COMMISSION STAFF WORKING DOCUMENT Action Programme for Reducing Administrative Burdens in the EU Final Report Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions EU Regulatory Fitness
Date: 2012-12-12
Institutions: European Commission
Subjects: application of EU law, collective interest, drafting of EU law, public consultation

EUROPEAN 
COMMISSION 

Strasbourg, 12.12.2012  
SWD(2012) 423 final 

COMMISSION STAFF WORKING DOCUMENT 

Action Programme for Reducing Administrative Burdens in  the EU Final Report 

Accompanying the document 

Communication from the Commission to the European Parliament, the Council, the 
European Economic and Social Committee and the Committee of the Regions 

EU Regulatory Fitness 

{COM(2012) 746 final} 
{SWD(2012) 422 final}

EN 

   EN 

 
 
 
 
 
  
 
 
TABLE OF CONTENTS 

EXECUTIVE SUMMARY 

1. 

2. 

BACKGROUND OF THE ACTION PROGRAMME 

OVERVIEW OF FINAL RESULTS   

2.1 MEASURES ADOPTED 

2.2 MEASURES PROPOSED 

3. 

CONCLUSIONS 

ANNEX: SECTORAL PLANS FOR REDUCING ADMINISTRATIVE BURDENS — 
FINAL RESULTS DECEMBER 2012 

1. 

2. 

3.  

4.  

5.  

6.  

7.  

8.  

9.  

Agriculture and Agricultural Subsidies 

Annual Accounts / Company law 

Cohesion Policy 

Environment   

Financial Services 

Fisheries 

Food Safety 

Pharmaceutical Legislation 

Public Procurement 

10.  

Statistics 

11.  

Taxation (VAT) / Customs 

12. 

Transport 

13.  Working Environment/Employment Relations 

2 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EXECUTIVE SUMMARY 

Reducing  administrative  burdens  so  as  to  improve  the  business  environment  in  the  EU  has 
been a high priority for the European Commission in recent years. The Action Programme for 
Reducing  Administrative  Burdens  on  business  stemming  from  EU  legislation  by  25 %  was 
launched by the Commission and endorsed by the Council in 20071. 

The  aim  of  the  ABR  Action  Programme  was  to  measure  costs2  imposed  by  information 
obligations on businesses and to eliminate any unnecessary administrative burdens in thirteen 
selected  priority  areas.  Under  this  programme,  measures  worth  EUR  30.8  billion  in  annual 
savings  for  businesses  have  been  adopted  at  EU  level.  This  represents  a  25 %  reduction  in 
existing administrative burdens stemming from EU legislation, which have been estimated at 
EUR 123.8 billion. Another 5.5 % of burden reduction, which would take the total to 30.5 %, 
could  be  achieved  if  the  additional  measures  already  proposed  by  the  Commission  were 
adopted  by  the  European  Parliament  and  the  Council.  It  has  been  estimated  that  in  the 
medium  term  the  programme  could  lead  to  an  increase  of  1.4 %  in  EU  GDP,  equivalent  to 
EUR 150 billion.  

The process has also given rise to a change in administrative culture, establishing a priority 
focus  on  achieving  public-policy  objectives  in  the  least  burdensome  way  for  business  and 
citizens. 

This final report presents the results achieved in the Action Programme. 

Concerning the achievements of the programme itself, the legislative changes adopted at EU 
level  will  yield  their  full  impact  only  if  they  are  implemented  in  Member  States  without 
undue delay and in the most efficient and least burdensome way. Continued collaboration and 
sustained  effort  at  all  levels  of  government  are  needed  to  ensure  that  the  EU  measures  are 
implemented so as to produce the greatest benefits at least costs. 

The  search  for  further  possible  reductions  in  reporting  requirements  will  continue  so  as  to 
achieve  a  broader  and  deeper  overall  reduction  in  the  regulatory  burden  at  EU  level,  as 
detailed in the Communication on ‘EU Regulatory Fitness’. 

1 COM(2007) 23 "‘ Action Programme for Reducing Administrative Burdens in the European Union’" 

2  COM(2006)  691:  ‘Measuring  administrative  costs  and  reducing  administrative  burdens  in  the  European Union’- 
accompanying the Strategic Review of Better Regulation in the EU. 

3

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
 
Action Programme for Reducing Administrative Burdens in the EU   
Sectoral Reduction Plans. Final Report   

1.   BACKGROUND 

Following the first strategic review of the Better Regulation initiative in November 2006, the 
Commission  proposed  an  ambitious  joint  strategy  with  the  Member  States  to  reduce  the 
administrative  burden  on  business  stemming  from  EU  legislation  by  25 %  by  2012.3  The 
proposal was part of the efforts to generate growth and jobs in Europe. 

The  Action  Programme  for  Reducing  Administrative  Burdens  in  the  European  Union4  was 
launched  by  the  Commission  in  January  2007  and  endorsed  by  the  European  Council  in 
March of the same year. The Council simultaneously invited Member States ‘to set national 
targets of comparable ambition’. 

The aim of the Action Programme was to measure costs imposed by information obligations 
on  business  and  to  eliminate  unnecessary  administrative  burdens  in  order  to  improve  the 
efficiency of legislation without jeopardising its purpose. 

The  programme  covered  both  EU  legislation  and  national  legislation  implementing  and 
transposing EU law. The scope of the programme initially included 42 legislative acts which 
were  later  extended  by  a  further  30  acts5  in  13  Priority  Areas  identified  as  the  most 
burdensome for businesses. 

In  2007  a  measurement  exercise  was  performed  in  all  27  Member  States  to  estimate  the 
existing  level  of  administrative  burden.  This  baseline  measurement  identified  the  extent  of 
existing  administrative  burden  and  provided  a  basis  for  the  subsequent  calculation  of  the 
reduction  measures.  The  Commission  hired  a  consortium  of  consultants  to  assist  in  this 
exercise using the so-called ‘EU Standard Cost Model’6 inspired by different variants of the 
Standard Cost Model (SCM)7 used in a number of Member States. 

Member  States’  contribution  to  the  exercise  was  mainly  channelled  through  the  High  Level 
Group of National Experts on Better Regulation and the Single Points of Contact designated 
in each Member State to coordinate the national feedback on the Action Programme. 

3 COM(2006) 689 ‘ A strategic review of better regulation in the European Union ‘. 
4  COM(2007) 23 ‘ Action Programme for Reducing Administrative Burdens in the European Union ‘. 
5 COM(2009) 16 ‘Reducing Administrative Burdens in the European Union’. Annex to the 3rd Strategic Review 
on ‘Better Regulation’ in the European Union.  . 
6 COM(2005) 518 ‘EU common methodology for assessing administrative costs imposed by legislation’ and 
SEC(2005) 1329; Annex Outline of the proposed EU common methodology and Report on the Pilot Phase 
(April– September 2005). 
7 ‘The SCM approach does not aim at producing statistically valid results, but rather expert-based estimates that 
help in understanding the nature of the problem and assessing reduction progress in relative terms.’ 
COM(2009) 16 Commission working Document. Reducing Administrative Burdens in the European Union — 
Annex to the 3rd Strategic Review on Better Regulation. 

4

 
 
 
 
 
 
 
 
 
                                                 
Stakeholders’  involvement  was  structured  around  three  pillars:  the  work  of  the  High  Level 
Group of Independent Stakeholders on Administrative Burdens established in 20078 to advise 
the  Commission  on  the  implementation  of  the  programme;9  extensive  consultation  to  give 
businesses the possibility to voice their concerns and make concrete suggestions10 which was 
supported by an online tool; and the organisation of local workshops and seminars. 

The  findings  of  this  measurement  exercise  were  presented  in  the  Communication  of  22 
October  200911  together  with  concrete  sectoral  reduction  plans  that  would  contribute  to 
achieving the overall target. Two so-called ‘Fast-track’ packages of measures to help achieve 
the reduction target had already been presented in 2007 and 2008. 

The  sectoral  reduction  plans  included  burden  estimates  and  defined  specific  actions  to  be 
taken in each of the 13 Priority Areas listed in the Programme: Agriculture and Agricultural 
Subsidies;  Annual  Accounts  /  Company  Law;  Cohesion  Policy;  Environment;  Financial 
Services; Fisheries; Food Safety; Pharmaceutical Legislation; Public Procurement; Statistics; 
Taxation and Customs; Transport; Working Environment / Employment Relations. 

The administrative burdens on business at the beginning of the Commission’s term of office 
(2005) were estimated at EUR 123.8 billion. A 25 % reduction would thus amount to cutting 
the burden on businesses by around EUR 40 billion. 

Following the 2009 Communication, the Commission has published12 regular updates on how 
much  the  administrative  burden  has  been  reduced  by  the  measures  included  in  the  sectoral 
reduction plans.   

2.  OVERVIEW OF THE FINAL RESULTS 

The  final  results  of  the  programme  show  that  the  25 %  reduction  target  was  duly  achieved. 
The  Commission  has  tabled  proposals  with  an  administrative  burden  reduction  potential  of 
EUR 40.9 billion. Some of this potential (roughly EUR 3.2 billion) was lost in the legislative 
process with the European Parliament and Council, the overall reduction is then estimated at  

8  Commission  Decision  of  31  August  2007  setting  up  the  High  Level  Group  of  Independent  Stakeholders  on 
Administrative Burdens — C(2007)4063. 

9 In 2010, the group chaired by Dr Edmund Stoiber saw its mandate in relation to the Programme extended until 
2012. In November 2011, the HLG adopted a report: ‘Europe can do better: Report on best practice in Member 
States to implement EU legislation in the least burdensome way’, a report providing concrete examples of best 
practice proposed primarily by Member States themselves. 

The members of the Group include the leaders of several bodies overseeing programmes to cut red tape in the 
Member States, as well as representatives from industry, small and medium-sized enterprises and environmental 
and consumer organisations and social partners. . 

10 Businesses were consulted in numerous occasions. More than 3000 interviews of business stakeholders were 
conducted to spot unnecessary burdens and possible solutions, and additional public consultations were carried 
out for the sectoral reduction measures. 

11 COM(2009) 544  ‘Action Programme for Reducing Administrative Burdens in the EU. Sectoral Reduction 
Plans and 2009 Actions’. 
12 http://ec.europa.eu/dgs/secretariat_general/admin_burden/result_burden/result_burden_en.htm 

5

 
 
 
 
 
 
 
 
                                                 
EUR  37.6  billion  (30.5 %  of  the  total  estimated  burden).  Measures  worth  EUR  30.8  billion 
with a reduction potential of 25 % have already been adopted by the European Parliament and 
the Council. However, some of them still need to be implemented in the Member States. 

