage  List  underlined  that  the  Unesco  initiative  had 
very  different  criteria:  sites  must  be  universal,  authentic  and  with  architectural  value.  The  World 
Heritage  List  was  first  and  foremost  a  prize  for  conservation,  while  the  Label  should  aim  at  raising 
awareness. It could not be ruled out that a site was awarded both by Unesco and EHL, on condition 
that  it  matched  the  different  criteria  required  by  the  respective  awards.  The  aims  of  the  Council  of 
Europe  Cultural Routes were more similar to those of EHL, did not focus on specific sites but rather 
on  themed  routes  across  different  countries,  and  complementarity  with  EHL  seemed  possible. 
Participants felt there was scope for EHL, as it should award sites with a symbolic value for Europe, 
with  a  strong  educational  focus  and  not  necessarily  of  great  aesthetic  value.  Furthermore  it  was 
observed  that  EHL  was  open  to  contemporary  sites,  such  as  the  Gdansk  shipyards,  as  well  as  to 
immaterial heritage, as long as it was attached to a site. Some participants felt that the transnational 
dimension should be emphasised. EHL criteria should be defined in such a way that they did not leave 
grey  zones  with  other  existing  activities.  As  the  Label  was  aimed  at  citizens,  a  communication  plan 
should be required from competing sites as part of the selection criteria. 

4.2.  Which selection criteria would enable this specificity to be highlighted? 

Participants commented that selection should not involve much bureaucracy for the sites and for the 
Member States. On the one hand, some participants proposed a European selection process, with sites 
applying directly to a European panel. This would ensure a consistent interpretation of the European 
dimension  and  would  encourage  the  participation  of  transnational  sites  proposed  by  more  than  one 
country.  As  one  participant  put  it  “How  will  the  European  value  be  ensured  by  27  national 
committees, each with their own national interpretations of history?” On the other hand, organisations 
currently managing the intergovernmental Label were more sceptical about skipping a national level 
of selection, arguing that this could help to filter out many applications, thereby lightening the burden 
for  the  European  panel.  They  favoured  a  two-stage  selection  procedure,  first  at  the  national  level, 
followed by the European level. 

The participants were also divided on whether the panel should be composed of independent experts, 
linked  to  civil  society  or  whether  it  should  be  comprised  of  national  representatives  supported  by 
expert advice. ICOMOS, the Institute of Cultural Routes and Europa Nostra reported on the selection 
procedure of their respective initiatives. The representative of ICOMOS underlined that the procedure 
for the World Heritage List had become very heavy over the years and strongly recommended learning 
from this experience in order to implement a lighter approach for the Label. A single level selection 
approach could be the solution. 

4.3.  How to enhance the European dimension of our cultural heritage? 

An  awarded  site  should  have  cultural  and  historic  meaning  for  several  countries,  across  Europe,  for 
instance  by  highlighting  the  contribution  of  artists  coming  from  different  countries,  or  remembering 
events  with  an  impact  on  many  countries.  Attention  should  be  given  to  the  interpretation  and 

EN 

45 

   EN 

 
transmission  of  the  symbolic  value  of  these  sites.  Sites  should  be  living  places,  communicating  not 
only about the sites themselves but also about the European project. 

As the European cultural space reached beyond current EU borders, some participants proposed that 
that  EHL  should  be  open  to  cooperation  with  neighbouring  countries,  in  order  to  help  build  bridges 
and  value  common  European  memories.  It  was  also  mentioned  that  sites  should  be  very  carefully 
selected, in order to avoid reigniting recent memories of some conflicts. 

4.4.  How to promote the access of young people to European cultural heritage? 

As expressed earlier, participants emphasised the educational efforts EHL sites should make in order 
to involve schools and other educational organisations, for instance through virtual visits and learning 
facilities based on new technologies. Sites could also cooperate with tourism associations to promote 
visits by young people. 

OPEN DISCUSSION: WHICH ROLE FOR THE EUROPEAN UNION IN THE 

5. 
EUROPEAN HERITAGE LABEL? 

After the specificity and the added value of the European Heritage Label, the debate focussed on the 
potential  benefits  of  transforming  the  intergovernmental  initiative  into  a  formal  EU  initiative.  The 
discussion was guided by the following key questions: 

5.1.  Would the Label benefit from a closer involvement of the European Union? 

Stakeholders  were  in  agreement  with  the  Council  that  a  closer  involvement  of  the  European  Union 
would  help  in  broadening  the  geographical  coverage,  defining  clearer  and  more  transparent  criteria 
and  procedures,  as  well  as  improving  the  visibility  of  the  Label,  all  of  which  were  difficult  with  a 
rotating secretariat. 

5.2.  What role for the European Union in the selection process of the sites and in the 
monitoring process? 

Some  participants  felt  that  a  formal  designation  by  the  Council  of  Ministers  would  be  important 
symbolically and help the visibility of the initiative. Some other comments referred to the Commission 
as  a  permanent  secretariat,  playing  a  role  similar  to  the  one  it  ensured  for  the  European  Capitals  of 
Culture.  This  permanent  secretariat  would  ensure  a  consistent  monitoring  of  the  awarded  sites  and 
facilitate networking among them. 

OPEN DISCUSSION: HOW TO IMPLEMENT THE EUROPEAN HERITAGE 

6. 
LABEL EFFECTIVELY? 

The discussion was preceded by a presentation by French and Spanish representatives who had been 
ensuring the secretariat of the intergovernmental Label since its creation in 2007. They described the 
concept of the Label, the current number of sites (it had been agreed that each country participating in 
the  Label  could  award  up  to  4  Labels)  and  the  new  website  of  the  initiative  hosted  by  the  Spanish 
Ministry  of Culture.  They  saw  the  Label's  first  years  as  a  transition  towards a  Community  initiative 
which  would  broaden  the  scope  of  the  initiative  and  increase  the  number  of  participating  countries. 
Some networking among the sites was already in place, but this aspect needed to be further developed. 
Many questions were raised by the participants to the French and Spanish representatives in order to 
clarify  the  aims  and  functioning  of  the  current  intergovernmental  initiative.  This  confirmed  that  the 
EHL currently lacked visibility and was still rather unknown, even by the heritage sector itself. It also 
confirmed that in order to have an effective impact in the future, the new Label would need to have a 
strong communication strategy. The debate was then guided by the following key questions: 

EN 

46 

   EN 

 
6.1.  How to ensure that the number of sites awarded the Label will remain reasonable 
and representative? 

As the Label started as an intergovernmental initiative, a given number of awards per country were set 
out.  With  the  EU  taking  the  lead,  some  participants  questioned  this  approach  as  it  would  prevent 
transnational  applications  (unless  a  special  quota  was  foreseen).  On  the  one  hand  the  number  of 
awarded Labels should be limited to ensure their value and prestige, on the other hand bigger countries 
would be penalised if they had the same quota as smaller ones. In the case of national quotas, it was 
mentioned that in view of the aim of the initiative to reach citizens, it would be important that for the 
sites  to  be  sufficiently  spread  out  geographically  in  order  to  ensure  that  all  citizens  had  reasonable 
access to such a site over the long run. 

Another  suggestion  was  to  fix  quotas  over  Europe  focussing  different  categories/sectors,  like  the 
Europa  Nostra  Prize.  Alternatively  quotas  for  sectors  could  also  be  fixed  at  national  level  (plus 
national  quotas).  One  participant  suggested  a  categorisation  of  sites:  Europe  of  artistic  creators; 
Europe  of  architecture,  styles  and  landscapes,  Europe  of  the  sacred  and  spirit,  Europe  of  industry, 
Europe of democracy. 

6.2. 

Should the Label be attributed on a permanent basis or for a limited time only? 

Most participants felt that, for the sake of consistency, the Label should be attributed on a permanent 
basis, as its symbolic value did not change over time. Nevertheless periodic review should be possible 
to ensure that the key communication and educational activities were still in place. It was mentioned 
by  one  participant  that  EHL  sites  could  receive  a  Commission  grant  for  communication  activities, 
either on a temporary basis and renewable or permanent but subject to monitoring. This would provide 
incentives to keep EHL sites up to the requested level, in a similar way as the Melina Mercouri prize 
did  for  the  European  Capitals  of  Culture.  Nevertheless  it  was  noted  that  a  communication  strategy 
would  take  time  to  be  implemented;  this  should  be  considered  while  fixing  the  time  span  for 
monitoring or renewals. 

6.3.  How to raise the profile and visibility of the European Heritage Label? 

Participants  suggested  linking  the  EHL  to  the  European  Heritage  Days,  encouraging  national 
coordinators to include EHL sites available in the Days programmes. It was also recommended, that, 
although  EHL  could  be  awarded  to  immaterial  heritage,  this  should  nonetheless  be  anchored  to  a 
physical  site.  Partnership  with  local  authorities  and  civil  society  was  considered  essential.  A 
participant noted that EHL was two-fold, coupling the symbolic value of a site with a communication 
effort.  In  order  to  ensure  that  communication  would  be  well  conducted  competing  sites  should  not 
only  provide  a  communication  plan,  but  also  some  evidence  of  the  quality  of  their  current 
communication  work.  EHL  awarded  sites  should  clearly  explain  to  visitors  how  and  why  they  had 
been chosen. 

6.4.  How to keep the administrative arrangements light and flexible both at European 
and national level? 

As a general remark it was suggested to keep EHL as open as possible in terms of categories, sectors 
and  definitions.  As  the  question  of  eligibility  of  private  sites  was  raised,  participants  suggested  that 
private  sites  should  be  eligible  if  they  provided  reasonable  assurance  of  their  capacity  and  with  a 
guarantee of the Member States concerned (as in the case of Unesco). 

7. 

CONCLUSIONS AND CLOSE OF THE MEETING 

EN 

47 

   EN 

 
Ms Branch closed the meeting recalling next steps in preparing the proposal, which should be 
adopted by the Commission in February 2010 and then submitted to Parliament and Council 
during the Spanish presidency.  

LIST OF REGISTERED PARTICIPANTS 

Name 

First Name 

Organisation 

Arribas Pérez 

Beatriz 

Delegación Permanente de Castilla y León ante la UE 

Arrizabalaga 

Esperanza 

Oficina del Gobierno de Cantabria en Bruselas 

Balogh 

Zoltán 

Representation of Eszak-Alfold Region in Brussels 

Barraca de Ramos   Pilar  

Bentz 

Prof. Dr. 
Martin 

Spanish Ministry of Culture; Subdirección General de 
Protección del Patrimonio Histórico 

Deutscher Archäologen-Verband e.V. 

