COMMISSION STAFF WORKING DOCUMENT of the European Heritage Label Action Accompanying the document 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

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 14.8.2020  SWD(2020) 161 final  COMMISSION STAFF WORKING DOCUMENT of the European Heritage Label Action Accompanying the document 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) {COM(2020) 372 final}  
 
 
Contents 

1. 

2. 

INTRODUCTION ................................................................................................................................ 2 

BACKGROUND TO THE INTERVENTION ..................................................................................... 2 

2.1 The European Heritage Label ................................................................................................ 2 

2.2 Objectives of the EHL Action ................................................................................................. 3 

2.3. Baseline ................................................................................................................................ 7 

3. 

IMPLEMENTATION / STATE OF PLAY .......................................................................................... 8 

4.  METHOD............................................................................................................................................ 11 

4.1 Short description of methodology ...................................................................................... 11 

4.2 Limitations and robustness of findings ............................................................................... 12 

5.  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS .......................................... 13 

5.1 Relevance ............................................................................................................................ 13 

5.1.1 The EHL objectives and current needs in the EU ......................................................... 13 

5.1.2 The geographical scope ................................................................................................ 15 

5.2 Coherence ........................................................................................................................... 17 

5.3 Efficiency and governance................................................................................................... 20 

5.3.1 Application Form .......................................................................................................... 20 

5.3.2 Efficiency of selection arrangements ........................................................................... 20 

5.3.3 Efficiency of the monitoring process ............................................................................ 23 

5.3.4 Efficiency of communication processes ....................................................................... 23 

5.4 Effectiveness ........................................................................................................................ 24 

5.4.1 Extent of achievement of specific objectives ............................................................... 24 

5.4.2 Action’s achievement of general and intermediate objectives ................................... 26 

5.4.3 Sustainability of the positive effects ............................................................................ 26 

5.5 EU added value .................................................................................................................... 27 

6. 

CONCLUSIONS ................................................................................................................................. 27 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................................ 29 

ANNEX 2: STAKEHOLDER CONSULTATION ....................................................................................... 31 

ANNEX 3: METHODS AND ANALYTICAL MODELS .......................................................................... 37 

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1.  INTRODUCTION 

This  document  describes  the  methodology  and  findings  of  the  evaluation  of  the  European 
Heritage  Label  (EHL)  Action  as  required  by  Article 18  of  Decision  No.  1194/2011/EU1  of  the 
European Parliament and Council. This staff working document (SWD) accompanies the Report 
to the European Parliament, the Council and the Committee of the Regions. The evaluation aimed 
to  assess  the  implementation  of  the  EHL  Action  during  its  first  six  years  of  existence  (2011-
2017) with a view to improve its implementation in the upcoming period in accordance with the 
principles of Better Regulation. As the EHL is still in its early stages of implementation, the main 
purpose of this evaluation was to assess the impact of the action and focus on the improvement of 
its operational aspects: to define which processes are working well or not working and to identify 
the  best  practices  for  improving  these  processes.  Most  importantly,  the  evaluation  aimed  to 
identify whether the action was sustainable, whether its geographical scope should be widened, 
and  whether  the  EHL  should  be  continued.  The  evaluation  examined  five  criteria:  relevance, 
coherence, efficiency, effectiveness, and EU added value.  

The evaluation was supported by an external contractor’s report. It covered the period 2011-2017 
with  a  strong  focus  on  the  period  following  the  first  selection  of  sites  in  2013.  The  evaluation 
provides  a  detailed  analysis  of  the  29  sites  that  received  the  European  Heritage  Label  before 
2017.  

2.  BACKGROUND TO THE INTERVENTION 

2.1 The European Heritage Label 

The  European  Heritage  Label  was  launched  in  2006  as  an  intergovernmental  action  under  the 
leadership of France, Spain and Hungary with the goal to identify and designate sites that played 
a key role in building and uniting Europe, and to promote the European context of the selected 
sites.  By  2010,  the  Label  had  been  assigned  to  68  sites  across  18  EU  Member  States  and 
Switzerland.  Participating  countries  designated  sites  independently,  based  on  their  own 
judgement  and  interpretation  of  ‘European-ness’.2  According  to  the  Impact  Assessment  that 
preceded  the  Commission  initiative  in  2010,  the  intergovernmental  selection  procedures  had 
resulted  in  disparities  between  the  sites  labelled,  their  relevance  and  activities.  In  addition,  the 
EHL  lacked  visibility  among  stakeholders,  and little progress  had been  made  in  the initiative’s 
educational dimension. On request from participating Member States, the EHL was transformed 
into a formal action of the EU, with the aim of strengthening coordination between the states, and 

1   OJ L 303/1, 22.11.2011 
2   Commission Staff Working Document. Summary of the Impact Assessment. Accompanying document 
to the Proposal for a Decision of the European Parliament and of the Council establishing a European 
Union  action  for  the  European  Heritage  Label,  9  March  2010,  SEC(2010)  198,  9.3.2010,  p.  2 
[hereinafter, ‘Impact Assessment’] 

2 

 
 
 
                                                           
developing  “common,  clear,  and  transparent  selection  criteria”.3  The  current  EU  action  for  the 
European Heritage Label was established in 2011 by Decision No. 1194/2011/EU.4  

The new European Heritage Label is intended for sites that not only have made a contribution to 
European history and/or the building of the Union, but also promote and highlight their European 
dimension  and  demonstrate  their  operational  capacity  to  carry  out  these  activities.  The  new 
requirements  are  an  intrinsic  part  of  (or  contribution  to)  the  added  value  of  the  new  European 
Heritage Label. 

The  procedure  for  attributing  the  European  Heritage  Label  is  carried  out  in  two  stages:  at  the 
national level a maximum of two candidate sites are pre-selected every two years. Out of these 
and  based  upon  the  recommendations  made  by  a  European  Panel  of  independent  experts5,  the 
European  Commission  decides  to  attribute  the  European  Heritage  Label  to  a  maximum  of  one 
site per participating Member State per year. 

2013  and  2014,  the  first  two  years  of  the  action  at  the  European  Union  level,  were  transition 
years: in 2013 participation was restricted to those Member States, which had not taken part in 
the intergovernmental initiative, whilst 2014 was reserved for candidate sites from the Member 
States, which had been involved in the intergovernmental initiative. 2015 was the first year that 
participation was open to all Member States, if they confirmed their interest: 24 Member States 
signed up. 

Sites awarded are monitored on a regular basis in order to ensure that they continue to meet the 
criteria for which they were selected. 2016 was the first monitoring year and the European Panel 
has examined the sites awarded in 2013 and 2014. The next monitoring year will take place in 
2020 and will include all sites that received the Label prior to 2019. 

2.2 Objectives of the EHL Action  

The  EHL  is  an  EU  action  that  brings  cultural  heritage  sites  with  a  European  dimension  to  the 
fore. All types of heritage, from monuments and landscapes, to books and archives, objects and 
intangible heritage, linked to a place, are eligible if they are significant in terms of the history and 
culture of Europe or the European integration. 

The Label’s general objectives are to strengthen European citizen’s sense of belonging to the 
European  Union  in  particular  that  of  young  people,  based  on  shared  values  and  elements  of 

3   Proposal for a Decision of the European Parliament and of the Council establishing a European Union 
action for the European Heritage Label, 9 March 2010, COM (2010) 76 final, p. 3 [hereinafter referred 
to as the ‘Proposal for the European Heritage Label].  

4   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 L303/1, 22.11.2011 

5   A European panel of independent experts has been established to carry out the selection and monitoring 
at Union  level. It ensures that the criteria are properly applied by the sites across the Member States. 
The  European  panel  consists  of  13  members,  four  of  whom  have  been  appointed  by  European 
Parliament, four by the Council, four by the Commission and one by the Committee of the Regions, in 
accordance  with  their  respective  procedures.  The  members  are  independent  experts  with  substantial 
experience and expertise in the fields relevant to the objective of the action.  

3 

 
 
                                                           
 
European  history  and  cultural  heritage  as  well  as  an  appreciation  of  national  and  regional 
diversity; and to strengthen intercultural dialogue.  

The establishment of the EHL at the EU-level was expected to lead to increased access to cultural 
heritage resources especially for young people, increased interest in and knowledge of a common 
European Heritage and the understanding of European cultural diversity, increase in intercultural 
dialogue,  greater  sense  of  belonging  to  the  European  Union  and  stronger  participation  in  the 
democratic process. 

Secondary  economic  benefits  were  presumed  in  the  Impact  Assessment  and  include  positive 
effects on the local tourism industry, including number of people employed; development of links 
with cultural and creative industries; and development of innovation and creativity. 

The  intermediate  objectives  of  the  Label  will  be  to  enhance  the  value  and  the  profile  of  sites 
which  have  played  a  key  role  in  the  history  and  the  building  of  the  European  Union,  and  to 
increase  European  citizens’  understanding  of  the  building  of  Europe,  and  of  their  common  yet 
diverse  cultural  heritage,  especially  related  to  the  democratic  values  and  human  rights  that 
underpin the process of European integration. This is the highest level of impact that EHL can 
achieve on its own. 

At a more basic level, a set of specific objectives will relate to the direct improvements that sites 
would be expected to deliver because of their activities linked to the EHL designation or that the 
new  practical  arrangements  would  be  expected  to  deliver.  The  sites  themselves  shall  seek  to 
attain the following specific objectives: 

•  Highlighting their European significance. 
•  Raising European citizens; awareness of their common cultural heritage, especially that 

of young people. 

•  Facilitating the sharing of experiences and exchanges of best practices across the Union. 
• 
• 
•  Fostering  synergies  between  cultural  heritage  on  one  hand  and  contemporary  creation 

Increasing and/or improving access for all. 
Increasing intercultural dialogue through artistic, cultural and historical education. 

and creativity on the other. 

•  Contributing  to  the  attractiveness  and  the  economic  and  sustainable  development  of 

regions, in particular through cultural tourism. 

The  EHL  brings  together  outstanding  heritage  sites  with  a  symbolic  European  value.  All  the 
labelled sites have played a significant role in the history and culture of Europe or in European 
integration.  Visitors  can  enjoy  European  Heritage  sites  as  single  destinations  or  as  a  part  of  a 
tour. Either way, the will get a real feel for the breadth and scale for what Europe has offer and 
what it has achieved.To be assigned the EHL sites must have a symbolic European value, played 
a significant role in the history and culture of Europe and/or the building of the European Union. 
The sites must also offer specific activities that strengthen the relationship between the European 
Union and its citizens and must possess adequate capacities to implement in these activities.  

The objectives, expected outputs and impacts are presented in the table below.  

4 

 
5 

 
 
 
 
6 

 
 
 
 
2.3. Baseline 

The original concept of the EHL emerged in 2005 as one of the responses to the gap between the 
European Union and its citizens. This gap can be attributed to an important extent to a lack of 
knowledge  of  the  history  of  Europe,  of  the  role  of  the  European  Union  and  of  the  values  on 
which it is based. 

The  scheme  was  initially  launched  by  several  European  states  in  April  2006  on  an 
intergovernmental  basis.  Its  aim  was  to  strengthen  European  citizens’  sense  of  belonging  to 
Europe  and  to  promote  a  sense  of  European  identity  by  improving  knowledge  of  Europe  as 
shared  history  and  heritage,  especially  among  young  people.  A  total  of  64  sites  located  in  17 
European Union Member States as well as in Switzerland have been awarded the label. However, 
the practical arrangements for the initiative have shown some weaknesses and it has not therefore 
managed to fulfil its potential. This is why, following the example of the European Capitals of 
Culture,  the  Member  States  asked  the  European  Commission  in  the  Council  conclusions  of 
November  2008  to  transform  the  intergovernmental  EHL  into  a  formal  action  of  the  European 
Union in order to improve its functioning and ensure its long-terms success. 