Reducing administrative burdens is a dynamic process and the Action Programme could still 
generate  additional  savings  for  businesses  worth  EUR  6.8  billion  (5.5 %)  if  the  measures 
already proposed by the Commission were adopted by the European Parliament and Council 
in a way that  their full burden-reduction potential remains untouched. 

Table 1 provides an overview of the overall results of the Action Programme. It indicates the 
estimated burden reduction contained in the measures originally proposed by the Commission 
in  each  priority  area  and  the  reduction  resulting  from  the  measures  as  adopted  by  the 
Parliament  and  the  Council.  The  last  column  presents  the  estimated  total  reduction  in 
administrative  burden  to  be  achieved  by  the  measures  already  adopted  or  proposed  by  the 
Commission.13  

13 The Annex presents detailed results achieved by the measures contained in each sectoral reduction plan. 

6

 
 
 
 
                                                 
Table 1 

Priority Area  

1. Agriculture / 
Agricultural 
Subsidies 

2. Annual Accounts 
/ Company Law 

Proposed 
 by the 
Commission  

A 
Adopted/ 
Completed  

B 
Pending 

adoption by co-
legislator 

D=A+B 
Total reduction 
potential  

-1 891.4 

-1 891.4 

- 

-1 891.4 

-10 043.5 

-4 931.3 

- 1 700 

-6 631.3 

3. Cohesion Policy 

-234.9 

- 179.9 

-55.0 

- 234.9 

4. Environment 

-302.7 

- 302.7 

- 

- 302.7 

5. Financial 
Services 

+29.5 

- 141.5 

+171 

+29.5 

6. Fisheries 

-33.4 

- 25.9 

- 

-25.9 

7. Food Safety 

+78.8 

+79.2 

-0.4 

+78.8 

8. Pharmaceutical 
Legislation 

9. Public 
Procurement 

-101.1 

- 101.1 

-267.4 

- 368.5 

-216.6 

- 60.1 

-156.5 

-216.6 

10. Statistics 

-329.6 

- 329.6 

- 

- 329.6 

11. 
Taxation/Customs 

-26 334.3 

- 21 936.9 

- 4 397.4 

- 26 334.3 

12. Transport 

-1 263.3 

- 748.3 

- 415 

- 1 163.3 

13. Working 
Environment 
/Employment 
Relations 

-232.5 

- 232.5 

- 

- 232.5 

 (million Euro) 

-40 875 

-30 802

-6 820.7 

-37 622.7 

 % of the total AB 
estimated 
(123 760.8) 

33 

25

5.5 

30.5 

7

 
 
 
 
 
 
 
2.1. MEASURES ADOPTED 

The  sectoral  reduction  plans  include  more  than  120  measures  to  reduce  the  administrative 
burden  affecting  the  13  priority  areas.  Measures  adopted  include  more  than  40  changes 
introduced  through  regulations  and  26  through  directives.  Additional  reductions  have  been 
achieved through 15 measures of a non-legislative nature 

The  biggest  reductions  have  taken  place  in  3  policy  areas:  Agriculture,  Annual  Accounts  / 
Company  Law  and  Taxation  /  Customs,  with  potential  reductions  worth  EUR  28.7  billion 
(23 % of the initially estimated burden), reflecting the fact that these three areas accounted for 
more than 80 % of the administrative burden initially estimated.   

Reducing inspection costs stemming from marketing standards for fruits and vegetables (part 
of Regulation (EC) No 1234/2007 — Single Common Market Organisation Regulation) alone 
amounted to a potential burden reduction of EUR 973.7 million. 

Additionally,  the  measure  allowing  Member  States  to  exempt  micro-enterprises  from 
accounting  directives  (part  of  Directive  2012/6/EU  of  14  March  2012)  presented  potential 
savings  of  close  to  EUR  3.5  billion.  Although  high,  this  savings  potential  is  substantially 
lower than that proposed by the Commission (EUR 6.3 billion). 

In the area of Taxation and Customs, the measure to foster equal treatment between paper and 
e-invoices  to  enable  wider  use  of  electronic  invoicing  (part  of  Directive  2010/45/EU 
amending  Directive  2006/112/EC  on  the  common  system  of  value  added  tax  as  regards  the 
rules on invoicing) produced a burden reduction potential of EUR 18.8 billion. The measures 
to  modernise  customs  procedure  and  especially  to  switch  to  a  fully  electronic  customs 
procedure  (Regulation  (EC)  No  450/2008  laying  down  the  Community  Customs  Code 
(Modernised Customs Code and Decision 70/2008/EC on a paperless environment for custom 
and trade) while not being still in application, are expected to produce a burden-reduction of 
EUR 2.43 billion. 

2.2. MEASURES PROPOSED  

Among  the  measures  proposed  by  the  Commission  which  are  still  pending  before  the 
European  Parliament  and  Council,  the  economically  most  significant  reductions  are  also 
expected within the areas of Annual Accounts/Company Law and Taxation and Customs. 

Among  these  reduction  measures  is  the  proposal  to  modernise  EU  accounting  directives 
through a general overhaul14 which could deliver annual savings worth EUR 1.7 billion. 

The Commission 2004 proposal setting up a One Stop Shop and increasing thresholds for the 
use of special schemes for SMEs and distance sales of goods,15 with potential savings worth 

14 COM(2011) 684 Proposal for a directive of the European Parliament and the Council on the annual financial 
statements, consolidated financial statements and related reports of certain types of undertakings. 

15 COM(2004) 728 Proposal for a Council directive amending Directive 77/388/EEC with a view to simplifying 
value added tax obligations, Proposal for a Council directive laying down detailed rules for the refund of value 
added tax, provided for in Directive 77/388/EEC, to taxable persons not established in the territory of the country 
but  established  in  another  Member  State,  Proposal  for  a  Council  regulation  amending  Regulation  (EC)  No 

8

 
 
   
 
 
 
 
 
  
                                                 
EUR 4.4 billion, is still pending in the Council.  Nonetheless, an important first step has been 
taken to address the complexity of the EU VAT system for businesses. Member States have 
given  their  agreement  to  the  setting  up  of  a  mini-One  Stop  Shop  for  cross  border  sales  to 
private  individuals  of  telecoms,  broadcasting  and  e-services  which  will  enter  into  force  on 
January 2015. It is an extension of the e-commerce scheme which exists since 2003 for non-
EU  suppliers  of  e-services  that  allows  the  submission  of    a  single  VAT  declaration  and 
payment  via  an  electronic  portal  with  the  payment  allocated  automatically  to  the  different 
Member  States  where  VAT  is  due  on  the  basis  of  the  information  supplied.  The  mini-One 
Stop Shop will reduce significantly the burdens imposed on business and could be extended to 
other types of transactions thereafter, as was mentioned in the Communication on the future 
of VAT16.   

The two measures, modernisation of the accounting directives and the proposal setting up a 
One  Stop  Shop  system,  in  themselves  would  account  for  a  further  reduction  of  5 %  of  the 
administrative burden initially estimated. 

3.  CONCLUSIONS 

The  Action  Programme  has  delivered  on  the  Commission’s  commitment  to  reduce 
administrative burdens for business stemming from EU legislation by 25 % by 2012. Part of 
its success is due to the strong support from all EU institutions at the highest political level. 

Moreover, the Commission had pointed out from the beginning that the 25 % reduction target 
was a joint objective which could only be attained on the basis of shared responsibility and 
common  endeavour  on  the  part  of  the  Member  States  and  the  European  Institutions. 
Following  the  European  Council’s  invitation  to  Member  States  to  adopt  targets  of  similar 
ambition,  all  Member  States  adopted  similar  targets  to  reduce  administrative  burdens  at 
national level. The next few years will show whether these commitments have been met and 
EU proposals implemented at national level, so that the businesses can feel the difference ‘on 
the ground’. 

The  programme  has  also  served  as  an  important  driver  for  a  change  in  the  culture  of  EU 
administration  so  that  the  impact  of  legislation  on  administrative  burdens  and  thus  on 
businesses is taken into account from the beginning. 

However,  concerns  have  been  raised  in  various  quarters  regarding  elements  of  the 
programme, including:   

-  the  programme’s  exclusive  focus  on  administrative  burdens,  not  taking  into  account  other 
costs  and  benefits  that  must  be  assessed  to  achieve  a  full  picture  of  the  efficiency  and 
effectiveness of legislation; and 

- the extent of resources deployed in measuring the baseline level of administrative burdens 
and on maintaining an overview of the progress of the programme. 

1798/2003 as regards the introduction of administrative cooperation arrangements in the context of the one-stop 
scheme and the refund procedure for value added tax. 

16 COM(2011) 851 final 

9

 
 
 
 
 
 
 
 
 
 
                                                                                                                                                         
Another  key  issue  relates  to  the  shared  responsibility  of  the  European  Institutions  and 
Member  States.  There  have  been  specific  cases  where  the  Commission  had  identified  and 
proposed suitable measures to simplify and to reduce the administrative burdens on business, 
but  where  the  measures  adopted  by  the  European  Parliament  and  the  Council  offered  less 
scope administrative burden reduction. In addition, EU legislation needs to be implemented in 
Member States; the benefits of the programme cannot be achieved unless measures adopted at 
EU level are implemented in Member States by the competent authorities in the most efficient 
and least burdensome way. 

regulatory  burden  within 

The  Commission  is  determined  to  go  further  and  remove  not  only  administrative  but  any 
unnecessary 
the 
the 
Communication  on  ‘EU  Regulatory  Fitness’.  The  Regulatory  Fitness  and  Performance 
Programme  (REFIT)which  seeks  to  reduce  the regulatory  burden  and  to  ensure  the  body  of 
EU  legislation  remains  fit  for  purpose  will  take  Smart  Regulation  to  the  next  level.  It  will 
include a follow-on programme called ABR-Plus which will focus on the implementation in 
the Member States of the measures adopted at EU level under the ABR Action Programme.  

integrated  approach  explained 

in 

10

 
 
 
SECTORAL PLANS FOR REDUCING ADMINISTRATIVE BURDENS (2012) — RESULTS 2012 

ANNEX 

The tables included in this section cover the results of the actions taken in 13 priority areas and 72 legal acts in scope of the Action Programme. 
They report the estimated changes in the level of administrative burden for each of the measures included in the sectoral reduction plans. The 
presentation follows  the order used in Communication COM(2009) 544,17 where  detailed explanations for each of the measures, estimations 
and the correspondence between the measures listed in the sectoral reduction plans and the legal acts in scope of the Action Programme can be 
found.  The  ‘change  in  the  level  of  AB’  indicates  the  final  consolidated  impact  of  the  measure,  including  changes  introduced  by  other  EU 
institutions as the case may be. The total figures for each sectoral plan  refer to the maximum  estimated potential of the measures, assuming 
that gold plating18 is not introduced at the national level (they do not include changes resulting from factors other than those specified in the 
tables). Estimations were based on background studies or impact assessments carried out by the Commission between 2007 and 2012. 