Bolton Holloway 

Julia 

Association of Significant Cemeteries in Europe 

Broehl 

Bucher 

Maximilian 

Vertretung des Landes Nordrhein-Westfalen bei der 
Europäischen Union 

Jean-Marc  

Ville de Troyes, France 

Callizo Azqueta 

Silvia 

Delegación del Gobierno de Navarra, Brussels 

Cardama  

Maruxa 

South West UK Brussels Office 

Castenholz 

Castro 

Frank 

Alexis 

Vertretung der Freien Hansestadt Bremen bei der EU 

Culture Lab 

Chambron 

Claire-Lyse 

Ministère de la culture et de la communication, France 

Chameroy 

Fabienne 

Student 

Chaney 

Edward  

Southampton Solent University 

Cormann 

Tatjana 

Ministerium der Deutschsprachigen Gemeinschaft - Abteilung 
Kulturelle Angelegenheiten 

Coxen  

Alexandra 

English Heritage  

d'Alessandro 

Alberto  

Ministri per i Beni e le Attività Culturali  + Associazione via 
Francigena 

D'Almeida 

Henri 

Ministère de la culture et de la communication, France 

EN 

48 

   EN 

 
 
 
Devillers 

Ghislaine 

Département du Patrimoine; Région wallonne de Belgique 

Engelke 

Thomas 

Hanse-Office - Joint Representation of the Free and Hanseatic 
City of Hamburg and the State Schleswig-Holstein to the EU 

Favel 

Bruno 

Direction de l'architecture et du patrimoine; Ministère de la 
Culture et de la Communication, France 

Fourcroy 

Nicolas 

ESSA - European  States Stud Association 

Garcia Alvarez 

Ana María 

Student 

Gasc 

Gerber 

Gluck  

Hervé 

Fanny 

Oliver 

David 

Julie 

Antenne Interrégionale Auvergne-Centre-Limousin 

Mission de la Suisse auprès de l'Union européenne 

ECOTEC 

EUROCITIES 

Honoré 

Frederique 

Site archéologique et musée du Coudenberg  

Hornung 

Stefanie  

Büro des Landes Berlin bei der EU  

Hurtado Ory 

Alejandro 

Andalusian delegation in Brussels  

Infante 

Claude 

Confrontations Europe 

Ingelaere  

Pascale  

Gouvernement de la Région de Bruxelles-Capitale 

Jungeblodt 

Gaia 

ICOMOS International Council on Monuments and Sites  

Lecci 

Silvia 

GEIE Culture-Routes Europe; Institut Européen des Itnéraires 
Culturels 

Lekakis 

Stelios  

ELLINIKI ETAIRIA  - Society for the Environment and 
Cultural Heritage 

Leon Burgos 

Diego 

Delegation of the Goverment of the Canary Islands, Brussels 

Leopold 

Amandine  

AVEC - Alliance de Villes Européennes de Culture 

Mariucci  

Andréa  

Gouvernement de la Région de Bruxelles-Capitale 

Martín Ramos 

Miguel Angel 

European Academy of Yuste Foundation  

Martinez soliño 

Gemma Maria  Delegacion del Gobierno de Canarias en Bruselas 

McCoshan 

Andrew 

ECOTEC 

Meissnitzer 

Heidi  

Permanent Representation of Austria to the EU 

Miroir 

Morales 

Mme 

Commune d'Anderlecht - Echevine à la culture 

Margarita  

Oficina de la Región de Murcia 

EN 

49 

   EN 

 
Papaioannou  

Maria 

Patricio 

Teresa 

ICOMOS Wallonie - Bruxelles 

Peuziat 

Pintus 

Jean-Philippe 

Représentation des Régions Bretagne, Pays de la Loire et 
Poitou-Charentes à Bruxelles 

Barbara 

Culture Lab 

Pradayrol 

Sophie  

Quadvlieg-
Mihailovic 

S.  

Développement touristique & Promotion internationale - Ville 
de Troyes 

Europa Nostra 

Quémarec 

France 

Direction de l'architecture et du patrimoine; Ministère de la 
Culture et de la Communication, France 

Röhrs 

Dr. Friedrich 

Permanent Representation of Germany to the EU 

Ruiz Paniagua 

Blanca 

Junta de Castilla y León  

Sarazá Jimena  

Pablo  

Delegación de la Junta de Andalucía, Brussels 

Sexauer 

Katharina 

Büro des Landes Berlin bei der EU  

Simeone 

Gian Giuseppe  Culture Lab 

Stiévenart 

M. 

Commune d'Anderlecht 

Teller 

Sarah  

 Student 

Thomann 

Stephanie  

Representation of the state of Saarland (Germany) at the EU 

Thys 

Torra 

Arlette 

Flemish Ministry of Culture, Youth, Sports and Media 

Alberto  

Archivo de la Corona de Aragón (Barcelona) 

Torres Martín 

María 

Delegación de la Junta de Andalucía en Bruselas 

van Iersel 

Rob  

Dutch Permanent Representation 

van Rijckevorsel 

L.  

Europa Nostra 

Van Rompaey 

Sara 

Order of Architects Belgium 

Vandewattyne 

Claude 

Communauté française, Belgique 

Victor 

Stephane 

Représentation de l'Ile-de-France à Bruxelles  

Walazyc 

Anne-Sophie 

Cabinet du Secrétaire d'Etat à la Région de Bruxelles-Capitale 

Wert 

Carlos 

Sitio Español de Patrimonio Europeo Residencia de 
Estudiantes 

EN 

50 

   EN 

 
  
Wittling  

Isabelle  

Representation of the state of Saarland (Germany) at the EU 

Zhang 

Li 

Mission of the People's Republic of China to the European 
Communities  

EN 

51 

   EN 

 
 
ANNEX 2: 

MEETING SUMMARY 

EHL MEMBER STATES' EXPERTS MEETING 

24 JUNE 2009 

EN 

52 

   EN 

 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 
Directorate-General for Education and Culture 

Culture, Multilingualism and Communication 
"Culture" programme and actions 

EUROPEAN HERITAGE LABEL (EHL) MEMBER STATES' EXPERTS MEETING 
 BRUSSELS, 24 JUNE 2009 

SUMMARY OF THE MEETING 

PRESENTATION  OF  THE  MAIN  STEPS  OF  THE  IMPACT  ASSESSMENT  AND 
OBJECTIVES OF THE MEETING 

Ms  Odile  Quintin,  Director  General  of  DG  Education  and  Culture,  opened  the  meeting  and  briefly 
recalled  the  origins  of  the  Label,  as  an  intergovernmental  initiative  and  the  Council  Conclusions  of 
November 2008 inviting the Commission to submit to it "an appropriate proposal for the creation of a 
European  Heritage  Label  by  the  European  Union  and  specifying  the  practical  procedures  for  the 
implementation  of  the  project.".  She  then  informed  the  participants  on  the  main  steps  of  the  impact 
assessment  which  was  currently  underway  and  which  included  a  public  consultation  (online 
consultation,  stakeholder  meeting  and  current  meeting).  She  announced  that  the  Commission 
envisaged presenting its draft proposal at the beginning of 2010, during the Spanish Presidency. 

She restated that the Commission would take into account the achievements of the intergovernmental 
phase  of  the  Label  in  the  impact  assessment  and  in  the  preparation  of  the  Commission's  proposal. 
However she also underlined that with the adoption of the Council conclusions, the Label entered into 
a  new  phase  and  that  the  Commission  and  the  27  Member  States  would  now  have  to  determine 
together what the new forms of the Label should be in order to make it as effective and attractive as 
possible. 

Ms Quintin made clear that, throughout the consultation phase a broad consensus emerged concerning 
the  general  orientations  of  the  future  Label.  However,  two  important  questions  still  raised  some 
concerns  concerning  the  practical  details  of  the  implementation  of  the  label  and  needed  further 
discussion:  how  to  ensure  that  the  number  of  sites  awarded  the  European  Heritage  Label  remained 
reasonable  and  representative  and  how  to  keep  the  administrative  arrangements  for  the  future 
European Heritage Label light and flexible at national and European level? The current meeting would 
therefore  focus  on  those  two  issues.  She  invited  MS  experts  to  intervene  freely  and  frankly  in  the 
discussion, to test a range of ideas in order to find the most suitable solutions. 

PRESENTATION OF THE FIRST RESULTS OF THE PUBLIC CONSULTATION 

Mr Jean-Philippe Gammel, European Commission, presented the key messages received through the 
online public consultation (attached).  He then briefly related feedback from the stakeholder  meeting 
held on 10 June, where the key messages had echoed those of the on-line consultation, with a stronger 
focus on the practical arrangements for the implementation of the Label. This had been greatly helped 
by the presence of Icomos (consultative body for Unesco, in charge of the instruction of applications 
for the World Heritage List), the European Institute of Cultural Routes (in charge of the instruction of 
applications for the Council of Europe's Cultural Routes) and Europa Nostra (managing the European 
Union Prize for Cultural Heritage). They all agreed that the scope of EHL would not overlap existing 
initiatives and put forward concrete proposals to implement it in a flexible way. 

EN 

53 

   EN 

 
 
 
 
 
The  number  of  sites  to  be  awarded  per  country  and  the  way  of  selecting  the  sites  seemed  to  be  the 
most  complex  issues.  The  Member  States  actually  implementing  the  intergovernmental  European 
Heritage Label were in favour of keeping a two level selection process starting with a pre-selection at 
national level. Civil society organisations were more in favour of an open, single stage competition at 
European level without any quotas of sites per country.  

OPEN DISCUSSION ON: 

How to ensure that the number of sites awarded the European Heritage Label remains reasonable 
and representative? 

How  to  keep  the  administrative  arrangements  for  the  future  European  Heritage  Label  light  and 
flexible at national and European level? 

As  proposed  by  Ms  Quintin  at  the  beginning  of  the  meeting,  it  was  agreed  to  take  together  the  two 
points in the agenda, as they partially overlapped. The two questions guided the interventions, which 
had been prepared on the basis of two discussion papers (attached) received in advance by participants 
and presenting a detailed set of implementation issues. 

ES  thanked  the  Commission  for  its  readiness  to  take  EHL  forward.  It  highlighted  the  dual  nature  - 
political and technical – of selection issues. As three levels of power were involved (local, national, 
European) ES feared that a selection only at EU level would undermine the political dimension and be 
detrimental to smaller or more peripheral sites. Other examples of combined selection procedures at 
national and EU level were available, for instance in the education field. A maximum number of sites 
should  be  set  to  ensure  quality  as  well  as  a  quota  of  sites  per  country.  ES  proposed  a  rotation 
procedure,  with  9  MS  entitled  to  apply  each  year  for  a  maximum  of  3  Labels  per  country.  Quality 
should  be  the  main  criterion  to  decide  to  award  the  Label.  Although  some  costs  were  inevitable,  it 
should  be  remembered  that  there  would  also  be  benefits,  especially  from  an  awareness-
raising/educational  point  of  view.  ES  strongly  recommended  to  learning  from  the  experience  of  the 
Unesco scheme in order not to repeat the same mistakes: procedures should stay as light as possible. 

IT  proposed  to  take  inspiration  from  a  national  practice  in  place  to  facilitate  applications  to  the 
UNESCO World Heritage List: a committee set in place to disseminate information, provide guidance 
and “filter out” applications. This same Committee also provided follow-up after selection of a site. IT 
proposed  a  two-phase  selection,  with  national  pre-selection  managed  by  a  national  authority  on  the 
basis of common criteria set at European level. Final selection should be managed by a panel of EU 
experts. IT would leave the number of Labels open. As for duration, the Label should be permanent in 
order to enable sites to invest in sustainable activities. National monitoring should be foreseen. Priority 
should be given to sites with a broad access to the public and with a transnational character. 

CZ called for a system similar to the one for the European Capitals of Culture. Each MS should be left 
free  to  define  what  European  added  value  meant  nationally.  CZ  was  in  favour  of  a  rotation  system, 
with  each  MS  applying  every  fourth  year,  in  order  not  to  inflate  the  number  of  Labels.  Monitoring 
would be ensured at national level. The attribution of the Label should be permanent. 

AT favoured an open selection procedure (in two phases) on a rotation base, with no set number of 
Labels. EHL should remain a voluntary initiative, leaving MS free to decide whether to participate. As 
for  the  duration,  Labels  should  be  temporary,  but  renewals  could  be  allowed.  Costs  should  be  as 
limited as possible, both for the selection procedure and for the sites themselves.  

The  AT  representative  welcomed  the  EHL  as  a  way  of  highlighting  the  richness  of  common  EU 
heritage. He recalled that the EU dimension should be ensured consistently: common guidelines and 
selection forms were much needed AT commented that communication efforts were needed in order to 
raise the EHL profile. 