European  Union  involvement  in  the  EHL  was  expected  to  strengthen  coordination  between 
Member  States  and  thus  to  contribute  to  the  development  and  proper  application  of  common, 
clear and transparent selection criteria, as well as a new selection and monitoring procedures for 
the label, thereby ensuring the relevance of the sites in the light of the objectives. Other expected 
benefit of European Union action was an increase in the number of Member States participating 
in the initiative. 

The  European  Parliament  supported  the  development  of  the  EHL,  first  in  its  resolution  of  29 
November 2007 on a Renewed European Union Tourism Policy: Towards a stronger partnership 
for  European Tourism  where  it  proposes  “that  support  be  given  for the creation  of  a  European 
Heritage label aimed at highlighting the European dimension of the European Union’s sites and 
monuments”  and  subsequently  in  its  resolution  of  10  April  2008  on  a  European  agenda  for 

7 

 
 
 
culture  in  a  globalising  world  in  which  it  underlines  “that  European  heritage  label  should  be 
established with a view to emphasising the  European dimension of cultural goods, monuments, 
memorial  sites,  and  places  of  remembrance,  which  all  bear  witness  to  Europe’s  history  and 
heritage”. 

Following the Council’s conclusions and in line with its procedures, the European Commission 
launched an impact assessment with the aim to determine whether action by the EU was indeed 
justified in this area, whether it could really add value to the EHL and, if this is the case, which 
form  this  action  should  take.  The  analysis  of  the  various  impacts  has  demonstrated  that  the 
primary direct effects of the EHL would be social or societal ones. These effects would include 
increased access to heritage sites, notably for young people, increased interest in and knowledge 
of  common  European  heritage,  increased  understanding  of  European  cultural  diversity,  an 
increase in intercultural dialogue and a greater sense of belonging to the European Union. 

Economic  benefits  could  also  be  expected  as  the  EHL  has  the  potential  to  produce  positive 
effects  on  the  local  tourism  industry,  including  the  number  of  people  employed.  However  the 
impact on the number of visitors to a site will greatly depend on the quality and credibility the 
label will acquire and thus on the prestige it will develop over the years. 

3.  IMPLEMENTATION / STATE OF PLAY 

The  operational  structure  of  the  action  was  established  in  2011  taken  directly  from  Decision 
No.1194/2011/EU. The adopted  legal  basis calls  for the  European  Commission  to implement  a 
two-stage  selection  process  (nationally  and  at  the  EU  level).  The  legal  basis  created  common 
selection criteria and the European panel to oversee the initiative. 

8 

 
 
 
Implementation of the Label occurred in two stages, preparatory and transitional.6 The transition 
period occurred between 2013 and 2014 from the intergovernmental initiative. Starting in 2015 
after the end of the transition period, the EHL is managed in three stages: selection, monitoring, 
and evaluation. Selection occurs every two years with a maximum of one site per Member State. 
Every four years there will be monitoring and every six years there will be an external evaluation 
of  the  action.  This  staff  working  document  accompanies  the  evaluation  report  of  the  European 
Heritage  Label  submitted  in  accordance  with  Article  18  of  Decision  1194/2011/EU  of  the 
European Parliament and of the Council.7 

2013  and  2014,  the  first  two  years  of  the  action  at  the  European  Union  level,  were  transition 
years: in 2013 participation was restricted to those Member States that had not taken part in the 
intragovernmental initiative. Austria, Denmark, Estonia, Luxemburg and Netherlands confirmed 
their interest and sent applications. Four sites were labelled. 

Archaeological Site of Carnuntum  
Great Guild Hall 
Peace Palace 
Camp Westerbork 

Petronell-Carnuntum (Austria) 
Tallinn (Estonia) 
The Hague (Netherlands) 
Hooghalen (Netherlands) 

2014  was  reserved  for  candidate  sites  from  the  Member  States  that  had  been  involved  in  the 
intergovernmental initiative. 18 Member States confirmed their interest and sent applications. 16 
new sites were included in the Label list. 

Heart of Ancient Athens 
Abbey of Cluny 
Archive of the Crown of Aragon 
General Library of the University of Coimbra 
Union of Lublin (1569) 
Sites of the Peace of Westphalia (1648) 
3 May 1791 Constitution 
Hambach Castle 
Charter  of  Law  for  the  Abolition  of  the  Death 
Penalty (1867) 
Student Residence or Residencia de Estudiantes 
Kaunas of 1919-1940 
Franja Partisan Hospital 
Robert Schuman’s House 
Alcide de Gasperi’s House Museum 
Historic Gdansk Shipyard 
Pan-European Picnic Memorial Park 

Athens (Greece) 
Cluny (France) 
Barcelona (Spain) 
Coimbra (Portugal) 
Lublin (Poland) 
Munster and Osnabruck (Germany) 
Warsaw (Poland) 
Hambach (Germany) 
Lisbon (Portugal) 

Madrid (Spain) 
Kaunas (Lithuania) 
Cerkno (Slovenia) 
Scy-Chazelles (France) 
Pieve Tesino (Italy) 
Gdansk (Poland) 
Sopron (Hungary) 

Since  2015,  the  selection  process  takes  place  every  other  year  and  participation  is  open  to  all 
Member States provided that they confirmed their interest. In 2015, 24 Member States confirmed 
their interest in the EHL and eleven sent applications. Nine sites were labelled. 

Neanderthal Prehistoric Site and Kaprina Museum 
Olomouc  Premyslid  Castle  and  Archdiocesan 
Museum 

Husnjakovo/Kaprina (Croatia) 
Olomuc (Czech Republic) 

6   Decision No. 1194/2011/EU. 

7   OJ L 303/1, 22.11.2011 

9 

 
 
 
                                                           
Sagres Promontory 
Imperial Palace 
Historic Ensemble of the University or Tartu 
Franz Liszt Academy of Music 
Mundaneum 
World War I Eastern Front Cemetery No.123 
European District of Strasbourg 

Sagres (Portugal) 
Viena (Austria) 
Tartu (Estonia) 
Budapest (Hungary) 
Mons (Belgium) 
Luzna-Pustki (Poland) 
Strasbourg (France) 

In 2017, the European Commission received applications from 25 candidate sites in 19 Member 
States. Four Member States participated for the first time and four out of the 25 candidates sites 
were  transnational sites: the applications demonstrate a broader geographical range and a trend 
towards larger scale applications. In terms of heritage typologies, the candidate sites belonged to 
more traditional heritage such as castles and fortifications. The Panel recommends nine new EHL 
sites,  six  sites  present  the  European  history  and  culture  and  three  sites  are  related  to  European 
integration. 

Leipzig’s Musical Heritage Sites 
Dohany Street Synagogue Complex 
Fort Cadine 
Javorca Church and its cultural landscape 
Former  Natzweiler  concentration  camp  and  its 
satellite camps 

Sighet memorial 
Bois du Cazier 
Village of Schengen 
Maastrich Treaty 

Leipzig (Germany) 
Budapest (Hungary) 
Trento (Italy) 
Tolmin (Slovenia) 
Alsace-Moselle, Haut Rhin (France) 
Baden-Wurttemberg,  Hessen,  Rhineland-Palatinate 
(Germany) 
Sighet (Romania) 
Marcinelle (Belgium) 
Schengen (Luxembourg) 
Maastrich (Netherlands) 

Up to now, 25 Member States have confirmed they  wish to take part in the EHL. Sweden and 
Ireland will not participate for the time being, but can join the initiative later if they wish. The 
EHL  should  focus  on  developing  its  identity  within  Member  States  before  extending  its 
geographical scope. First, the EHL should look to include all Member States before it expands to 
non-EU  states.  At  this  point,  expanding  the  Label  in  its  early  stages  of  development  appears 
premature.  

Several  candidate  sites  had  a  link  to  other  EU  initiatives,  but  this  does  not  result  in  being 
automatically awarded the Label because the sites must meet the three specific EHL criteria. In 
particular,  not  all  applicants  had  fully  understood  to  what  extent  presenting  the  European 
dimension  of  their  site  is  paramount:  if  the  dimension  of  a  site  is  not  well  established  or 
articulated,  the  projects  presenting  the  European significance  of the  site  to  European audiences 
almost never meet the threshold for the Label. 

EHL  sites  are  gateways  to  information  about  Europe’s  history,  culture  and  integration,  and 
further  questioning.  For  the  European  institutions,  the  EHL  sites  are  excellent  examples  to 
illustrate  and  explain  current  challenges  to  the  citizens,  in  particular  through  social  media, 
because the sites provide contextual information. All EHL sites have an enormous potential for 
education including the sites linked to more recent events and history. 

The  European  Panel  has  gained  experience  based  on  four  selection  years  and  one  monitoring 
year.  It  has  streamlined  its  working  methods  and  paid  special  attention  to  building  up  and 
maintaining institutional memory as its composition evolves over the years. 

10 

 
 
 
Sites awarded the EHL are monitored on a regular basis in order to ensure that they continue to 
meet  the  criteria  for  which  they  were  selected.  2016  was  the  first  monitoring  year  and  the 
European Expert Panel examined the sites awarded in 2013 and 2014. The next monitoring year 
will take place in 2020 and will include all sites that received the label prior to 2019. 

4.  METHOD 

4.1 Short description of methodology 

This is the first evaluation of the European Heritage Label Action. The methodology employed 
two broad types of method for data collection: desk research and stakeholder consultation. The 
latter included an open public consultation (OPC), interviews and focus groups. Quantitative data 
was  collected  via  the  OPC  and  desk  research  while  qualitative  data  was  obtained  through 
interviews,  focus  groups  and  desk  research.  The  main  evaluation  sources  can  be  identified  as 
follows: 

Desk Research: 

The  Impact  Assessment  and  2009  Open  Public  Consultation  Report  provided  an  assessment  of 
the  previous  intergovernmental  initiative  as  well  as  stakeholder  expectations  in  regards  to  the 
new EU-level action. These were the main sources used to reconstruct the intervention logic of 
the EHL.  

The  evaluation  team  analysed  all  application  forms  from  the  2013-2017  period  consisting  of 
selected and non-selected candidates, for a total of 88 forms. Emphasis of the analysis was placed 
on  the  sites’  articulation  of  their  European  significance,  work  plans  and  outlines  of  their 
operational capacities.  

The  Panel  Reports  on  the  2013,  2014,  2015,  2017  selections8  produced  by  European  Panel 
members  were  analysed  to  determine  how  sites  were  selected,  to  classify  them  into  categories 
and to assess their geographic distributions. The Panel Reports were also indicative of the quality 
of applications and contained suggestions for improvements.  

The evaluation team analysed all monitoring forms from the 20 sites that participated in the 2016 
monitoring process, and simplified monitoring forms from eight sites that were not involved in 
the  monitoring  process,  but  which  were  covered  by  this  evaluation.  The  Panel  constructed  the 
2016  Panel  Report  on  Monitoring,  which  provided  information  on  the  benefits  and  challenges 
faced by the EHL sites and recommendations made to the sites by the EHL Panel. The report was 
used extensively in this evaluation.  

