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The Cost driven Approach to
               Regulatory burdens (CAR)


      “What will the Nordic business environment look like in the future?”
                                  06-03-2013
Conference organized by the Swedish Ministry of Enterprise, Energy and Communications and Nordic
Innovation, within the framework of the Swedish Presidency of the Nordic Council of Ministers in 2013


                                        Presentation

               Peter Bex, managing director SIRA Consulting
The Cost driven Approach to Regulatory burdens
(CAR)
   Introduction
The Dutch government identified 10 business sectors in which the Dutch
Economy is most competitive internationally; so called Top Sectors.
The Top Sectors are:
    ■   Chemical industry;
    ■   Horticulture;
    ■   Water;
    ■   Agri & food;
    ■   Gmo;
    ■   Life sciences & health;
    ■   High tech;
    ■   Energy;
    ■   Logistics;
    ■   Creative industry (design, media & entertainment, fashion, etc.).
The  intention of the “top sector approach” is to strengthen the international lead
of Dutch companies by – amongst others – reducing their regulatory burdens and
coordinating investment in R&D and innovation.
The Dutch Cabinet aims to achieve €2,5 billion in regulatory burden reduction.
The Dutch Ministry of Economic Affairs asked SIRA Consulting to develop the
CAR methodology in order to support the top sector approach.
                SIRA Consulting BV | Edisonbaan 14G-1 3439 MN Nieuwegein | www.siraconsulting.nl
The Cost driven Approach to Regulatory burdens
(CAR)
    Working principles
Perspective of business: “Any approach should focus on the real costs (i.e.
compliance costs) as much as possible (VNO NCW, MKB Nederland)”.
Responsive government: The CAR methodology integrates the perspective of
the end-user (business) in a cyclical better regulation program.

                                                Better
                                              Regulation
                                               Program




                                  Sector
                                                              Sector
                                 Reduction
                                                             Analysis
                                   Plan




                                               Business
                                               Analysis




The   CAR methodology takes the financial administration of a business as its
starting point and makes all regulatory burdens visible.
The focus on real costs enables scoping of new reduction measures that
directly increase competitiveness, innovation and employment opportunities.
               SIRA Consulting BV | Edisonbaan 14G-1 3439 MN Nieuwegein | www.siraconsulting.nl
The Cost driven Approach to Regulatory burdens
(CAR)
  Stepwise approach
                                                          In this step we get an                     Result :
                                      Step 1
                                                        understanding of the main             An overview of the
                                   Identify cost
                                                      characteristics of the business     organisation and an outline
                                     centres
                                                         and how it is structured.           of its cost structure.
       Business Analysis

   We take as our starting            Step 2            In this step we quantify the                Result:
      point the business            Step-down          cost flows in the business, its    A (macro) understanding of
  administration. Through it       allocation of       turnover, and (in)direct and      the business economics based
   we identify and quantify            costs                 conversion costs.                on annual accounts.
       the costs of legal
      obligations. These
    regulatory burdens are
                                      Step 3            In this step we measure the                   Result:
    then expressed as % of
                                     Quantify           costs of legal obligations per   A (micro) understanding of the
     total business costs.
                                    regulatory         cost centre and express these     costs of legal obligations based
                                     burdens           as % of (non)personnel costs.       on invoices and accounting.
       The goal is to scope
      solutions and identify
    measures that lead to a
  tangible burden reduction .          Step 4            In this step we trace legal                 Result:
  Findings are summarised in        Trace origin       obligations to their codifying    A (genealogic) understanding
   a sector specific reduction     of regulatory       laws, including EU directives     of the origin and original form
  plan that leads to increased        burdens               and/or regulations.               of legal obligations.
          profitability,
      competitiveness, and
  employment opportunities.                             In this step we report our                   Result:
                                      Step 5                findings, and make           A report summarising step 1- 4
                                      Report          recommendations on a sector           including graphs, figures,
                                                         specific reduction plan.        tables and recommendations.