PL  was  in  favour  of  a  two-phase  selection  with  no  national  quotas.  The  European  panel  should  be 
composed by recognised EU cultural experts. Rotation was an option that could be considered, but it 
could involve imbalances between MS who had already implemented the intergovernmental Label and 
those  who  did  not.  It  might  be  introduced  in  a  second  phase  only.  Labels  should  be  permanent,  but 

EN 

54 

   EN 

 
subject  to  monitoring  and  there  should  a  possibility  of  withdrawal  in  case  the  criteria  were  not 
respected.  PL  was  in  favour  of  the  selection  of  transnational  sites  but  drew  attention  to  possible 
problems with sites which are common with third countries. PL commented that communication costs 
should not be disproportionate for EHL awarded sites. 

NL was in favour of national selections, based on common guidelines and criteria, especially to define 
the European dimension. It raised attention to the fact that the same number of Labels per MS would 
go against quality in smaller countries. If a limited number was to be decided, it should be weighted 
upon the country size and population. NL would be against rotation as it did not seem to encourage 
transnational cooperation. 

LT  supported  an  open  competition,  with  no  fixed  quota  per  country.  Nevertheless  MS  should  be 
responsible for ensuring the quality and EU significance of the proposed sites. As for priorities, sites 
should have a strong transnational dimension and promote cross-border cooperation. It was in favour 
of awarding the Label for a limited time of 5-7 years, renewable upon monitoring of educational and 
communication  activities  in  place.  LT  supported  a  permanent  EU  secretariat,  with  monitoring 
procedures at national level. Participation in EHL should be voluntary for each MS. 

FR thanked the Commission for the very comprehensive feedback on the consultation process and the 
focussed  questions  for  discussion.  FR  agreed  with  ES  concerning  a  rotation  principle  (9  countries 
every  third  year),  with  a  fixed  number  of  Labels  per  country  at  every  selection  (with  no  difference 
between bigger and smaller countries)... It supported a selection at two levels (national and European) 
and  agreed  on  the  need  for  common  criteria  and  guidelines.  At  European  level,  FR  suggested  the 
creation of a panel on the model of the European Capitals of Culture which should be supported by a 
consultative scientific committee. FR strongly supported the permanent nature of the Labels, is it took 
time to be set in place and should be based on long term strategies, but with monitoring. The European 
dimension should be strongly emphasised, as well as the networking among sites, in order to maximise 
awareness-raising of citizens. 

UK thanked the Commission for the consensual way it was steering the process. It agreed on keeping 
procedures  light  and  on  shifting  EHL  focus  away  from  conservation  and  towards  projects  with  a 
strong educational dimension. UK could support EHL as it was being currently developed. UK would 
be  in  favour  of  temporary  designations,  as  it  felt  it  would  be  more  appropriate  for  the  nature  of 
projects targeted by the Label, although it agreed that it should be for a realistic duration. UK strongly 
reminded  that  as  EHL  should  not  insist  on  architectural  value;  there  would  be  no  contradiction  in 
awarding  temporary  labels,  as  they  would  be  devoted  mainly  to  the  communication  activities 
implemented. 

SE  did  not  have  yet  an  established  position,  but  was  inclined  at  the  current  time  to  favour  an  open 
competition, but could accept rotation between Member States. It stressed the need for very clear EU 
criteria  and  guidelines,  with  a  special  focus  on  the  EU  dimension  and  the  educational  value.  EHL 
should  remain  voluntary  for  Member  States.  Thematic  criteria  could  also  be  proposed  to  promote 
cooperation among countries. As for selection procedures: the most efficient would be to allow sites to 
apply  directly  to  a  European  panel,  but  this  way  the  local  and  national  involvement  would  be  lost. 
Sites  should  not  be  inward  looking  but  promote  access  and  cooperation  across  borders.  The  Label 
should  be  either  permanent  with  a  possibility  of  withdrawal,  or  temporary  but  long-term  with  the 
possibility for renewal. 

FI would welcome a maximum number of Labels per year at EU level, with no national quotas, but 
with a rotation process. This would minimize the selection workload at national level. As for length, 
FI  was  in  favour  of  temporary  Labels,  in  order  to  avoid  heavy  monitoring.  It  would  also  support 
thematic priorities. 

BE  emphasised  the  transnational  aspect  of  sites  designation.  BE  warned  that,  as  the  definition  of 
heritage  was  evolving,  including  modern,  contemporary,  etc.  a  closed  number  of  perennial  sites  did 
not  seem  to  be  adapted.  A  national  committee  should  be  set  in  place,  supported  by  an  expert 
committee: it would be in charge of pre-selection and monitoring. For the final selection, BE would be 
in favour of a European panel made up of recognised experts. The number of sites per country should 

EN 

55 

   EN 

 
be  linked  to  the  frequency  of  calls  (for  instance  three  every  year  per  country  plus  a  number  of 
transnational  sites).  Rotations  would  not  help  transnational  cooperation.  Monitoring  should  be  done 
nationally  and  upon  two  negative  monitoring  opinions  for  example,  the  Label  could  be  withdrawn. 
The  mechanism  of  a  “passive  list”  could  be  a  way  of  documenting  the  history  of  the  Label: 
intergovernmental sites and those no longer matching Label criteria could be put on the list.  

DE  was  in  favour  of  a  two-phase  open  procedure  (national  and  European),  with  no  national  quotas. 
Nevertheless there should be no more than 10-15 labels per year, favouring transnational applications. 
Final  decision  should  be  taken  by  the  Council  of  Culture  Ministers,  on  the  basis  of  the 
recommendations  of  the  European  panel.  The  Label  should  be  permanent,  but  could  be  withdrawn; 
alternatively, it could be temporary but renewable. As for the secretariat, DE invited to consider the 
most cost effective solution which might be an external solution such as the EAC executive agency or 
a third body like Europa Nostra for example. 

DK although initially not in favour of EHL, could agree with the current focus, especially with the aim 
of raising awareness of young people of common EU history. DK thought that a European panel was 
essential to guarantee the European dimension. It supported a country rotation, with no fixed number 
of Labels. The Label should be permanent, with periodic monitoring and with a strong transnational 
focus. 

LUX  recommended  fixing  very  detailed  criteria  and  priorities.  In  a  first  phase  there  should  not  be 
limits  per  country.  All  applications  should  be  submitted  to  a  European  panel.  In  a  second  phase  a 
rotation  system  could  be  envisaged.  The  Label  should  be  permanent  as  it  highlighted  a  permanent 
value. Regular monitoring should be set in place with a possibility of withdrawal of the Label. 

HU  was  in  favour  of  a  two-phase  selection  procedure,  with  very  stringent  criteria,  especially on  the 
European dimension. There should be a pre-selection at national level, but the final selection should be 
European  and  made  by  an  independent  jury.  HU  would  favour  no  rotation  and  no  fixed  number. 
Thematic priorities could be set in place to better focus applications. 

MT pleaded for an open call, with no set number per country but stringent criteria and transnational 
value. The Label should permanent, but monitored and with the possibility of withdrawal. 

EL proposed a two-phase selection, with pre-selection at national level and selection made by an EU 
independent expert committee. EL was not in favour of setting a fixed number of Labels, at least in the 
first phase, but quality criteria should be stringent and with a transnational dimension. Labels should 
be permanent. 

SI agreed on two-phase selection with common stringent criteria and no fixed quotas. Special priority 
should  be  given  to  transnational  nominations.  Labels  should  be  permanent  or  alternatively,  firstly 
temporary (during a trial phase) rather than permanent. 

SK was in favour of an open competition in two phases, with a permanent secretariat. Labels should 
be permanent with monitoring. 

Conclusions by the European Commission 

Mr  Vladimir  Šucha  thanked  the  participants  for  the  very  constructive  and  frank  debate,  based  on 
mutual trust and invited them to send in detailed position papers, if they so wished.  He underlined the 
many challenging questions which remained open either because there were still divergences between 
Member States on certain issues or, more strikingly, because the positions expressed by some of the 
Member States were not entirely free of contradictions, namely: how to reconcile the wish to have an 
open competition at European level with the will to keep a pre-selection at national level ? 

•  how to foster the selection of transnational sites while setting quotas of sites per country ? 

•  how to keep the administrative arrangements light and flexible despite a selection at two levels 

and the involvement of the Council of Ministers in the designation procedure? 

•  how  to  strengthen  the  role  of  the  European  panel  of  experts  without  jeopardising  local 

involvement ? 

EN 

56 

   EN 

 
•  how to ensure the excellence of the Label and the relevance and quality of the selected sites 

without any limitations on the number of Labels awarded each year? 

Mr Šucha concluded by saying that the Commission would nevertheless take up these challenges and 
was  confident  it  would  find  reasonable  solutions,  on  the  basis  of  the  common  willingness  of  the 
Member States to develop the EHL. 

EN 

57 

   EN 

 
Member States' experts meeting 24 June 2009 

List of participants 

AUSTRIA 

Mr Norbert Riedl 
Head of Unit for EU cultural affairs  
Federal Ministry for Education, Arts and Culture 

Ms Heidemarie Meissnitzer 
Counsellor for Cultural Affairs 
Permanent Representation of Austria to the EU 

BELGIUM 

Ms Arlette Thys 
International Cultural Heritage 
Flemish Ministry of Culture, Youth, Sports and Media 

Mr Claude Vandewattyne 
Direction Générale de la Culture 
Ministère de la Communauté Française  

BULGARIA  

Ms Dolya Yordanova 
Architect, Chief Expert 
Directorate “European Union and International Cooperation”  
Ministry of Culture of the Republic of Bulgaria 

CYPRUS  

 Mr Kyriakos Costeas  
Education and Culture Attaché 
Permanent Representation of Cyprus to the EU 

CZECH REPUBLIC 

Ms Jaromira Mizerova 
Head of EU Unit 
Ministry of Culture 

EN 

58 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
  
 
 
 
 
 
Mr Zdenek Příhoda 
Expert - EU Unit 
Ministry of Culture 

DENMARK   

Mr Michael Lauenborg 
Head of Section 
Heritage Agency of Denmark 

ESTONIA 

Mr Anton Pärn  
Undersecretary of Cultural Heritage 
Estonian Ministry of Culture 

FINLAND 

Ms Päivi Salonen 
Counsellor for Cultural Affairs 
Division for Cultural Policy 
Ministry of Education 

FRANCE 

Mr Bruno Favel 
Chef de la mission européenne et internationale  
Direction de l'architecture et du patrimoine 
Ministère de la culture et de la communication 

Mr France Quémarec  
Direction de l'architecture et du patrimoine  
Ministère de la culture et de la communication 

Ms Claire-Lyse Chambron  
Département des affaires européennes et internationales 
Ministère de la culture et de la communication 

Mr Henri d'Almeida   
Département des affaires européennes et internationales 
Ministère de la culture et de la communication 

EN 

59 

   EN 

 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
GERMANY  

Mr Dr. Werner von Trützschler 
Leiter der Abteilung für Kultur, Kunst und Kirchenangelegenheiten 
Kultusministerium Thueringen 

Mr Dr. Friedrich Röhrs 
Botschaftsrat Europäische Kulturpolitik 
Permanent Representation of Germany to the EU 

GREECE 

Ms Marioanna Louka   
Archaelogist 
General Directorate of Antiquities and Cultural Heritage 
Hellenic Ministry of Culture  

HUNGARY 

Mr László Mihalyfi 
Directeur du Département de la Protection du Patrimoine culturel et de la Coordination 
Ministry of Education and Culture 