The measures are listed as ‘adopted’ and ‘proposed’. 

Measures adopted at EU level include adoption of legal acts by Parliament and the Council and executive acts adopted by the Commission, as 
well as some measures of a non-legislative  nature. Where the measure adopted is legislative and it is addressed only to the EU level, the dates 
of the entry into force and application are indicated. The deadline for transposition into national law is stated where the legal act requires joint 
action by the EU and the Member States. Measures of this type are highlighted in green. 

Proposed  measures  (e.g.  Commission  legislative  proposals  pending  adoption  by  the  Council  and  Parliament)  are  highlighted  in  blue  and 
indicate the date of adoption by the Commission. 

17 Communication from the Commission to the European Parliament and the Council on the Action Programme for Reducing Administrative Burdens in the Sectoral Reduction Plans 
and 2009 . 

18  ‘gold  plating‘  by  Member  States  is  defined  in  COM(2005)  97  Better  Regulation  for  Growth  and  Jobs  in  the  European  Union  as  ‘…the  introduction  of  requirements  or 
procedures in the course of the transposition of EU legislation which are not required by that legislation ‘. 

11

 
 
 
 
 
 
 
 
 
                                                 
1.    AGRICULTURE   

The  priority  area  Agriculture  and  Agricultural  Subsidies  is  the  third-biggest  priority  area  in  terms  of  administrative  burdens  imposed  on 
businesses. The lion’s share of that burden (EUR 3.81 billion) stems from Council Regulation (EC) No 1782/2003 (now Council Regulation 
(EC) No 73/2009) establishing common rules for direct support schemes and certain support schemes for farmers (also known as the Single 
Payment Scheme). 

The so-called ‘Health Check’ reform simplified formalities for farmers benefiting from the Single Payment Scheme and reduced administrative 
burdens for business by an estimated EUR 250 million. For instance, further decoupling of direct payments was introduced by removing the 
link between the receipt of a direct payment and the production of a specific product. This gave farmers greater freedom to produce according 
to market demand. Decoupling also means that farmers no longer need to provide information on specific crops (before the reform there were 
more than 3 million crop specific applications annually, among which almost 800,000 applications for energy crops). 

The  highest  burden  reduction,  estimated  at  more  than  EUR  970  million,  was  achieved  when  the  Commission  adopted  Regulation  (EC)  No 
1221/2008  reducing  the  number  of  products  subject  to  specific  marketing  standards  for  fruit  and  vegetables  from  36  to  10:  labelling-class 
details were no longer required for 26 products representing 25 % of the trade in fresh fruits and vegetables. The regulation also rationalised the 
associated  checking  operations,  introducing  risk-based  controls,  and  established  a  general  marketing  standard  covering  most  fruit  and 
vegetables. Another major change with estimated savings of more than EUR 606 million was the simplification of egg-labelling requirements. 
This greater flexibility reduces costs not only for farmers but also for the downstream sector, as well as control costs for Member States. By 
exempting  producers  with  up  to  50  laying  hens,  more  than  5  million  farms  producing  more  than  100  billion  eggs  can  be  exempted  from 
marking eggs with the producer code. 

At the other end of the spectrum, Commission Regulation (EC) No 1291/2000 (now Commission Regulation (EC) No 376/2008) laying down 
rules for the system of import and export licences was often considered a major irritant even if it meant only EUR 12 million in administrative 
burdens.  The  number  of  products  requiring  an  import  or  export  licence  has  now  been  reduced  from  over  500  to  65  for  imports  and  43  for 
exports. 

Most  of  the  measures  reducing  administrative  burdens  were  adopted  at  an  early  stage  in  the  Action  Programme  (between  2007  and  2009), 
leading to estimated savings of about EUR 1.9 billion. 

12

 
 
 
 
 
 
 
Agriculture 

1. Simplifying formalities for farmers benefiting from the 

‘Single Payment Scheme’ (part of the ‘Health Check’) 

2. Reducing farmers’ book-keeping and inspection costs 

stemming from ‘cross-compliance’ obligations 

3. Reducing the number of agricultural products for which a 

licence is necessary 

4. Simplifying egg labelling 

5. Reducing inspection costs stemming from marketing 

standards for fruit and vegetables 

6. Suppressing administrative burdens linked to special 

support schemes (part of the ‘Health Check’)  

7. Reducing information obligations for payments to farmers 

by abolishing the '10-month' rule 

8. Repealing legal requirements on registration of contracts in 

the hops sector 

9. Simplifying controls on farmers by striving for appropriate 

control rates 

10. Increasing the tolerable risk of errors for funds used in 

rural development 

11. Concentrating cross-compliance rules in one legal 

instrument 

12. Reducing control frequency related to dried fodder (EUR 

16.2 m reduction included in No 6 above) 

13. Simplifying measures implementing the Single Payment 

Scheme for farmers, including cross-compliance, modulation 
and the integrated administration and control system 

Change in 
the level of 
AB 
(million 
EUR) 

-250.0

-5.5

-6.0

-606.7

-973.7

-28.0 (it also 
concerns 
item 12)

-21.5

n/a

n/a

n/a

n/a

Change 
included in 
item 6.

State of play 

Entry in force (E) 
Application (A) 
Transposition (T) 

Adopted   
Council Regulation (EC) No 73/2009 of 19 January 2009 

Adopted   
Commission Regulation (EC) No 1550/2007 of 20 December 2007 amending 
Regulation (EC) No 796/2004 
Adopted 
 Commission Regulation (EC) No 514/2008 of 9 June 2008 amending Regulation (EC) 

No 376/2008 

Adopted 
Commission Regulation (EC) No 557/2007 of 23 May 2007 

Adopted 
Commission Regulation (EC) No 1221/2008 of 5 December 2008 amending Regulation 
(EC) No 1580/2007 

E: 1.02.2009 
A: 1.01.2009  

E: 24.12.2007 
A: 1.01.2008 

E: 13.06.2008: A: for 1.07, 1.08, 1.09 
and 1.10 = 2008 

E: 31.05.2007 
A: 1.07.2007 

E: 16.12.2008 
A: 1.07.2009 

Adopted 
Council Regulation (EC) No 1234/2007 of 22 October 2007; Council Regulation (EC) 

E: 23.11.2007 
A: 1.12.2008 with exceptions 

No 72/2009 of 19 Jan 2009 

Adopted 
Council Regulation (EC) No 146/2008 of 14 February 2008 

Proposed 
COM(2011) 626 final/2 of 19.10.2011 

Working Documents DS/2009/27 and DS/2009/28; cf. also Measure 13 below  

Preparation completed. Communication 
COM(2010) 261 final; SEC(2010) 640; SEC(2010) 641 

Proposed 
COM(2011) 628 final/2 of 19.10.2011 

Adopted Council Regulation (EC) No 72/2009 of 19 January 2009 amending 

Regulation (EC) No 1234/2007 The support scheme for dried fodder will end in 2012 

n/a

Proposed and partially adopted 
Initially COM(2010) 537/539, now included in Commission Proposal for Council 
Regulation COM(2011) 625, amended by COM(2012) 552 final. 
Cf. Commission Regulation (EC) No 146/2010; Commission Regulations No 1122/2009; 
No 1120/2009; DS/2009/27; DS/2009/28 

13

E: 28.02.2008 
A: 1.01.2008 

A: 1.01.2010 

E: 3.02.2009 
A: 1.04.2012 

E: 1.03.2010  

 
 
 
 
 
 
 
 
Sectoral total 

-1 891.4

14

 
 
 
2.  

ANNUAL ACCOUNTS 

The Commission has proposed measures worth more than EUR 10 billion and measures so far adopted by the co-legislator have achieved a 
potential administrative-burden reduction for EU business of EUR 4.9 billion. 

The final adoption in spring 2012 of the Commission proposal on allowing micro-enterprises to be exempted from accounting directives was 
an  important  step  in  achieving  the  Action  Programme's  25 %  reduction  target,  although  savings  will  be  substantially  lower  than  initially 
estimated.  The  original  Commission  proposal  for  an  outright  exemption  for  micro-entities  from  all  EU  accounting  requirements  included 
potential  savings  estimated  at  around  EUR  6.3 billion.  However,  the  amendments  introduced  by  the  Parliament  and  Council  during  the 
legislative  process  (retaining  minimal  accounting  requirements  for  micro-entities  and  thus  affecting  fewer  companies  than  originally 
anticipated)  reduced  the  potential  savings  to  EUR  3.4  billion.  It  is  also  regrettable  that  the  proposal  COM(2008) 194  of  17  April  2008  to 
simplify  obligations  concerning  the  publication  and  translation  of  financial  information  —  which  could  have  led  to  savings  of  EUR  660 
million — was finally withdrawn by the Commission due to lack of agreement in the Council. 

The losses might nonetheless be outweighed by the proposal modernizing EU accounting directives through a general overhaul, which aims, 
in particular, to create a new simple and harmonised regime for small companies and entails savings worth EUR 1.7 billion. Whether this 
potential will be fully realised depends on the negotiations in the Council and Parliament. It is also worth noting that the recently adopted 
Directive on the interconnection of central, commercial and companies’ registers will lead to a reduction of EUR 69 million in addition to the 
savings presented in the sectoral plan in 2009. 

. 

