REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Evaluation of the European Heritage Label (EHL)
Date: 2020-08-14
Institutions: Directorate-General for Education, Youth, Sport and Culture, European Commission
Subjects: EU initiative, European Movement, European identity, cultural cooperation, cultural heritage, cultural pluralism, cultural promotion, cultural relations, heritage protection, promotion of the European idea

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   EUROPEAN COMMISSION  Brussels, 14.8.2020  COM(2020) 372 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Evaluation of the European Heritage Label (EHL)  {SWD(2020) 161 final}  
 
 
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE 
COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE 
COMMITTEE OF THE REGIONS 

Evaluation of the European Heritage Label (EHL) 

The European Heritage Label (EHL) is a European Union action1 which aims to strengthen 
European citizens’ sense of belonging to the Union, in particular that of young people, based 
on  shared  values  and  elements  of  European  history  and  cultural  heritage,  as  well  as  an 
appreciation  of  national  and  regional  diversity.  The  Action  focuses  on  common  European 
history and values and contributes to strengthen intercultural dialogue; it places less emphasis 
on the preservation of sites. All Member States participate in the action, with the exception of 
Ireland and Sweden2.  

By today, the Commission has awarded the European Heritage Label to forty-eight sites for 
their symbolic value, the role they played in European history, and the activities they offer in 
order to bring the European Union and its citizens closer together. For the purpose of the 
action, “sites” mean monuments, natural, underwater, archaeological, industrial or urban sites, 
cultural landscapes, places of remembrance, cultural goods and objects and intangible heritage 
associated with a place, including contemporary heritage. The European Heritage Label is not 
associated with a monetary award. 

The  Commission  implements  the  European  Heritage  Label  with  the  support  of  a  European 
panel of independent experts to carry out the selection and monitoring at Union level.  

This  evaluation  report  of  the  European  Heritage  Label  is  submitted  in  accordance  with 
Article  18  of  Decision  1194/2011/EU3  and  is  accompanied  by  a  staff  working  document 
(SWD) presenting all evidence. It builds on 102 responses received from all interested parties 
in  the  framework  of  an  open  public  consultation.  The  evaluation  assesses  progress  in  the 
implementation of the action during its first six years of existence 2011–2017, with a view to 
further developing the action to reach its full potential and to take a qualitative step forward. 
The evaluation examines five criteria: relevance, coherence, efficiency, effectiveness and EU 
added value, as provided in the Commission’s Better Regulation Guidelines4. 

Overall, the evaluation suggests that the European Heritage Label action remains relevant 
to the current needs of the EU and is in line with the New European Agenda for Culture5 
and  the  rising  interest  in  culture  and  cultural  heritage  among  EU  citizens,  as  shown  by  the 
high  participation  in  the  European  Year  of  Cultural  Heritage  2018.  The  findings  of  this 
evaluation, as detailed in the Staff Working Document (SWD), show that the  Action should 

The UK was a Member State at the time of the evaluation but did not participate in the EHL action. 
OJ L 303/1, 22.11.2011 

1 Decision No 1194/2011/EU of the European Parliament and of the Council of 16 November 2011 establishing 
a European Union action for the European Heritage Label, OJ L 303/1, 22.11.2011 
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3 
4 https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and-
how/better-regulation-guidelines-and-toolbox_en 
5 
Communication from the Commission to the European Parliament, the European Council, the Council, 
the European Economic and Social Committee and the Committee of the Regions “A New European Agenda for 
Culture”, COM(2018) 267 final, 22.05.2018.  

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continue to be developed, but its geographical scope should not expand beyond the EU until 
the action becomes better-established within the EU.  

1. 

Relevance 

The  findings  of  this  evaluation  show  that  the  European  Heritage  Label  is  relevant  to  the 
rising interest in culture and cultural heritage among EU citizens. Facilitating the sharing 
of experiences and exchanges of best practices across the Union is highly relevant to the need 
for European cooperation in the field of culture and cultural heritage. It is the most promising 
way  to  develop  professional  understanding  and  practice,  and  to  strengthen  peer-to-peer 
connections within Europe. However, during the first years of implementation, this potential 
of the action has not yet been fulfilled, and not all Member States are involved in the action.  

  The  Commission  will  continue  to  further  develop  the  action  and  step  up  efforts  to 

involve all Member States in the action.   

2. 