Mr Aron Balázs 
Permanent representation of Hungary to the EU 

IRELAND 

Mr Dermot Burke 
Director of Heritage Services 
Office of Public Works 

Mr Caoimhin OCiaruain 
Permanent representation of Ireland to the EU 

ITALY 

Mr Patrizio Fondi 
Conseiller Diplomatique 
Ministère du Patrimoine et des Affaires Culturelles 

Ms Leila Nista  
Ministère du Patrimoine et des Affaires Culturelles 

EN 

60 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
  
 
 
 
 
 
 
 
 
LATVIA 

Ms Agnese Rupenheite-Čodare 
Cultural Heritage Policy Unit 
State Inspection for Heritage Protection 

LITHUANIA 

Ms Vida Graziene 
Attaché for Culture 
Permanent Representation of Lithuania to the EU 

LUXEMBURG 

Mr Alex Langini  
Chargé de Mission 
Ministère de la Culture 

MALTA 

Mr Kenneth Gambin    
Heritage Malta Head Office 

NETHERLANDS 

Ms Arda Scholte 
Head of Unit - Policy Development 
Directorate Cultural Heritage, 
Ministry of Education, Culture and Science 

Mr Aart de Vries 
Cultural Heritage Agency 

POLAND 

Ms Małgorzata Fokt-Willman 
Chief specialist  
Monuments Preservation Department 
Polish Ministry of Culture and National Heritage 

Ms Hanna Jędras 
Head of Unit 

EN 

61 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Department of International Relations 
Polish Ministry of Culture and National Heritage 

PORTUGAL 

Mr Joao De Almeida Filipe 
Portuguese Ministry of Culture  

ROMANIA 

Mr Mircea Angelescu   
Ministry of Culture, Religious Affairs and National Heritage 

SLOVAKIA 

Ms Lucia Pawlikova 
Permanent Representation of the Slovak Republic to the European Union 

SLOVENIA   

Mr Dusan Kramberger 
Secretary 
Directorate for Cultural Heritage 
Ministry of Culture 

SPAIN 

Mr Fernando Gómez Riesco  
Sous-directeur de la coopération culturelle internationale 
Ministère de la culture 

Ms Josefina López 
Service de la coopération culturelle multilatérale 
Ministère de la culture 

Ms Pilar Barraca de Ramos 
Sous-direction générale de la protection du patrimoine historique 
Ministère de la culture 

SWEDEN 

Mr Henrik Selin 
Permanent Representation of Sweden to the EU 

EN 

62 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
UNITED KINGDOM 

Mr Harry Reeves  
Department of Culture, Media and Sport 

EN 

63 

   EN 

 
 
 
 
 
EUROPEAN HERITAGE LABEL 
Member States' experts meeting 
Brussels, 24 June 2009 

Discussion papers 

Introduction: 

At  its  meeting  on  20  November  2008,  the  Council  of  the  European  Union  (Education,  Youth  and 
Culture)  adopted  conclusions  inviting  the  European  Commission  to  submit  to  it  "an  appropriate 
proposal  for  the  creation  of  a  European  Heritage  Label  by  the  European  Union  and  specifying  the 
practical procedures for the implementation of the project."  

These conclusions give a fairly detailed basis for the European Commission for the preparation of its 
proposal. However, during the negotiations for the adoption of these conclusions, a number of issues 
were left open by the Member States for further analysis. 

The Impact Assessment and public consultation which were launched by the European Commission, 
and which are still underway, have been very useful in helping to move forward on several of these 
issues.  It  transpires  that  there  is  indeed  broad  consensus  concerning  the  general  orientations  of  the 
future Label. However, two important questions still raise some concerns and need further discussion: 
how to ensure that the number of sites awarded the European Heritage Label remains reasonable and 
representative  and  how  to  keep  the  administrative  arrangements  for  the  future  European  Heritage 
Label light and flexible at national and European level? The Member States experts' meeting offers an 
opportunity  to  make  substantial  progress  on  these  issues.  The  following  two  discussion  papers  are 
aimed at contributing to the orientation of the discussions. 

EN 

64 

   EN 

 
 
 
 
 
 
 
Discussion paper n°1: how to ensure  that the number of sites awarded the European Heritage 
Label remains reasonable and representative? 

The Council conclusions mention as one of the main principles of the future European Heritage Label 
that  the  project  should  be  based  on  a  "regular  selection  procedure  […]  covering  a  reasonable  and 
representative number of sites each time" (section 3b). 

The need to keep the number of sites awarded the label reasonable has indeed been a major concern of 
Member States and of stakeholders during the negotiation phase for the adoption of the conclusions as 
well as during the current public consultation process. It is considered an essential condition to ensure 
the quality and credibility of the European Heritage Label, as well as to keep the initiative manageable 
both  at  national  and  European  level.  It  also  has  implications  for  the  very  design  of  the  selection 
process. However, beyond consensus on the fact that the number should be reasonable, few concrete 
solutions have been proposed as to how this should be implemented in practice. 

A  first  important  question  which  still  requires  an  answer  is  what  is  actually  a  reasonable  and 
representative number of sites? Once this is determined, practical arrangements for the implementation 
need to be designed. 

1. Shall the label be attributed on the basis of an open competition or shall there be a reserved number 
of sites for each Member State? 

Two main options are possible for the attribution of the Label to the sites. The first is to have an open 
competition  which  does  not  take  into  account  the  national  origin  of  the  candidate  sites.  Only  the 
quality  of  the  sites  and  the  proposed  programmes  would  be  considered.  Special  attention  could  be 
given  to  sites  with  a  strong  transnational  dimension.  This  solution  would  guarantee  the  overall 
excellence  of  the  selected  sites.  The  risk  is  that  this  could  create  an  imbalance  between  the  various 
Member  States.  However  the  advantage  would  be  that  it  would  in  many  ways  be  better  adapted  to 
reality in the sense that it could better accommodate the fact that some countries have a greater pool of 
potential sites than others, due to their size and other factors. By avoiding systematic national quotas, 
it would also be easier to keep to a reasonable number of sites. If this option were chosen, the number 
of sites per year to be selected would need to be defined.  

The other option is to have a reserved number of sites for each Member State according to a system 
close to the one implemented for the European Capitals of Culture (in this instance two Member States 
per year can host the title). In this case, should the same number of sites be attributed to each Member 
State  or  should  the  size  of  each  country  be  considered,  and  if  so,  what  should  be  the  formula  for 
deciding the number of sites? 

Should  transnational  sites  be  made  a  special  priority?  For  example,  should  a  parallel  procedure  be 
launched  for a  small  number  of  transnational  sites  which  could apply  directly  to  the  European  level 
every year, thereby providing an added incentive for this kind of initiative?  

2. Is a system of rotation for the selection of the sites the solution? 

One solution that came up during the consultation process is to have a system of rotation between the 
Member States for the selection and attribution of the Label. For example, only one third or one fourth 
of  the  Member  States  would  be  allowed  to  propose  sites  in  any  given  year.  Such  a  rotation  system 
would help to avoid the number of sites awarded the Label increasing too fast, it would help to keep 
the  selection  procedure  more  manageable  each  year  and  it  would  considerably  decrease  the  work 
burden at national level. 

EN 

65 

   EN 

 
 
Would such a rotation system be an acceptable solution? If yes, what would be a reasonable time span 
between two selection rounds for a Member State? Three years, four years or five years? 

3. Shall the label be attributed to the sites for a limited period of time or on a permanent basis? 

Another idea which emerged during the negotiation process in the Council was to attribute the label 
for  only  a  limited,  but  renewable,  duration.  The  arguments  in  favour  of  this  solution  were  that  this 
would be coherent with the fact that this label is much more about the educational and cultural projects 
put forward by the sites (cf. 2b of the conclusions) than about conservation or preservation, and that 
this would help to ensure its distinctiveness vis-à-vis other existing initiatives. On the other hand, it 
was also mentioned that the time period needed to be long enough, and renewable, for the sites to feel 
that the investment effort was justified. 

The  label  could  thus  be  awarded  for  example  for  5  or  6 years  and  after  this  period  a  Member  State 
could choose to either propose the renewal of the same site for a new period or to propose a new site. 
The advantage here would be to keep control over the overall number of sites awarded the label and to 
ensure  that  the  sites  actually  comply  with  the  commitments  they  have  made.  This  idea  appealed  to 
many stakeholders during the consultation process. 

Would the attribution of the label for a limited period be acceptable or is such an option inconceivable 
in the heritage field where organisations are traditionally used to work in the long term? If yes, would 
it be conceivable to have two lists as was proposed by several stakeholders: one "active" list with the 
sites which currently hold the label and one "passive" list with the sites which held it in the past? 

In case the label is attributed on a permanent basis, how can it be ensured that the sites comply with 
commitments they may have made ten or twenty years earlier? The conclusions mention that the sites 
"could be subject to periodic review" (3f). What form should this review take if the label is attributed 
on a permanent basis? Should it be possible for the label to be withdrawn from certain sites? Under 
which conditions? 

EN 

66 

   EN 

 
 
Discussion  paper  n°2:  how  to  keep  the  administrative  arrangements  for  the  future 
European Heritage Label light and flexible at national and European level? 

The Council conclusions mention that the European Heritage Label should keep "flexible and 
streamline administrative arrangements in compliance with the principle of subsidiarity." (3b) 

This  was  indeed  a  central  element  in  the  negotiations  for  the  adoption  of  the  conclusions. 
Without a strong commitment to keep the costs limited both at national and European level 
and  a  strong  commitment  to  avoid  all  unnecessary  bureaucracy,  no  agreement  could  have 
been  reached  between  the  Member  States.  This  same  concern  has  been  expressed  on 
numerous occasions during the consultation process and several stakeholders have underlined 
the importance of also taking into account the potential hidden costs (including for example 
self-generating  bidding  processes)  or  potential  inflation  of  the  workload  which  might  only 
become apparent after several years.    

An  appropriate  division  of  tasks  between  national  and  EU  level  will  be  one  of  the  main 
challenges for the future label. There is general consensus that subsidiarity should remain the 
key principle and that the EU should intervene only where it can bring a clear added value to 
the initiative. Concerning the selection procedures for example, the conclusions mention that 
the  selection  procedure  should  be  carried  out  initially  at  national  level  and  then  only  at 
European level. 

The main tasks for the Member States would thus be to organise the first stage of the selection 
procedure  and  the  regular  monitoring  of  all  the  sites  awarded  the  label  on  their  territory  in 
order  to  ensure  that  they  comply  with  undertakings  they  have  given.  The  main  tasks  of  the 
Commission  would  be  to  ensure  the  homogeneous  application  of  the  criteria  by  all  the 
Member  States,  to  guarantee  the  continuity  of  the  label  through  a  permanent  secretariat,  to 
support  the  work  of  the  group  of  European  experts  in  charge  of  the  second  stage  of  the 
selection  and  monitoring  procedures,  to  facilitate  networking  activities  and  to  ensure  the 
visibility of the label, for example through a common portal or website. 

1.Which practical arrangements at European level? 

the 
The  permanent  secretariat  would  replace 
intergovernmental label and its core tasks would be the general coordination of the label and 
provision of support for the European experts panel. This secretariat should remain as light as 
possible. 

the  current  revolving  secretariat  of 

Concerning the financial implications at European level, in addition to the secretariat of the 
label,  the  costs  should  be  limited  to  funding  the  work  of  the  European  experts,  some 
networking activities between the sites and a website.  