15

 
 
 
 
 
 
 
 
Annual Accounts / Company Law 

 Allowing more small and medium-sized companies to benefit from simplified accounting/auditing 
regimes  

  Limiting the amount of information in the notes to the accounts for medium-sized enterprises. 
 Clarifying that consolidated accounts are not required if all subsidiaries are non-material  

Allowing Member States to exempt micro-enterprises from accounting directives 

 Modernising EU accounting directives through a general overhaul 

Simplifying the obligations related to changes to the capital of public limited liability companies 

Abolishing the obligation to provide an independent expert’s report on merger or division in case of 
waiver 

Simplifying the reporting requirements in case of a merger or division 

Change in 
the level of 
AB (million 
EUR) 

- 862.6 

- 8.2 

State of play 

Adopted 
Directive 2006/46/EC of 14 June 2006  

Adopted 
Directive 2009/49/EC of 18 June 2009  

-3 499.4  

Adopted 
Directive 2012/6/EU of 14 March 2012 (burden reduction of 
 6 300.0 million) 
the original Commission proposal was  — €

-1 700.0  

- 150.0 

- 170.1 

- 172.0 

Proposed 
COM(2011) 684 of 25 October 2011  

Adopted 
Directive 2006/68/EC of 6 September 2006  

Adopted 
Directive 2007/63/EC of 13 November 2007 

Adopted 
Directive 2009/109/EC of 16 September 2009 

 Interconnection of business registers  

- 69.0 

Adopted 
Directive 2012/17/EU of 13 June 2012  

Entry in force (E) 
Application (A) 
Transposition (T) 

E: 5.09.2006 
T: 5.09.2008 

E: 20.08.2009 
T: 1.01.2011 
simplifications under the 
new Directive are only 
optional, no transposition 
period for MS is required.- 

E: 15.10.2006 
T: 15.04.2008 

E: 7.12.2007 
T: 31.12.2008 

E: 22.10.2009 
T: 30.06.2011 

E: 20.07 2012 
T: 7.07.2014, special 
provisions affect 
implementing acts referred 
to in Art. 4c of Directive 
2009/101/EC 

Sectoral Total 

 -6 631.3 

16

 
 
 
 
 
 
 
3.  

COHESION POLICY 

Cohesion Policy is a special priority area where the measurement of administrative costs was not limited to businesses. Implementation of the 
Cohesion Policy is multilayered, involving national, regional and local authorities; its beneficiaries are also public and semi-public authorities 
and non-profit organisations. 

Estimated burdens stemming from EU legislation for the 2007-2013 funding period, calculated on the basis of the previous period, amounted 
to EUR 929 million. Following the economic and financial crisis, the framework established for cohesion policy for the programming period 
2007-2013 was simplified to make implementation of the programmes easier and to boost absorption of the funds. The amendments to the 
general  provisions19  and  implementing  rules  adopted  under  the  Action  Programme  for  the  period  2007-20013  simplify  reimbursement 
calculations, reduce the work load and control burden on beneficiaries and lighten reporting in terms of information obligations. At several 
meetings with the stakeholders, those responsible for actually implementing the measures expressed considerable appreciation for these two 
measures and for the simplification package in general. In addition to the legislative measures during 2008 and 2009, the Commission has 
provided extensive guidance through the management committees and regular technical meetings of audit authorities and has organised large-
scale training and sectoral events for Member States. 

A study of the feasibility of developing national-level central clearing houses for Cohesion Policy reporting was completed and has served as 
the basis for introducing in COM(2011) 615 a requirement for the financing period 2014-2020 (CPR) to set up a system by the end of 2014 
enabling  all  exchanges  of  information  between  the  beneficiary  and  the  national/regional  authorities  to  take  place  by  way  of  electronic 
information exchange, without a duplicating paper trail and supplying all information only once. The Council, however, has expressed a wish 
to postpone the deadline from 2014 to 2016, potentially postponing some of the benefits this proposal would offer to beneficiaries. 

It  is  worth  noting  that  in  addition  to  the  simplification  and  burden-reduction  achieved  under  the  Action  Programme,  the  Commission  has 
proposed  for  the  period  2014-2020  a  legislative  framework  which  aims  to  further  simplify  the  management  of  EU  Funds  under  cohesion 
policy. The results of a study undertaken by the Commission on the impact of regulatory changes proposed for the period 2014-2020 on the 

19  

 Council Regulation (EC) No 1083/2006 laying down general provisions on the European Regional Development Fund, the European Social Fund and the Cohesion Fund  
repealing the single legal act in scope of the Action Programme, Council Regulation (EC) No 1260/1999. 

17

 
 
 
 
 
 
                                                 
administrative burden of beneficiaries of the ERDF and the Cohesion Fund20 indicate, with regard to the baseline established for the period 
2007-2013,21  that: 

-  the  Commission’s  proposal  for  a  shift  to  ‘e-cohesion’  would  reduce  the  aggregate  administrative  burden  at  EU  level  by  approximately 
11 %.22    This  requirement  is  based  on  the  main  recommendation  of  the  High  Level  Group  of  Independent  Stakeholders  on  Administrative 
Burdens stemming from the initial assessment of administrative burden in the period 2000-2006. 

- the estimated potential burden reduction of the remaining modifications proposed by the Commission, if implemented in full by Member 
States,  is  9 %.23  These  include  rules  allowing  for  a  simpler  use  of  flat  rates,  unit  costs  and  lump  sums,  harmonisation  of  eligibility  rules 
applied under shared management and annual closure leading to a shorter period for the retention of documents and audit. 

-  in  the  context  of  shared  management,  the  Commission  and  the  Member  States  share  responsibility  for  simplification  and  administrative-
burden  reduction.  The  Commission  has  therefore  also  proposed  that  Member  States  undertake  an  assessment  of  administrative  burdens 
stemming from national procedures and practices and set out in their Partnership Contract and programmes for the period 2014-2020 actions 
to reduce this burden. This requirement is expected to contribute to a further reduction of the administrative burden on beneficiaries. 

20   ‘Measuring the impact of changing regulatory requirements to administrative cost and administrative burden of managing EU structural funds (ERDF and Cohesion Fund)’, to 
be  finalised  in  2012.  The  study  does  not  cover  the  European  Social  Fund  and  since  the  interventions  financed  are  different  from  those  supported  under  the  ERDF  and  the 
Cohesion Funds, the results should not be extrapolated to this instrument. 

21       See ‘EU project on baseline measurement and reduction of administrative costs’ 5 March 2009 http://ec.europa.eu/enterprise/policies/smart-

regulation/documents/ab_studies_2009_en.htm#h2-3. This assessment also covered the European Social Fund; accordingly, a direct comparison of results is not possible. 

22   Referred to the baseline established for the period 2007-2013. 

23   Referred to the baseline established for the period 2007-2013. 

18

 
 
 
 
 
 
                                                 
Cohesion Policy  

Change in the 
level of AB 
(million 
EUR) 

State of play 

Entry in force (E) 
Application (A) 
Transposition (T) 

Reducing administrative burdens for projects (co)financed by EU Structural Funds regarded as 

revenue-generating 

- 18.4 

Adopted 
Council Regulation (EC) No 1341/2008 of 18 December 2008 

Simplifying the management and control of operations co-financed by the ESF and the ERDF 

- 45.8 

Simplifying and clarifying general provisions on the ERDF, ESF and the Cohesion Fund 

- 33.4 

Providing guidance and training on control and audits of Structural Funds 

Facilitating, simplifying and clarifying certain general provisions on the ERDF, ESF and the 
Cohesion Fund  

- 20.0 

- 62.3 

Adopted 
Regulation (EC) No 396/2009 of 6 May 2009 and Regulation 
(EC) No 397/2009 of 6 May 2009 

Adopted 
Commission Regulation (EC) No 846/2009 of 1 September 
2009 

Adopted. 
Guidance notes (on annual control reports and opinions; on 
reliance on the work of other auditors; on management 
verifications on certification; on partial closure; on revenue 
generating projects; and on fraud indicators) 

Adopted 
Regulation (EU) No 539/2010 of 16 June 2010 

E: 25.12.2008 
A: 1.08.2006 

396/2009 
E: 22.05.2009 
A: 1.08.2006 

397/2009 
E: 11.06.2009 
A: 1.08.2006 
E: 14.10.2009 
A (exception): 16.01.2007 

E: 25.06.2010 
A (exceptions): 
1.08.2006 
1.01.2007 
10.06.2009  

Developing, at national/regional level, central clearing houses for Cohesion Policy reporting 

- 55.0 

Proposed 
Commission Proposal 
COM(2012)496 final for 2014-2020 (CPR) 

Sectoral Total 

.

- 234.9  

19

 
 
 
 
 
 
 
 
 
4. ENVIRONMENT 

The  administrative  burden  stemming  from  the seven  acts  in  scope  within  the  priority  area  Environment  was  estimated  at  EUR  1.2  billion, 
which amounts to only one percentage point of the estimated total administrative burden. This figure is relatively low in comparison with the 
perception by businesses; this is partly due to confusion with compliance costs in the environmental area and to the high visibility of certain 
requirements. 

Often Member States incur different costs for doing the same thing — around one third of the administrative burden is estimated to be the 
result  of  inefficient  public  and  private  administrative  practices,  meaning  there  is  further  scope  for  sharing  good  practice.  A  recent  study24,  
pointed  to  relevant  other  issues.  For  example,  the  flexible  implementation  allowed  in  several  directives  has  resulted  in  higher  overall 
administrative costs. Uneven implementation implies different administrative requirements for companies operating across the EU in terms of 
labelling, monitoring, reporting, notification, permits, etc. As a result, companies operating in different Member States need to run different 
systems and so incur additional costs. Such costs are very hard to quantify but, could amount to a few million euros per year. This could be 
particularly relevant for SMEs, where such administrative costs could be a barrier to exporting to other Member States.  

To  date,  the  Commission  has  taken  action  to  address  eight  out  of  the  eleven  measures  included  in  the  Action  Programme.  Three  other 
measures fall under the responsibility of the Member States and it is assumed for the purposes of this report that they have also taken the 
necessary steps to ensure that the required measures are introduced and the administrative burdens removed/reduced. In most instances, the 
deadline for transposition or application has not yet been reached; it is therefore not yet possible to measure the actual reductions achieved. 
The figures in the table are accordingly the figures presented in the 2009 Communication.   

The newly adopted directive 2012/19/EU (Waste electrical and electronic equipment) is expected to cut unnecessary burdens for producers of 
such  equipment  by  harmonising  the  registration  format  and  certain  reporting  requirements.  This  will  allow  the  integration  of  horizontal 
reporting between MS and integration of vertical reporting chains. The new directive also requires cooperation between administrations and 
MS must ensure that multiple payments are reimbursed. Proportionally, SMEs are presumed to benefit the most. 