Stakeholder Consultation: 

8   https://ec.europa.eu/programmes/creative-europe/sites/creative-europe/files/library/ehl-2013-panel-

report_en.pdf 
https://ec.europa.eu/programmes/creative-europe/sites/creative-europe/files/library/ehl-2014-panel-
report.pdf 
https://ec.europa.eu/programmes/creative-europe/sites/creative-europe/files/library/ehl-2015-panel-
report_en.pdf 
https://ec.europa.eu/programmes/creative-europe/sites/creative-europe/files/library/ehl-2017-panel-
report_en.pdf 

11 

 
                                                           
 
Open public consultation. 
Interviews. 

Focus discussions 

103 responses. 
30 managers/senior staff members EHL sites. 
5 managers’ non-selected sites. 
21 national coordinators. 
7 members of European Panel. 
8 EHL manager Commission and EU actions in cultural heritage. 
2 external experts. 
3 representative stakeholders’ networks and organisations. 
10 (covered 19 EHL sites). 

During the evaluation, the following stakeholder categories were targeted: 

  Those affected by the action (citizens). 
  Those who implement the action (EHL site managers, national coordinators, members of 

the European panel of experts, EHL managers at the European Commission). 

  Those  who  have  an  interest  in  the  action  (local,  regional  and  national  authorities,  state 

institutions, cultural heritage sites, museums, libraries, schools, etc.). 

The open public consultation (OPC) gathered views on all interested citizens and organizations 
on the role of cultural heritage in bringing the European citizens closer to the Union. Consultation 
was carried out via an online questionnaire accompanied by a background document. The scope 
of the OPC covered the visibility of the Label, as well as the relevance, coherence, effectiveness, 
efficiency  and  EU  added  value.  The  questionnaire  covered  15  questions,  seven  targeting  the 
general public and eight for those involved in the action. The questionnaire was published for 12 
weeks  (1  March  2018  -  28  May  2018)  on  a  dedicated  consultation  webpage  and  was  made 
available in three EU languages (English, French and German). In total, it received 103 responses 
of which one was not valid.  

Interviews were crucial in obtaining data on the perceptions and attitudes of respondents towards 
the EHL. 76 interviews were conducted by the evaluation team with different stakeholder groups 
and conducted in a semi-structured manner and followed interview guidelines tailored for each 
specific stakeholder group. The sample size was proposed in the Inception Report and aimed to 
cover different types of non-selected sites. 

A programme of site-specific and national-level focus groups was also used in the evaluation to 
provide a platform for various stakeholders to discuss the EHL action within a local or national 
context. In total 10 focus group discussions were carried out. Six took place at selected EHL sites 
and  involved  the  managers  of  those  sites  and  local  stakeholders,  namely:  Kaunas  1919-1940 
(Lithuania); Franz Liszt Academy of Music (Hungary); Sites of the Peace of Westphalia (1648), 
Munster and Osnabruck (Germany); Franja Partisan Hospital (Slovenia); Camp Westerbork (The 
Netherlands);  and  the  Premyslid  Castle  and  Archdiocesan  Museum  Olomouc  (the  Czech 
Republic).  Another  four  focus  group  discussions  took  place  in  Poland,  France,  Austria  and 
Portugal,  usually  at  the  national  Ministry  of  Culture,  and  involving  national  coordinators, 
managers of EHL sites located in the respective country, and national stakeholders. In total, focus 
group discussions covered 19 EHL sites. 

4.2 Limitations and robustness of findings 

The weaknesses in the methods applied and data collected were as follows: 

12 

 
 
 
 
  Due  to  variations  in  the  methodology  used  to  monitor  different  EHL  sites  with  no 
common  indicators  to  measure  progress,  it  is  difficult  to  compare  site-specific  data  on 
progress.  In  these  situations  further  data  was  collected  from  other  sources  (interviews, 
websites or request in writing) to triangulate findings and ensure validity.  

  A  few  of  the  interviewees (national  coordinators  and EHL  site  managers)  were new  to 
their  positions  and  could  not  provide  an  informed  opinion  on  EHL  processes. 
Nevertheless,  the  majority  of  interviewees  provided  good  insights,  and  thus  provided 
sufficient data for analysis. 

  As  the  evaluation  drew  upon  answers  from  interviews,  focus  groups  and  OPC  to  draw 
certain  opinions  and  perceptions,  the  data  represents  evidence  where  an  evaluation 
question or sub-question was naturally influenced by the respondents’ affiliation with the 
EHL.  The  evaluation,  therefore,  corroborated  perception-based  sources  with  other 
sources of evidence – in particular, data from desk research. 

  One change was required to the original work plan, as one of the sites refused to host a 
group discussion. This site was replaced with another site with similar characteristics.  
  Evaluators took into account that the OPC does not provide a representative view of the 
public  opinion  on  the  EHL.  For  this  reason,  the  OPC  was  not  used  as  the  main  data 
source. All data conclusions drawn were based on triangulated data.  

5.  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS 

All figures  appearing  in the  following  sub-sections  have  been drawn  directly  from  the  external 
evaluation report conducted by PPMI and EDUCULT. The reader will find many more examples 
illustrating the conclusions presented below in the full document.9 

The  evaluation  results  are  given  with  respect  to  the  five  criteria  of  relevance,  coherence, 
efficiency, effectiveness and EU added value. Often, examples and figures can illustrate different 
points  made  under  the  sub-sections.  For  ease  of  reading,  repetitions  have  been  limited  and  the 
reader is invited to correlate some conclusions presented below with information given in other 
sub-sections.  

5.1 Relevance  

5.1.1 The EHL objectives and current needs in the EU 
Since the Maastricht Treaty of 1992, the EU has defined cultural heritage as one of its duties and 
objectives by calling for the conservation of cultural diversity at local and regional levels, as well 
as  safeguarding  cultural  heritage  of  European  significance  (Article  128).    Article  167  of  the 
Treaty  on  the  Functioning  of  the  European  Union  reconfirmed  the  commitment  of  the  EU  to 
cultural  heritage  and called  upon the  EU  to  bring  its  common  cultural  heritage  to the  forefront 
and support the efforts of Member States to safeguard their heritage.  Article 167 is characterized 
by  the  principle  of subsidiarity,  meaning  that  the  EU  must  respect the national importance  and 
interpretation of sites, while offering a European dimension to their interpretation that highlights 
a common European history.  

9   Evaluation of the European Heritage Label Action. Report:https://publications.europa.eu/en/publication-

detail/-/publication/6d66be3f-8d84-11e9-9369-01aa75ed71a1/language-en/format-PDF/source-
99344265  Summaries:https://publications.europa.eu/en/publication-detail/-/publication/6699e8c5-8d85-
11e9-9369-01aa75ed71a1/language-en/format-PDF/source-99344284 
Annexes:https://publications.europa.eu/en/publication-detail/-/publication/2c883308-8d89-11e9-9369-
01aa75ed71a1/language-en/format-PDF/source-99344296 

13 

 
 
                                                           
In 2014 the Council of the EU published the “Council conclusions on participatory governance of 
cultural heritage”, which highlighted the need for exchange, cooperation and networking between 
different  actors  in  the  field  in  order  to  “make  cultural  governance  more  open,  participatory, 
effective and coherent”10. The participatory approach is reflected in the aims of the objectives of 
the EHL.  

To  assess  if  the  EHL  objectives  are  relevant  to  the  current  needs  of  the  EU,  the  following 
indicators were applied:  

  The extent to which the action considers current societal and political developments;  
  The extent to which the actions objectives are consistent with EU policy goals;  
  The  extent  to  which  the  action  establishes  a  contemporary  understanding  of  cultural 

heritage in Europe;  

  The extent to which the action considers the needs of EU citizens in the field of cultural 

heritage.  

The Impact Assessment identified several needs11 in relation to the EU: to develop the sense of a 
shared European identity among Europe’s diverse populations through its cultural heritage and to 
develop  a  European  reading  of  cultural  heritage.  The  Label  seeks  to  address  the  growing  gap 
between  Europe’s citizens and the  European  Union  and  to  promote  access  to  Europe’s cultural 
heritage. The responses from the OPC indicated that a large majority thought it was important for 
the  EU  to  act  in  order  to  reinforce  a  sense  of  belonging  to  a  common  European  space  (93% 
agreed,  of  which  62%  strongly  agreed);  to  strengthen  intercultural  dialogue  (97%  agreed,  of 
which  65%  strongly  agreed);  and  to  promote  cultural  heritage  as  a  resource  for  economic 
development (90% agreed, of which 57% strongly agreed).  

Current EU policy goals in the field of culture are determined in the New European Agenda for 
Culture, published in 2018. Its strategic objectives are categorized in three dimensions: 

•  Social  dimension,  harnessing  the  power  of  culture  and  cultural  diversity  for 

social cohesion and well-being. 

•  Economic  dimension,  supporting  culture-based  creativity  in  education  and 

innovation, as well as jobs and growth. 

•  External dimension, strengthening international cultural relations.12 

The  examples  above  demonstrate  that  the  EHL  is  in  accordance  with  the  EU  policy  goals  and 
priorities in the field of cultural heritage. The objectives set out in the Decision establishing the 
initiative are consistent with the goals identified in the New European Agenda for Culture.13  

The  European  Year  of  Cultural  Heritage  2018  (EYCH),  implemented  by  Creative  Europe, 
motivated  many  EHL  sites  to  implement  activities  or  be  involved  with  activities  taking  place 
within  the  frame  of  the  EYCH.  Creative  Europe  puts  European  cooperation  at  the  core  of  its 

10  Council Conclusions on participatory governance of cultural heritage (2014/C 463/01), 23.12.2014. 
11  Impact  Assessment,  p.5.  The  needs  of  EU  do  not  seem  to  have  changed  in  nature  since  the  Impact 

Assessment was carried out, but do appear to have increased. 

12  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 , 22.5.2018, pp. 2-8.  
13  A New European Agenda for Culture, COM (2018) 267, 22.05.2018. 

14 

 
                                                           
programme. The 2018 Annual Work Programme of Creative Europe mentions that “Cooperation 
projects will continue to represent the main bulk of EU support in 2018”.14 

Participants in the OPC agreed that it was important for the EU to raise awareness of common 
European  history  and  values  (94%  agreed,  64%  of  which  agreed  strongly),  and  to  reinforce  a 
sense  of  belonging  to  a  common  European  space  (92%  agreed,  61%  agreed  strongly).  The 
participants also indicated it was important to promote access to cultural heritage through the use 
of digital technologies (91% agreed, 58% agreed strongly). The EHL needs to establish a network 
of sites to reinforce cooperation activities in addition to the collaboration projects undertaken by 
half of the EHL sites. Interviewees mentioned that transnational sites offer a valuable opportunity 
for cross-border cooperation but these were not sufficiently established within the scheme.  

5.1.2 The geographical scope  

It is observed that the geographical scope and distribution of the labelled sites in the EU action 
has narrowed in comparison with the intergovernmental EHL. This has occurred  due to the EU 
action  being  only  open  to  Member  States,  therefore  Switzerland  was  not  eligible  to  continue 
participating.  Secondly,  the  selection  process  at  the  EU  level  appears  to  be  a  barrier  to  the 
geographical  distribution  of  EHL  sites.  Currently,  Denmark,  Bulgaria,  Cyprus,  Latvia  and 
Slovakia, all of which held the Label under the previous initiative, have no sites that have passed 
the selection at the EU-level.  