2. Which practical arrangements at national level? 

In  accordance  with  the  subsidiarity  principle,  the  practical  arrangements  at  Member  State 
level should remain as flexible as possible in order to be tailored to national circumstances. 
However,  how  can  it  be  ensured  that  this  flexibility  will  not  harm  the  overall  quality  and 
prestige of the label and that each Member State will respect the common rules and criteria? 

Participation in the label will be on a voluntary basis. Each Member State which decides to 
participate  will  have  to  commit  itself  to  the  effective  organisation  of  the  selection  and 

EN 

67 

   EN 

 
monitoring procedures at national level. How can it be ensured that the workload associated 
with these procedures can be kept under control?  

The  financial  obligations  linked  to  the  label  at  a  national  level  should  be  limited  to  the 
practical  organisation  of  these  procedures.  Any  other  expenses  linked  to  the  label,  either 
during the bidding phase for the attribution of the label or during the implementation of the 
educational  and  cultural  programmes  on  the  sites  should  be  left  to  the  free  decision  of 
Member States and should not create formal obligations for them. How can potential hidden 
costs of the label be avoided (for example, expensive self-generating bidding processes)?  

Although  the  Council  conclusions  refer  to  a  first  selection  occurring  at  national  level,  the 
consultation leads us to believe that this will in fact be a rather expensive approach and more 
difficult to prevent unexpected costs arising both for Member States and the sites themselves. 
Another  more  cost-effective  solution  which  came  up  during  the  consultation  would  be  to 
leave the sites themselves to apply directly to an independent expert organising body recruited 
by  the  European  Commission  (see  also  question  1  above),  which  would  design  a  simple 
procedure  and  simple  application  form.  This  would  have  the  advantage  of  taking  away  the 
organising  burden  and  its  associated  costs  at  the  national  level.  Would  such  a  solution  be 
conceivable? 

__________ 

EN 

68 

   EN 

 
 
 
ANNEX 3:  

CRITERIA FOR THE SELECTION OF THE SITES 

EN 

69 

   EN 

 
 
 
 
 
The first question which needs to be raised concerning the criteria is which type of 
heritage should be eligible for the attribution of the EHL. This question was debated 
in  the  Council  during  the  preparation  of  the  conclusions.  After  long  and  complex 
negotiations,  MS  agreed  on  a  list  inspired  by  various  UNESCO  and  Council  of 
Europe conventions. This list includes: "monuments, natural or urban sites, cultural 
lanscapes  and  places  of  remembrance,  as  well  as  cultural  goods  and  intangible 
heritage attached to a place, including contemporary heritage". The complexity of the 
negotiations  between  the  MS  leaves  little  room  for  manoeuvre.  During  the  Inter-
service  group  meetings,  DG  MARE  and  DG  INFSO  requested  the  addition  of 
"cultural objects" to the list in order to ensure that traditional ships or film heritage 
were also covered by the definition as far as they were linked to a physical site. 

Further  to  the  question  of  the  type  of  heritage  which  should  be  eligible,  a  set  of 
criteria was designed for the actual selection of the candidate sites. These criteria are 
largely  inspired  by  the  Council  conclusions  in  which  the  MS  made  a  number  of 
proposals.  These  proposals  were  then  discussed  and  re-evaluated  during  the 
consultation process and they were then further developed by the Commission. Two 
main  concerns  were  taken  into  account.  Firstly,  to  ensure  that  there  will  be  no 
overlap  with  other  existing  initiatives  in  the  field  of  cultural  heritage  and  reinforce 
the added value of the EHL. Secondly, to link these criteria as much as possible to 
the  objectives  of  the  EHL,  especially  to  the  operational  objectives  and  to  the 
activities  that  should  be  implemented  by  the  sites  in  order  to  contribute  to  the 
specific,  intermediate  and  general  objectives.  The  criteria  are  listed  below  and  are 
divided  into  three  categories  linked  to  the  European  dimension  of  the  sites,  the 
quality of the projects they submit and the quality of the management proposed. 

1. European dimension 

Candidates for the label shall have a symbolic value for Europe's identity and shall 
have  played  a  key  role  in  the  history  and  the  building  of  Europe.  The  sites  shall 
therefore justify: 

(cid:190)  their cross-border or pan-European nature: the past and present influence and 
attraction  of  a  candidate  site  must  go  beyond  the  national  borders  of  a 
Member State; 

(cid:190)  and/or  the  place  and  role  of  a  site  in  European  history  and  European 
integration, and its links with key European events or personalities, as well as 
with cultural, artistic, political, social, scientific or technological movements ; 

(cid:190)  and/or  the  place  and  role  of  a  site  in  the  development  and  promotion  of 
common  values  such  as  freedom,  democracy,  respect  for  human  rights, 
cultural diversity, tolerance and solidarity that underpin European integration. 

These  criteria  are  not  cumulative.  Each  site  must  justify  that  it  fits  into  one  of  the 
criteria as a pre-condition for being selected. The strong European dimension and the 
symbolic  value  of  sites  are  essential  elements  for  the  originality  of  the  EHL 
compared to other initiatives, notably the UNESCO World Heritage List. The three 
criteria  are  built  mainly  on  elements  which  are  present  in  the  Council  conclusions 

EN 

70 

   EN 

 
 
and were discussed at length by the MS in this context. Some room for interpretation 
was  deliberately  left  open,  firstly  for  reasons  of  subsidiarity  as  there  are  some 
differences in interpretation between MS, and secondly in order not to close the door 
to  highly  original  sites  which  might  have  a  strong  potential  and  are  difficult  to 
foresee.  The  selection  panels  at  national  and  /  or  EU  level  will  therefore  have  an 
essential role to play in evaluating if the European dimension and the symbolic value 
of a site are strong enough and if the site is relevant in the light of the objectives of 
the EHL. Inspiration should be drawn from the experience of managing the European 
Capitals  of  Culture,  which  have  a  degree  of  flexibility  in  the  criteria,  and  which  is 
recognised as necessary for such an event in the light  of European diversity in this 
area. 

2. Quality of the project submitted 

Candidates  for  the  label  shall  submit  a  project  which  promotes  their  European 
dimension and commits them to all the following elements: 

(cid:190)  raising  awareness  on  the  European  significance  of  the  site,  in  particular 

through appropriate information activities, signage and staff training; 

(cid:190)  organising educational activities, especially for young people, which increase 
the  understanding  of  the  common  history  of  Europe  and  of  its  shared  yet 
diverse  heritage  and  which  strengthen  the  sense  of  belonging  to  a  common 
space; 

(cid:190)  promoting  multilingualism  by  using  several  languages  of  the  European 

Union; 

(cid:190)  taking  part  in  the  activities  of  networks  of  sites  awarded  the  European 
Heritage  Label  in  order  to  exchange  experiences  and  initiate  common 
projects; 

(cid:190)  raising  the  profile  and  the  attractiveness  of  the  site  on  a  European  scale, 

notably through the use of modern technologies. 

(cid:190)  The  organisation  of    artistic  and  cultural  activities  (for  example  events, 
festivals,  residencies)  which  foster  the  mobility  of  European  artists  and 
collections,  stimulate  intercultural  dialogue  and  encourage  linkage  between 
heritage  and  contemporary  creation  and  creativity  are  welcomed  whenever 
the specificity of the site allows it. 

These  criteria  are  cumulative  except  for  the  last  indent  which  will  depend  on  the 
"physical" capacity of a site to actually organise such artistic and cultural activities. 
They  derive  directly  from  the  operational  objectives  of  the  EHL  and  will  therefore 
contribute  concretely  and  progressively  to  the  achievement  of  the  higher  level 
objectives.  These  elements  are  all  derived  from  the  Council  conclusions  and  are 
essential to ensuring the added value of the label and to achieving its objectives, so 
that  the  sites  actively  reach  out  to  and  educate  citizens,  rather  than  simply  limiting 
themselves, for example, to a plaque placed on a building. 

EN 

71 

   EN 

 
 
3. Quality of the management proposed 

Candidates for the label shall submit a management plan which commits them to all 
the following elements: 

(cid:190)  ensuring the sound management of the site; 

(cid:190)  ensuring the protection of the site and its transmission to future generations in 

accordance with the relevant protection regimes; 

(cid:190)  ensuring  the  quality  of  the  reception  facilities  such  as  the  historical 

presentation, the visitors information, the signage, etc. 

(cid:190)  ensuring  access  for  the  widest  possible  public,  notably  through  site 

adaptations or staff training; 

(cid:190)  according  special  attention  to  young  people,  in  particular  by  allowing  them 

privileged access to the site; 

(cid:190)  undertaking the promotion of sites as tourist destinations; 

(cid:190)  developing  a  coherent  and  comprehensive  communication  strategy 

highlighting the European dimension of the site; 

(cid:190)  ensuring  the  management  plan  is  as  environmentally  friendly  as  possible  in 

order to limit potential negative impacts of tourism. 

These criteria are also cumulative and derive from the operational objectives of the 
EHL. The quality of management was a concern expressed notably by the MS which 
do not yet participate in the intergovernmental initiative and was therefore included 
in  the  Council  conclusions.  Furthermore,  it  is  essential  for  ensuring  the  effective 
implementation of the key elements of the project, mentioned above. 

Two remarks need to be made concerning the criteria in the last two categories and 
the  fact  that  they  are  cumulative.  The  first  is  that  although  these  criteria  may  look 
very ambitious, many potential sites for the EHL do already fulfil a number of them 
and  will  therefore  only  have  to  make  limited  adjustments  and  investments.  This  is 
notably a lesson learnt from the analysis ECOTEC made from the sites which were 
already awarded the label in the intergovernmental initiative12. The second is that a 
very diverse range of sites can potentially be awarded the label. If we take the list of 
the  intergovernmental  EHL,  the  Robert  Schumann  house  in  Scy-Chazelles  is  very 
different from the Acropolis in Athens, and the Gdansk shipyards are very different 
from  the  Franja  Hospital  at  Dolenji  Novaki  in  Slovenia.  The  level  of  requirements 
for each criterion will therefore vary considerably from one site to another and must 
be  adapted  to  the  specificity  of  each  site.  In  the  case  of  some  prestigious  sites, 
ambitious educational, information or promotion activities can be expected, whereas 
for  smaller  sites  with  a  strong  symbolic  value,  the  criteria  can  be  met  in  a  more 
modest way. Here too, the national and / or European selection panels will have an 

12 

See ECOTEC report: http://ec.europa.eu/dgs/education_culture/evalreports/index_en.htm  

EN 

72 

   EN 

 
                                                 
essential  role  to  play  by  evaluating  what  is  relevant  and  appropriate  for  each 
candidate site. 

For  the  reasons  mentioned  above,  it  is  also  very  difficult  to  estimate  the  costs  of 
participating  in  the  EHL  for  a  site.  Each  criteria  in  the  last  two  categories  may 
potentially ask for investments from a site and have costs. But this will vary greatly 
from  one  site  to  another  and  on  what  is  already  in  place.  Quantification  is  not 
therefore possible. 

It needs to be repeated in this context that participation of the MS and the sites will 
be voluntary, so none of the costs will be "imposed". On the other hand, one of the 
benefits  for  the  sites  is  that  it  may  of  course  open  the  door  for  them  to  sources  of 
national funding. 

