Administrative burden in Impact Assessments for Commission proposals November 2012 – February 2013 Dr. Marianne Klingbeil Deputy Secretary General European Commission 7 March 2013

D irective on Marine Equipment The IAB opinion asked in its second opinion that the report should "provide some quantitative illustration […] of regulatory burden reductions for the main policy options".

Revision of the Tobacco Product Directive The IAB asked in its first and second opinion that the IA "should also assess in greater detail the administrative costs for national authorities."

EU Guidelines for the application of State aid rules in relation to rapid deployment of broadband networks The IAB asked for move evidence: "The available evidence from the case studies should be more explicitly used to give an indication of the likely costs and benefits for the different parties involved, including the costs for national administrations".

Alternative Investment Fund Management Directive Level 2 Measures The IAB asked for a better assessment of administrative burden: "First, it should try to quantify [impacts] as much as possible. This is particularly important for impacts on costs and administrative burden."

Revision of the Regulation 1346/2000 in insolvency proceedings The IAB asked for further quantification: "[The report] should also strive to estimate all expected economic impacts, in particular, administrative burden".

Regulation on occurrence reporting in civil aviation The IAB asked for a better description of costs: "The report should also provide a breakdown of the administrative burden costs for each of the major stakeholders affected, within the main text".

Action Plan against tax fraud and evasion and on recommendations on good governance The IAB asked for further clarifications of impacts and conclusions: "The report should better explain the impacts on administrative burden and better justify certain conclusions […]".

Voluntary agreement concluded under the Ecodesign Directive 2009/125/EU to improve the energy efficiency of imaging equipment IAB recommendation: "[The report] should then assess the potential impacts on consumers and on retail prices, and substantiate the administrative costs to industry and national authorities, and especially the administrative burden associated with the yearly reporting and evaluation arrangements".

Reinforcing the protection of the Euro against counterfeiting by means of criminal law IAB recommendation: "The report should clearly distinguish between compliance costs and administrative costs, and specify which of the two apply where, and how they are analysed. Administrative costs should be further analysed, including an indication of their expected magnitudes across the Member States, given the different legal systems".

Legislative proposals to eliminate remaining administrative and technical barriers in the field of interoperability and safety on the EU railway market IAB recommendation: "It should correctly apply relevant cost concepts, for example by clearly distinguishing between administrative costs for different economic actors, and the costs of public administration, including the administration costs of ERA".

Statistics 22 IA reports were published from November 2012 to February of these have been identified as being especially interesting from the point of view of administrative burden Economic Environ- mental Social

Challenges November 2012 – February 2013 clearer assessment of administrative costs/burden, more detailed quantification specific indication of administrative costs for national/public authorities clearer distinction between administrative burden/costs and compliance costs