Coherence 

The evaluation found that the European Heritage Label is a distinctive initiative within the 
EU.  The  European  Heritage  Label  places  less  emphasis  on  the  preservation  of  the  sites, 
focusing instead on raising European citizens’ awareness of European history and culture. The 
evaluation also found that in terms of objectives, the European Heritage Label displays more 
similarities  with  other  EU  initiatives  and  programmes  in  the  cultural  field,  rather  than  with 
UNESCO programmes. However, some risk of overlap was identified between the European 
Heritage Label and the Council of Europe’s Cultural Routes. 

Due to the transversal nature of cultural heritage, the European Heritage Label offers some 
potential  for  synergies  with  social,  economic  and  international  policy  areas.  These  could  be 
developed as a result of more active policy collaboration under the New European Agenda for 
Culture,  and  the  European  Framework  for  Action  on  Cultural  Heritage6.  Some  synergies 
could also be achieved between the European Heritage Label and EU programmes in the field 
of education and training such as the Erasmus+ programme. 

  The  Commission  will  maintain  the  focus  on  the  European  significance  of  the 
European  Cultural  Heritage  sites  in  the  history  and  culture  of  Europe  and/or  the 
building  of  the  Union  as  a  distinctive  feature  of  the  action  and  the  basis  for  its 
development and achievement of its objectives.  

  The Commission will seek to exploit coherencies and synergies identified between the 
European Heritage Label and other EU actions in the fields of culture, education and 
citizenship (e.g. Europe for Citizens programme, Erasmus+ programme, DiscoverEU, 
European Capitals of Culture, etc.). 

3. 

Efficiency and governance 

A  wide  range  of  sites,  both  tangible  and  intangible,  individual  and  multiple,  national  and 
transnational, are eligible for the attribution of the European Heritage Label. The evaluation 
considers this  an advantage in attracting  and uniting a variety of potential sites for the 
Label and the distinction of the action from other initiatives in the field of cultural heritage. 
The  introduction  of  common  selection  criteria  was  one  of  the  key  changes  introduced  in 
2011,  when  the  European  Heritage  Label  was  transformed  from  an  intergovernmental 
initiative to an EU-level action. The common selection criteria ensure the relevance of sites to 

6 European Framework for Action on Cultural Heritage, SWD(2018) 491 final, 05.12.2018.  

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the  European  Heritage  Label’s  objectives  as  the  designated  sites  clearly  define  their 
European  significance  and  commit  to  implementing  activities  to  achieve  the  action’s 
objectives. Moreover, the common selection criteria have contributed to shaping the action’s 
identity. 

The evaluation highlighted that, compared with other programmes or initiatives in the field of 
cultural  heritage,  the  criterion  of  European  significance  is  a  distinctive  feature  of  the 
action,  and  de  facto  the  core  criterion  for  the  attribution  of  European  Heritage  Label.  The 
evaluation found, however, that the development of a European narrative is difficult for a 
large share of candidate sites. 

  The Commission will seek to support potential sites for attribution of the label, as well 
as European Heritage Label sites to develop their European narratives in order to meet 
and continue meeting the criterion of European significance.  

The evaluation found that while the potential for cooperation and thematic networking is 
built  into the eligibility  categories, it has not  yet been fully  exploited. The majority of sites 
labelled  between  the  years  2013  and  2017  were  individual  sites,  mostly  historic  buildings, 
documentary  and architectural  heritage,  and places of  remembrance. Prior to  the  year 2018, 
only one transnational and one national thematic site were labelled. 

  The  Commission  will  step  up  its  efforts  to  promote  cooperation  and  thematic 
networking between Member States, with  a view to labelling more transnational and 
national thematic sites.  

The  Impact  Assessment  of  the  action  assumed  that  a  two-stage  selection  process,  i.e.  pre-
selection at national level first, and then selection at Union level, would be a way to ensure 
fair  geographical  distribution  of  the  Label  across  the  EU.  The  evaluation  found  that 
geographical distribution of European Heritage Label sites remains imbalanced after the first 
years of implementation of the action, with more EHL sites in larger states.  

  The Commission will encourage all the Member States to participate in the action and 
promote applications from participating Member States without a designated site . 

The selection of sites for the attribution of the Label involves two stages: Pre-selection of up 
to  two  sites  at  national  level  every  two  years;  following  that,  selection  of  the  sites  by  the 
European panel under the responsibility of the Commission. The evaluation found that a two-
stage selection process may lack efficiency as all applications are assessed, even those where 
the  applicant  site  does  not  clearly  demonstrate  the  symbolic  European  value  in  the 
application. As each participating Member State  establishes its own procedures  and its own 
calendar for the pre-selection in accordance with the principle of subsidiarity, this results in 
different opportunities for cultural heritage sites to participate in the action. 