Concerning biocidal products, the Commission proposal introduced simplified, more effective and efficient legislation, reducing unnecessary 
burdens  for  Member  States  and  industry  whilst  maintaining  a  high  level  of  protection  of  human  health  and  the  environment.  Significant 
savings to business will be achieved through obligatory sharing of data from tests involving vertebrate animals at the substance-evaluation 
and product-authorisation stage. SMEs in particular will benefit from the partial harmonisation of the fee structure. 

24         The costs of not implementing the environmental acquis, published in September 2011. 

20

 
 
 
 
 
 
 
 
                                                 
Directives  2010/75/EU  on  industrial  emissions  (IED)  and  2012/18/EU  on  the  control  of  major-accident  hazards  involving  dangerous 
substances,  amending  and  subsequently  repealing  Council  Directive  96/82/EU  (Seveso)  will  ensure  improved  coordination  of  inspections 
between the two regimes. Recital 26 of Seveso makes clear that ‘Where possible, inspection should be coordinated with those under other 
Union  legislation,  including  Directive  2010/75/EU  on  industrial  emissions,  where  appropriate’.  Furthermore,  Article  23(3)  of  the  IED 
includes scope for inspection plans to introduce provisions on cooperation between different inspection authorities. 

Directive 2010/75/EU on industrial emissions (IED) provides greater clarity with regard to the reconsideration and updating of permits.  The 
Directive requires reconsideration and updating of the permit conditions by the competent authority, not the renewal of permits.  Most permit 
reconsideration and updating will take place as a result of the publication of the best available techniques (BAT) conclusions under the IED, which 
are published eevery eight years. The reconsideration and updating will likely have the same frequency. 

21

 
 
 
 
 
       Environment  

Simplifying procedures for controlling waste shipments 

Simplifying the regime for integrated pollution prevention and control 

Harmonise national information obligations on waste electrical/electronic equipment and ensure 
register interoperability 

Streamlining reporting obligations on substances depleting the ozone layer 

Change in the  
level of AB 

State of play 

Entry in force (E) 
Application (A) 
Transposition (T) 

Adopted 
Regulation EU No 1013/2006 of 14 June 2006 on Shipments of 

E: 17.06.2006 
A: 12.07.2007 

Waste 

Adopted 
Directive 2010/75/EU of 24 November 2010 on industrial 
emissions (integrated pollution prevention and control)  
Adopted 
Directive 2012/19/EU,on waste electrical and electronic equipment 
OJ L 197, 24.7.2012, p. 38–71 

E: 6.01.2011 
T: 7.01.2013 

E: 13.08. 2012 
T: 14. 02. 2014 

Adopted 
Regulation (EC) No 1005/2009 of 16 September 2009 

E: 20.11.2009 
A: 1.01.2010 

- 3.6 

- 32.0 

- 66.0 

- 0.5 

Simplifying authorisation procedures for the placing of biocidal products on the market 

-140.0  

Adopted. 
Regulation (EU) N  528/2012 of 22 May 2012 concerning the 
making available on the market and use of biocidal products 
(replacing Directive 98/8/EC) 

E:17.07.2012 
A: 1.09. 2013 

Setting up a website for submitting and changing notifications of presence or changes of dangerous 
substances 

Improving coordination between IPPC and Seveso inspections by national authorities (legislative 
proposal) 

- 1.5 

The notification procedure is handled by Member States  

7: Adopted 
Directive 2010/75/EU of the European Parliament and of the 
Council of 24 November 2010 on industrial emissions (integrated 
pollution prevention and control)  

- 1.1 

Improving coordination between IPPC and Seveso inspections by national authorities 
(implementing provisions) 

Encouraging Member States to update IPPC permits rather than demand their renewal 

Simplifying and streamlining the notification system for shipments of waste 

Introducing online systems through which treatment facilities can issue vehicle-destruction 
certificates 

Sectoral Total 

8: Adopted. Directive 2012/18/EU on the control of major-accident 
hazards involving dangerous substances, amending and subsequently 
repealing Council Directive 96/82/EC  

Adopted. 
Directive 2010/75/EU of the European Parliament and of the 
Council of 24 November 2010 on industrial emissions (integrated 
pollution prevention and control)  
The Commission recommended that MS introduce such a system 
by letter to the Perm Reps in July 2010. 

The Commission recommended that MS set up an IT system, as 
this is a matter for implementation by MS. 

- 5.0 

- 44.0 

- 9.0 

  302.7  

22

-- 

E: 6.01.2011 
T: 7.01.2013 

E: 13.08.2013 
T: 31.05.2015 

E: 6.01.2011 
T: 7.01.2013 

-- 

-- 

 
 
 
 
 
 
 
5. FINANCIAL SERVICES   

Financial  Services  have  been  a  focal  point  of  the  financial  crises;  filling  in  the  gaps  in  financial-sector  regulation  and  strengthening  the 
supervision  of  the  financial  sector  in  Europe  have  been  key  aspects  of  stabilising  the  financial  markets.  The  increasing  regulation  of  the 
financial services has in some cases led to increases in administrative burdens in this sector as the focus has been on additional supervision 
and  increased  transparency,  so  as  to  increase  market  confidence.  Such  increases  are  only  partly  reflected  in  the  final  results  of  the 
programme, as measures taken refer mainly to legal acts that were adopted at a very early stage of the crisis.25  

The  latest  proposal  from  the  Commission  included  in  the  Financial  Services  measures,  the  proposal  on  key  information  documents  for 
investment products (COM(2012) 352, has the drawback of increasing the administrative burden. The proposal reflects the need for increased 
transparency regarding investments, as the financial crisis has shown that retail investors lost money through investments that carried risks 
that  were  not  transparent  or  understood  by  those  investors.  Investors  have  lost  confidence  in  financial  services  and  rebuilding  confidence 
through transparency is vital. Greater transparency often goes together with increased administrative burdens, in this case by about EUR 171 
million.  As  the  Proposal  was  adopted  by  the  Commission  only  on  3  July  2012,  the  final  result  of  the  legislative  process  in  Council  and 
Parliament is not included in the figures below. 

The most relevant impact in terms of reduced administrative burden in this sector concerns the new provisions on large-exposure regimes 
under Directive 2009/111 (part of the CRD II package).  
In  the  overview  table  for  Financial  Services,  one  figure  for  a  change  in  the  level  of  administrative-burden  reduction  is  missing.  This  is 
because the measure refers to guidelines or similar provisions that, following the final adoption by the Council and Parliament, have been 
delegated to agencies (such as the Committee of European banking Supervisors). In such cases, no figures have been included in this final 
overview as it is not the responsibility of the Commission to prepare the guidelines.  

25 An example concerns measure 4 of the CDRII package. The reduction in administrative burden will be offset by increased compliance costs stemming from additional requirements in 
relation  to  a  more  prudent  approach  in  the  area  of  interbank  exposures  (CRDII);  to  the  enhanced  disclosure  for  securitisations  in  banks’  trading  books  (CRDIII)  and  to  the  new 
measures in the area of liquidity risk and counterparty credit risk management (CRDIV). The latter may have a lesser impact on the smallest EU banks with a simple balance structure. 

23

 
 
 
 
 
 
 
 
 
                                                 
Financial Services  

Revising capital and solvency requirements for credit institutions 

Revising mandatory and solvency capital requirements for insurance and reinsurance 
companies (Solvency II) 

Reducing administrative burdens on ‘Undertakings for Collective Investment in 
Transferable Securities’ (UCITS) 

Simplifying rules on large exposures of credit institutions (CDR II package) 

Abolishing the obligation to report on initial capital, own funds and investment limitation 
for e-money service providers 

Reducing reporting obligations on cross-border payments 

Simplifying the provision of pre-contractual information required from insurance 
companies 

Harmonising the format and frequency of reporting by credit institutions and investment 
firms 

Sectoral Total 

Change in the 
level of AB 
(million 
EUR) 

+16.7

+0.9

- 45.0

- 105.0

-2.4

- 6.7

+171.0

State of play 

Adopted 
Directive 2006/48/EC of the European Parliament and of the Council of 14 
June 2006 

Adopted. 
Directive 2009/138/EC of the European Parliament and of the Council of 25 
November 2009.  
Adopted. Directive 2009/65/EC of the European Parliament and of the 
Council of 13 July 2009  

Adopted. Directive 2009/111/EC of the European Parliament and of the 

Council of 16 September 2009 

Adopted 
Directive 2009/110/EC of the European Parliament and of the Council of 16 
September 2009  

Entry in force (E) 
Application (A) 
Transposition (T) 

E: 20.07.2006 

E: 6.01.2010 
T: 31.10.2012 

E: 7.12.2009 
T: 1.07.2011 

E: 7.12.2009 
T: 31.12.2010 

E: 31.10.2009 
T: 30.04.2011 

Adopted 
Regulation (EC) No 924/2009 of the European Parliament and of the Council 

E: 30.10.2009 
A: 1.11.2009 

of 16 September 2009 

Proposed 
COM(2012) 352 final 

Adopted. 

E: 7.12.2009 
T: 31.12.2010 

n/a

Directive 2009/111/EC of the European Parliament and the Council of 16 

09 2009.  

29.5 

24

 
 
 
 
 
 
 
 
 
6. 

FISHERIES 

Administrative  burdens  stemming  from  information  obligations  on  Fisheries  are  the  smallest  among  the  13  priority  areas  covered  by  the  Action 
Programme for Reducing Administrative Burdens in the European Union in absolute terms (less than 0.1 %). The Action Programme covers only one 
legal act regulating fisheries, Council Regulation (EEC) No 2847/93 (the ‘Control Regulation’), which accounted for burdens estimated at EUR 73.9 
million.  On  14  November  2008,  the  Commission  presented  a  proposal  to  replace  Regulation  (EEC)  No  2847/93  that  would  halve  the  burden,  in 
particular through the extensive use of electronic logbooks. This proposal was adopted in 2009 as Council Regulation (EC) 1244/2009. 

It is worth noting that one of the measures included in the sectoral plan for fisheries had been proposed before the Programme was launched, using 
electronic  reporting  by  way  of  electronic  logbooks  for  vessels  above  a  certain  size,  generating  estimated  savings  of  EUR  19  million.  During 
implementation  of  the  2006-2008  Action  Plan  for  Simplifying  the  Common  Fisheries  Policy  (CFP)26,  the  Council  had  adopted  in  2006  a  reform 
introducing electronic reporting. This electronic reporting was included in Regulation (EC) No 1224/2009. Implementing measures were adopted in 
2008  and  the  new  system  has  been  compulsory  for  sales  data  since  2009  and  for  catch  data  since  2010  for  vessels  larger  than  24 m;  it  is  being 
gradually  extended  to  vessels  above  12 m.  However,  as  Regulation  (EC)  No  1224/2009  in  the  end  extended  the  use  of  electronic  logbooks  to  a 
smaller group of fishing vessels than originally proposed, the reduction of administrative burdens was less than originally envisaged. A reform of the 
system of fishing authorisations has also been introduced together with simpler rules for the European Maritime and Fisheries Fund. 