EN 

73 

   EN 

 
ANNEX 4:  

LIST OF THE COUNTRIES PARTICIPATING IN THE  

INTERGOVERNMENTAL EUROPEAN HERITAGE LABEL 

AND OF THE SELECTED SITES 

(OCTOBER 2009)

EN 

74 

   EN 

 
 
 
 
 
 
COUNTRY 

SITE 

BELGIUM 

Palace of the Prince-Bishops at Liege 

Stoneware of Raeren (German Community) 

Archaeological site of Ename 

Archaeological site of Coudenberg 

BULGARIA 

Archaeological site of  Debelt 

Memorial Vassil Lesvki 

Historic town of Rousse 

Boris Christoff Music Centre 

CYPRUS 

Fortifications of Nicosia 

Castle of Kolossi 

Site of Kourion 

Circuit of 6 churches with Byzantine and post Byzantine frescos, 
Troodos 

CZECH 
REPUBLIC 

Castle of Kynzvart 

Zlín, town of Tomas Bat'a 

Vítkovice coal mine at Ostrava 

Memorial of Antonin Dvorak at Vysoka 

FRANCE 

Cluny Abbey 

House of Robert Schumann, near Metz 

Pope's Palace Court, Avignon 

GREECE 

Acrópolis, Athens 

Knossos Palace 

Archaeological site of Poliochne 

Byzantine site of Monemvasia 

HUNGARY 

Royal castle of Esztergom 

Szigetvar fortress 

The Reformed college and great church at Debrecen 

Royal palace of Visegrád 

ITALY 

Birthplaces of Rossini, Puccini and Verdi 

Birthplace of Gasperi 

EN 

75 

   EN 

 
 
 
COUNTRY 

SITE 

Ventotene Island 

Capitole Place in Roma 

LATVIA 

Historic centre of Riga 

Rundale Palace 

Town of Kuldiga 

LITHUANIA 

Mikalojus Konstantinas Ciurlionis' works 

Historical centre of  Kaunas 

Zemaitija (lowlands) region and the Hill of Crosses 

Museum of Genocide Victims (1940-41) at Vilnius 

MALTA 

Catacombs of Rabat 

POLAND 

Gdansk Shipyards 

Hill of Lech at Gniezno (Cathedral, church, palaces, museum) 

Cathedral St Wenceslas and Stanislas, Krakow  

Town of Lublin 

PORTUGAL 

Braga cathedral 

Convent of Jesus at Setubal 

General library of the University of Coimbra 

Abolition of the death penalty 

ROMANIA 

Archaeological site of Istria 

Cantacuzino Palace at Bucarest 

Roman Athenaeum at Bucarest 

Park Brancusi at Targu Jiu 

SLOVAKIA 

Pre Romanesque Ecclesiastical Architecture, St Margaret church, 
Kopcany 

The Castle of Červený Kameň 

The Barrow of General Milan Rastislav Štefánik at Bradlo 

SLOVENIA 

Memorial church of the Holy Spirit at Javorca 

Franja Hospital at Dolenji Novaki 

Zale Cemetery at Ljubljana 

SPAIN 

Crown Aragon Archive 

Yuste Royal Monastery 

Cap Finisterre  

EN 

76 

   EN 

 
 
COUNTRY 

SITE 

Students Residence, Madrid 

SWITZERLAND 

Cathedral St Peter in Geneva 

Castle of La Sarraz 

Hospice of St Gotthard 

EN 

77 

   EN 

 
 
ANNEX 5:  

TABLE 1 

COMPARISON OF THE OPTIONS IN TERMS OF 

LIKELY IMPACTS COMPARED TO BASELINE OPTION 

EN 

78 

   EN 

 
 
 
 
 
Table 1:  Comparison of options in terms of likely impacts compared to the baseline option  

Option 1: 

Option 2: 

Option 3: EU initiative… 

Status quo 

Status quo 
plus EU 
funding 

..with MS 
selection 

(a) 

..with EU 
level 
selection 
(b) 

.. with MS 
pre-
selection 
and EU 
level 
approval (c) 

Assessment 

Option 

KEY: 

=  baseline or equivalent to baseline                        + to +++ minor to major improvement compared to baseline                         - to --- minor to major worsening compared to baseline 

SOCIAL/SOCIETAL IMPACTS 
Increased  access 
= 
cultural 
resources 

to 
heritage 

+ 

++ 

++ 

+++ 

Increased  access 
heritage 
people 

to 
for  young 

Increased  interest  in 
and  knowledge  of 
common 
European 
heritage 

= 

(+) 

+ 

++ 

+++ 

= 

(+) 

+ 

++ 

++ 

This effect is most likely to be felt for under-developed sites for whom the Label offers a more 
substantial opportunity for profile-raising and increased visitor numbers. There might be some 
improvement under option 2 due to improvements in visibility and profile (see table 2). Access 
is likely to be most improved under option 3 on account of enhanced management plans and 
improved monitoring. MS involvement in option 3c would enhance this further. 

There  might  be  some  improvement  under  option  2  in  light  of  the  likely  general  effects  on 
access.  Access is likely to be improved under option 3 on account of enhanced management 
plans  and  improved  monitoring.  Option  3  provides  for  enhanced  opportunities  to  link 
heritage/culture  with  education  (and  thereby  young  people)  through  an  integrated  approach 
from  the  Commission  via  DG  EAC.  3(c)  would  ensure  MS  inter-  (or  intra-)  ministry 
engagement (between education and culture domains). 

This impact assumes that as a consequence of visiting a labelled site individuals will increase 
their interest in and knowledge of common European heritage.  Achieving this will depend on 
sites  realising  a  number  of  obligations  including  effectively  communicating  their  European 
aspects.  Improvements  against  the  baseline  would  be  realised  through  better  central 
coordination and emphasis on commonalities, expressed through activity at labelled sites and 
higher profile/access to information pertaining to the EHL from central (web based) sources. 
Such  benefits  would  most  likely  be  realised  under  option  3  and  especially  where  there  is  a 
strong  EU  tier  (3b  and  3c).    Some  benefits  might  be  achieved  through  option  2  where  there 
may be a slight improvement in the European dimension (see table 2) 

EN 

79 

EN

 
  
 
 
 
Option 1: 

Option 2: 

Option 3: EU initiative… 

Option 

Status quo 

Status quo 
plus EU 
funding 

..with MS 
selection 

..with EU 
level 
selection 
(b) 

.. with MS 
pre-
selection 
and EU 
level 
approval (c) 

+++ 

++ 

+ 

+ 

(a) 

+ 

+ 

= 

= 

= 

(+) 

(+) 

(+) 

Increased 
understanding 
European 
diversity 

of 
  cultural 

Increase 
in 
intercultural dialogue 

sense 
Greater 
belonging 
to 
European Union 

of 
the 

= 

= 

= 

Stronger  participation 
in 
democratic 
the 
process 

= 

= 

= 

= 

= 

Assessment 

This  impact  assumes  that  individuals  will  have  an  increased  understanding  of  European 
cultural diversity on account of interacting with labelled sites.  EU intervention might be better 
able  to  emphasise  such  cultural diversity  aspects.  This  impact  is  likely  to  flow  most  directly 
through  an  emphasis  upon  the  transnational  aspects  of  the  Label.  Option  3(b)  provides  an 
enhanced opportunity to co-ordinate and emphasise this as a priority. 

This effect goes a step beyond impacts on the knowledge and understanding of individuals and 
assumes that as a result of increases in these areas there will be greater levels of intercultural 
dialogue.  This is therefore a long-term term effect and would be more difficult to achieve than 
other effects since it would involve more complex activities – especially transnationality - and 
might  not  be  inherent  to  all  sites.  EU  intervention  would  be  better  able  to  emphasise 
intercultural dialogue through the secretariat and by co-ordinating events, networking etc. 

Strong evidence from across many fields of research makes the link between cultural identity 
and  heritage.  But  any  impacts  the  Label  might  make  on  sense  of  belonging  would  be 
considerably affected by other factors and would be realised only in the long term.  Again, it 
goes a step beyond raised levels of knowledge and understanding.  However, the key aim of 
the EHL to increase a sense of belonging to Europe (and the EU) would be enhanced by EU 
involvement  and  the  coordination  and  encouragement  of  this  level  of  activity  aimed 
specifically at emphasising the European aspects of the Label. 

This  would  be  an  indirect  effect  of  the  Label,  would  be  highly  dependent  on  many  other 
factors, and could be realised only in the long-term; however, the relation between democratic 
participation  and  a  sense  of  belonging  or  ownership  is  evidenced  in  research  and  the 
assumption  then  is  that  citizens  will  be  encouraged  to  participate  as  they  understand  the 
European dimensions of their own cultural heritage. For New Member States this may be of 
particular importance as they seek greater integration with 'old' Europe.  

EN 

80 

EN

 
  
 
 
 
 
 
 
Option 1: 

Option 2: 

Option 3: EU initiative… 

Option 

Status quo 

Status quo 
plus EU 
funding 

..with MS 
selection 

(a) 

..with EU 
level 
selection 
(b) 

.. with MS 
pre-
selection 
and EU 
level 
approval (c) 

ECONOMIC IMPACTS 
Positive effects on the 
local tourism industry, 
including  number  of 
people employed 

= 

= 

(+) 

(+) 

(++) 

Development  of  links 
and 
cultural 
with 
creative industries 

Development 
innovation 
creativity 

of 
and 

= 

= 

= 

= 

(+) 

(+) 

(+) 

(+) 

(+) 

(+) 

Assessment 

Direct economic benefits through increased visitor numbers are unlikely to be major effect of 
the EHL in a first stage, especially in established tourist sites with already high visitor figures.  
Rather, EHL is likely to impact most on the quality of the visitor experience and in developing 
and enhancing their understanding of the site from a European perspective.  Nonetheless there 
are likely to be positive effects on local and regional tourism through the greater publicity and 
potentially the attraction of new visitors attracted via networked activity, which are likely to be 
greater under a EU initiative for the reasons set out in Table 2. Some additional employment is 
likely  to  be  generated  directly  and  indirectly  at  sites  and  downstream  through  service 
industries,  especially  if  the  EHL  acquires  a  strong  credibility  and  prestige.  Option  3c  might 
have the strongest impact in the long term because it ensures best mix between the quality of 
the selected sites and the fair distribution of labels across MS. 

Impacts here as a direct result of the EHL are likely to be minimal in a first stage.  But option 3 
could  potentially  place  a  greater  emphasis  upon  integration  with  creative  industries, 
particularly on site and through networked events and activities. Improvements on this impact 
may also flow from better links to other EU policies and programmes. 

Direct impacts as a result of EHL are likely to be marginal.  However, option 3 could provide 
greater  priority  for  integrating  innovative  techniques  for  promoting  the  EHL  on  sites,  and 
through  networking,  particularly  emphasising  the  use  of  Information  and  Communication 
Technologies.    Improvements  might  also  be  derived  from  closer  links  to  other  policies  and 
programmes of the EU. 

ENVIRONMENTAL IMPACTS 
Negative 
= 
linked 
to 
development 
tourism 

effects 
over-
of 

EN 

= 

+ 

+ 

+ 

Effects  are  highly  variable  due  to  locality-dependent  nature  of  this  impact.  However,  the 
enhanced monitoring capacity offered by option 3 would enable a greater emphasis and more 
resource  to  be  placed  upon  amelioration  and  monitoring  of  impacts,  with  management  plans 
and sustainable development objectives incorporated into monitoring and evaluation. 

81 

EN

 
  
 
 
 
 
Option 1: 

Option 2: 

Option 3: EU initiative… 

Option 

Status quo 

Status quo 
plus EU 
funding 

..with MS 
selection 

Protection  of  cultural 
heritage 

= 

= 

(a) 

+ 

..with EU 
level 
selection 
(b) 

.. with MS 
pre-
selection 
and EU 
level 
approval (c) 

= 

+ 

Assessment 

The  label  may  be  regarded  as  an  extra  'layer'  of  conservation/protection  –  although  clearly 
there is no legal basis or intent for this to be so. However, as an unintended 'side effect', the 
raising of the profile of some sites from a heritage perspective should be regarded as a positive 
effect.    This  should  be  a  little  bit  stronger  under  options  3a  and  3c  which  would  ensure  a 
greater ownership by the MS. 

