Cableways Impact Assessment Study - Final Report - saferail.nl
Cableways Impact Assessment Study - Final Report - saferail.nl Cableways Impact Assessment Study - Final Report - saferail.nl
IA Study Concerning the Revision of the Cableways Directive expected that alignment with the NLF may ensure greater transparency as importers and distributors (as well as other economic operators) will be aware of the specific role and responsibilities of both importers and distributors. More importantly, under the NLF, importers and distributors are obliged to ensure that the product they are marketing is suitable for the market, verify that the product has the required safety markings and accompanying documentation, and is in conformity with the Community harmonisation legislation. Summary of Stakeholder Views Most stakeholders that have responded to the second round of consultation would support alignment of the Cableways Directive with the NLF (in particular through Option E3). This is in line with the results of the first round of consultation where 92% of responding national authorities and 75% of responding notified bodies identified likely benefits clarifying the roles and responsibilities of economic operators in line with the NLF (see Table 4.11 in Section 4). Those competent authorities and notified bodies that support Option E3 consider it to be beneficial from a regulatory standpoint and because it allows a uniform approach to be adopted for a number of Directives and sectors. This is particularly beneficial for those Member States authorities where one department is responsible for a number of Directives. However, one competent authority and one notified body do not believe there is any need to align the Cableways Directive with the NLF as it is a very specific sector which is transparent. Furthermore, one competent authority emphasised the importance of not applying a carbon copy of the NLF to the Cableways Directive but to consider the particularities and nuances of the cableways sector. However, not all stakeholder groups consulted have expressed support for Option E3. Most cableways manufacturers who expressed an opinion see the current Directive as sufficient and therefore do not consider there to be any need to align it with the NLF. In general, cableways operators associations do not have an opinion on the alignment of the Directive with the NLF and the obligations of economic operators. Only the Finnish cableway operator’s association believe that there is likely to be any particular benefits from clarifying the roles and responsibilities of economic operators in accordance with the NLF. Impact on the Internal Market and Competition Options E2 and E3 are unlikely to lead to any significant impacts with regard to consumer choice, prices, barriers to new suppliers, emergence of monopolies or market segmentation. Option E3 in particular can be expected to contribute to reducing or preventing operators that market non-compliant products (e.g. ropes) from gaining an unfair advantage. Option E3 can be considered to contribute to ensuring a level playing field for all operators. Page 112
Risk & Policy Analysts Impact on Competitiveness, Trade and Investment Flows By reducing the likelihood that non-compliant ropes are imported into the EU, Option E2 and in particular Option E3 can be expected to improve the competitive position of EU rope manufacturers. No impacts on productivity are expected to occur. Operating Costs and Conduct of Business/SMEs Option E2 and in particular Option E3 are likely to impose some additional costs on importers and distributors. These are linked to both checking compliance as well as record keeping requirements (although it is assumed that these activities might already be routinely carried out under the baseline scenario). However, these costs are likely to be relatively small, because the numbers of products for which compliance would have to be checked and records kept is assumed to be relatively small (due to the small size of the sector, each importer and distributor is expected to sell only a very small number of products each year). In addition, the UK national authority identified cost savings from alignment with the NLF associated with avoided error and misunderstandings due to greater clarity on operators’ obligations, in particular when dealing with imported products. Administrative Burdens on Businesses No significant additional burden is expected. Public Authorities National authorities in Liechtenstein and Denmark noted that alignment with the NLF would have the advantage of aligning the requirements applicable in the cableways sector with those in other sectors thus reducing the administrative burden on a public authority in a small country with a small cableways sector. Based on the study team’s assessment of the cableways sector in individual European countries, it is estimated that these benefits may arise in approximately one-third of EU/EEA states. Innovation and Research No impacts on research and innovation are expected. Consumers and Households No impacts on prices paid by cableways users are anticipated. Specific Regions and Sectors Impacts are likely to differ between Member States as some countries have manufacturers of cableways, subsystems and safety components and/or a large demand for cableways while other countries do not. However, as noted above, aligning requirements applicable in the cableways sector with those in other sectors Page 113
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- Page 87 and 88: Risk & Policy Analysts subject to E
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- Page 93 and 94: Risk & Policy Analysts out in Table
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- Page 107 and 108: Risk & Policy Analysts may come to
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- Page 113 and 114: Risk & Policy Analysts To this end,
- Page 115 and 116: Risk & Policy Analysts respondents
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- Page 119 and 120: Risk & Policy Analysts Summary of S
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- Page 129 and 130: Risk & Policy Analysts However, the
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- Page 137 and 138: Risk & Policy Analysts 6.6 Problem
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- Page 141 and 142: Risk & Policy Analysts Kaiser (nd):
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- Page 149 and 150: Risk & Policy Analysts feedback was
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- Page 155 and 156: Risk & Policy Analysts Table B2.2:
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- Page 169: Risk & Policy Analysts the NLF, imp
Risk & Policy Analysts<br />
<strong>Impact</strong> on Competitiveness, Trade and Investment Flows<br />
By reducing the likelihood that non-compliant ropes are imported into the EU, Option<br />
E2 and in particular Option E3 can be expected to improve the competitive position of<br />
EU rope manufacturers. No impacts on productivity are expected to occur.<br />
Operating Costs and Conduct of Business/SMEs<br />
Option E2 and in particular Option E3 are likely to impose some additional costs on<br />
importers and distributors. These are linked to both checking compliance as well as<br />
record keeping requirements (although it is assumed that these activities might<br />
already be routinely carried out under the baseline scenario). However, these costs<br />
are likely to be relatively small, because the numbers of products for which<br />
compliance would have to be checked and records kept is assumed to be relatively<br />
small (due to the small size of the sector, each importer and distributor is expected to<br />
sell o<strong>nl</strong>y a very small number of products each year).<br />
In addition, the UK national authority identified cost savings from alignment with the<br />
NLF associated with avoided error and misunderstandings due to greater clarity on<br />
operators’ obligations, in particular when dealing with imported products.<br />
Administrative Burdens on Businesses<br />
No significant additional burden is expected.<br />
Public Authorities<br />
National authorities in Liechtenstein and Denmark noted that alignment with the NLF<br />
would have the advantage of aligning the requirements applicable in the cableways<br />
sector with those in other sectors thus reducing the administrative burden on a public<br />
authority in a small country with a small cableways sector. Based on the study team’s<br />
assessment of the cableways sector in individual European countries, it is estimated<br />
that these benefits may arise in approximately one-third of EU/EEA states.<br />
Innovation and Research<br />
No impacts on research and innovation are expected.<br />
Consumers and Households<br />
No impacts on prices paid by cableways users are anticipated.<br />
Specific Regions and Sectors<br />
<strong>Impact</strong>s are likely to differ between Member States as some countries have<br />
manufacturers of cableways, subsystems and safety components and/or a large<br />
demand for cableways while other countries do not. However, as noted above,<br />
aligning requirements applicable in the cableways sector with those in other sectors<br />
Page 113
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