26 COM(2005) 647. 

25

 
 
 
 
 
 
 
 
 
                                                 
Fisheries 

Change in the 
level of AB 
(million 
EUR) 

State of play 

Using electronic logbooks for vessels 15 meters length overall and above 

Extending the use of electronic logbooks to certain types of vessels   

Introducing a standard method for fishing inspections across the EU 

-19.0 

Adopted. 
Council Regulation (EC) No 1224/2009 of 20 November 2009 and 
Commission Implementation Regulation (EU) No 404/2011 of 8 
April 2011  

-6.5 

Adopted. 
Council Regulation (EC) No 1224/2009 of 20 November 2009 
(The ABR potential of the original proposal was 14 million EUR) 

-0.4 

Adopted. 
Council Regulation (EC) No 1224/2009 of 20 November 2009; 
and Commission Implementation Regulation (EU) No 404/2011 of 
8 April 2011 

Sectoral Total 

-25.9 

Entry in force 
(E) 
Application 
(A) 
Transposition 
(T) 

1224/2009 
E: 23.12.2009 
A: 1.01.2010 

404/2011 
E: 7.5.2011 

E: 23.12.2009 
A: 1.01.2010 

1224/2009 
E: 23.12.2009 
A: 1.01.2010 

404/2011 
E: 7.5.2011 

26

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
7.          FOOD SAFETY 

The potential burden reduction estimated in this area takes into  account  EUR  103.8  million  of  additional administrative burdens that were 
estimated to be linked to the Commission proposal on food information to consumers. It must be noted, however, that the final adopted text, 
Regulation (EC) No 1169/2011 modernising the general food labelling and nutritional labelling regime, which responded to a strong request 
from stakeholders and industry, entails major achievements in terms of simplification and modernisation of the food-labelling rules: it recasts 
in a Regulation a considerable number of ‘scattered’ labelling provisions, reducing the information costs for food businesses and facilitating 
implementation by control authorities. It also introduces the principle of systematic use of transitory periods and the exhaustion of stocks in 
EU  food-labelling  legislation  and  of  uniform  implementation.  In  addition,  it  narrows  the  scope  for  national  labelling  rules.  It  provides  the 
Commission with the legal basis to enable (via delegated acts) the provision of mandatory food information a) by other means than the label 
and b) by using logos or pictograms instead of words. This Regulation will enter into force in December 2014. 

Among the measures adopted it is also worth noting that Regulation (EC) No 1069/2009 streamlining legislation on animal by-products (item 
7)  may  lead  to  a  burden  reduction  higher  than  the  EUR  21.2  million  initially  estimated,  according  to  a  study  carried  out  by  an  external 
contractor.27  In addition, the elimination of veterinary border-inspection posts between the EU and Switzerland, thanks to the alignment of 
Swiss animal health and welfare standards with the European ones, will considerably reduce red tape for operators importing livestock and 
consignments of animal products from third countries via Switzerland (some 32 000 consignments per year). 

The new proposal simplifying bovine identification procedures and repealing provisions on voluntary beef labelling will add savings worth 
EUR 0.4 million to the initial estimates in this field. 

27 DG ENTR CEPS Brussels, 25 August 2009. 

27

 
 
 
 
 
 
 
                                                 
Food Safety 

Simplifying bovine identification procedures  

Repealing provisions on voluntary beef labelling  

Simplifying ovine identification procedures 

Reducing the number of veterinary checks on intra-community maritime trade 

Eliminating veterinary border-inspection posts between the EU and Switzerland 

Streamlining legislation on the production, marketing and use of animal by-products 

Abolishing authorisation procedures and simplifying labelling requirements for feed materials 

Setting a common and shorter authorisation procedure for food-improvement agents 

Simplifying general food labelling and nutritional labelling 

Sectoral Total 

Change in 
the level of 
AB (million 
EUR) 

State of play 

Entry in force (E) 
Application (A) 
Transposition (T) 

Proposed. 
COM(2011) 525 of 30 August 2011 

Adopted 
Commission Regulation (EC) No 759/2009 of 19 August 2009  

E: 10.09.2009 

Adopted 
SANCO/10473/2009 — Guidance Document on procedures for 
checks on live animals and products of animal origin arriving at EU 
points of entry which have full veterinary clearance for the EU 
market 

Adopted 
Decision no 1/2008 of the joint veterinary committee set up by 
the agreement between the EC and the Swiss Confederation on 
trade in agricultural products of 23 Dec. 2008  

Adopted 
Regulation (EC) No 1069/2009 of 21 October 2009 
Implementing Regulation (EU) No 1142/2011 of 26 02 2011  

Adopted 
Regulation (EC) No 767/2009 of 13 July 2009  

Adopted 
Regulation (EC) No 1331/2008 
Regulation (EC) No 1333/2008  

Adopted 
Regulation (EC) No 1169/2011 of 22 November 2011 

E: 5.12.2009 
 A: 4.03.2011 

E: 21.09.2009 
A: 1.09.2010 

1331 
E: 20.01.2009 
1333 
E: 20.01.2009 
A: 20.01.2010 

E: Food labelling 

13 12 2014; 
nutritional labelling 
13 12 2016 

- 0.4 

n/a 

n/a 

- 1.3 

- 21.2 

- 2.0 

- 0.1 

+103.8 

-78.8  

28

 
 
 
 
 
 
 
 
 
 
 
 8.       PHARMACEUTICAL LEGISLATION 

The five information obligations in the priority area of Pharmaceutical Legislation that were scrutinised, reduced and simplified relate to the 
application needed for marketing authorisation, to notification of planned changes in the marketing authorisation, to submission of a periodic 
safety  report,  to  requests  for  authorisation  to  commence  a  clinical  trial  and  to  the  registering  of  detailed  records  of  suspected  adverse 
reactions. 

Implementation  of  the  new  pharmaco-vigilance  legislation  not  only  enhances  public  health  protection  but  will  also  mean  a  reduction  of 
administrative  burdens  and  greater  simplification,  once  it  is  fully  implemented.  The  intended  streamlining  of  the  processing  of  marketing 
authorisations for medicinal products for human use was covered by the simplifications introduced in the procedure for reporting ‘Variations’  
(i.e.  Commission  Regulation  (EC)  No  1234/2008  of  24  of  November  2008;  Directive  2009/53/EC  of  the  European  Parliament  and  of  the 
Council of 18 June 2009). 

Once adopted by the legislator, the Commission proposal on the new Clinical Trials Directive would reduce administrative burdens by EUR 
267.4  million  per  year  —  a  figure  up  on  the  initial  estimate  of  EUR  37.4  million,  following  a  careful  impact-assessment  exercise. 
Furthermore,  it  would  also  reduce  other  compliance  costs  for persons  conducting  clinical  trials  (‘sponsors’)  by  over  EUR  500  million  per 
year. Once implemented, the measures proposed will speed up and simplify the authorisation and reporting procedures, while maintaining the 
highest standards of patient safety and robustness and reliability of data. The measures will also more closely match obligations to the risk-
profile  of  the  trial,  improve  transparency  (including  with  regard  to  trials  performed  in  third  countries)  and  make  it  possible  for  the 
Commission to conduct controls in Member States and other countries to make sure that the rules are being properly supervised and enforced. 

The total reduction potential of the measures included in this area has increased from EUR 154.6 million (initial estimate28) to EUR 368.5 
million. 

. 

28 COM(2011) 544 Annex C, page 65 

29

 
 
 
 
 
 
 
 
                                                 
Pharmaceutical Legislation 

Simplifying the procedure for reporting ‘Variations’ (changes) to medicines already authorised for 
marketing 

Simplifying pharmaco-vigilance reporting obligations 

Simplifying the application to commence a clinical trial required to test new medicines 

Change in the 
level of AB 
(million 
EUR) 

State of play 

Entry in force (E) 
Application (A) 
Transposition (T) 

Adopted 
Commission Regulation (EC) No 1234/2008 of 24 November 
2008; Directive 2009/53/EC of the European Parliament and of 
the Council of 18 June 2009; and Commission Regulation (EU) 
No 712/2012 of 3 August 2012 

Adopted 
Directive 2010/84/EU of the European Parliament and of the 
Council of 15 December 2010. 

-40.0

-61.0

1234/2008 E: 
1.01.2009 
A: 1.01.2010 
712/2012 A: 
2.11.2012; 3.08.2013 
E: 1.01.2011 
A: 21.07.2012 

-267.4 
(initially 
estimated 
37.4)

Proposed. COM(2012) 369 of 17 July 2012 (2012/0192 
(COD)) for a Regulation on clinical trials on medicinal 
products for human use, and repealing Directive 
2001/20/EC) 

Simplifying Community procedures for the establishment of residue limits of pharmacologically 
active substances in foodstuffs of animal origin 

-0.1

Adopted 
Regulation (EC) No 470/2009 of the European Parliament and 
of  the  Council  laying  down  Community  procedures  for  the 
establishment  of  residue  limits  of  pharmacologically  active 
substances  in  foodstuffs  of  animal  origin,  repealing  Council 
(EEC)  No  2377/90  and  amending  Directive 
Regulation 
2001/82/EC of the European Parliament and of the Council and 
Regulation (EC) No 726/2004 of the European Parliament and of 
the Council 

E: 6.07.2009 

Streamlining the processing of the marketing authorisation for medicinal products for human use 

n/a

Covered by the simplifications of the procedure for 
‘Variations’ (item 1). 

Sectoral Total   

-368.5

30

 
 
 
 
 
 
 
 
 
 
 
9.     PUBLIC PROCUREMENT 

Public  Procurement  measures  have  led  to  an  additional  overall  reduction  of  EUR  156.6  million  compared  to  what  was  presented  in  the 
sectoral plan in 2009, thus amounting to a total reduction potential of EUR 216.6 million. This is due to the Commission proposal on public 
procurement COM(2011) 896, which cuts administrative burdens by requiring only the winning enterprise to submit tender documents. The 
negotiations in the Council and Parliament have not yet been finalised and thus the reduction potential indicated reflects only the Commission 
proposal. 