EN 

82 

EN

 
  
 
 
 
ANNEX 6:  

TABLE 2 

COMPARISON OF THE OPTIONS AGAINST 

EFFECTIVENESS, EFFICIENCY AND COHERENCE CRITERIA 

EN 

83 

   EN 

 
 
 
 
 
 
 
Table 2:  Comparison of the options against effectiveness, efficiency and coherence criteria 

Option 1: 

Option 2: 

Option 3: EU initiative… 

Status quo 

Status quo 
plus EU 
funding 

..with MS 
selection 

..with EU level 
selection (b) 

.. with MS pre-
selection and EU 
level selection (c) 

(a) 

Assessment 

Option 

KEY: 

=  baseline or equivalent to baseline                        + to +++ minor to major improvement compared to baseline                         - to --- minor to major worsening compared to baseline 

EFFECTIVENESS 

Representativeness  

= 

= 

+  

- 

+ 

European 
significance of sites 

dimension 

– 

= 

(+) 

+ 

+++ 

++ 

Transnationality 
networking 

and 

= 

+ 

+ 

+++ 

++ 

Transforming  the  EHL  into  a  EU  action  would  probably  increase  the 
number  of  MS  participating  in  the  initiative.  EU  level  selection  alone, 
without reference to the nationality of a site (option 3b), carries the risk 
that  it  would  favour  countries  with  well-developed  cultural  heritage 
sectors  who  are  more  used  and  better  able  to  make  high  quality 
applications,  irrespective  of  the  actual  merit  of  a  site.  Some  countries 
might therefore be under-represented. 

Under the intergovernmental initiative, Labelled sites have varied in their 
European significance and the way in which they have sought to make it 
clear, yet this is central to developing European citizens' understanding of 
their  common  yet  diverse  cultural  heritage.    In  general,  improvements 
would  be  possible  through  better  marketing  and  networking.  Additional 
funding  alone  (option  2)  might  have  a  marginal  positive  effect  on  the 
priority accorded to the European significance of sites, provided it were 
used to support expert meetings.  More substantial gains would be likely 
if an EU level secretariat were in place (option 3), since it would be more 
possible to ensure that this dimension were given priority.  This would be 
especially  so  if  there  was  some  form  of  EU  level  selection  (options  3b 
and  3c).    EU  level  selection  alone  would  be  most  likely  to  stress  the 
European dimension (option 3b). 

Funding to support networking would achieve some improvement on this 
dimension  (option  2).  It  is  also  important  to  facilitate  the  selection  of 
"transnational sites" which thus depend simultaneously from several MS.  
If MS selection were to predominate (option 2 or 3a) this would still be 
difficult..    The  transnational  dimension  could  be  better  emphasised  if 
there were to be some form of EU level selection process (options 3b and 
3c),  and  especially  if  MS  level  selection  were  to  be  removed  altogether 
(option 3b).  There is also experience in the Commission about how best 
to  ensure  exchanges  of  good  practice  and  build  partnerships.    The  EU 

EN 

84 

EN

 
  
 
 
 
 
 
 
 
Option 1: 

Option 2: 

Option 3: EU initiative… 

..with MS 
selection 

..with EU level 
selection (b) 

.. with MS pre-
selection and EU 
level selection (c) 

Option 

Status quo 

Status quo 
plus EU 
funding 

Visibility, profile and access 

= 

+ 

= 

= 

= 

= 

= 

= 

Artistic, cultural and historical 
education 

Programmes 
activities 

of 

cultural 

EFFICIENCY 

Selection processes 

EN 

(a) 

++ 

+ 

+ 

+ 

++ 

+++ 

++ 

++ 

++ 

++ 

Assessment 

also has strong potential to act as an 'honest broker' (legitimacy). 

High visibility and profile are important for raising awareness of the sites 
and  for  opening  up  access.  The  low  visibility  from  which  the 
intergovernmental  EHL  has  suffered  might  be  improved  through  the 
extra  funding  available  under  option  2.    But  leaving  the  secretariat 
function  at  MS  level  means  that  the  effectiveness  of  publicity  and 
marketing  activities  will  depend  upon  the  competences  of  a  particular 
ministry  to  effectively  commission  these  activities  on  a  pan-European 
level.  Visibility would be improved by being a full EU initiative (option 
3),  able  to  benefit  directly  from  being  able  to  use  the  EC's  established 
media channels and experience in this area (e.g. through European Years, 
ECOC,  EU  Prize  for  Cultural  Heritage  /  Europa  Nostra  Awards)  );  and 
access would be more likely to be enhanced by ensuring compliance with 
this  objective.    Profile  would  also  stand  to  benefit  through  the 
involvement of a tier of EU level selection which would be more likely to 
be perceived as expert and independent (options 3b and 3c).  Having both 
MS  and  EU  involvement  would  be  most  likely  to  ensure  high  visibility 
and profile since marketing and publicity could take place at both levels, 
as  used  in  the  European  Years  to  good  effect.  Access  would  probably 
also benefit through improved sharing of good practice through close MS 
involvement. 

Additional funding for central activities (option 2) would be unlikely to 
lever  improvements  in  sites'  educational  activities.    Making  the  EHL  a 
EU initiative  (option 3) could deliver improvements if greater  emphasis 
were to be placed upon this component through selection and subsequent 
enforcement, which would be strongest under options 3b and 3c. 

Extra  funding  alone  (option  2)  would  not  have  any  effect  on  the 
effectiveness of sites' cultural programme.  Greater stress could be placed 
on  this  element  through  the  more  rigorous  selection  processes  possible 
under a EU initiative, especially under options 3b and 3c. 

++ 

+++ 

Whilst selection criteria were established for the intergovernmental EHL, 
the selection process has not always been transparent, and there has been 
much scope for national interpretation of the criteria. Additional funding 

85 

EN

 
  
 
 
 
 
 
Option 

Option 1: 

Option 2: 

Option 3: EU initiative… 

Status quo 

Status quo 
plus EU 
funding 

..with MS 
selection 

..with EU level 
selection (b) 

.. with MS pre-
selection and EU 
level selection (c) 

(a) 

Delivery 
(monitoring and QA) 

and 

compliance 

= 

(+) 

++ 

+ 

+++ 

Assessment 

for the status quo model (option 2) would be unlikely to impact upon this 
to  any  significant  degree.  Making  the  EHL  a  EU  initiative  (option  3) 
would  have  the  effect  of  increasing  the  transparency  of  the  process  and 
the  clarity  with  which  the  criteria  are  applied.    Selection  at  EU  level 
(options  3b  and  3c)  would  in  particular  help  to  ensure  that  criteria  are 
consistently  applied.    However,  it  is  important  that  MS  commitment  is 
maintained (as in option 3c), not least because (a) the complex processes 
through  which  European  identity  will  be  realised  need  to  involve  both 
European  level  and  national  interpretations  of  culture  and  history;  (b) 
there  is  a  need  to  ensure  a  fair  distribution  of  sites  across  MS  (see 
'Representativeness' criterion above); and (c) MS represent an important 
resource and infrastructure. MS commitment would be jeopardised under 
option 3b. 

Additional  funding  for  the  status  quo  option  (option  2)  might  make 
monitoring (which has not taken place under the intergovernmental EHL) 
possible  on  the  part  of  the  secretariat  but  establishing  and  maintaining 
systems  would  still  depend  on  the  expertise  available  within  a  given 
ministry. 

A EU initiative (option 3) in contrast would be more likely to be able to 
use  expertise  available  to  the  Commission  to  set  up  and  maintain  the 
necessary systems and would not be subject to having to transfer systems 
periodically,  as  would  be  the  case  with  a  revolving  ministry-based 
secretariat.  However, centralising responsibility for monitoring and QA 
processes at EU level which would be necessary if there were solely EU 
level selection (option 3b) would probably be too remote (and hence less 
efficient)  and  would  also  load  additional  administration  onto  the  
secretariat.    Critically,  it  would  carry  a  significant  risk  of  losing 
commitment  at  MS  level  to  their  sites  and  thus  disengagement  of  the 
ministries (and their agencies) who should maintain the key relationship 
with sites in this regard. At the same time, there would be value in having 
some form of review at EU level which is independent of each MS, e.g. 
the  expert  panel  to  check  that  obligations  have  been  fulfilled  after  3 
years.  This  would  suggest  that  the  best  model  would  be  a  clear 
distribution of functions between MS and EU levels (option 3c). 

EN 

86 

EN

 
  
 
 
 
 
 
Option 1: 

Option 2: 

Option 3: EU initiative… 

Option 

Status quo 

Status quo 
plus EU 
funding 

Administrative  arrangements 
at EU and MS level 

= 

Financial impacts for the EU 

= 

Communication  with  other 
international bodies 

= 

COHERENCE 

Limitation  of  trade-offs  across 
social, 
and 
environmental domains 

economic 

Synergies 
and 
complementarities  with  other 
initiatives 

= 

= 

- 

- 

+ 

= 

= 

..with MS 
selection 

..with EU level 
selection (b) 

.. with MS pre-
selection and EU 
level selection (c) 

(a) 

- 

-- 

--- 

-- 

--- 

-- 

Assessment 

The  administrative  burden  would  increase  under  all  of  the  options 
compared  to  the  baseline.    Under  option  3a  the  administrative  burden 
would  be  largely  shared  across  MS,  whereas  under  3b  a  significant 
burden  would  fall  on  the  central  secretariat  in  organising  selection, 
monitoring etc. Administration would probably be most substantial under 
option  3c  where  it  would  be  necessary  to  ensure  close  integration 
between  the  MS  and  EU  selection  processes,  requiring  significant 
communication and liaison functions.   

to 

Although all of the options would have very limited impacts on the EU 
budget,    the  financial  implications  for  the  EU  need  to  be  taken  into 
account.  In  addition 
the  funding  of  some  networking  and 
communication activities (option 2), option 3 would also imply the costs 
of  the  secretariat  which  would  be  provided  by  the  Commission.  The 
financial 
the 
administrative  tasks  required  from  the  EU  level  and  thus  would  be 
greater under options 3b than under options 3a and 3c where more tasks 
would be shared between EU and MS level. 

therefore  related 

implications  are 

the  scale  of 

to 

++ 

+++ 

+++ 

A secretariat at MS level (option 2) would be unlikely to be able to open 
up  the  same  quality  of  communication  with  other  international  bodies 
than  a  secretariat  at  EU  level.    Credibility  in  those  communications 
would be increased where the EU has a role in selection (options 3b and 
3c). 

