COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT Accompanying the document PRODUCT SAFETY AND MARKET SURVEILLANCE PACKAGE A proposal for a Regulation of the European Parliament and the Council on consumer product safety and a proposal for a Regulation of the European Parliament and of the Council on market surveillance for products
Date: 2013-02-13
Institutions: European Commission
Subjects: customs inspection, economic growth, environmental protection, exchange of information, market supervision, marketing standard, product safety, single market

EUROPEAN 
COMMISSION 

Brussels, 13.2.2013  
SWD(2013) 34 final 

Product Safety and Market Surveillance Package 

COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

PRODUCT SAFETY AND MARKET SURVEILLANCE PACKAGE 

A proposal for a Regulation of the European Parliament and the Council on consumer 
product safety and a proposal for a Regulation of the European Parliament and of the 
Council on market surveillance for products 

{COM(2013) 75 final} 
{COM(2013) 78 final} 
{SWD(2013) 33 final}

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   EN 

 
 
 
 
 
  
 
COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

PRODUCT SAFETY AND MARKET SURVEILLANCE PACKAGE 

A proposal for a Regulation of the European Parliament and the Council on consumer 
product safety and a proposal for a Regulation of the European Parliament and of the 
Council on market surveillance for products 

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1. 

SUMMARY OF THE PROBLEM DESCRIPTION, SUBSIDIARITY AND OBJECTIVES 

1.1. 

Policy context 

The free movement of safe and compliant products is one of the cornerstones of the 
European  Union.  This  principle  constitutes  an  important  pillar  of  the  single  market 
and  allows  consumers  and  enterprises  to  purchase  or  sell  products  in  another 
Member State. 

The  impact  assessment  concerns  manufactured  non-food  products  which  are  either 
subject to EU harmonisation rules for specific categories of products, or to Directive 
2001/95/EC  on  general  product  safety  (the  "General  Product  Safety  Directive"), 
applicable to consumer products. This set of EU rules has put in place product safety 
requirements for a large number of products, while the free movement provisions of 
the  Treaty  and  the  mutual  recognition  principle  govern  the  remaining  product 
categories. 

Effective  market  surveillance  should  enable  unsafe,  or  otherwise  harmful,  products 
to  be  identified  and  kept  or  taken  off  the  market  and  allow  for  the  penalisation  of 
unscrupulous or even criminal operators. It should also act as a powerful deterrent. In 
a  single  market  in  which  products  circulate  freely,  market  surveillance  needs  to  be 
highly coordinated and capable of reacting rapidly over a huge area.  

However,  market  surveillance  has  not  kept  pace  with  developments  in  the  Union's 
regulatory  framework.  Advances  have  been  made  over  the  last  decade  with  the 
implementation of the General Product Safety Directive, which had to be transposed 
by  15  January  2004,  and  with  the  coming  into  application  of  Regulation  (EC)  No 
765/2008  setting  out  the  requirements  for  accreditation  and  market  surveillance 
relating  to  the  marketing  of  products  on  1  January  2010.  These  legal  instruments, 
for  certain  sector-specific  Union 
rules 
together  with  market  surveillance 
harmonisation  legislation,  provide  today  an  EU  legal  basis  for  the  market 
surveillance of all consumer products (both harmonised and non-harmonised) and for 
all  harmonised  products  (for  consumers  and  professional  users).  However,  the 
market  surveillance rules  are  fragmented and spread over different pieces of Union 
legislation  (Regulation  765/2008,  the  General  Product  Safety  Directive  and  sector-
specific Union harmonisation legislation) which creates confusion on the part of both 
operators and national authorities.  

Overall architecture of Union product safety and compliance rules 

Products 

Consumer 

Professional 

Harmonised 

Sector specific Directives 
and Regulations and the 
General Product Safety 
Directive 

Non-harmonised 

General Product Safety 
Directive 

Sector specific Directives and 
Regulations 

National product safety rules 
under the 'Mutual Recognition 
Regulation' 

Article 34-36 TFEU 

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This  initiative  is  one  of  the  important  actions  of  the  European  Consumer  Agenda1 
and the Single Market Act II2, both adopted by the Commission in 2012. 

1.2. 