The legislative proposal recognises the potential of e-procurement as a way to reduce the administrative burden of the public procurement 
directives. E-procurement benefits businesses by reducing the time and costs associated with public-procurement procedures. Realising this 
potential requires alignment on common architectures and processes for organising e-procurement procedures, and the use of inter-operable 
systems  which  are  open  to  the  widest  possible  range  of  potential  tenderers.  The  Commission  is  therefore  proposing  that  all  MS  should  be 
capable of conducting their procurement electronically by 2016. 

A complete specification for a ‘Virtual Company Dossier’ (VCD) for use by businesses in public-procurement procedures has been developed 
in the Pan-European Public Procurement Online (PEPPOL) project, partially funded by the EU. This VCD specification provides the means 
for a tenderer to assemble, and for a procurer to access, all the data required to verify the evidence, certificates and attestations which may be 
requested in calls for tenders. This specification is publicly available and is already in use by a number of contracting authorities and 
economic operators across the EU. 
. 

31

 
 
 
 
 
Public Procurement 

Only by the winning enterprise need submit the documents demonstrating suitability as a tenderer in a 
procurement procedure  

Change in 
the level of 
AB 
(million 
EUR) 

-12.5 

-156.5 

State of play 

Adopted 
European Code of Best Practices Facilitating Access by SMEs to 
Public Procurement Contracts, SEC(2008) 2193 

Proposed 
Revision of EU public-procurement Directives (COM(2011) 896 of 
20 12 11. Negotiations in Council and Parliament are continuing in 
2012. 

Entry in force 
(E) 

Application (A) 

Transposition 
(T) 

E: 25/6/2008 

Creating a ‘Virtual Company Dossier’ for businesses in public-procurement procedures 

 Creating an online information database on business certificates for public-procurement procedures 

- 47.6 

n/a 

A full specification developed in a pilot project (PEPPOL VCD) has 
been available since May 2012  
E-CERTIS on-line database launched in Nov 2010 — about 70’000 
document downloads since launch  

A: 20/10/2010 

Sectoral Total 

-216.6  

32

 
 
 
 
 
 
 
 
 
 
 
 
10. STATISTICS 

Legislation in the area of statistics accounts only for a small part of the total administrative burden in the EU. Nevertheless, statistical surveys 
give rise to irritation and  the perceived burden of statistics is often higher than the real burden. This part of EU legislation is output orientated: 
it defines what a Member State has to deliver in terms of statistical information but not how this information has to be collected; each Member 
State decides how it will produce the necessary data. This means that effective reduction of administrative burdens relies to a large extent on the 
Member State. 

Under the Action Programme, 11 measures have been adopted with estimated savings for business equivalent to EUR 329.6 million; it has been 
proposed that two other measures be included in Member States’ programmes. 

As further major burden reduction could have an impact of the quality and relevance of the data, a strategy29 to build a modern and integrated 
statistical system was developed by the Commission to improve the efficiency of the production process of statistics. A new legal framework 
for the production of European statistics30 paved the way for re-engineering the whole architecture of the European Statistical System (ESS). 

In the area of business and trade statistics, this strategy is supported by the Programme for the Modernisation of European Enterprise and Trade 
Statistics (MEETS).31 Projects within MEETS include improving legal and technical aspects of data collection for Intrastat (including studying 
the possibility of introducing a single-flow reporting system), more efficient use of administrative data in business statistics and Intrastat and 
the linking of micro data from different surveys used in business and external-trade statistics. 

The  most  relevant  measures  for  business are  the  early  amendment  introduced  to  Regulation  EC)  638/2004  which  enabled  Member  States  to 
remove a large number of companies from Intrastat reporting obligations by decreasing the minimum coverage rate of intra-EU imports from 
97 %  to  95 %,  in  terms  of  value,  and  a  measure  adopted  in  2012  to  reduce  reporting  requirements  on  road  transport  (Regulation  (EU)  No 
70/2012). 

On the whole, results in this area must be considered positive. 

29  COM(2009) 404 on the production method of EU statistics: a vision for the next decade. 

30  Regulation (EC) No 223/2009 on European statistics and repealing Regulation (EC, Euratom) No 1101/2008 on the transmission of data subject to statistical confidentiality to the Statistical Office of the 
European  Communities,  Council  Regulation  (EC)  No  322/97  on  Community  Statistics,  and  Council  Decision  89/382/EEC,  Euratom  establishing  a  Committee  on  the  Statistical  Programmes  of  the 
European Communities, in force from 1 April 2009. 

31  Decision No 1297/2008/EC of the European Parliament and of the Council of 16 December 2008 on a Programme for the Modernisation of European Enterprise and Trade Statistics. 

33

 
 
 
 
 
 
 
 
                                                 
Statistics  

Change in 
the level of 
AB (million 
EUR) 

State of play 

 Reducing the number of respondents when compiling statistics on intra-EU trade 

- 1 34.3

Adopted. Regulation (EC) 638/2004 of 31 March 2004 

 Reducing the administrative burden on businesses by supporting MS in making better   
use of administrative data and introducing enhanced and more efficient e-Gov solutions 
to collect data  

Updating the statistics on fruit trees in line with today’s needs 

Reducing reporting obligations on pig livestock and meat 

Reducing reporting obligations on bovine livestock and meat 

n/a

n/a

- 3.7

 - 1.2

Reducing reporting requirements on industrial production in the EU 

- 101.6

Completed. Decision No 1297/2008/EC of the EP and of the Council of 16 
December 2008 on the MEETS Programme, implemented by annual work 
programme 2009-2012 

Adopted. Regulation (EU) No 1337/2011 of 13 December 2011 concerning 
European statistics on permanent crops and repealing Council Regulation 
(EEC) No 357/79 and Directive 2001/109/EC 

Adopted. Regulation (EC) No 1165/2008 of 19 November 2008 

Adopted. Regulation (EC) No 1165/2008 of 19 November 2008 

Adopted 
Annual Prodcom lists implementing Council Regulation 3924/91 (e.g. 
Commission Regulation (EC) No 36/2009 of 11 July 2008) 

Reducing reporting requirements for Structural Business Statistics 

- 19.0

Adopted. Regulation (EC) 295/2008 of 11 March 2008 

Reducing the administrative burden for businesses stemming from Structural Business 
Statistics surveys 

Discussions 
on going n/a

Proposed to Member States, 
 to be implemented as part of the Framework Regulation Integrating 
Business Statistics.  

 Reducing reporting requirements for statistics on Information and Communication   
Technologies 

- 3.7

Adopted. Commission Regulation (EC) No 847/2007 of 18 July 2007 
Commission Regulation (EU) No 937/2011 of 21 September 2011 

concerning Community Statistics on the Information Society 

Reducing reporting requirements for producing Short-Term Statistics 

-64.8 

Adopted. Regulation 1158/2005 of 6 July 2005 Initial estimated BR 64.8 

Reducing reporting requirements for statistics on tourism 

Reducing reporting requirements on road transport 

Simplifying the legislation relating to statistics on sea transport 

Sectoral Total 

Adopted. Regulation (EU) No 692/2011 of the EP and Council 6.07.11 
concerning European statistics on tourism and repealing Council Directive 
95/57/EC 

Adopted. Regulation (EU) No 70/2012 of 18 January 2012 on statistical 
returns in respect of the carriage of goods by road 
Adopted. Commission Decision of 14 April 2010 amending Directive 
2009/42/EC of the European Parliament and Council 

-1.3

n/a

n/a

 -329.6

34

Entry in force (E) 
Application (A) 
Transposition (T) 

E: 27.04.2004 
A: 1.01.2005 

E: 21.12.2008 
A:1.01.2009 

E: 21.12.2008 
A:1.01.2009 

E: latest 11.02.2009, 

A: 1.01.2008, 
1.01.2007, 
1.01.2006.1.01.2005 

E/A: 29.04.2008 

E/A: 8.08.2007 

E/A: 11.08.2005 

E/A: 11.08.2011 

E/A: 08.02.2012 

E/A: 16.4.2010 

 
 
 
 
 
 
 
 
 
 
11. TAXATION AND CUSTOMS 

Taxation  and  Customs  legislation  is  considered  the  most  important  priority  area  in  terms  of  administrative  costs  and  burdens  imposed  on 
businesses. Under the Action Programme, six measures have been adopted and one is pending. 

The  Invoicing  Directive  adopted  in  2010  will  take  effect  from  1  January  2013.  The  Directive  creates  equal  treatment  between  paper  and  e-
invoices  and  no  longer  allows  Member  States  to  prescribe  a  certain  technology  for  e-invoices.  It  is  estimated  that  if  all  businesses  adopted  e-
invoicing savings would amount to EUR 18 billion in the medium term, which represents a 26 % reduction in VAT administrative burdens. DG 
TAXUD  has  issued  Explanatory  Notes  on  invoicing  (published  on  the  Commission's  website  on  5  October  2011)  which  should  help  inform 
businesses of the changes and encourage Member States to implement provisions in a consistent manner. 

The Refund Directive provides for electronic submission in the Member State where the business is established of VAT refund claims from other 
Member States. Its administrative burden reduction potential is estimated at EUR 447 million (1 % burden reduction). 

The VAT Package established a general rule concerning  the place of supply for B2B services. From 2015, the place of supply for B2C supplies 
of telecoms, broadcasting and e-services will be where the customer belongs, thus ending VAT-rate distortions. With the mini-One Stop Shop, 
VAT on B2C telecoms, broadcasting and e-services due in Member States where the supplier is not established can be declared and paid in the 
Member State of the supplier. Its burden-reduction potential is estimated at EUR 463 million (1 %). 

The Modernised Customs Code and the e-Customs decision aim at achieving a major change in the way economic operators accomplish customs 
formalities  and  Customs  perform  controls.  It  implies  reducing  significantly  administrative  burden  in  customs  activities;  developing  a  fully 
electronic customs environment based on streamlined and more unified rules; and the setting up of interoperable electronic systems. However, the 
application of the Modernised Customs Code, initially planned in June 2013, will be postponed through a recast of the regulation aiming to align 
it to the Treaty on the functioning of the EU, to introduce limited corrections, and to “phase in” the extensive IT developments involved in the 
application of the new legislation. The proposed new date of application is 1January 2015, but it will depend on the outcome of the on-going 
legislative procedure. 