The action’s European-level selection with the support of the EU panel works well. The 
evaluators  identified  one  area  in  which  the  efficiency  of  the  assessment  process  could  be 
increased. The Label may be attributed to a site only if its application meets all three criteria. 
Although  three-quarters  of  non-selected  sites  did  not  meet  the  criterion  of  European 
significance,  and  could  therefore  not  be  attributed  the  label,  the  EU  panel  assessed  the 
application  against  the  other  two  criteria,  namely  the  project  proposed,  and  the  operational 
capacity.  

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The  panel  communicates  its  selection  decisions  to  candidate  sites  through  their  national 
coordinators, and issues a report on the pre-selected sites to the Commission for publication. 
Selected sites consider this communication and feedback sufficient,  while non-selected sites 
would prefer a more individualised and detailed explanation. Candidate sites not selected for 
attribution  of  the  label  in  a  selection  at  Union  level  can  submit  new  applications  for  pre-
selection at national level in the following years.  

  For the future selections, the Commission will consider ways to increase the efficiency 
of  the  selection  process,  as  well  as  the  opportunities  to  participate  in  the  action  for 
cultural heritage sites, namely through enhanced information.  

  The  Commission  will  explore  options  for  streamlining  the  selection  and  evaluation 
processes and for providing more detailed feedback on the selection results. The EU 
Panel will continue to assess all criteria for attribution of the label with the objective to 
base the assessment on all information included in the application.  

The evaluation questions the efficiency of national quotas, the selection of maximum one site 
per Member State per selection  year. While the quotas might  have been useful  in  the initial 
stages of the action as a means to control the number of EHL sites, they are likely to become 
an obstacle for the action’s further development. 

  Should Decision No 1194/2011/EU (legal base) be reviewed,  the Commission would 
consider,  in  consultation  with  Member  States,  options  for  the  elimination  of  the 
national quota of one site per Member State. 

The  evaluation  found  that  site  managers  and  the  European  panel  involved  in  the  exercise 
positively  perceived  the  first  Monitoring  of  sites  awarded  the  label  in  2016  aiming  to 
ensure that they continue to meet the criteria and that they respect the project and work plan 
submitted in  their application. The majority of site managers appreciated  the opportunity of 
taking stock of their achievements and of the improvements brought to the site’s performance. 
Analysis shows that half of all recommendations provided by the European panel during the 
Sslection  process  had  been  fully  or  partially  implemented  by  the  time  of  monitoring. 
However, the monitoring in  its current  form functions more as a performance review  rather 
than a monitoring in a strict sense. It puts forward the need for a clear monitoring framework 
with  common  indicators  for  the  Member  States  to  ensure  a  coherent  approach  to  the 
monitoring procedure. 

  The Commission will continue to evaluate and improve the monitoring procedures for  

future monitoring exercises.  

The evaluation found that communication of the European Heritage Label to the public is 
moderate.  Not  all  sites  have  exploited  the  visibility  and  branding  materials  created  by  the 
Commission. Furthermore, communication between the actors involved in the implementation 
of  the  European  action,  namely  the  Commission,  the  national  coordinators  and  the  site 
managers,  is  an  area  for  improvement.  Networking  among  sites  is  emerging,  and  great 
demand exists within the action for more intense communication.  

  The Commission will step up its efforts to enhance communication activities about the 
European action and to promote cooperation and thematic networking among sites.  

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  Under  the  current  Creative  Europe  programme7,  funds  have  been  allocated  to  the 
design  and management  of networking and  capacity building  activities for European 
Heritage Label sites in 2019 and 2020.  

4. 

Effectiveness  

The  evaluation  found  that  since  its  launch,  the  European  Heritage  Label  action  has  made 
progress  in  reaching  its  two  general  objectives,  namely  strengthening  European  citizens’ 
sense  of  belonging  to  the  Union  and  strengthening  intercultural  dialogue.  The  majority  of 
respondents to the Open Public Consultation who visited European Heritage Label sites agree 
that the visit  had strengthened their sense of belonging to  Europe. As regards strengthening 
intercultural dialogue, a limited understanding among site managers of intercultural dialogue 
and limited multilingual communication are the main obstacles to achieving progress towards 
this objective.  

  The  Commission  will  explore  ways  to  enhance  the  site  manager’s  understanding  of 
and the commitment to strengthening intercultural dialogue to contribute better to the 
general objectives of the action.  