Problem definition - Unsafe and non-compliant products in the single market 

The internal market for products is enormous. In 2010, intra-EU trade of harmonised 
and  non-harmonised  consumer  products  amounted  to  almost  EUR  1  trillion.  The 
value of harmonised sectors (including both consumer and professional goods) in the 
EU-27 is estimated to be no less than EUR 2,100 billion. 

An  internal  EU  market  should  be  a  place  where  safe  products  circulate  freely. 
Effective  application  of  the  free  movement  principle  in  the  product  safety  area 
requires that the assessment of whether a product is safe or not - and thus, whether it 
should  stay  on  the  market  or  not  -  be  performed  in  the  same  way  in  all  Member 
States.  Free  circulation  of  safe  products  should  be  promoted  and  unsafe  products 
effectively tracked down and removed from the single EU market.  

1.2.1.  Problem 1: Difficulties in compliance with EU product safety requirements 

Compliance with the EU product safety requirements is often difficult for economic 
operators  since,  in  general,  requirements  in  the  area  of  so-called  non-harmonised 
products  are  not  consistent  with  those  in  the  harmonised  area.  Furthermore,  in  the 
non-harmonised  area, the EU product safety  requirements  are  often  ambiguous  and 
lack  detailed  benchmarks  for  safety  evaluation,  while,  in  the  harmonised  area, 
different and overlapping layers of product safety undermine legal certainty. 

Unsafe and non-compliant products not only pose risks to consumers and other users, 
they  also  have  important  economic  consequences:  they  lead  to  unfair  competition. 
Operators  not  adhering  to  the  rules  can  make  significant  savings  on  compliance 
costs.  They  can  consequently  offer  their  products  at  lower  prices  than  their 
competitors  who  respect  the  law.  In  sectors  where  there  is  tough  competition  from 
imported, low-price products, European industry is at a disadvantage. The situation 
therefore  “punishes”  the  law-abiding  manufacturer,  as  compliance  becomes  a 
“competitive disadvantage”. 

With  the  intensification  of  trade  globalisation,  the  problem  of  unsafe  and  non-
compliant products concerns increasingly (but not exclusively) those goods imported 
from third countries.  

1.2.2.  Problem 2: Market surveillance for products within the single market is fragmented  

Despite the widespread harmonisation of safety standards and other requirements for 
products (e.g. environmental) across the Union, and the fact that many products are 
regularly  marketed  in  more  than  one  Member  State,  the  Single  Market  is  regulated 
through 27 separate systems of enforcement. 

A  major  reason  for  the  considerable  number  of  non-compliant  products  on  the 
market is that market surveillance does not operate effectively within the European 
Union. The principal causes of ineffective and inefficient market surveillance on the 
single  EU  market  are:  weak  coordination  of  the  market  surveillance  authorities  of 
different  Member  States,  poor  functioning  of  EU  procedures  for  the  exchange  of 
information  on  product  risks  and  inconsistent  enforcement  of  EU-wide  product 
safety action. 

1 
2 

COM(2012)225 final. 
COM(2012)573 final. 

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Where action is needed beyond the border, authorities must rely on their colleagues 
in  other  Member  States.  However,  in  contrast  to  other  areas,  for  example  the 
Consumer Protection Cooperation Regulation or the Services Directive, in the area of 
product  safety,  market  surveillance  authorities  do  not  benefit  from  procedures  for 
effective  cross-border  enforcement.  Thus,  significant  resources  are  wasted  and 
important synergies are lost. 

1.3. 

EU right to act 

The single market for products is a key achievement of the European Union. Yet the 
elimination  of  national  barriers  for  consumer  and  other  products  offers  plenty  of 
opportunities to less scrupulous traders who do not apply the consumer safety rules 
or refuse to implement the EU legislation on products. The EU therefore has the right 
to act on the basis of Article 114 TFEU in order to ensure the proper functioning of 
the  single  market  for  consumer  products  and  to  increase  the  efficiency  of  cross-
border market surveillance. Article 168(1) and Article 169(1) TFEU complement this 
right to act. The first stipulates that a high level of human health protection shall be 
ensured in the definition and implementation of all Union policies and activities; the 
latter  provides  that  in  order  to  promote  the  interests  of  consumers  and  to  ensure  a 
high  level  of  consumer  protection,  the  Union  shall,  amongst  others,  contribute  to 
protecting the health, safety and economic interests of consumers. 