AUSTRIA (2) 

BELGIUM (2) 

Archaeological Site of Carnuntum 
Imperial Palace Viena 
Mundaneum 

2013 
2015 
2015 

14  2018 Annual work programme for the implementation of the Creative Europe Programme. C(2017)6002 

of 6 September 2017, p.10.  

15 

 
 
 
 
                                                           
2017 
2015 
2015 
2013 
2015 
2014 
2014 
2015 
2017 
2014 
2014 
2017 
2017 

2014 
2014 
2015 
2017 
2014 
2017 
2014 
2017 
2013 
2013 
2017 
2014 
2014 
2014 
2015 
2014 
2014 
2015 
2017 
2014 
2017 
2014 
2014 

CROATIA (1) 
CZECH REPUBLIC (1)  Olomouc Premysild Castle and Archdiocesan Museum 
ESTONIA (2) 

Bois du Cazier 
Neanderthal Prehistoric Site and Krapina Museum 

Great Guild Hall 
Historic Ensemble of the University of Tartu 
Abbey of Cluny 
Robert Shuman’s House 
European District of Strasbourg 
Former Natzweiler concentration camps (with GERMANY) 
Sites of the Peace of Westphalia (1648) 
Hambach Castle 
Leipzig’s Musical Heritage Sites 
Former Natzweiler concentration camps (with FRANCE) 

FRANCE (4) 

GERMANY (4) 

GREECE (1) 
HUNGARY (3) 

ITALY (2) 

LITHUANIA (1) 
LUXEMBURG (1) 
NETHERLANDS (3) 

POLAND (4) 

PORTUGAL (3) 

ROMANIA (1) 
SLOVENIA (2) 

SPAIN (2) 

Heart of Ancient Athens 
Pan-European Picnic Memorial Park 
Franz Liszt Academy of Music 
Dohany Street Synagogue Complex 
Alcide de Gasperi’s House Museum 
Fort Cadine 
Kaunas of 1919-1940 
Village of Schengen 
Peace Palace 
Camp Westerbork 
Maastricht Treaty 
Union of Lublin (1569) 
3 May 1791 Constitution 
Historic Gdansk Shipyard 
World War I Eastner Front Wartime Cemetery No.123 
General Library of the University of Coimbra 
Charter of Law for the Abolition of the Death Penalty 
Sagres Promontory 
Sighet Memorial 
Franja Partisan Hospital 
Javorca Memorial Church and its cultural landscape 
Archive of the Crown of Aragon 
Student Residence 

16 

 
 
 
4

3

2

1

0

Member States with EHL Sites 

EHL Sites

However,  the  EU-level  action  has  attracted  Member  States  that  were  not  previously  involved, 
including  Austria,  Croatia,  Estonia,  Luxembourg,  and  the  Netherlands.  Currently,  the  EU 
initiative has 38 sites (2013-2017) in 18 countries while the previous initiative had 68 sites in 19 
countries  (2006-2011).  In  conclusion,  the  geographical  location  has  narrowed  under  the  EU 
action and has not resulted in the participation of all Member States.  

This evaluation identified that the biggest difference between the objectives of selected and non-
selected sites was the European dimension. 89% of selected sites describe sensitizing to the site’s 
European values and history’ as one of their objectives while only 10% of non-selected choose 
this. These findings confirm the relevance and defining role of the first selection criteria for the 
EHL action.  

17 

 
 
 
  
5.2 Coherence 

The 2010 Impact Assessment found that EHL differs from other initiatives and has the potential 
to  add  value  in  terms  of  a  European  dimension,  pedagogy  and  networking.15  The  evaluation 
found that the EHL is a distinctive initiative within the EU. The Label places emphasis on raising 
European  citizens’  awareness  of  European  history  and  culture  rather  than  emphasis  on  the 
preservation  of  sites.  Analysis  of  other  EU  and  international  initiatives  revealed  that  the  Label 
shares  similarities  with  other  EU  initiatives  and  programmes  in  the  cultural  field:  European 
Capitals  of  Culture  (ECOC)16,  Europe  for  Citizens17,  and  Cultural  Routes  of  the  Council  of 
Europe.18 The EHL is complementary to the ECOC, as EHL activities can be viewed as further 
enhancing the European dimension of cultural heritage sites, which receive less coverage in the 
ECOC action. The data collected revealed some examples of complementary activities between 
the EHL and ECOC at the national level. The ECOC title was awarded to Mons, Belgium (2015), 
while  the  EHL  was  awarded  to  the  Mundaneum19  in  Mons,  and  the  site  participated  in  events 
organized  in  the  ECOC  year.  The  Mundaneum  reported  in  its  2016  monitoring  form  that  the 
ECOC had helped it develop a dialogue with artists.  

The  analysis  revealed  potential for  establishing  synergies  with  EU  programmes  in the fields  of 
culture,  education  and  citizenship  (e.g.  Europe  for  Citizens  programme,  Erasmus+  programme, 
European Capitals of Culture, etc.).  The Erasmus+ Key Action 1 provides mobility opportunities 
for students to undertake traineeships in other EU states. Labelled sites could use this opportunity 
to  host  trainees  with  relevant  skills  such  as  translation,  conservation  or  education,  -  thus 
increasing  their  operation  capacity  and  engaging  youth.  Key  Action  2  of  Erasmus+  provides 
opportunity under Strategic Partnerships, which could also be explored by EHL sites. The EHL 
could also benefit from the increasing number of mobility opportunities established in the New 

15  Impact Assessment. 
16  European Capitals of Culture, was developed in 1985 and has, to date, been awarded to more than 
50 cities across the European Union. European Capitals of Culture are formally designated four years 
before  the  actual  year.  The  idea  is  to  put  cities  at  the  heart  of  cultural  life  across  Europe.  Through 
culture and art, European Capitals of Culture improve the quality of life in these cities and strengthen 
their sense of community. Citizens can take part in the year-long activities and play a bigger role in their 
city’s  development  and  cultural  expression.  Capitals  of  Culture  highlight  the  richness  of  Europe’s 
cultural  diversity  and  take  a  fresh  look  at  its  shared  history  and  heritage.  They  promote  mutual 
understanding and show how the universal language of creativity opens Europe to cultures from across 
the world. 

17  Europe for Citizens Programme adopted for the period 2014-2020 is an important instrument aimed at 
getting the Union’s 500 million inhabitants to play a greater part in the development of the Union. By 
funding schemes and activities in which citizens can participate, the Programme is promoting Europe’s 
shared history and values, and fostering a sense of ownership for how the Union develops. 

18  Cultural Routes of the Council of Europe are transnational  grass-roots networks.   Since 1987, they 
act  as  channels  for  intercultural  dialogue  and  promote  a  better  knowledge  and  understanding  of 
European shared heritage. Over 30 networks certified "Cultural Route of the Council of Europe" provide 
a wealth of leisure and educational activities across Europe and beyond. They cover a range of different 
themes such as architecture, cultural landscape, gastronomy or major figures of European art, music and 
literature. Through its programme, the Council of Europe offers a model for transnational cultural and 
tourism management and allows synergies between national, regional and local authorities and a wide 
range  of  associations  and  socio-economic  actors.  The  networks  crossed  more  than  50  countries  in 
Europe and beyond, and federate over 1600 members working towards cultural democracy and diversity 
but also mutual understanding and exchanges across boundaries. 

19  A  landmark  in  the  intellectual  and  social  fabric  of  Europe.  The  Mundaneum’s  aim  was  to  gather  all 
information  available  in  the  world,  regardless  of  its  medium  (books,  newspapers,  postcards…)  and  to 
classify it according to a system the fondateurs developed: the Universal Decimal Classification. 

18 

 
                                                           
European Agenda for Culture20, for which the Commission launched an open call to prepare the 
ground for a mobility scheme in the creative and cultural sectors from 2021 onwards in the next 
generation of EU programmes.21 

Risk of overlap was revealed in the evaluation with the Cultural Routes of the Council of Europe, 
with  substantial  similarities  between  the  objectives  pursued  by  the  two  actions.  While  some 
similarities  exist  in  terms  of  processes,  differences  are  evident  with  respect  to  the  actions’ 
outputs. The evaluation identified a trend within the EHL to award the Label more frequently to 
sites  that focus  on  the  20th  century,  while  Cultural  Routes  display  little  focus  on  this  historical 
period.  The  design  of  the  EHL  allows  the  recognition  of  sites  that  are  important  to  European 
integration,  culture or  history,  but  which  do  not  possess  many  thematic  connections  with  other 
places  in  Europe  unlike  the  Cultural  Routes.  Some  interviewees  and  OPC  respondents 
highlighted similarities between the EHL and UNESCO programmes. However, the mapping of 
objectives  revealed  little  overlap  between the  programmes.  The  UNESCO  World  Heritage  List 
emphasises the preservation of sites and awards sites based on their Outstanding Universal Value 
(OUV), promoting a panhuman approach to cultural heritage while the EHL places less emphasis 
on preservation and instead focuses on raising European citizens’ awareness of European history 
and culture.  

20  A New European Agenda for Culture, COM (2018) 267, 22.05.2018.  
21  European  Commission,  Mobility  Scheme  for  Artists  and/or  Culture  Professionals.  Available  at: 

https://ec.europa.eu/programmes/creative-europe/calls/eac-18-2018_en  

19 

 
 
 
                                                           
Given  that  the  EHL  is  a  recent  initiative,  it  can  be  assumed  that  greater  synergies  will  be 
developed  in  the  upcoming  years.  Great  synergies  were  already  developed  in  2018  with  the 
launch  of  two  different  calls  that  offer  potential  benefits  to  the  EHL  action  and  its  sites  –  the 
European Heritage Stories and the call to support networking and cooperation among EHL sites. 
The  call  for  European  Heritage  Stories  is  a  pilot  initiative  that  aims  to  identify  the  European 
dimension of heritage sites and heritage work undertaken by communities in Europe. The call is 
associated with the European Year of Cultural Heritage (EYCH) 2018.22 The call was open to the 
winners of the EU Prize for Cultural Heritage/Europa Nostra Award as well as EHL sites. The 
total  budget  of  this  action  is  EUR  100,000,  which  allowed  for  10  grants  of  EUR  10,000  to  be 
awarded  to  different  projects.23  The  five  EHL  sites  that  were  successful  in  receiving  the  grant 
were: Heart of Ancient Athens (Greece); Camp Westerbork (Netherlands); Historic Ensemble of 
the University of Tartu (Estonia); and a joint application by the Peace Palace (Netherlands) and 
the Mundaneum (Belgium). The second call was launched by the Creative Europe programme in 
2018  and  was  dedicated  to  the  design  and  management  of  networking  and  capacity  building 
activities  for  EHL  sites.24  The  Commission  will  fund  one  project  within  the  designated  EUR 
500,000 budget. Applications may be submitted either by a consortium including a minimum of 
10 EHL-awarded sites, or by a single legal entity with at least 10 EHL sites as stakeholders.  