The  evaluation  observed  progress  since  the  launch  of  the  action  in  highlighting  the  sites’ 
European significance and symbolic value and in raising the profile and attractiveness of the 
sites on a European scale. Despite this, developing a European narrative is still a challenge for 
some  of  the  sites  and  identifying  common  topics  remains  difficult  for  the  whole  European 
Heritage Label network.  

The  evaluation  also  found  that  progress  has  been  made  in  increasing  European  citizens’ 
understanding  of  the  history  of  Europe  and  the  building  of  the  Union,  as  well  as  of  their 
common  yet  diverse  cultural  heritage.  Respondents  to  the  Open  Public  Consultation  agreed 
that a visit  to  any of the EHL sites, directly or online, had improved their understanding of 
European  history  and  culture  and  that  it  improved  their  knowledge  about  the  building  of 
Europe and its integration.  

The  evaluation  found  that  most  sites  have  improved  and  increased  their  access  for  visitors, 
including  virtual  accessibility  in  foreign  languages.  While  the  Label  has  been  successfully 
added  to  the  communication  and  education  activities  of  the  sites,  there  is  still  a  need  to 
develop  further  educational  activities  that  address  common  cultural  heritage.  Reaching 
local audiences for collaboration with local communities remains a challenge for many sites. 
Up to now, little progress has been made in fostering synergies between cultural heritage and 
contemporary  creation  and  creativity.  Furthermore,  no  evidence  was  found  that  the  EHL 
contributes  to  the  economic  and  sustainable  development  of  regions,  in  particular  through 
cultural  tourism,  although  one-third  of  sites  report  that  they  are  involved  in  collaboration 
activities with local communities and businesses.  

The evaluation found that half of all sites have implemented joint activities with EHL sites in 
other  Member  States,  e.g.  exhibitions,  conferences,  lectures,  concerts,  workshops  and 
promotion events. Some sites prefer to cooperate with non-EHL sites dealing with a common 
topic,  while  half  of  EHL  sites  would  like  to  improve  cooperation  within  the  action. 

7  
Regulation (EU) No 1295/2013 of the European Parliament and of the Council of 11 December 2013 
establishing the Creative Europe Programme (2014 to 2020), OJ L 347/221, 20.12.2013. 

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Establishing an EHL network as a structure for cooperation is a desire explicitly mentioned by 
stakeholders.  

EHL sites report having gained a great number of benefits from being designated, including 
strengthened  local  support  and  European  dimension;  greater  media  attention;  closer 
integration  into  Europe;  as  well  as  increased  visibility  and  visitor  numbers.  Conversely, 
becoming an EHL site is also  demanding in  terms  of human and financial resources for the 
implementation of their project.  

  The Commission has launched activities to contribute to the capacity building of EHL 
sites to  act  at  international  level  and to  contribute to  the achievements of the EHL’s 
objective  and  the  sustainability  of  its  results,  such  as  through  training  activities  and 
staff mobility between sites.  

5. 

EU added value  

lies  primarily 

intergovernmental  action, 

The added value provided by having the action operate at  European level, in  comparison  to 
the  previous 
the  European 
significance of EHL sites. The sites can provide  tangible  content that fills abstract  concepts 
like  European  values  and  identity.  Furthermore,  EHL  sites  can  serve  as  a  link  between  the 
European narratives and local sites and citizens. No concrete EU added value has so far been 
witnessed in strengthening intercultural dialogue. This might be a result of the characteristics 
of heritage sites, which seldom place a special focus on activities that offer great potential to 
support intercultural dialogue, as is seen in the fields of socio-culture, performing arts, urban 
spheres, etc.  

in  highlighting 

The involvement of the EU has resulted in the establishment of common selection criteria, as 
well  as  selection  and  monitoring  procedures  at  European  level.  These  developments  can  be 
identified  as  an  important  added  value  compared  to  the  former  intergovernmental  initiative. 
EHL sites recognise EU added value of the action in the opportunity to share their experiences 
and best practices, to learn from each other, and to develop narratives on common European 
topics.  

The evaluation found that the action’s EU added value may be limited by its scope being too 
narrow (i.e. by its focus on sites). A termination of the action would, however, be premature  
and could send a negative signal to citizens, and specifically to the stakeholders of the sites 
and  the  cultural  heritage  sector.  The  efforts  undertaken  by  EHL  sites  to  highlight  their 
European significance and raise awareness among citizens would be severely damaged.  

  The Commission will consider additional ways of broadening the scope of the action, 
in  particular  by  developing  and  communicating  the  European  narratives  of  the  sites; 
enhancing cooperation and thematic networking among EHL sites; and contributing to 
their capacity building. 

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