+ 

+ 

+ 

++ 

+++ 

+++ 

The social and economic success of sites (greater access, more tourism) 
is likely to lead to negative environmental effects under whichever option 
is  pursued.  However,  the  magnitude  of  the  trade-off  may  be  positively 
affected  by 
sustainable 
incorporating  management  plans 
development objectives into selection and monitoring requirements. 

and 

An  EU-level  secretariat  (option  3)  offers  much  greater  prospect  of 
realising such synergies and complementarities than where the secretariat 
rests  with  the  MS  (options  1  and  2)  since  communication  channels  and 
joint working are already established (e.g. with the Council of Europe on 
Heritage Days).  The credibility of the EU with other bodies is probably 
greatest where there is some form of EU-level selection (options 3b and 

EN 

87 

EN

 
  
 
 
 
 
Option 

Option 1: 

Option 2: 

Option 3: EU initiative… 

Status quo 

Status quo 
plus EU 
funding 

..with MS 
selection 

..with EU level 
selection (b) 

.. with MS pre-
selection and EU 
level selection (c) 

(a) 

Assessment 

3c) 

Participation of third countries 
in Culture programme 

= 

= 

+++ 

+++ 

+++ 

Even if it is quite likely that the EHL will commence with the EU 27 and 
that  the  participation  of  third  countries  would  be  considered  only  in  a 
second  stage  after  a  first  evaluation,  this  is  much  more  likely  to  be 
the 
facilitated  effectively  where 
Commission  (option  3).    It  is  unlikely  that  there  would  be  much 
difference between the sub-options under option 3. 

is  provided  by 

the  secretariat 

EN 

88 

EN

 
  
 
 
 
 
ANNEX 7: 

OTHER INTERNATIONAL INITIATIVES 

IN THE FIELD OF CULTURAL HERITAGE 

EN 

89 

   EN 

 
 
 
 
 
 
 
 
Besides the EHL a number of other international initiatives exist in the field of cultural 
heritage including notably the UNESCO World Heritage List, the Council of Europe 
Cultural Routes or the EU Prize for Cultural Heritage / Europa Nostra Awards. This 
has  created  confusion  around  the  EHL,  as  well  as  some  fears  concerning  possible 
overlaps. Therefore, the Commission asked ECOTEC as part of their support services 
to examine these different schemes. ECOTEC's analysis demonstrated clearly that the 
EHL  is  very  different  from  the  other  initiatives  and  that  it  has  the  potential  to  add 
value in terms of all three of its core elements: the European dimension, pedagogy and 
networking13. 

The UNESCO World Heritage Convention was adopted in 1972. Once a country has 
ratified  the  Convention,  it  can  nominate  sites  to  be  considered  for  inclusion  on  the 
World  Heritage  List.  To  date,  890  sites  are  listed:  689  cultural,  176  natural  and  25 
mixed properties, in 148 states. There are four main differences between the EHL and 
the World Heritage List. The EHL focuses on sites which have played a key role in the 
history  and  the  building  of  Europe  while  the  UNESCO  list  designates  sites  of 
universal value. The EHL is not about the beauty of a site or its architectural quality 
but about its symbolic value for European integration. To name just one example, the 
UNESCO  designated  the  Kremlin  and  the  Red  Square  in  Moscow  which  has  a 
wonderful  architecture  but  was  also 
the 
intergovernmental  EHL  designated  the  Gdansk  Shipyards  which  have  a  symbolic 
signification for the reunification of Europe. In contrast to the UNESCO list, the EHL 
is  not  about  the  conservation  of  sites,  but  about  the  activities  they  propose  and  their 
educational  dimension,  especially  for  young  people.  Finally,  the  EHL  seeks  to 
stimulate the networking of labelled sites, as well as common projects. 

residence  of  Stalin,  while 

the 

The  Europa  Nostra  Awards  began  in  1978  and  became  the  EU  Prize  for  Cultural 
Heritage  /  Europa  Nostra  Awards  in  2002  when  Europa  Nostra  started  to  cooperate 
with  the  European  Commission  in  the  framework  of  the  Culture  programme14.  In 
2009, 60 % of the budget of the Prize / Awards came from a EU grant (200 000 € for a 
333  333  €  total  budget).  Each  year  awards  are  attributed  in  four  categories: 
conservation, research, education and dedicated services. In contrast to the EHL, the 
Awards focus on the conservation of cultural heritage. They are one off prizes which 
recognize  achievements  after  the  fact,  and  unlike  the  EHL  do  not  set  in  train 
development  activities;  nor  are  they  designations  which  can  be  subsequently 
withdrawn if criteria are not met. Furthermore, the awarded achievements do not need 
to have a European narrative, but the prize seeks to highlight excellence at European 
level and promote exchange of practice. 

The Cultural Routes programme was launched by the Council of Europe in 1987. 25 
routes have been designated to date involving approximately 30 000 towns and cities.  
The  Mozart  route  for  example  is  a  network  set  up  along  18  historic  routes  taken  by 
Mozart  across  ten  countries.  Technical  support  is  provided  to  the  routes  by  the 
European Institute of Cultural Routes in Luxembourg which currently benefits from an 

13  
14 

See ECOTEC report: http://ec.europa.eu/dgs/education_culture/evalreports/index_en.htm  
Europa  Nostra  is  the  pan-European  federation  for  cultural  heritage.    It  represents  over  250  heritage 
NGOs in 45 countries across Europe, and works to recognise good practice among heritage projects. 

EN 

90 

   EN 

 
 
                                                 
EU  operating  grant  in  the  framework  of  the  Culture  programme  for  which  it  has  to 
compete through an open call for proposals. In terms of objectives, the Cultural Routes 
are  probably  the  closest  to  the  EHL  as  they  also  aim  at  raising  awareness  on  a 
European  cultural  identity  and  European  citizenship  or  at  promoting  intercultural 
dialogue.  However  the  modus  operandi  of  the  Routes  is  very  different  to  the  EHL. 
Firstly, while the EHL concentrates mostly on the 27 EU MS, the Cultural Routes are 
open  to  the  47  MS  of  the  Council  of  Europe  and  over  recent  years,  the  focus  of  the 
initiative  has  been  very  much  on  the  countries  which  are  not  in  the  EU.  Secondly, 
while the EHL is attributed to individual sites which have to implement a number of 
very specific activities, the Cultural Routes concern very loose and very large thematic 
networks  of  sites  that  span  several  countries  and  often  simply  signpost  visitors  to 
towns  and  cultural  attractions  en  route  with  very  little  obligations  for  the  sites 
themselves.  Thirdly,  while  the  EHL  aims  at  promoting  a  European  reading  of 
symbolic sites of the building of Europe, the objective of the thematic networks of the 
Cultural Routes is to illustrate the history of influences and exchanges across Europe, 
but the themes in themselves can sometimes have a limited European significance (the 
Routes of the Olive Tree, Parks and Gardens, the Iron Route in the Pyrenees, …). 

As  mentioned  in  section  1.2.2.2  of  the  IA  report,  the  representatives  of  ICOMOS 
(consultative  body  for  the  UNESCO  World  Heritage  List),  the  European  Institute  of 
Cultural  Routes  and  Europa  Nostra  who  participated  in  the  consultation  meeting  all 
confirmed the added value of the EHL. Nevertheless, they also underlined that clearer 
communication would be needed to clarify the differences, especially for the general 
public. 

Communication between the intergovernmental EHL and the other initiatives has 
remained very limited so far, which has hindered the building of synergies. There is 
however a potential for cooperation. Firstly, because the initiatives all reward 
excellence and stimulate improvements in the field of cultural heritage, but they cover 
different aspects of the domain (preservation, conservation, promotion, information, 
education…). Secondly, because the initiatives have very different geographical 
scopes. It is also possible that one specific site takes part or is rewarded by two or 
more initiatives for different aspects of its work. So far, among the 64 sites of the 
intergovernmental label, 6 are also on the World Heritage List, 12 are part of Cultural 
Routes networks and 3 were rewarded by EU Prize for Cultural Heritage / Europa 
Nostra Awards. This is also a basis on which synergies could be developed.

EN 

91 

   EN 

 
Profiles of other international initiatives against key features of the EHL: 

Initiative 

Objectives 

Scope 

European 
Heritage Label 

Council of 
Europe 
Cultural 
Routes 

EU Prize for 
Cultural Heritage / 
Europa Nostra 
Awards 

UNESCO World 
Heritage List 

Identification and 
promotion of 
European 
dimension of 
cultural heritage 

Promotion of 
European 
heritage and 
culture 

Conservation of 
European heritage 

Preservation of 
global heritage 

Emphasises common – yet diverse 
– European heritage 

High 

High 

Low 

Aims to develop stronger sense of 
European citizenship/belonging 

High 

High 

Low 

No 

No 

Promotes use of cultural tourism as 
a tool in social and economic 
development 

High 

High 

Low 

Medium 

Targets needs of young people 

High 

High 

Medium 

Low 

Modus operandi 

General focus 

Individual  
heritage sites 

Development of 
routes based 
around themes 
that link cultural 
heritage sites 

Individual heritage 
sites 

Individual built 
heritage sites 

Trans-national dimension (e.g. 
networking between heritage sites) 

High 

High 

High 

Contains explicit pedagogical aspect 

High 

High 

High 

Scale 

64 sites 
designated in 18 
countries 

25 routes 
currently 
designated 
involving approx. 
30,000 towns 
and cities and 
174 NGOs 

Around 30 awards 
are made each year 
with up to six prizes 
being awarded the 
Grand Prize of €10k 
each 

Low 

Low 

890 sites in 148 
countries 

EN 

92 

   EN 

 
 
 
 
Heritage designations:  summary of selection criteria and processes: 

UNESCO World Heritage List 

Selection Criteria 

Selection processes 

Guidance for selection processes now 1000 pages 
long. To be included on the WH list, sites must be of 
outstanding universal value and meet at least one of 
the 10 criteria set out at:  

http://whc.unesco.org/pg.cfm?cid=57 

For example: 

1.  To represent a masterpiece of human 

creative genius. 

2.  To exhibit an important interchange of 
human values over a period of time. 
3.  Unique/exceptional testimony to culture. 
4.  Outstanding architecture, technology, 

landscape. 

Country proposes site – a) tentative list created, then 
b) formal proposal made. 

Evaluation of dossier by ICOMOS15 and IUCN16 
according to site type. 

On site evaluation – technical site report + Report 
by expert in the field. 

Expert panel discussion and recommendation to 
World Heritage Committee to: 

a.  Put on list 
b.  Return for further information 
c.  Postpone 
d.  Reject 

1.5 – 2 years for the process to complete. 

Council of Europe Cultural Routes 

Selection Criteria 

Selection processes 

The routes are to be centred on a theme, which, in 
order to qualify for the programme, must fulfil a 
series of criteria. 

Each theme or sub-theme is to be dealt with in a 
series of co-operation projects in specified priority 
fields of action.  

Project initiators must form a network so as to 
improve co-operation and pool their experience. In 
order to be approved, these networks must in turn 
satisfy a number of criteria.  

A 2007 resolution of the Council of Europe presents 
all selection criteria : 
https://wcd.coe.int/ViewDoc.jsp?id=1194679  

The certification is awarded by the Council of 
Europe committee responsible for the Cultural 
Routes programme on a proposal from the advisory 
committee. 

Networks must submit every three years an activity 
report to the Council of Europe. If some criteria are 
not fulfilled, a recommendation will be issued. If the 
recommendation is not followed within a year, the 
committee may withdraw the certification.  

15 
16 

International Council on Monuments and Sites. 
World Conservation Union. 

EN 

93 

   EN 

 
 
 
 
 
 
 
 
 
                                                 
 
Europa Nostra Awards (selection procedure as of 2010 call) 

Selection Criteria 

Selection processes 

Europa Nostra Awards are awarded in 4 categories 
(conservation, research, dedicated service and 
education/training/awareness-raising). Each of the 
four categories has its own selection criteria.  
http://www.europanostra.org/UPLOADS/FILS/HA20
10_call_conditions.pdf  

Applicants from all European Countries*  must fill a 
dossier and submit it in French or English to Europa 
Nostra Secretariat 

A European Jury of independent experts designated 
by Europa Nostra select the award-winners. 3 out of 
4 categories are also assessed on location by a local 
expert prior to the Jury meeting. 

*only entries from countries that are part of the EU Culture 
programme are eligible for the monetary award 

EN 

94 

   EN