Commission staff working document - Summary of the 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) 197}
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

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EUROPEAN COMMISSION 

Brussels, 9.3.2010 
SEC(2010) 198 

COMMISSION STAFF WORKING DOCUMENT 

SUMMARY OF THE 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) 197} 

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EXECUTIVE SUMMARY 

This impact assessment will accompany the proposal for a Decision of the European 
Parliament and of the Council establishing a European Union action for the European 
Heritage Label. 

1. 

PROBLEM DEFINITION 

The original concept of the European Heritage Label (EHL) was born as one of the 
responses to the gap between the reality of the EU and the perceptions of its citizens. 
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  scheme  was  subsequently  launched  in  April  2006  as  an  intergovernmental 
initiative. To date, a total of 64 sites located in 17 EU MS as well as in Switzerland 
have  obtained  the  label.  The  aim  of  the  original  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  in  the 
field  of  communication,  education,  culture  or  citizenship  aimed  at  addressing  the 
same problem.  

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  not  optimally  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 sharing of experience and best practices.  

the  Ministers  of  Culture  who 

launched 

However, the intergovernmental EHL has not achieved concrete results so far. 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. 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 be addressed. This was confirmed by an evaluation 
of  the  initiative  carried  out  by  the  external  consultant  ECOTEC  as  part  of  their 
support services for this impact assessment, which demonstrated for example that as 
a  consequence  of  the  current  selection  procedures,  the  nature  of  the  selected  sites, 
their relevance, and their activities are rather disparate and in some cases difficult to 
comprehend; that the EHL lacks visibility even among the main stakeholders in the 
heritage  sector;  and  that  little  progress  has  been  made  so  far  on  the  educational 
dimension and networking between labelled sites. In order to achieve concrete results 
and  to  make  an  impact,  the  EHL  needs  a  more  proactive  approach  and  to  take  a 
qualitative step forward. 

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2. 

ANALYSIS OF SUBSIDIARITY 

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’.  

The  legal  basis  for  the  EHL  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  should  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  an  increase  in  the  number  of  MS  participating  in  the 
initiative  and  a  solution  to  the  problems  linked  to  the  present  rotating  secretariat. 
This should help to improve the value of the initiative in order to ensure its quality, 
credibility and long-term success. 

3. 

OBJECTIVES OF EU INITIATIVE 

As mentioned above, the gap between the EU and its citizens 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 and it is important to stress that the label 
will certainly not have an impact on the same level as for example student exchanges 
or  language  learning.  Therefore  it  has  been  decided  to  propose  four  levels  of 
objectives  for  the  renewed  EHL,  with  general  objectives  which  reflect  the  overall 
ambition  of  the  EHL  and  link  it  into  the  wider  EU  policy  agenda  and  intermediate 
objectives which are the highest level of impact that the EHL can achieve on its own. 
At a more basic level, specific and operational objectives are included. 

3.1. 

General objectives 

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. 

Strengthen intercultural dialogue. 

3.2. 

Intermediate objectives 

Enhance the value and profile of sites which have played a key role in the history and 
the building of the European Union. 

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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 

Develop sites’ European significance. 

Raise young people’s awareness of their common cultural heritage. 

Facilitate sharing of experiences and exchanges of best practice across Europe. 

Increase  access  to  heritage  sites  for  all  members  of  the  public,  especially  young 
people. 

Increase  intercultural  dialogue,  especially  among  young  people,  through  artistic, 
cultural and historical education. 

Foster synergies between cultural heritage and contemporary creation and creativity. 

Contribute to the attractiveness and the sustainable development of the regions. 

3.4. 

Operational objectives 

a) Practical arrangements for the EHL 

Ensure the application of common, clear and transparent criteria for the selection of 
the sites. 

Foster a fair distribution of labels across the European Union. 

Introduce  a  monitoring  procedure  to  ensure  that  the  labelled  sites  respect  their 
commitments. 

Improve  the  complementarity  with  other  initiatives  in  the  field  of  cultural  heritage, 
notably through good communication with relevant international bodies. 

Ensure that the practical arrangements remain light and flexible for the EU and the 
MS. 

Increase  the  visibility  at  European  level,  notably  through  the  development  of  a 
website. 

Develop  transnational  networks  of  sites  to  develop  their  European  profile  and 
exchange. 

b) Activities of the labelled sites 

Develop the European dimension of sites through appropriate information activities 
and multilingual signage. 

Develop programmes of educational activities. 

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Undertake marketing and promotion of sites as tourist destinations locally, nationally 
and at European level. 

Develop  access  to  sites  through  site  adaptations,  visitor  tools,  staff  training, 
privileged access for the young public. 

Develop  programmes  of  cultural  activities:  events,  festivals,  artist-in-residence 
schemes, etc.. 

4. 

POLICY OPTIONS 

The  Council  conclusions  mention  that  the  new  EHL  should  keep  ‘flexible  and 
streamline  administrative  arrangements  in  compliance  with  the  principle  of 
subsidiarity.’  This  same  concern  to  keep  the  costs  limited  both  at  national  and 
European  level  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 view 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 an EU initiative with significant financial 
support to the sites.  

As a result of this initial screening process, three main options which appeared to be 
realistic and feasible were developed, with one of the options containing three sub-
options. All of these options would have very limited impacts on the EU budget. All 
of them also comply with the principles of subsidiarity and proportionality. 

4.1. 