Despite  the  existence  of  the  single  EU  market,  the  enforcement  of  product  safety 
requirements is the responsibility of the Member States. According to the principle of 
subsidiarity actions against products posing risks are carried out by Member States. 
However,  the  way  in  which  market  surveillance  is  performed  and  organised 
significantly varies from one Member State to another. 

Differences  in  the  organisation  of  market  surveillance  at  national  level  cause 
problems  when  viewed  in  a  framework  where  controls  at  national  borders  have 
practically disappeared. To ensure that only safe and compliant products circulate on 
the  market,  every  Member  State  depends  on  the  market  surveillance  of  its 
neighbours. Consequently, weaknesses in the organisation of market surveillance in 
one Member State can seriously undermine the efforts taken by other Member States. 
This justifies EU action to address this issue. 

1.4. 

Objectives 

1.4.1.  General policy objectives  

The general  objective  of this initiative is to improve the functioning of the internal 
market  and  to  achieve  a  high  level  of  protection  of  consumers  and  other  product 
users  through  the  reduction  of  the  number  of  unsafe  or  non-compliant  products  on 
the market. 

1.4.2. 

Specific policy objectives  

• 

• 

• 

Consolidation and reinforcement of EU product safety requirements; 

Better  coordination  and  increased  effectiveness  of  market  surveillance 
activities on the single EU market for goods; 

Simplification of the EU legislative framework. 

1.4.3.  Operational policy objectives  

• 

Ensuring consistency of EU product safety requirements; 

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• 

• 

Reducing  ambiguity  of  product  safety  requirements  for  non-harmonised 
consumer products; 

Reinforcing EU cooperation mechanisms;  

•  Making EU product safety procedures more coherent;  

•  More effective EU-wide product safety action. 

2. 

POLICY OPTIONS 

The  presented  policy  options  were  established  by  the  Commission  in  close 
cooperation  with  all  groups  of  stakeholders.  Certain  policy  options  were,  however, 
discarded  at  an  early  stage,  including  regulating  the  safety  of  services,  adopting 
product  safety  requirements  for  non-harmonised  professional  products3,  adopting 
specific  rules  concerning  products  marketed  via  the  internet  and  abolishing  the 
general requirement that all consumer products must be safe. 

2.1. 

Specific  policy  objective  1:  Consolidation  and  reinforcement  of  EU  product 
safety rules 

2.1.1.  Operational  policy  objective:  Ensuring  consistency  of  EU  product  safety 

requirements 

Option  1.A  –  Baseline  scenario:  Keeping  differences  between  consumer  product 
safety requirements and harmonised product safety requirements 

Option  1.B  –  Aligning  consumer  product  safety  requirements  with  harmonised 
product safety requirements 

Option 1.C – Consumer product safety requirements to be defined less strictly then 
harmonised product safety requirements 

Option 1.D – Consumer product safety requirements to be defined more strictly than 
harmonised product safety requirements 

2.1.2.  Operational policy objective: Reducing ambiguity of product safety requirements for 

non-harmonised consumer products 

Option 2.A – Baseline scenario: Existence of pre-standardisation procedures for non-
harmonised  consumer  products  that  are  not  aligned  with  the  new  European 
standardisation regime  

Option 2.B – Direct applicability of ad-hoc safety requirements  

Option  2.C  –  Abolition  of  formal  adoption  of  the  non-binding  ad-hoc  safety 
requirements (alignment with the new European standardisation regime) 

Option 2.D – Fast-track procedure for adopting already existing European standards 
without mandates 

3 

Professional products mean those products which are only used by professionals and not by consumers, 
such as industrial machines, raw materials or semi-finished products. 

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2.2. 

Specific  policy  objective  2:  Better  coordination  and  increased  effectiveness  of 
market surveillance activities on the single EU market for goods  

2.2.1.  Operational policy objective: Reinforcing EU cooperation mechanisms 

Option 3.A – Baseline scenario: keep status quo based mostly on  voluntary market 
surveillance coordination 

Option 3.B – Coordination of cross-border enforcement of measures resulting from 
"on the-field" market surveillance 

Option 3.C – Overall rationalisation of coordination of market surveillance activities  

Option  3.D  –  Centralisation  of  EU  market  surveillance  in  the  area  of  non-food 
products (EU Market surveillance agency) 