5.3 Efficiency and governance  

5.3.1 Application Form 
Since the EHL has become an EU-level action, the Commission has reviewed and improved the 
application form several times. The 2013-2015 selection forms were too complex, and two-thirds 

22  European  Heritage  Days,  Call  for  European  Heritage  Stories.  Terms  and  Conditions,  p.2.  Available  at 
https://www.europeanhertiagedays.com/App_Documents/Uploads/files/JEP(2018)02EN%20Call%20for
%20European%20Heritage%20Stories%20TCs%2012Apr18%20a.pdf 
23  European Heritage Days (2018b), European Heritage Stories. Available at: 

http://www.europeanheritagedays.com/Story/  

24  Creative Europe, Design and management of networking and capacity building activities for European 
at: 

Heritage 
for 
https://ec.europa.eu/programmes/creative-europe/sites/creative-europe/files/2018-s39-
specifications_en.pdf 

EAC/S39/2018. 

Proposals 

Available 

Label 

sites. 

Call 

– 

20 

 
 
 
 
                                                           
 
of  the  site  managers  interviewed  expressed  that  the  form  was  too  long,  repetitive  and  time-
consuming. A new version of the form was introduced in 2017. The 2017 Panel Report indicated 
that the new form was shorter and easier for candidates to fill-in but could be further improved. 
Analysis  during  the  evaluation  procedure  revealed:  overlap  between  the  project  and  work  plan 
sections  (communication  activities  planned  to  undertake  to  highlight  its  European  significance 
II.B.I and II.C.5 of the form, information activities II.B.2 and II.C.3). The 2017 application form 
also posed difficulties for national thematic and transnational sites to demonstrate how the efforts 
of different sites/institutions will be coordinated, and required each site of national thematic and 
transnational sites to each fill in separate application forms.  

5.3.2 Efficiency of selection arrangements 

The analysis revealed that the action has attracted applicants of diverse types. The figure 
below  demonstrates  the  visual  representation  of  the  labelled  sites  by  the  type(s)  of  cultural 
heritage they represent.  

The analysis yields no negative effects stemming from the EHL’s current eligibility categories. 
The current eligibility criteria as set out in the Decision allow for all types of sites be attributed 
the label as long as the sites have a symbolic European value and played a significant role in the 
history and culture of Europe and/or the building of the Union.25 The evaluation considers this an 
advantage in attracting and uniting a variety of potential sites for the Label.  

The Impact Assessment anticipated that the EU-level action would increase the involvement of 
transnational  sites  in  comparison  to  the  intergovernmental  action.26  The  data  collected  did  not 
indicate  a  clear  reason  behind  the  low  level  of  participation  by  national  thematic  and 
transnational  sites.  Several  factors  may  contribute  to  the  trend  including:  the  lack  of 
understanding of how to prepare the application, and coordination between states as all entities 
applying  for  designation  must  fill information  on  their  sites  individually.  A  revised  application 
form for the 2017 selection process was introduced but the application could be further unified 
and simplified.  

25  For  the  purpose  of  the  Decision,  “sites”  means  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 (Article 2 of the Decision 
No 1194/2011/EU). 

26 SEC(2010) 198. 

21 

 
 
                                                           
The  introduction  of  common  selection  criteria  was  developed  for  the  EHL  upon  the  initiative 
commencing as an EU-level action. The introduction of a common selection criteria ensures the 
relevance of the sites to the European Heritage Label’s objectives, as the designated sites must 
clearly define their European significance and commit to implementing activities that achieve the 
action’s objectives. Analysis of the evaluation demonstrates that of the sites labelled in the 2013-
2017  period,  34  out  of  the  28  sites  were  able  to  demonstrate  their  European  significance.  The 
common  selection  criteria  clarifies  the  type  of  sites  represented  by  the  action  and  positively 
contributes to the action’s identity.  

The figure demonstrates that the criterion of European significance provides a framework and the 
main  categories  of  which  the  European  significance  of  a  site  may  be  defined.  Further  analysis 
conducted in  the  evaluation  demonstrates that  candidate  sites  still  have  difficulty  in  expressing 
their  European  dimension,  and  the  Commission  plans  on  assisting  candidate  and  existing  sites 
develop  their  narrative.  Analysis  of  the  selection  criteria  demonstrated  that  while  managers  of 
sites  and  OPC  respondents  deemed  the  selection  criteria  clear,  data  from  interviews  and  focus 
groups found that the criterion of European significance was ambiguous and resulted a significant 
challenge for a majority of non-selected sites. The analysis of the four selection cycles between 
2013 and 2017 found that 38 out of 50 non-selected sites failed to meet the criterion. While the 
legal  basis  does  not  establish  a  hierarchy  of  the  criteria,  the  European  significance  has  been 
assumed as the core criterion, so if a site failed to demonstrate the European dimension it would 
not be in a position to achieve the action’s objectives. Currently, the Panel evaluates the projects 
and work plans of candidate sites who fail to demonstrate the European significance, rendering 
this part of the process inefficient.  

If multiple sites meet the EU-level selection criteria, Article 11-2 of Decision No 1194/2011/EU 
specifies that the European panel shall select a maximum of one site per participating Member 
State in each selection year. However, the Decision does not establish how the decision should be 
made if two sites from a Member State are pre-selected at the national level and both meet the 
criteria for selection at the EU-level. The Decision also does not clarify if Article 11-2 should be 
applied  to  transnational  sites.  In  2017,  the  Panel  awarded  two  sites  in  Germany  (Leipzig’s 
Musical  Heritage  Sites  and  the  Former  Natzweiler  concentration  camp  and  satellite  camps  –  a 

22 

 
 
 
transnational  application  made  by  France  and  Germany).27  The  lack  of  clarity  in  the  article’s 
application  hinders  the  transparency  of  selection  decision.  Panel  Reports  from  2015  and  2017 
suggest that if the legal basis is reviewed, it should consider removing the limit of one  site per 
Member  State  per  selection  year.28  Based  on  the  evaluation  findings,  stakeholders  concur  the 
sentiment  and  view  Article  11-2  in  a  negative  light.  The  national  quotas that  were  expected  to 
ensure equal distribution of the Label have instead hindered the process.  

At the pre-selection level, national coordinators filter the applications to identify the sites that are 
most  relevant  to  the  Action’s  objectives.  The  coordinators  should  be  evaluating  the  extent  to 
which the national sites meet the selection criteria and the EU level. The analysis shows that half 
of  all  nationally  pre-selected  sites did  not  qualify  for  selection  at the  EU level. Between  2013-
2017, the EHL was awarded to 38 out of 75 pre-selected sites, a selection rate of 51%. 29  If the 
selection criteria was applied adequately at the national level, the pre-selected sites should also 
meet the criteria at the EU level and receive the label unless Article 11-2 is applied.  

The  EU-level  selection  is  carried  out  by  a  European  panel  consisting  of  13  members;  four 
appointed by the European Parliament; four by the Council; four by the Commission; and one by 
the Committee of Regions as stipulated by the legal basis. Analysis of interviews with European 
panel members concludes that the overall operation of the Panel is smooth.  

Post-selection,  managers  of  selected  sites  and  most  OPC  respondents  perceived  the  EU-level 
selection  procedures  to  be  transparent.  However  non-selected  sites  deemed  the  feedback 
insufficient. In order to make the panel’s feedback on European significance more specific, the 
evaluation recommended the use of sub-criteria as follows: 

-What is the cross-border or pan-European nature of the site? 

-What is the site’s past and present influence that goes beyond national borders? 

-What was the site’s role in European history and integration? 

-What were its links with key European events, personalities, or movements? 

-What values that underpin European integration does it represent? 

-What was the site’s role in developing or promoting these values? 

The sub-criteria and more specific feedback results in a guiding approach that would encourage 
applicants to re-apply. In addition, to increase the transparency of the action, scholars recommend 
making  successful  applications  either  fully  or  partially  public  (following  the  ECOC  action  and 
UNESCO  Heritage  Lists).  This  suggestion  could  not  be  implemented  under  the  current 
arrangements of the action, as selected sites do not currently agree to have their application forms 
made public.  

5.3.3 Efficiency of the monitoring process 
A monitoring process was established when the EHL became an EU-level action as no previous 
monitoring process existed when the action was an intergovernmental initiative. Member States 
are responsible for the monitoring of all sites and must submit a report every four years to the 

27  2017 Panel Report. 
28  2015 Panel Report; 2017 Panel Report. 
29  2017 Panel Report. 

23 

 
 
 
 
 
 
 
                                                           
European  Panel,  via  the  Commission.30  The  first  monitoring  year  in  2016  covered  the  20  sites 
that had received the Label in 2013 and 2014. The monitoring was report and dialogue based and 
required  sites  to  report  on  the  progress  of  the  EHL  activities  they  had  proposed  in  their 
application forms and outlining new activities for the 2016-2020 period. Participating sites were 
required  to  present  to  the  Panel  and  other  EHL  sites  their  activities  as  well  as  participate  in  a 
discussion with panel members.31 In its current form, the monitoring process is appropriate with 
the relatively small number of sites, however it could become less practical if the EHL fulfils the 
vision outlined in the 2017 Panel Report and expands to 100 sites.32 Since the monitoring process 
is not outlined in the legal basis, the Panel could consider altering the approach.  In the current 
form, the 2016 monitoring process was perceived positively by sites and panel members, 14 out 
of the 20 sites perceived it to be useful. OPC results support the conclusion, as most respondents 
engaged  in  the  action  perceived  the  monitoring  as  helpful  in improving  sites’  performance. To 
date, no EHL site has lost the Label.  

The  2016  monitoring  form  included  four  parts:  I)  an  updated  original  monitoring  sheet;  II)  a 
feedback sheet on benefits and challenges; III) a monitoring form for the next monitoring period 
(2016-2020); IV) a communication and network sheet. The analysis of the monitoring data shows 
that  most  EHL  sites  demonstrated  the  capacities  to  participate  in  the  monitoring  process.  The 
Panel recommended in the 2016 Monitoring Report that the form should be revised for 2020 to 
make it more user-friendly.33 Additionally, the national-thematic site had been required to submit 
two  separate  monitoring  forms,  like  the  application  forms,  and  to  lighten  the  administrative 
burden  posed  to  national-thematic  and  transnational  sites.  It  is  recommended  this  process  be 
revised.  

5.3.4 Efficiency of communication processes 
One  of  the  main  arguments  for  establishing  the  EHL  as  an  EU-level  initiative  was  the  need  to 
improve its visibility and raise its profile.34 The communication of the EHL can be viewed as a 
three-level process, the framework of which was initiated at the beginning of the action. Analysis 
of  the  communication  process  reveals  that  EHL  sites  have  not  made  extensive  use  of  the 
communication  tools  provided  by  the  Commission.  Visibility  of  the  EHL  remains  low,  but 
stakeholders  involved  in  the  action  perceive  it  has  improved  in  comparison  with  the 
intergovernmental  label.  Analysis  of  OPC  results  supports  these  conclusions,  as  only  16%  of 
respondents not involved in the action shared the same understanding and knowledge of the EHL. 
The  data  collected  during  focus  group  and  interviews  suggests  that  the  Label  is  not  widely 
recognized among the general public, and even among cultural heritage professionals. Therefore, 
the Commission needs to emphasize the branding and visibility of the Label. These findings are 
important as 65% of OPC respondents expressed interest in learning more about the EHL action.  

OPC  data  also  demonstrates  that  visitors  to  the  EHL  sites  acknowledge  their  European 
significance and the majority of respondents involved in the action agree that progress has been 
made in highlighting the European significance of EHL sites. The respondents felt that real-life 
communication  measures  (exhibitions,  guided  tours,  etc.)  are  the  most  effective  way  to  reach 
target audiences. Within the action, the Commission has established the EHL days, consisting of 
three-day  annual  meetings  with  national  coordinators  and  the  EHL  sites,  that  were  viewed 

30  Article 15(3) of the Decision No. 1194/2011/EU. 
31  2016 Monitoring Report, p. 45.  
32  2017 Panel Report. 
33  2016 Panel Report, p.33. 
34  Impact Assessment. 