Option 1: Status quo (baseline scenario) 

The  EHL  continues  as  an  intergovernmental  initiative  with  a  secretariat  hosted  by 
participating countries on a rotating basis (unfunded by the EU) and without any EU 
action.  

4.2. 

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.  

4.3. 

Option 3: The EHL becomes an 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 clearly 
allocate  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 organisation of expert meetings by the Commission. The 

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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: 

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. 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. 

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. 

3(c)  Sites  are  pre-selected  by  MS  and  then  subject  to  final  selection  by  an 
independent panel at EU level. Monitoring is primarily a MS responsibility, but with 
supervision and review by the independent panel and the possibility of withdrawal of 
the designation.  

5. 

ASSESSMENT OF IMPACTS 

In  order  to  undertake  the  impact  assessment  a  range  of  potential  impacts  were 
identified  in  cooperation  with  the  external  consultant.  They  were  derived  from 
various 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  the  individuals,  organisations  and  MS  that  participated  in  the 
consultation process. 

The following impacts were analysed: 

5.1. 

Social / societal impacts: 

Increased access to cultural heritage resources. 

Increased access to heritage for young people. 

Increased interest in and knowledge of common European heritage. 

Increased understanding of European cultural diversity. 

Increase in intercultural dialogue. 

Greater sense of belonging to the European Union. 

Stronger participation in the democratic process. 

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5.2. 

Economic impacts: 

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

Development of links with cultural and creative industries. 

Development of innovation and creativity. 

5.3. 

Environmental impacts: 

Negative effects linked to over-development of tourism. 

Protection of cultural heritage. 

The  analysis  of  the  various  impacts  showed  that  the  primary  direct  effects  of  the 
EHL  would  be  social  ones.  Economic  benefits  should  rather  be  considered  as 
secondary or indirect benefits in a first stage, although this does not preclude MS and 
sites  from  pursuing  them  more  actively.  The  capacity  of  the  EHL  to  have  a 
significant impact on the number of visitors to a site may increase over time, but this 
will  depend  on  the  quality,  credibility  and  prestige  of  the  label  as  it  develops. 
Environmental impacts are unlikely in general to be substantial. 

The  analysis  also  demonstrated  that  the  transformation  of  the  EHL  into  a  EU 
initiative  through  a  Decision  by  the  Council  and  the  Parliament  (option  3)  would 
bring  a  clear  added  value  and  enable  benefits  that  could  not  be  achieved  by  MS 
acting alone, even with EU financial support. Among the three sub-options of option 
3, the sub-option of MS selection with an EU secretariat (3a) would probably deliver 
less marked improvements across the range of impacts.  

Between sub-options 3b (selection at EU level only) and 3c (combined MS and EU 
level  selection),  sub-option  3b  offers  the  prospect  of  a  better  level  of  improvement 
only  concerning  the  increased  understanding  of  cultural  diversity,  while  sub-option 
3c  is  likely  to  deliver  greater  improvements  on  several  fronts,  including  increased 
access  to  cultural  heritage  resources,  increased  access  to  heritage  for  young  people 
and,  in  the  longer  term,  positive  effects  on  the  tourism  industry,  including  the 
number of people employed.  

6. 

COMPARISON OF OPTIONS 

Having  looked  at  the  likely  impacts  of  the  different  options  we  turned  to  an 
assessment  in  terms  of  three  main  criteria:  effectiveness,  efficiency  and  coherence. 
However, within these general criteria there were a range of sub-criteria to consider. 
These  derived  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  closely  mirrored  all  of  the 
objectives proposed for the renewed EHL. 

In relation to the effectiveness of the options, we considered the fair distribution of 
Labels  across  the  MS,  the  promotion  of  the  European  dimension  of  the  sites, 
networking  between  the  sites,  the  visibility  and  profile  of  the  EHL,  the 

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implementation  of  educational  activities  and  the  implementation  of  cultural 
activities. 

In relation to the efficiency of the options, we analysed the selection processes, the 
delivery  and  compliance,  the  administrative  arrangements  required,  the  financial 
impacts, and communication with other international bodies. 

Finally, concerning the coherence of the options, we took into account the limitations 
of trade-offs across social, economic and environmental domains, the synergies and 
complementarities with other initiatives, and the possibility of participation by non-
EU countries, although such participation is likely to take place only once the EHL is 
already well established. 

The comparison of the options has shown clearly that, here too, sub-options 3b and 
3c  offer  the  prospect  of  the  most  significant  improvements.  Between  the  two  sub-
options, 3c (combined MS and EU level selection) is preferable on the grounds that it 
would ensure a fairer distribution of sites across Europe and hence be more likely to 
ensure the ownership and the commitment of all Member States. It is also 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, and it would be able to draw on both 
MS  and  EU  resources  for  selection  and  monitoring,  whilst  ensuring  a  consistent 
application  of  criteria.  Finally,  option  3c  also  proved  to  be  the  most  cost-effective 
option. 

6.1. 

Preferred policy option: 

On  the  basis  of  the  assessment  above,  as  well  as  of  the  consultation  process,  the 
preferred option for the EHL is option 3c.  

7. 

MONITORING AND EVALUATION 

The  monitoring  and  evaluation  framework  of  the  EHL  will  comprise  two  elements 
which need to be distinguished: 

The monitoring of the labelled sites 

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, which will report to the European panel. After 
a period of dialogue, in the event that specific sites no longer meet their obligations, 
there will be a possibility to withdraw the Label. 

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. 

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