2.2.2.  Operational policy objective: Making EU product safety procedures more coherent 

Option  4.A  –  Baseline  scenario:  Keeping  the  parallel  notifications  under  RAPEX 
procedure and safeguard procedure 

Option 4.B – Simplification of the RAPEX procedure 

Option  4.C  –  Simplification  of  the  RAPEX  procedure  and  streamlining  of  that 
procedure with the safeguard procedure 

2.2.3.  Operational policy objective: More effective EU-wide product safety action 

Option  5.A  –  Baseline  scenario:  Keeping  EU-wide  product  safety  measures 
indirectly applicable for a period of one year only 

Option  5.B  –  Extension  of  the  scope  of  EU-wide  product  safety  measures  to 
harmonised non-consumer products 

Option 5.C - Making EU-wide product safety measures directly applicable 

Option 5.D – Removal of the limited validity of EU-wide product safety measures 

Option 5.E – Combination of options 5.B, 5.C and 5.D 

2.3. 

Specific policy objective 3: Simplification of the EU legislative framework 

The  two  other  specific  policy  objectives  are  complemented  by  the  objective  to 
simplify the legislative framework regarding product safety and market surveillance. 
The simplification consists in (1) merging the market surveillance rules of different 
pieces  of  legislation  into  a  single  horizontal  market  surveillance  regulation,  (2)  the 
transformation of the revised General Product Safety Directive into a regulation and 
(3)  the  repeal  of  Directive  87/357/EEC  and  the  transfer  of  its  concept,  that  food-
imitating  products  must  not  endanger  the  health  and  safety  of  consumers,  into  the 
new  Consumer  Product  Safety  Regulation  replacing  the  General  Product  Safety 
Directive. 

3. 

ANALYSIS OF IMPACTS AND COMPARISON OF ENVISAGED POLICY OPTIONS 

Due  to  the  absence  of  reliable  statistics  or  even  estimates  regarding  the  number  of 
unsafe  and  non-harmonised  consumer  products,  and  the  number  of  non-compliant 
harmonised products, the assessment of the options is mainly qualitative. 

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3.1. 

Specific  policy  objective  1:  Consolidation  and  reinforcement  of  EU  product 
safety rules 

3.1.1.  Operational  policy  objective:  Ensuring  consistency  of  EU  product  safety 

requirements 

In  order  to  provide  consumers  and  other  users  with  an  equally  high  level  of 
protection against unsafe products throughout the EU, as well as to prevent barriers 
on the EU internal market, the EU product safety rules must be clear and compatible 
across different product sectors. 

Comparison of the options against the baseline scenario 

Options 

Issues 

Safety of consumers 

Legal clarity and 
certainty 
Market surveillance 
effectiveness and 
efficiency 

Option 1.B 

Option 1.C  

Option 1.D  

++ 

++ 

++ 

- 

+ 

-- 

++ 

- 

+ 

Comparison of the change in costs for economic operators compared to the baseline scenario 

Options 

Cost types 
Information 
costs/legal costs 

research 

Option 1.B 

Option 1.C  

Option 1.D  

Decrease 

Slight decrease 

0 

Production costs 

0* 

0 

Increase 

* slight increase except for a very small group of producers 

Preferred option:  Option  1.B  -  Alignment  of  consumer product safety  requirements 
with harmonised product safety requirements 

3.1.2.  Operational policy objective: Reducing ambiguity of product safety requirements for 

non-harmonised consumer products 

Policy  options  aimed  at  reducing  the  ambiguity  of  product  safety  requirements  for 
non-harmonised consumer products are assessed according to the ease in which they 
can lead to the development of European standards under the general product safety 
rules,  the  coherence  of  procedures  with  the  general  regime  under  the  new 
the  costs  for  public 
Standardisation  Regulation  (EU)  No  1025/2012  and 
administration. 

In terms of timeliness and reduced administrative burden, Options 2.C and 2.D. can 
both be considered to be superior to Option 2.B. Between Options 2.C and 2.D the 
criterion of coherence of procedures for requesting standards favours Option 2.C to 
Option 2.D. 

Comparison of options against the pre-defined criteria 

Criteria 

Rapidity 

Coherence 

Options 

Option 2.B 

Option 2.C  

Option 2.D  

- 

- 

+ 

+ 

++ 

- 

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Costs for 
authorities 
(including national 
authorities and EU) 

Unchanged 

Decrease 

Decrease 

Preferred option: Option 2.C – Abolition of formal adoption of the non-binding ad-
hoc safety requirements (alignment with the new European standardisation regime) 

3.2. 

