In April 2021, the European Commission published its new Better Regulation Communication1 aimed at improving EU policy-making. The undersigned European trade associations strongly welcome the principles and the objectives of the Communication. Nonetheless, we would like to herewith share recommendations to further improve the European policy-making process in the context of the busy policy agenda and ahead of crucial upcoming policy initiatives.
To this purpose, we call for:
● EU Legislation to be developed fully on the basis of and supported by evidence and thorough impact assessments;
● Sufficient time and resources to be allocated at all phases of the decision-making process, so as to ensure sound policy decisions;
● Consultations to be conducted via thorough process, involving expert input from all relevant stakeholders, and allow for sufficient time to provide feedback;
● Key regulatory provisions such as definitions and scope to be agreed upon and clearly defined at a primary legislative stage, rather than through implementing acts or guidance documents, to prevent the adoption of diverging and disproportionate national measures and EU market fragmentation;
● The impact on innovation to be considered in all legislative initiatives to ensure
● EU legislation to be implemented and enforced in a harmonised way
safeguarding the Single Market. If applicable, legal requirements that need
specific verification procedures by authorities must be verifiable through
established methods, including the timely listing in the OJ of references to the
An evidence-based approach for all initiatives:
Legislation needs to be developed on the basis of and supported by evidence. The complexity of many sensitive and highly political topics, particularly regarding the EU Green Deal, requires high quality data, and evidence-based impact assessments. To this end, legislative proposals should be published following a thorough impact assessment that clearly outlines the implications of all the policy options proposed.
Stakeholders’ responses to consultations as well as findings of impact assessments should be made available and published ahead of, and not together with, the respective legislative proposal. This will help improve transparency and accountability, and support a constructive exchange of views among stakeholders.