24 

 
                                                           
favourably by interviewees and focus group participants, but EHL managers viewed the days as 
insufficient in terms of frequency and the exchange formats provided at the meeting.  

5.4 Effectiveness 

5.4.1 Extent of achievement of specific objectives 
The EHL has made some progress in reaching its two objectives in its early years of the Action. 
The OPC results demonstrate that 71% of respondents who visited EHL sites directly or online 
agreed that the visit had strengthened their sense of belonging to Europe. Progress has been made 
towards  its  second  objective-  strengthening  intercultural  dialogue  is  visible  but  could  be 
enhanced.  

In  the  interviews  conducted,  25  of  the  29  site  managers  reported  they  could  fully  or  partly 
implement the activities included in their EHL project as laid out by Article 3.3 of the Decision. 
This  contrasted  with  the  responses  by  the  OPC  respondents  had  a  mixed  view  of  the  progress 
made  by  EHL  sites  towards  their  objectives.  The  most  progress  was  perceived  in  the  site 
objectives  of  highlighting  their  European  significance  and  increasing  access  to  sites  through 
digital tools.  

Activities  undertaken  by  sites  included:  communication  activities;  education  activities; 
information activities; activities to improve access; cultural activities; and collaboration activities 
with  other  EHL  sites.  Most  Label  sites  were  able  to  implement  five  or  six  different  types  of 
activities,  while  a  minority  implemented  between  two  to  four.  The  2016  monitoring  data 
concluded  that  all  sites  implemented  communication  activities  and  all  sites  display  the  EHL 
plaque on-site. The biggest obstacle to sites implementing activities was operational capacities, 
size  and structure  therefore  affecting  the  quantity  and  complexity  of  the  activities the sites  can 
implement.  This  was supported  by  data collected  in the  2016  monitoring  process.  16  of  the  20 
sites  provided  feedback  that  receiving  no  additional  financial  support  for  EHL  activities  was  a 
challenge.  The  analysis  of  the  interview  data  supported  this  analysis,  with  20  site  managers 
noting the implementation of activities was difficult or unsuccessful due to a lack of finances.  

The table below details responses to question on the benefits and challenges of receiving the EHL 
label: 

BENEFITS OF AN EHL SITE 

CHALLENGES OF AN EHL SITE 

  Media attention at local, national, and 

international levels. 

  Strengthened 

local 
evoking of the European dimension. 

support 

and 

  Greater  integration  into  Europe  and 
becoming  part  of 
a  European 
network,  exchange  with  other  EHL 
sites. 
Increased  visibility  for  the  site  and 
awareness  about  the  site  among  the 

 

 

 

Insufficient 
from  other 
funding 
bodies  (national  and  EU  institutions, 
non-governmental institutions, etc.).  
Insufficient  financial  assistance  from 
the  EHL  for  the  implementation  of 
the project, increasing of multilingual 
tools and staff training. 
  Low visibility of the EHL. 

 

Insufficient  human 
implement activities. 

resources 

to 

25 

 
 
 
local  population,  especially  young 
people. 
Increased  visitor  numbers  and  social 
media followers. 

 

  Undeveloped 

infrastructure 

the 
region may hinder accessibility to the 
site. 

in 

  The Label as a sign of quality. 
  Support 

for 

the 

  Developing the EHL network. 
 
Increasing number of visitors. 

protection/preservation of the site. 

  Additional funding sources. 

Another positive benefit noted was the collaboration between labelled sites. There have been 13 
collaborations and three exchange projects between EHL sites from different Member States. In 
total,  16  out  of  29  sites  were  involved  in  these  projects.  A  best  practice  to  be  identified  is  the 
collaboration of the Franz Liszt Academy of Music and the Peace Palace. The two sites found a 
common  theme  and  established  a  collaborative  event  with  Hague  Music  Academy  in  2016 
consisting of joint lectures and a concert. As the event was perceived as a success, a second event 
took place in 2017. To further strengthen collaboration, a network of sites should be developed. 
Also identified in the interviews was the need for the establishment of common themes to further 
promote collaboration activities.  

One of the aims of the EHL is to increase intercultural dialogue, and monitoring data shows that 
22  sites  implemented  activities  on  the  topic.  However,  some  of  the  experts  interviewed 
questioned whether multilingualism alone could be classified as intercultural activity and whether 
it  supports  the  aim  of  strengthening  intercultural  dialogue.  It  was  made  clear  in  the  interviews 
that  not  all  of  the  site  managers  had  a  clear  understanding  of  the  definition  of  intercultural 
dialogue, leading to diverse interpretations. Further analysis of the topic using a combination of 
monitoring  data  and  interviews  leads  to  the  conclusion  that  15  sites  could  be  identified  as 
implementing or planning to implement educational activities that directly promote intercultural 
dialogue  as  defined  by  the  Commission.  An  example  of  these  is  the  project  “Lab  Europe” 
organized  by  the  Peace  of  Westphalia  site  in  Osnabruck  implemented  in  2018.35  The  project 
involved inviting 51 young people (ages 18-25) from other cities with EHL sites and from other 
European  countries  to  participate  in  an  exchange  of  ideas  and  work  creatively  on  different 
European topics. The project supported co-operation between different EHL sites and promoted 
the  Label.  The  respondents  in  OPC  did  not  recognize  such  progress  in  sites’  overall  and  were 
doubtful about many sites’ progress in increasing intercultural dialogue (9 out of 24 respondents 
involved  in  the  action  recognized  some  progress,  while  9  respondents  saw  minimal  progress). 
91%  of  OPC  respondents  felt  that  the  EU  needs  to  put  efforts  into  strengthening  intercultural 
dialogue.  The  Commission  will  seek  to  explore  ways  to  enhance  the  site  manager’s 
understanding of and the commitment to strengthening intercultural dialogue to better contribute 
to the general objectives of the action as this aim has not yet been fulfilled.  

5.4.2 Action’s achievement of general and intermediate objectives 
The methods used to identify evidence for this section are desk research (analysis of monitoring 
and site-specific data, and the Panel Report 2016), interview and focus group analysis, and the 

35  City  of  Osnabruck  –  The  Lord  Mayor  (2018),  Lab  Europe.  Available  at:  https://www.lab-europe-

osnabrueck.de/  

26 

 
 
 
 
                                                           
OPC  analysis.  The  effectiveness  of  general  and  intermediate  goals  can  mainly  be  assessed  by 
analysing  the  achievement  of  site-level  objectives.  A  majority  of  interviewees  and  focus  group 
participants felt that the EHL goals needed more time to be achieved as the action is still in its 
early  stages.  More  than  half  of  OPC  respondents  involved  in  the  action  believed  that  some  or 
significant progress has been made by the EHL goals. More progress was perceived in stressing 
the symbolic value and raising the profile of the sites. In  general, 92% of all OPC respondents 
agreed that a visit to any of the EHL sites had improved their understanding of European history 
and culture and had encouraged them to learn more. 71% of respondents also stated that a visit to 
an EHL site had strengthened their sense of belonging to Europe.  

5.4.3 Sustainability of the positive effects 
As  the  first  EHL  sites  at  the  EU-level  action  were  selected  in  2013,  it  is  not  yet  possible  to 
analyse the sustainability of positive effects created by the action. The analysis conducted in the 
evaluation  of  interviews  and  focus  groups indicates the  likelihood  of sustaining  project results, 
based  on  the  intervention  logic.  Therefore,  the  assessment  focuses  on  the  necessary  pre-
conditions  for  the  sustainability  of  the  action’s  efforts,  including:  the  status  of  the  Label;  the 
operational  capacity  of  the  labelled  sites;  the  expertise  needed  to  achieve  the  objectives  of  the 
action; and networking with partners.  

In interviews, there was strong consensus among national coordinators that potential funding for 
the  EHL  sites  as  a  key  element  in  securing  long-term  effects  and  in  raising  the  impact  of  the 
action. While  panel  members  expressed  that  capacity  building  and  embedding  of  the site in  its 
local environment would ensure sustainability. Improved communication was also identified as a 
key measure to ensure the sustainability of the action.  

Analysis  of  the  OPC  data  provides  findings  in  terms  of  necessary  pre-conditions.  All  24 
respondents  believed  that  funding  would  help  to  develop  cooperation  projects  and  to  share 
knowledge; 23 out of 24 respondents supported the idea of grants to the sites to reinforce their 
operational  capacity  and  develop  education  activities.  All  OPC  respondents  agreed  that  a  pilot 
project in the field would be a valid measure. Besides these key measures, establishing a network 
is consistently perceived as a key factor in the sustainability of the action.  

5.5 EU added value  

The  added  value  provided  by  the  action  at  the  EU-level  is  the  promotion  of  the  European 
significance  of  the  Label  sites.  The  establishment  of  the  first  criterion,  having  a  symbolic 
European  value  and  playing  a  significant  role  in  the  history  and  culture  of  Europe,  and/or  the 
building  of  the  Union  demonstrates  the  added  value.  The  interviews  supported  this  as  national 
coordinators  and  representatives  of  both  selected  and  non-selected  sites  possess  good 
understanding of the significance of cultural heritage on European integration. Common  values 
and  common  European  identity  are  main  components  for  strengthening  European  integration. 
The  interviewees  believed  the  EHL  could  support  integration  by  filling  the  abstract  notion  of 
values with concrete content. In the OPC responses, 18 out of 24 sites were found to demonstrate 
their European significance. Analysis of the responses demonstrated that the communication of a 
European  narrative  is  not  implemented  by  all  the  sites,  and  is  influenced  by  national  priorities 
that could be developed by strengthening projects, monitoring and evaluation.  

27 

 
 
 
The  Impact  Assessment  detailed  assumptions  about  the  added  value that  would  result from  the 
change from the intergovernmental to EU action. It was expected that EU’s involvement would 
improve  the  functioning  and  visibility  of  the  EHL;  strengthen  networking  among  its  sites; 
enhance  coordination  between  Member  States  and  strengthen  their  commitment;  and  develop 
clear  and  transparent  selection  criteria  and  monitoring  procedures.36  The  Evaluation  report 
reveals that the EHL still suffers from a lack of visibility and 65% of the OPC respondents would 
like to learn more about the action. There was clear added value in cooperation between Member 
States as one-half of sites had already implemented collaboration projects, but hope to see further 
strengthening  of  the  networks  by  the  Commission.  OPC  respondents  who  were  engaged  in  the 
action  perceived  it  had  changed  positively  since  its  transformation  in  2011.  All  sites  reported 
gains  from  being  awarded  the  EHL,  including  increase  in  media  attention,  strengthened  local 
support, increased visibility and participation in the network. Respondents viewed termination of 
the action as premature, the majority believed this would send a negative message to the sites and 
to the cultural heritage sector.  