Specific  policy  objective  2:  Better  coordination  and  the  increased  effectiveness 
of market surveillance activities on the single EU market for goods  

3.2.1.  Operational policy objective: Reinforcing EU cooperation mechanisms 

The impact of the different policy options is assessed and compared according to the 
criteria of effectiveness and efficiency of market surveillance in accordance with the 
resources  available  and  the  aim  of  ensuring  seamless  market  surveillance  for  the 
single EU market. 

In contrast to Options 3.B and 3.C, which aim to do more with the same amount of 
resources, Option 3.D would likely lead to higher benefits for the single EU market 
and  for  consumer  safety  but  it  would  require  substantial  investment  to  build  a 
centralised  EU  framework  for  market  surveillance  in  the  area  of  non-food  product 
safety.  However,  even  under  option  3.D,  only  certain  activities  (such  as  system 
inspections,  peer  reviews  of  the  quality  of  the  functioning  of  market  surveillance 
authorities  in  Member  States,  monitoring  of  the  coordination  between  enforcement 
authorities  and  national  RAPEX  contact  points),  could  be  moved  to  the  central  EU 
level.  By  contrast,  core  market  surveillance  actions,  such  as  on-site  inspection  of 
manufacturers,  importers  and  distributors,  testing  of  products,  risk  assessment  and 
risk management would have to stay at national level. 

Thus  Option  3.C  seems  to  be  the  most  appropriate  for  fulfilling  the  objective  of 
achieving a coherent and seamless framework for decentralised market surveillance 
for the single EU market. In terms of benefits, it is superior to Option 3.B, although 
potentially  inferior  to  Option  3.D;  in  terms  of  costs  it  is  equal  to  Option  3.B,  but 
superior to Option 3.D. 

Comparison of the options against the baseline scenario 

Options 

Issues 

Safety 
consumers/users 

of 

Competitiveness 
compliant 
operators 

of 
economic 

Effectiveness 
market surveillance 

of 

Efficiency  of  market 
surveillance 

Potential 
harmonisation 
enforcement 
approaches  on 

of 
of 

the 

Option 3.B 

Option 3.C 

Option 3.D 

+ 

+ 

+ 

+ 

+ 

++ 

++ 

++ 

++ 

++ 

++ 

++ 

+++ 

+ 

+++ 

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internal market 

Comparison of the change in costs for public authorities compared to the baseline scenario 

Options 

Cost types 

Costs for national 
market surveillance 
authorities 

Option 3.B 

Option 3.C 

Option 3.D 

Slight increase 

Slight increase 

Increase 

Costs for the EU 

Slight increase 

Slight increase 

High increase 

Preferred  option:  Option  3.C  –  Rationalisation  of  the  overall  coordination  of 
decentralised market surveillance on the single EU market. 

3.2.2.  Operational policy objective: Making EU product safety procedures more coherent 

The options are assessed and compared according to the criteria of effectiveness in 
tracking  dangerous  products  and  the  efficiency  of  managing  the  EU  notification 
procedures for Member States and the Commission. 

Option  4.A  would  not  eliminate  or  mitigate  any  shortcomings  of  the  existing  EU 
notification  procedures  and  is  therefore  not  appropriate  to  achieve  the  pursued 
objective.  Options  4.B  and  4.C  would  both  offer  effective  means  to  track  unsafe 
products on the internal EU market since with both options the RAPEX notification 
conditions would be simplified and the objective of a better functioning of the alert 
procedures for dangerous non-food products would be achieved. Option 4.C appears 
to  be  superior  to  Option  4.B  because  it  would  have  the  additional  advantage  of 
streamlining various procedures, thus making their application more user-friendly. 

Comparison of the change compared to the baseline scenario in relation to public authorities 

Option 4.B 

Option 4.C  

Increase 

Increase 

Options 

Criteria 

Effectiveness in 
tracking down 
unsafe products 

Costs for national 
market surveillance 
authorities 

Slight decrease 

Costs for the EU 

0 

Decrease 

Decrease 

Preferred  option:  Option  4.C  –  Simplification  of  the  RAPEX  procedure  and 
streamlining of that procedure with the safeguard procedure 

3.2.3.  Operational policy objective: More effective EU-wide product safety action 

To fulfil the objective of making action at EU-level against products presenting a risk 
more  effective,  especially  in  situations  where  individual  action  by  Member  States 
fails to provide a coherent response, EU measures concerning product safety need to 
be  timely,  predictable  and  effectively  implemented  by  national  market  surveillance 
authorities. 