35

 
 
 
 
 
 
 
 
 
 
Taxation and Customs 

Suppressing additional requirements on invoices and enabling wider use of electronic 
invoicing 

Suppressing, in the VAT refund procedure, the obligation to fill out paper forms in the 
language of the Member State of refund 

Change in the 
level of AB 
(million EUR) 

- 18 803.8

- 447.0

State of play 

Adopted 
Council Directive 2010/45/EU of 13 July 2010  

Adopted 
Council Directive 2008/9/EC of 12 February 2008  

Simplifying the rules concerning the place of supply of services (mini-One Stop Shop) 

- 463.0 

Adopted Council Directive 2008/8/EC of 12 February 2008  

Entry in force (E) 
Application (A) 
Transposition (T) 

E: 11.08.2010 
T: 1.01.2013 
E: 20.02.2008 
T: 1.01.2010 

E: 20.02.2008 

Setting up a One Stop Shop and increasing thresholds of special schemes for SMEs and 
distance sales 

Adapting the frequency of the recapitulative statements on cross-border transactions and 
switching to an electronic procedure 

Modernising customs procedure and especially the switch to a fully electronic customs 
procedure (legislative proposal) 

Simplifying Regular Shipping Services 

- 4 397.4

+203.9

- 2 427.0

Proposed.  
CNS/2004/0261 — Proposal for a Council Directive COM(2004) 
728 of 29 October 2004. Awaiting Council Decision  
Adopted 

Council Directive 2008/117/EC of 16 December 2008  
Adopted 
Regulation (EC) No 450/2008 of 23 April 2008 is however under 
recast (to revise and align with the Treaty of Lisbon). Application to 
be postponed to 1 January 2015 at the latest (to be confirmed). 

; Decision No 70/2008/EC l of 15 January 2008  

n/a

Adopted 
Commission Regulation (EU) No 177/2010 of 2 March 2010  

E: 21.02.2009 
T: 1.01.2010 
450/2008:E: 24.06.2008   
A: postponed 
70/2008: E 16.02.2008 

E 10.03.2010 
Points 2 and 3 of Art. 
1A 01.01.2012 

Sectoral Total 

-26 334.3

36

 
 
 
 
 
 
12. TRANSPORT 

The process of simplification and modernisation which had started even before the Action Programme in 2007 has been carried further in the Strategy 
for a Single European Transport Area initiated in 2010. Over the last few years, the administrative burden due to existing EU transport legislation has 
been reduced by more than half a billion euros per year. 

The bulk of the reduction was achieved by updating and simplifying the rules on tachographs for road transport, for instance reducing the time spent 
on registering and transmitting information through the introduction of digital tachographs and by simplifying the use of digital tachographs. These 
measures  will  benefit  SMEs  in  particular  because  a  large  majority  of  road-transport  companies  are  SMEs.  A  further  big  package  of  tachograph-
simplification measures suggested by the Commission in 2011 is still under discussion in the European Parliament and Council. It would exempt craft 
businesses from tachograph requirements for journeys shorter than 100 km, facilitate the remote downloading of data from tachographs and integrate 
the  current  digital  tachographs  into  onboard  computers.  This  could  reduce  the  administrative  burden  by  another  half  billion  euros.  However,  the 
Council in its general approach of June 2012 and the European Parliament in its first reading in July 2012 did not include the Commission’s proposal 
to merge the driver card and driver licence, a measure which could have saved another EUR 100 million.  

Other considerable burden reductions were achieved in the area of transport-tariff notifications and the formalities for short sea shipping. The latter is 
fully in line with the Commission’s objective of making non-road transport (in particular rail freight, inland water transport and short sea shipping) in 
the EU more attractive and so increase the environmental sustainability of the transport sector.   

All legislative initiatives adopted by the European Parliament and the Council in the framework of the transport sectoral programme have already 
entered into force and are applicable. The Commission encourages the co-legislators to agree on the further tachograph package proposed in 2011 as 
soon as possible, so that a further 400 to 500 million euros of unnecessary administrative burden can be cut. 

37

 
 
 
 
 
 
 
                                                              
 
                                                                     
Transport  

State of play 

Change in 
level of AB 
(million 
EUR) 

Reducing time spent on registering and transmitting information on road transport through the 
introduction of digital tachographs 

Simplifying the use of digital tachographs and improving the ‘form of attestation" covering the 
driver´s  activities’   

- 286.6

Adopted 
Regulation (EC) No 561/2006 of the European Parliament and of the 

Council of 15 March 2006 

- 234.5

Adopted 
Commission Regulation 1266/2009 of 16 Dec. 2009 and Commission 

Decision of 14 Dec. 2009 

Exempting small craft businesses from tachograph requirement for short journeys 

Facilitating remote downloading of data from the tachograph and driver card 

 Integrating the current digital tachographs into onboard computers 

-415.0  
(initial 
estimated 
reduction  
-515)

See point 3

Making broader national use of all exception categories defined in the EU tachograph regulation 

See point 3

Facilitating cross-acceptance of rolling-stock  

- 0.4

Included in the Commission proposal for amending Regulation 

3821/85 of 19 July 2011 (estimated reduction -52.8) 

This measure is included in the Commission proposal for amending 
Regulation 3821/85 of 19 July 2011(estimated reduction -34.5) 

Partly included in the Commission proposal for amending Regulation 

3821/85 of 19 July 2011under ‘ITS standard interface’ 

Partly included in the Commission proposal for amending Regulation 

3821/85 of 19 July 2011 

Adopted. Directive 2008/57/EC of the EP and Council of 17 June 

2008 

Simplifying obligations for road haulage and road passenger transport 

- 34.9

Adopted 
Regulation 1071/2009 of 21/10/2009 and Regulation 1072/2009 of 

21/10/2009 

Entry in force (E) 
Application (A) 
Transposition (T) 

E 11.04.2007 except: 
10(5), 26(3), (4) & 27 
E 01.05. 2006 

E 11.01.11 ; A 1.10.11 
(3.1, 3.8, 3.9, 3.11, 
3.20, 8,.2, 9.2, 12.3, 
12.4 and 13 of the 
Annex A 1.10. 12 

E 18.07.2008 
A 19.07.2008 

1071/2009:    
E: 23.11.2010 
A: 24.11.2010 
1072/2009 
E: 12.12.2009 
A: 4. 12. 2011 
(exc. Art 8.9 A 
14.05.2010) 

Simplifying EU legislation on the inland transport of dangerous goods 

Abolishing the notification of transport tariffs and alleviating the obligation to keep documentary 
evidence on board 

Reducing formalities in Short Sea Shipping 

Sectoral Total 

- 2.2

- 114.7

- 75.0

- 1 163.3

38

Adopted Directive 2008/68/EC of the Eur. Parliament and of the 

E: 20.10.2008 

Council of 24 September 2008 

Adopted 
Council Regulation (EC) No 569/2008 of 12 June 2008 

E: 20.06.2008 
A: 11.07.2008 

Adopted Directive 2010/65/EU of the European parliament and the 
Council of 20 October 2010 

:E 29.10.2010 
A: 19.05.2012 

 
 
 
 
 
 
 
 
 
 
13.  WORKING ENVIRONMENT / EMPLOYMENT RELATIONS 

The  objective  of  the  Action  Programme  in  the  working  environment/employment  relations  sector  was  to  cut  unnecessary  burdens  on 
businesses, keeping in mind that the right to working conditions which respect workers’ health, safety and dignity and the right to information 
and  consultation  within  the  undertaking  are  fundamental  rights  of  every  worker  in  the  EU  as  recognised  by  the  ‘Charter  of  Fundamental 
Rights  of  the  European  Union’.  In  other  words,  the  aim  was  to  examine  what  burden  could  be  suppressed  without  compromising  the 
achievements already attained in terms of levels of protection and the reduction of occupational accidents and illnesses. 

The  Sectoral  Reduction  Plan  for  the  working  environment/employment  relations  sector  has  encountered  a  number  of  difficulties  in  the 
implementation  process.  Several  stakeholders  in  the  various  interest  groups  of  the  Advisory  Committee  on  Safety  and  Health  at  Work 
(governments,  employers  and  workers)  have  been  very  critical  of  the  Action  Programme  as  it  focuses  mainly  on  costs  and  quantification, 
which has proven to be a difficult concept to apply in the area of occupational health and safety. The risk of focusing on the costs and the 
quantitative aspects of EU measures, neglecting the benefits and qualitative aspects, has been pointed out. Another issue is the fact that in the 
area of health and safety it is often difficult to obtain data on the situation in SMEs and even more so in the case of micro enterprises. 

To meet the targets of the Action Programme, a number of initiatives have been taken that mainly took the form of guidelines or tools that 
sought to facilitate compliance by enterprises with obligations set by legislation (for details, see the table below). 

39

 
 
 
 
 
Working Environment/Employment Relations  

Improving the guidance for businesses on the health and safety of workers 

Easing the drafting of risk assessments on health and safety in businesses 

Making labour inspection visits more efficient  

Improving the guidance for construction-site enterprises 

Change in the level of 
AB (million EUR) 

- 92.5

(reduction of costs 
resulting from the 
Common Principles 
still needs to be 
assessed) 

State of play 

Entry in force 
(E)Application 
(A) 
Transposition 
(T) 

Adopted 
The European Agency for Safety and Health at Work, ‘Guidance on 
Risk Assessment — tool & check list’ (2006, 2007); ‘SLIC Common 
Principles for Labour Inspection in relation to Health and Safety in the 
Workplace’ (revised 2006). 

n/a 

Adopted 
The European Agency for Safety and Health at Work launched OiRA 
(Online interactive Risk Assessment Tool) on 13 September 2011 

n/a (still to be 
assessed)

Achieved through other means 
The measure has been achieved through the methods for sharing 
knowledge and good practice of the ‘Senior Labour Inspectors’ 
Committee’ (SLIC), as well as their Common Principles for Labour 
Inspection. These principles set a benchmark for all EU labour 
inspection services as they provide a framework for the organisation of a 
modern labour inspection system The reduction potential of this has not 
yet been estimated. 

 - 140.0

Adopted 
Guidance document was published in English in March 2011 (other 
languages to follow). 

Improving the efficiency of regulations concerning the European Works Councils 

-0.02

Sectoral Total 

- 232.5

Adopted 
Directive 2009/38/EC of the European Parliament and of the Council 
of 6 May 2009 on the establishment of a European Works Council or a 
procedure in Community-scale undertakings and Community-scale 
groups of undertakings for the purposes of informing and consulting 
employees (recast) 

E 16.05.2009 
A 6.06.2009 
T 05.06.2011 

40