6.  CONCLUSIONS 

The  Commission  concludes  that  the  main  objectives  of  the  EHL  –  strengthening  European 
citizen’s sense of belonging to the Union – and strengthening intercultural dialogue remain 
highly relevant to the current needs to the EU and are in line with the objectives of the New 
European  Agenda for  Culture37  and  a  rising  interest  in  culture  and  cultural heritage  among  EU 
citizens.  This  document  is  accompanied  by  the  report,  ‘Evaluation  of  the  European  Heritage 
Label’ that sets forth a list of recommendations with a view of furthering developing the action to 
reach its full potential. The findings of the evaluation show that the Action should continue to be 
developed, but its geographical scope should not expand beyond the EU until the action becomes 
well-established. The evaluation found the action’s EU added value may be limited by its scope 
being too narrow but a termination of the action was determined to be premature. It would send a 
negative  signal  to  citizens,  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.  

36  Impact Assessment, p.11.  
37  A New European Agenda for Culture, COM (2018) 267 final, 22.05.2018.   

28 

 
 
 
 
                                                           
ANNEX 1: PROCEDURAL INFORMATION 

1.  LEAD DG, DeCIDE PLANNING/CWP REFERENCES 

The  evaluation  was  led  by  Directorate  General  for  Education,  Youth,  Sport  and  Culture  (DG 
EAC).  It  is  included  in  the  Work  Programme  of  Creative  Europe  for  2017  and  in  the  Agenda 
Planning with the reference EAC-2017-0507. 

2.  ORGANISATION AND TIMING 

The evaluation was supported by an external and independent evaluator, under a service contract. 
The service contract was implemented via a Framework Contract (EAC/22/2013) with reopening 
of competition and in accordance to the Financial Rules Applicable to the General Budget of the 
Union and its Rules of Application. 

The  evaluation  Roadmap  was  adopted  on  May  2017  and  published38.  A  Steering  Committee 
including  staff from  DG  EAC  and  from  the  Secretariat  General  was  established  on  May  2017. 
The Steering Committee met in three occasions: to kick off the Agenda on 7th December 2017; to 
approve the Inception Report on 22th January 2018; to discuss the Draft Interim Report on 18th 
June 2018; and to approve the final report in July 2018. Extensive correspondence between the 
Steering Committee members was held in between the meetings to follow-up on the evaluation. 
The evaluation initial schedule foresaw a final report in the fourth quarter of 2018. Due to the late 
availability  of  data  used  for  the  evaluation,  it  was  agreed  to  delay  the  submission  of  the  final 
report to January 2019. 

The evaluation was not submitted to the Regulatory Scrutiny Board, as it not considered a major 
evaluation,  does  not  contain  an  impact  assessment  and  does  not  constitute  a  fitness  check  for 
legislation. 

3.  EXCEPTIONS TO THE BETTER REGULATION GUIDELINES 

None. 

4.  EVIDENCE, SOURCES AND QUALITY 

The 2018 Evaluation of the EHL used a series of data sets to inform its findings. The main ones 
being: 

-  An  open  public  consultation  at  European  level.  The  consultation  was  published  in  the 
relevant  Commission’s  website in  English,  German  and  French  and  was opened  for  12 
weeks. 

-  Consultations with a sample of selected and non-selected sites, the national coordinators, 

the experts of the panel and some stakeholders in the area of heritage. 

38  https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2017-3383232_en.  There  were  only  two 
feedbacks, both coinciding that EHL has a very small number of sites due to the restriction of only two 
sites per country/selection  year, and proposed to open the registration process to NGOs bypassing the 
national coordinators. 

29 

 
                                                           
 
 
-  The  evaluation  was  performed  in  accordance  with  the  European  Commission’s  Better 

Regulation Guidelines. 

-  The  evaluation  has  been  based  on  recognised  evaluation  techniques,  as  well  as  those 

stemming from the emerging domain of big data analytics when relevant. 

-  Secondary data has been obtained from all existing literature relevant to the evaluation 

subject, including any existing robust (academic) research into the topic. 

-  Primary  data  has  been  obtained  from  the  broadest  variety  of  sources  and  include  the 
views  of  key  informants  beyond  those  directly  involved  in  and  benefiting  from  the 
intervention. 

30 

 
 
 
 
 
ANNEX 2: STAKEHOLDER CONSULTATION 

1. METHODOLOGY USED 

The consultation activities described in this synopsis report were conducted in the context of the 
evaluation of the European Heritage Label Action during its first six years of its existence (2011-
2017). The consultations sought to collect information and stakeholders’ views on the evaluation 
criteria (relevance, effectiveness, efficiency, sustainability, coherence and EU added value. The 
relevant stakeholders were mapped at the early stage of the evaluation and are described below. 

2. OVERVIEW OF CONSULTATION METHODS AND CONSULTEES 

The methodological approach used involved the use of two types of data collection: desk research 
and stakeholder consultation. The latter included an open public consultation (OPC), interviews 
and  focus  groups.  Quantitative  data  was  collected  via  the  OPC  and  desk  research  while 
qualitative  data  was  obtained  through  interviews,  focus  groups  and  desk  research.  The  table 
below provides an overview of the types of stakeholders consulted. 

Type of consultation 

Type of Consultee 

High-level interviews 

In-depth interviews 

Focus group 

  European Commission officials. 
  Members of the European panel of experts. 

  National coordinators. 
  Managers  and  senior  staff  members  from 
labelled  and  pre-selected  but  non-selected 
sites. 

  Stakeholders of other actions (e.g. European 
Routes  of  Industrial  heritage,  European 
Institute of Cultural Routes, etc.). 

  National coordinators. 
  Managers  or  senior  staff  members  from 

labelled sites. 

  Stakeholders  or  local  or  national  networks, 
institutions  and  organisations  related  to  the 
labelled sites. 

Open public consultation (OPC) 

Online questionnaire  was open to any interested party or 
individual over a period of 12 weeks, available in English, 
French and German. 

31 

 
 
Interviews 

Interviews were crucial in obtaining data on the perceptions and attitudes of respondents towards 
the EHL. 76 interviews were conducted by the evaluation team with different stakeholder groups 
and conducted in a semi-structured manner and followed interview guidelines tailored for each 
specific stakeholder group. The sample size was proposed in the Inception Report and aimed to 
cover different types of non-selected sites. 

Focus group 

A programme of site-specific and national-level focus groups was also used in the evaluation to 
provide a platform for various stakeholders to discuss the EHL action within a local or national 
context.  Sites  and  countries  for the  focus  group  discussions  were  carefully  selected taking  into 
consideration the year of selection, characteristics of the site such as size and location. In total, 10 
focus group discussions were carried out. 

Open public consultation 

The open public consultation (OPC) gathered views on all interested citizens and organizations 
on the role of cultural heritage in bringing the European citizens closer to the Union. Consultation 
was carried out via an online questionnaire accompanied by a background document. The scope 
of the OPC covered the visibility of the Label, as well as the relevance, coherence, effectiveness, 
efficiency and EU added value. The questionnaire covered fifteen questions, seven targeted the 
general public and eight for those involved in the action. The questionnaire was published for 12 
weeks  (1  March  2018-  28  May  2018)  on  a  dedicated  consultation  webpage  and  was  made 
available  in  three  EU  languages  (English,  French,  and  German).  In  total,  it  received  103 
responses of which one was not valid.  

3. USE OF THE RESULTS OF THE CONSULTATIONS 

The  evidence  from  the  OPC  and  in-depth  interviews  have  been  taken  into  account  in  the 
preparation of the final report. The in-depth interviews provided evidence against the evaluation 
questions and was triangulated against evidence from other sources. 

3.1. Relevance  

Stakeholders consulted via all methods – interviews, focus groups and the OPC – emphasised the 
relevance of the EHL action and its general objectives to the current needs of EU societies.  

High-level  interviewees  perceived  the  EHL  to  have  potential  in  highlighting  the  European 
dimension.  In  other  in-depth  interviews,  the  interviewees  mainly  shared  a  similar  opinion  that 
cultural  heritage  and  the  EHL  can  promote  European  integration,  cohesion  and  intercultural 
dialogue.  In  terms  of  EHL’s  relevance  to  the  current  EU  needs,  only  a  minority  of  the  site 
representatives answered the question positively.  

The  interviewees  generally  expressed  that  the  action  should  include  all  EU  countries  into  the 
scheme. Some of the interviewees and participants in some national focus groups also perceived 

32 

 
 
 
advantages  in  widening  the  action’s  geographical  scope  to  non-EU  countries  and  even  non-
European countries.  

In all focus group discussions, the participants that are involved in the action also expressed the 
relevance  of  the  EHL  for  their  sites.  Nonetheless,  in  some  focus  group  discussions,  the 
participants  mentioned  that  current  societal  developments  have  to  be  better  addressed  by  the 
EHL. The OPC respondents shared similar views.  

3.2. Coherence  

High-level interviewees perceived potential synergies and complementarities to exist between the 
EHL and other EU-level actions.  

A few national coordinators and site managers perceived synergies or complementarities to exist 
with other  EU  actions (like  the  European  Heritages Days  or  Europe  for  Citizens  programmes); 
however,  most  of  other  interviewees  did  not  provide  a  clear  opinion  regarding  synergies  or 
complementarities.  The  focus  group  participants  did  not  cover  the  topics  of  synergies, 
complementarities and overlaps between EHL and other EU actions in-depth. However, some of 
the  stakeholders  underlined  that  more  synergies  could  be  created  between  EHL  and  other  EU 
actions in the areas of financial support to and capacity building of the labelled sites.  

Interviewees  widely  referred  to  UNESCO  programmes  when  asked  about  the  extent  to  which 
EHL’s objectives, instruments. For some of the interviewees EHL seemed clearly distinct from 
UNESCO  programmes,  while  for  others  similarities  between  them  were  evident.  The  same 
difference  of  views  regarding  EHL’s  coherence  with  UNESCO  programmes  was  identified 
among the focus group participants. The OPC respondents stated that the EHL has most overlaps 
with the UNESCO World Heritage List (69% strongly agreed or agreed), the Cultural Routes of 
the Council of Europe (64%), the UNESCO Representative List of Intangible Cultural Heritage 
of  Humanity  (54%)  and  the  European  Union  Prize  for  Cultural  Heritage/Europa  Nostra  Award 
(54%). Least overlaps were seen between the EHL and other initiatives targeted at intercultural 
dialogue or any other national and local initiatives.  

Respondents who are involved in the action reported most overlaps between the EHL and some 
European  programmes.  Meanwhile,  those  respondents  who  are  non-involved  in  the  action  saw 
most  similarities  between  the  EHL  and  the  UNESCO  initiatives.  The  share  of  “Do  not  know” 
responses was significantly higher among the non-involved respondents compared to those who 
are involved in the EHL. All OPC respondents were given an option to specify with what other 
initiatives the EHL is similar.  

3.3. Efficiency  

Participants to the focus group programme mostly stressed the low visibility of the label; lack of 
a clear identity and vision of the label; unclear definition of the European significance criterion; 
as well as a need for financial and other type of support to the labelled sites.  

Regarding  pre-selection  and  selection,  interview  evidence  show  that  there  are  two  type  of  pre-
selections organised in Member States. 53% of national coordinators reported organising bottom-
up pre-selections, while 47% of them stated implementing top-down method for pre-selection.  

33 

 
 
 
The  panel  members  interviewed  evaluated  the  EU-level  selection  process  to  be  working  well, 
including  the  communication  between  the  panel  and  the  Commission.  However,  some  non-
selected  sites  and  national  coordinators  interviewed  indicated that  explanations  provided  in  the 
Panel Reports regarding the selection decisions are sometimes insufficient.  

