Transcript Global value chains, trade in chemicals and „environmental

12 November 2014
Smart Regulation - Fit for the 21st century?
Fecc Membership Meeting
Ulrike Schmuelling, VCI Brussels Office
Smart Regulation involves ex-ante and ex-post analysis
Ex-ante
Ex-post
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• Stakeholder Consultations
• Impact Assessments
• Evaluation and Fitness Checks
• Cumulative Cost Assessment
• Withdrawal of legislative
proposals
• Cut red tape
The endless cycle of Smart Regulation
Evaluation/
Fitness
Check
New
regulation /
Revision
existing
regulation
Stakeholder
Consultation &
Impact
Assessment
Implementation
by Member
States
Ordinary
legislative
procedure
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COM
tables
proposal
What is REFIT?
“The Regulatory Fitness and Performance Programme
(REFIT) launched in December 2012 is a programme
aimed to make EU law lighter, simpler and less costly so
that it benefits citizens and businesses and helps to
create the conditions for growth and jobs. It does not put
into question the EU's policy objectives, but seeks for
more effective ways to achieve them.”
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Chemicals: A densely regulated sector
Occupational Safety
REACH
Safety of Production Site
Environmental Protection CLP
Transport
Export Control (PIC)
Product Design
Pharmaceutical products
Biocides
Plant Protection Products
Medical Devices
Food Safety
Cosmetics
Toys
Construction Products
Electronic Products
Packaging
Waste
Challenges: complexity, consistency, legal certainty
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unintended
consequences, accumulative costs
How fit is the chemicals sector?
Fitness Check: Comprehensive
policy evaluation assessing
coherence and consistency
between and within regulatory
areas and whether a larger
regulatory framework is fit for
purpose.
Fitness Check for CLP & and downstream regulation to start
in 2015, but process delayed
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CLP and interface with other regulation: inconsistencies &
(un)intended consequences identified by chemicals industry
More
Seveso
sites
More
mixtures
subject to
PIC
procedure
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Biocides/
PlantProtection/F
oodContact
Materials/EcoLabel
…
CLP
hazard (re)
classificati
ons
Measuring the costs of the regulatory burden
Cumulative Cost Assessment
Assess policy-induced costs in the EU compared to other trading
partners
Assess impact of compliance costs vs total cost of chemical
companies
Quantify the impact of regulatory pressure on competitiveness
Study started by consultant in July 2014, final report expected in
July 2015
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Fitness Programm for the 21st century urgently needed!
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Worrying trends
despite good
intentions
Put
competitiveness
back at center
stage
Smart
Regulation is not
only an exercise
by default but
requires a
change of
mindset
New
Commission:
Courage to
change the
course?
Smart Regulation in the 21st century is about ensuring a level
playing field in a globalised world
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Backup
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General principles of good regulatory practices
Transparency
Stakehold
er
Consultation
Evaluatio
n
„Good
Regulatory
Practices“
Accountability
International
Standards
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Impact
Assessment