Making  EU  product  safety  measures  directly  applicable  -  combined  with  the 
possibility of adopting these measures either for a period specified on a case-by-case 

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basis  or  without  limitation  of  their  validity  -  is  the  best  way  to  achieve  a  timely 
response  to  safety  issues  that  is  both  effective  and  predictable.  EU  product  safety 
measures  could  be  made  directly  applicable  so  that  market  surveillance  authorities 
could  take  enforcement  measures  without  any  additional  delays  or  uncertainties 
related to the transposition into national legislation by each individual Member State.  

Comparison of options 5.B, 5.C and 5.D against pre-defined criteria 

Options 

Criteria 

Rapidity 

Predictability 

Effective 
application 

Option 5.B 

Option 5.C  

Option 5.D  

Option 5.E 

0 

0 

+ 

+ 

0 

++ 

+ 

+ 

0 

++ 

++ 

+++ 

Preferred option: Option 5.E – Combination of options 5.B, 5.C and 5.D 

4. 

FORM OF THE LEGISLATIVE INSTRUMENTS 

It  is  suggested  that  the  selected  options  are  reflected  in  two  different  legal 
instruments: 

Problem  1  would  be  solved  through  the  adoption  of  the  Consumer  Product  Safety 
Regulation  replacing  the  General  Product  Safety  Directive,  which  would  maintain 
the general requirement that all consumer products must be safe and, in respect of the 
obligations of economic operators, would be aligned with the  respective  provisions 
of Annex 1 of Decision (No) 768/2008/EC4. Problem 2 would be addressed by a new 
Regulation  on  market  surveillance  of  products  that  would  constitute  the  main 
instrument  for  market  surveillance  in  the  area  of  non-food  goods.  Provisions  on 
market  surveillance  in  the  EU  internal  market  legislation,  which  are  currently 
scattered  over  several  pieces  of  sector-specific  EU  legislation,  Regulation  (EC)  No 
765/2008  and  the  General  Product  Safety  Directive,  would  be  replaced  by  the 
provisions of this new Regulation.  

A Regulation, being directly applicable in all Member States, would achieve a very 
high  degree  of  harmonisation  of  the  rules  on  consumer  product  safety  and  market 
surveillance. The Consumer Product Safety Regulation would impose obligations on 
economic operators that would be directly enforceable (thus creating a level playing 
field) and would empower market surveillance authorities to act immediately in case 
of unsafe consumer products or non-compliance, without the need for transposition 
of these rules into different national laws.  

5. 

MONITORING AND EVALUATION 

In addition to the evaluation of the legislative instruments five years after their entry 
into  force,  the  monitoring  of  the  application  of  EU  product  safety  rules  will  be 
performed through the collection of relevant information from (i) the Eurobarometer 
surveys relating to consumer safety, (ii) the GRAS-RAPEX information system, (iii) 
the general information support system (ICSMS) and (iv) the Enforcement Indicators 

4 

Articles R1 – R7. 

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monitoring  activity  which  surveys  certain  parameters  of  market  surveillance  in 
Member States. 

Eurobarometer  surveys  can  measure  how  consumers  and  economic  operators 
perceive  the  safety  of  products  on  the  market.  This  perception  is  relevant  to  assess 
whether  the  initiative  has  contributed  to  an  increased  level  of  safety  of  consumer 
products as well as increased consumer confidence in the market and the regulatory 
framework. 

The  contribution  of  the  future  legislation  to  the  reduction  of  compliance  costs  of 
economic operators and benefit gains due to fairer competition and the elimination of 
non-complaint  market  players  could  be  assessed  through  ad-hoc  studies performed, 
in particular, by the industry. 

Finally, better coordination and effectiveness of market surveillance activities in the 
single  market  could  be  demonstrated  by  means  of  the  Enforcement  Indicators 
monitoring activity and the data notified and exchanged through the IT systems that 
will be further developed under the new legislation.  

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