The  selection  criteria  were  clear  to  almost  half  of  the  site  managers  from  the  labelled  sites 
interviewed (47%) and unclear to only a minor share of them (10%). Some of the different-level 
interviewees  deemed  the  European  significance  criterion  to  be  ambiguous.  The  focus  group 
participants  generally  shared  the  same  view  regarding  the  European  significance  criterion  and 
stressed the need to clarify it to reduce its ambiguity.  

Some of the focus group participants were concerned that the diversity of the labelled sites may 
make it difficult to create a common brand and market it. The vision of the label, its future goals 
and objectives were unclear. Focus group participants generally stressed the need to clarify and 
disseminate the EHL vision.   

With regard to 2016 monitoring procedures, 14 out of 20 senior staff members interviewed from 
the monitored sites perceived it to be useful and reported that it was an opportunity to take stock 
of  their achievements,  as well  as  allowed them  to  discuss challenges  and  future  plans  with the 
panel. Three national coordinators stated that they conduct a national-level monitoring, yet it is 
more informal.   

Focus group participants generally emphasised that the label is not widely known neither among 
the general public nor among the cultural heritage professionals. Some participants reported that 
they were only aware of the label because of their affiliation with the labelled site.  

Only around half of the interviewees perceived the EHL action as sufficient. 50% of the labelled 
sites  and  57%  of  the  national  coordinators  deemed  communication  with  the  European 
Commission to be sufficient. Site managers of the labelled sites expected the Commission to play 
a greater role in communication instead.   

Focus group participants also had diverging views on communication roles within the action and 
promotion of the label to wider audiences. Likewise interviewees, some focus group participants 
repeatedly  stressed  that  a  greater  role  of  the  Commission  in  promoting  the  label  is  necessary. 
Meanwhile, a few others highlighted that some sites do not actively communicate the label and 
should demonstrate more initiative themselves.  

Only  37%  of  the  site  representatives  interviewed  perceived  communication  with  national 
coordinators to be sufficient. However, around half (48%) of the national coordinators reported 
an  active  communication  with  the  sites.  The  interviewees  highlighted  the  usefulness  of  EHL 
annual meetings.  

Some site managers interviewed reported that several forms used in the action are complicated 
and  could  be  further  simplified.  Most  of  them  reported  that  the  application  form  was  long, 
repetitive  and  time  consuming.  Similarly,  a  few  site  managers  who  participated  in  monitoring 
reported difficulties with uploading the information on the monitoring sheet.  

Overall, stakeholder consultation evidence highlight scope for improvements. Both interviewees 
and  focus  group  participants  expressed  a  strong  need  to  improve  the  communication  of  the 
action,  including  adopting  more  diverse  communication  measures  for  communicating  to  the 
public  and  within  the  action.  Some  focus  group  participants  also  mentioned  that  the  current 

34 

 
promotional tools are not efficient or wide reaching. Different-level interviewees and focus group 
participants called for establishing a network; providing financial support to the labelled sites to 
implement  their  activities;  and  also  highlighted  the  importance  of  capacity  building  of  the 
labelled sites. Yet, a few focus group participants also claimed that the sites themselves need to 
be more active and collaborate with other sites.   

A few focus group participants and interviewees underlined that the EHL is a recent initiative and 
needs time to evolve further and some of the issues EHL currently faces will resolve with time.  

In  respect  to  OPC  results,  respondents  involved  in  the  action  quite  favourably  evaluated  the 
efficiency  of  measures  and  tools  used  in  the  action  in  reaching  the  target  audiences  and 
communicating European narrative of the sites.  

3.4. Effectiveness  

The interviewees had difficulties to judge the achievements of the EHL in terms of the general 
objectives  of  “Strengthening  the  European  citizens’  sense  of  belonging  to  the  Union”  and 
“Strengthening  intercultural  dialogue”.  The  majority  of  interviewees  expressed  doubts  that  an 
impact was made concerning these objectives. The interviewees generally assumed that the EHL 
is still a young action that needs more time to achieve greater effects.  

All focus groups mentioned the lack of visibility of the EHL, especially among citizens and other 
local  and  regional  sites.  No  major  effects  were  perceived  in  terms  of  the  action’s  overall 
objectives  of  “Strengthening  European  citizens’  sense  of  belonging  to  the  Union”  and 
“Strengthening  intercultural  dialogue”.  In  addition,  most  participants  could  not  prove  a 
connection between the EHL award and a risen popularity of a site. Only more rural sites tended 
to acknowledge an increased visibility.  

Only  a  few  sites  representatives  interviewed  could  not  make  greater  progress  in  implementing 
their  projects.  National  coordinators  also  perceived  more  effects  to  be  visible  on  a  site  level 
compared to the national level. The site-level focus groups put more focus on the activities of the 
site. Although progress was perceived, participants indicated that further progress could still be 
made. Still, the exchange with other sites, especially during the EHL Days, was perceived as an 
important benefit for EHL sites.  Participants of national-level focus groups often did not know 
the EHL well before the evaluation. For them, it was difficult to link the effects to the action.  

Regarding sustainability of the action, high-level interviewees were asked for their perspectives 
on  the  sustainability  of  the  effects.  According  to  them,  the  necessary  preconditions  for  the 
sustainability are still to improve.  

OPC  respondents  stated  that  most  progress  in  reaching  the  overall  goals  and  objectives  of  the 
EHL  was  made  in  stressing  the  symbolic  value  and  raising  the  profile  of  sites  significant  for 
common history. Meanwhile, least progress was perceived to be made in strengthening European 
citizens’  sense  of  belonging  to  the  Union.  Regarding  the  attainment  of  site-specific  objectives, 
respondents  involved  in  the  action  perceived  most  progress  to  be  made  by  the  sites  in 
highlighting their European significance and increasing access to the sites through digital tools, 
especially for young people. The sites were perceived to be making least progress in the areas of 
fostering  synergies  between  cultural  heritage  and  contemporary  creation  and  creativity,  and 
contributing to the attractiveness and the economic and sustainable development of regions.  

35 

 
 
Meanwhile,  most  of  the  total  number  of  respondents  stated  that  a  visit  to  an  EHL  site  (either 
directly  or  online)  has increased  their  appreciation of  cultural  heritage  and  encouraged  them  to 
learn  more  about  European  history  and  culture.  Most  of  respondents  expressed  willingness  to 
know more about the EHL. The majority of respondents stated that knowing that a specific site 
bears the EHL would encourage them to find out more about the site and other labelled sites.  

3.5. EU added value  

Panel  members,  national  coordinators  and  Commission  officials  perceived  the  main  EU  added 
value  of  the  action  in  the  sites’  focus  on  the  European  dimension.  They  noted  that  sites  might 
need  support  in  strengthening  this  aspect  and  increasing  the  understanding  of  what  European 
identities  and  values  can  mean.  However,  slightly  less  than  half  of  site  representatives 
interviewed perceived a change in their site’s narrative towards a stronger European dimension. 
Some interviewees also highlighted the action’s importance for the increased value of culture on 
the EU-level, as well as for the European unification process.   

External  stakeholders  that  participated  in  national  focus  groups  especially,  but  also  other 
participants, had difficulties to identify the European values and/or narratives represented at the 
sites,  as  the  sites  are  very  diverse in  their  approaches  and  in  the  topics  covered.  This  diversity 
was perceived to be both a positive and challenging aspect.  

Regarding  a  hypothetical  termination  of  the  action,  most  interviewees  would  not  expect  major 
consequences if the action is discontinued. However, site representatives expressed fears that if 
the  action  was  discontinued,  a  disruption  of  their  achievements  and  efforts  could  occur.  The 
interviewees generally agreed that the EHL is a young action and needs more time to generate 
and increase its effects and added values. Focus group participants stated that EU role in shaping 
the EHL should be greater at this early stage of the action, especially as there is no other linking 
organisation, platform or official network that could fulfil this task.   

The OPC data show that respondents involved in the action quite favourably evaluated the added 
value  brought  by  the  transformation  of  the  initiative  to  an  EU-level  action,  specifically  in  the 
areas  of  functioning  and  visibility  of  the  Label  and  cooperation  between  Member  States. 
Regarding a hypothetical termination of the EHL action, the respondents perceived that it could 
bring  negative  impact  in  the  areas  of  European  citizens’  appreciation  of  European  values  and 
understanding  of  European  history,  fostering  intercultural  dialogue  and  strengthening  citizens’ 
sense  of  belonging  to  the  Union.  Only  3  respondents  stated  that  the  termination  of  the  action 
would bring no change. 

36 

 
 
 
 
 
 
 
ANNEX 3: METHODS AND ANALYTICAL MODELS 

1.  DATA ANALYSIS METHODS  

Four methods were used to analyse the quantitative and qualitative data: 

  Descriptive statistics to analyse the responses to the OPC 
  Content analysis to analyse qualitative data obtained via the open questions of the OPC, 

interviews, focus groups, and desk research  

  Comparative  analysis to  evaluate the transition  from  the  intergovernmental  EHL  to  the 

current EU scheme, their respective operation and results. 

  Prospective analysis to formulate recommendations for the future of the action. 

Table 1 Evaluation questions 

Relevance 
EQ1 
EQ2 
EQ3 

Coherence 
EQ4 

Efficiency 
EQ5 

EQ6 
EQ7 
Effectiveness 
EQ8 

EQ9 

EQ10 

EQ11 

EQ12 
EU added value 
EQ13  
EQ14 

Is the EHL still relevant to the current needs of the EU? 
To what extent would widening its geographical scope be relevant? 
What were the objectives of the sites applying for the label? To what extent were 
their objectives consistent with the Decision? 

To what extent was the EHL coherent with, and complementary to, other EU and 
international initiatives?  

How  did  the  selection  arrangements  of  the  European  Commission  –  and  of  the 
participating Member States – contribute to the achievement of outputs, results and 
impacts? 
Were the processes involved in running the action efficient? 
How could they be improved or simplified? 

To what extent were the EU-level general and intermediate objectives of the action 
met in its first years of implementation? 
To what extent were the specific objectives defined in Article 3.3 achieved by the 
sites designated to date? 
To what extent  were the specific objectives achieved? What type of activities are 
typically implemented by the sites? What are the main challenges to implementing 
it?  What  are  the  benefits  gained  so  far  from  being  designated?  Did  some 
collaboration projects between labelled sites take place already? 
To  what  extent  can  the  positive  effects  of  the  EHL  action  be  considered 
sustainable? 
Have there been any unintended consequences of the action? 

What has been the EU added value of the EHL? 
What would happen if the EHL were to be discontinued? 

2. WEAKNESSES OF THE METHODS USED AND HOW THEY WERE ADDRESSED 

  Variations in the methodology were used to monitor different EHL sites. Since there are 
no  common  indicators  to  measure  progress,  the  data  presented  in  monitoring  forms 
appeared inconsistent. Other data sources were sought to triangulate findings. 

  A few national coordinators and site managers were new to their positions. Nevertheless, 

the majority of provided good sufficient data for analysis. 

  The  evaluation  drew  upon  interviews,  focus  groups  and  the  OPC  to  ascertain  opinions 
and  perceptions.  Perception-based  sources  were  corroborated  with  other  sources  of 
evidence. 

37 

 
 
 
 
 
 
 
  One site refused to host a focus group discussion. This site was replaced by another site 

with similar qualities. 

  OPC  does  not  provide  a  representative  view  of  opinion  among  the  EU  public,  as 
respondents are self-selected. For this reason, the OPC was never used as the main data 
source. 

38