Interview guide “Internal Market for Goods – Digital Compliance” MARKET SURVEILLANCE AUTHORITIES STUDY DESCRIPTION VVA is conducting the study on Evaluation of Impact of the “ Internal Market for Goods – Digital Compliance ” , on behalf of the DG for Internal Market, Industry, Entrepreneurship and SMEs. The study will provide inputs to the Impact Assessment of the new Enforcement and Compliance initiative with respect to the internal market for products. The main purpose of our research is to collect economic data, quantify benefits/costs and measure the possible impact of the policy options identified by the Commission. This includes: A database where manufacturers can provide basic information electronically about product compliance with the specific sectorial legislation; Electronic tags and/or other data carrier technologies Your answers/ data will be used solely for the purpose of this study. They will not be used for marketing purposes. Entity / Company: Date: Interviewee: Role: DESCRIPTION OF THE POLICY OPTIONS Among the policy options to be considered in the context of this study, we are evaluating whether a potential electronic data management system should be: OPTION 1 : centralised and managed by the Commission or OPTION 2 : decentralised and managed by the manufacturer and/or importer. This study evaluates the costs and benefits of demonstrating compliance under each option. C osts do not include conformity assessment procedures (testing, drafting of documentation, affixing of the CE Marking), and strictly refer to costs incurred for demonstrating that a product is compliant to applicable legislation. Within each option, several provisions are studied with regards to their potential for decreasing costs of demonstrating compliance and facilitating access to required market surveillance information. These are: E-labelling : the use of displaying compliance information in the integral screen of the product (if the product has a screen), whereby no access code or permissions should be required for accessing all the information needed to demonstrate compliance. The information would have to be accessible in no more than three steps in a device’s menu. Auto ID : automatic identification through a range of technologies used to help machines identify objects and determine their belonging to a certain type or class of objects, or their individual identity. This can be done through barcodes, Radio Frequency Identification, smart cards and magnetic stripes. We also evaluate the extent to which such a digital compliance mechanism could be implemented. In this respect, two parameters are considered: Basic compliance requirements : Firms would only have to digitalise information related to the Declaration of Conformity, manufacturer contact data and the certificate of the Notified Body, if applicable. Full compliance information : Firms would have to digitalise the entire technical file of the product. INTERVIEW GUIDE FOR MARKET SURVEILLANCE AUTHORITIES GENERAL QUESTIONS 1 Could you please describe the procedures in place to demonstrate compliance with Union legislation by businesses ? 2 Are you aware of any electronic databases in your country where manufacturers can insert information about product compliance with specific sectorial legislation? 3 What are the main cross-sector differences in your country in how businesses covered by Union harmonisation legislation demonstrate compliance , if any ? 4 Have you introduced or a re you exploring options such as electronic tags , data carrier technologies or architectures to demonstrate compliance in your country? 5 What type of impacts do you expect a move from a paper-based compliance demonstration system to a digital one would have ? BASELINE SCENARIOS 6 Are there any issues caused by information asymmetr ies between you and manufacturers/operators that are not addressed by the current compliance demonstrating procedures ? 7 How much time and/or budget per year does your team spend on the followin g (please provide detail where available, otherwise focus on the total figure) : Type of activity Days/year Budget/year Assessing/collecting the information showing compliance from companies Interacting with market surveillance authorities in other Member States to assess information showing compliance Interacting with third parties (e.g. consumers, other public bodies, courts, etc) regarding the search for information showing compliance Costs for archiving/handling of documents showing compliance Training of new/existing employees on the process of verifying compliance Other activities related to searching for information showing compliance TOTAL FOR ALL ACTIVITIES ABOVE 8 Under the current system for demonstrating compliance , how likely is it for manufacturers to avoid compliance ? ASSESSING THE DIRECT IMPACTS 9 What uptake would each option have if it was voluntary? Please think of the uptake within the first year s Voluntary uptake (% of firms in the sector) Basic compliance Full compliance OPTION 1 (centralised database) … % … % OPTION 2 (decentralised database) … % … % 10 Do you think that the introduction of an E-labelling or Auto ID possibility would improve uptake for either of the options? If so, please specify what % of additional manufacturers would it convince to take up the option in addition to the % indic ated in the question above. Voluntary uptake (% of firms in the sector in addition to those indicated above) E-labelling Auto ID OPTION 1 (centralised database) … % … % OPTION 2 (decentralised database) … % … % 11 Assume that a digital compliance verification system is introduced, containing only basic compliance requirements (Declaration of Conformity, manufacturer contact data, Notified Body certificate). From your side as a MSA, how much time/budget would you need to set up the system from your side ( one-off costs ) compared to the business as usual scenario? Please add other types of activity you may need to carry out, if they are missing in the table below. Type of activity OPTION 1 (centralised database) OPTION 2 (decentralised database) Days /year Budget /year Days /year Budget /year One-off costs for training of new/existing employees with the process of verifying compliance One-off costs for equipment to facilitate the secure connection to the compliance database, as well as the reading of compliance information. Other (please specify) 12 What impact do you think the introduction of an E-labelling or Auto-ID function would have over each of the options’ one-off costs (question 11) under basic compliance requirements? One-off costs E-labelling Auto ID OPTION 1 (centralised database) +/- … % +/- … % OPTION 2 (decentralised database) +/- … % +/- … % 13 Considering the one-off costs estimated in question 11, b y how much would they change in case of full compliance requirements ( digitalisation of the entire technical file) in the following scenarios? One-off costs % change under full compliance requirements OPTION 1 (centralised database) +/- … % OPTION 2 (decentralised database) +/- … % ANY OPTION + E-labelling +/- … % ANY OPTION + Auto ID +/- … % 14 For both options under basic compliance requirements, please indicate how your time and operational budget investment ( recurring costs ) would be affected as compared to the business as usual scenario. Type of activity OPTION 1 (centralised database) OPTION 2 (decentralised database) Days /year Budget /year Days /year Budget /year Assessing/collecting the information showing compliance from companies Interacting with market surveillance authorities in other Member States to assess information showing compliance Interacting with third parties (e.g. consumers, other public bodies, courts, etc) regarding the search for information showing compliance Costs for archiving/handling of documents showing compliance Other activities related to searching for information showing compliance TOTAL FOR ALL ACTIVITIES ABOVE 15 W hat impact would the introduction of E-labelling or Auto ID possibilities have on the recurrent costs estimated in question 14 ? Recurring costs E-labelling Auto ID OPTION 1 (centralised database) +/- … % +/- … % OPTION 2 (decentralised database) +/- … % +/- … % 16 Considering the recurrent costs indicated in question 11, how would they change in case of full compliance requirements ( digitalisation of the entire technical file) in the following scenarios? Recurring costs % change under full compliance requirements OPTION 1 (centralised database) +/- … % OPTION 2 (decentralised database) +/- … % ANY OPTION + E-labelling +/- … % ANY OPTION + Auto ID +/- … % 17 Compared to the business-as usual scenario, what would happen to the risk of non-compliance in each of the options and scenarios presented? Please indicate in absolute terms (e.g. in case the risk doubles, indicate 100% rather than 2x current risk) Basic compliance Full compliance OPTION 1 (centralised database) +/- …% +/- …% OPTION 2 (decentralised database) +/- …% +/- …% 18 How would the number of complaints from consumers/end users change compared to the current situation, for each of the policy options? Basic compliance Full compliance OPTION 1 (centralised database) +/- …% +/- …% OPTION 2 (decentralised database) +/- …% +/- …% ANY OPTION + E-labelling +/- …% +/- …% ANY OPTION + Auto ID +/- …% +/- …% 19 Do you see other direct cost reductions or benefits by using any of the options? Please describe. ASSESSING WIDER IMPACTS 20 For each option under basic compliance requirements , please estimate how the following indicators would change compared to the current, business as usual scenario . Please tick in the appropriate cell according to th e percentage changes indicated. Type of activity OPTION 1 (centralised database) > -100% -100% -75% -50% -25% -10% 0% 10% 25% 50% 75% 100% >100% Quality of market surveillance End-user trust Waste reduction T rade Competitiveness of producers Innovation of producers Type of activity OPTION 2 (decentralised database) > -100% -100% -75% -50% -25% -10% 0% 10% 25% 50% 75% 100% >100% Quality of market surveillance End-user trust Waste reduction T rade Competitiveness of producers Innovation of producers 21 Do you think the figures would change under a full compliance requirement ? If so, please indicate how they would change with respect to the basic requirements scenario above? Please tick in the appropriate cell according to the percentage changes indicated. Type of activity OPTION 1 (centralised database) > -100% -100% -75% -50% -25% -10% 0% 10% 25% 50% 75% 100% >100% Quality of market surveillance End-user trust Waste reduction T rade Competitiveness of producers Innovation of producers Type of activity OPTION 2 (decentralised database) > -100% -100% -75% -50% -25% -10% 0% 10% 25% 50% 75% 100% >100% Quality of market surveillance End-user trust Waste reduction T rade Competitiveness of producers Innovation of producers 22 Do you think the figures would change if an E-labelling or Auto ID option was selected? If so, please indicate how they would change with respect to the basic requirements scenario above? Please tick in the appropriate cell according to th e percentage changes indicated. Type of activity OPTION 1 (centralised database) > -100% -100% -75% -50% -25% -10% 0% 10% 25% 50% 75% 100% >100% Quality of market surveillance End-user trust Waste reduction T rade Competitiveness of producers Innovation of producers Type of activity OPTION 2 (decentralised database) > -100% -100% -75% -50% -25% -10% 0% 10% 25% 50% 75% 100% >100% Quality of market surveillance End-user trust Waste reduction T rade Competitiveness of producers Innovation of producers 23 Do you have any remarks on how a digital compliance system should be structured? (e.g. amount of compliance data to include, who is best suited to manage it, etc) 24 Would you consider that an alternative policy option would have an overall larger positive impact upon verifying compliance for you as market surveillance authority? If so, please describe. 25 Finally, can you share with us any relevant documents or good practices of such compliance databases in your country?
Teema: RE: Interview for the European Commission study on digital compliance (please confirm)
From: Ricardas Juskevicius [mailto:
[email protected]
<mailto:
[email protected]> ]
Sent: Wednesday, January 11, 2017 12:53 PM
To: TKA Info <
[email protected]
<mailto:
[email protected]> >
Subject: Interview for the European Commission study on digital
compliance (please confirm)
Dear Madam/Sir,
I am contacting you concerning the assessment of the impact of the
"Internal Market for Goods – Digital Compliance” we are conducting on
behalf for the European Commission (DG GROWTH).
In the framework of this evaluation, we are undertaking interviews with
key stakeholders (market surveillance authorities and manufacturers
representatives) and we would value your input and expertise on the
topic.
For more information, please see the attached Interview Guide.
Would you be available for a 30-40 minutes phone interview in the
coming weeks on this topic?
Alternatively, we would appreciate written answers to the questionnaire
attached in the Interview Guide.
Should you not be the best person to direct this invitation to within
your organisation, then I would kindly request that you provide us an
alternative contact at your earliest convenience.
Thank you in advance for your support to this study, and please do not
hesitate to contact me should you have any further questions.
Kind regards,
Ricardas Juskevicius
Consultant
S: Ricardas.JSK
M: +44 (0) 748 473 0176
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