                    SIRA Consulting BV | Edisonbaan 14G-1 3439 MN Nieuwegein | www.siraconsulting.nl
The Cost driven Approach to Regulatory burdens
(CAR)
   Results
  The CAR methodology quantifies                                               The CAR methodology traces the
  regulatory burdens in relation to a                                          origin of all regulatory burdens
  company’s real costs.                                                        (administrative burdens and
                                                                               compliance costs).
  The methodology examines the
  impact of regulation from the                                                But rather than emphasizing
  perspective of business. It provides                                         abstract reduction targets, the
  factual information and hard data                                            focus is on growth and freeing up
  about the cost of legislation.                                               creative energy for innovation.
  40%

  35%

  30%

  25%
                                                                                                                                     Business expenses
  20%                                                     Regulatory burdens                                                         AB
  15%                                                     Business expenses                                                          CC
  10%                                                                                                                                IN

   5%

   0%
         Non-personnel Personnel costs   Material costs
             costs

 From: Comparison regulatory burdens SMEs in four EU member states (2013)      From: Comparison regulatory burdens SMEs in four EU member states (2013)




                            SIRA Consulting BV | Edisonbaan 14G-1 3439 MN Nieuwegein | www.siraconsulting.nl
The Cost driven Approach to Regulatory burdens
(CAR)
   Results
 The CAR methodology allows for a                                    The CAR methodology identifies
 comparison over multiple years.                                     tangible burden reductions.


 This makes it possible to assess                                    However, the objective is never to
 the impact of one-time, periodical                                  change or delete certain policy
 and annual regulatory burdens                                       goals, but rather to make sure that
 and expands the scope of                                            these policy goals are reached at
 possible reduction measures.                                        lower costs.


                                                                                                                    Business expenses


                                                                                                                    Food Safety (Food
                                                                                                                    Hygiene) Regulations
                                                                                                                    CBA/CEA pension
                                                                                                                    obligations
                                                                                                                    Employment Law


                                                                                                                    Food Labeling Regulations


                                                                                                                    Control and traceability




 From: Top Sector Chemistry (SIRA Consulting 2012)                  From: Comparison regulatory burdens SMEs in four EU member states (2013)




                          SIRA Consulting BV | Edisonbaan 14G-1 3439 MN Nieuwegein | www.siraconsulting.nl
The Cost driven Approach to Regulatory burdens
(CAR)
  Pilot studies
Chemical industry – “Top Sector Chemical Industry”
    ■   in this study the CAR methodology was applied in the Chemical Industry;
    ■   the focus was on “formulators” (these are blenders of chemical products,
        producing paint, pigments, glue, detergents etc.);
    ■   results of the pilot are used to draw up a specific ‘Regulatory Burden Reduction
        Plan’ for the chemical industry;
    ■   the Dutch Branch organization for the Chemical Industry (VNCI) is enthusiastic
        about the CAR methodology, and therefore a second project is planned for March;
    ■   the new project will focus on chemical production plants (more specifically, plants
        involved in the production of plastics);
    ■   both projects will be included in the policy initiative “Top Sector Chemical
        Industry”.


Bakery  Sector – “Comparison Regulatory Burdens small and medium-sized
enterprises (SMEs) in four EU member states”
    ■   an international comparison of the regulatory burdens experienced in the bakery
        sector of four EU member states: the Netherlands, Lithuania, Ireland and Spain;
    ■   provides an insight into the regulatory burdens (= administrative burden and
        compliance costs) of micro, small and medium sized bakeries;
    ■   reduction measures aimed at SME bakeries carry over and benefit other sectors
        too;
    ■   study is SIRA Consultingstage and the report will be published in March.
                 in its final BV | Edisonbaan 14G-1 3439 MN Nieuwegein | www.siraconsulting.nl
The Cost driven Approach to Regulatory burdens
(CAR)
  Examples of possible burden reduction measures
Fees for permits:
   ■   a bakery in the Netherlands serves ready-to-eat sandwiches for lunch;
   ■   provides clients with a small seating area outside like an outdoor café;
   ■   the municipality charges €5.000,- for a permit for this “outdoor terrace”;
   ■   the bakery has to literally sell thousands of breads just to pay for the permit.
Reliable   sampling:
   ■   a bakery in Lithuania is required to sample food and water for microbiological
       examination in a laboratory and has to pay an up-front fee for the privilege;
   ■   as there is no supervision of how or where samples are taken, Lithuanian bakers
       have no confidence in the credibility of the results as there are no safeguards build
       in to prevent cheating (if results are unreliable all costs are too high);
   ■   independent sampling by the inspectorate or an auditor would be such a safeguard.
Labeling   requirements:
   ■   allow different ways of labeling;
   ■   by allowing experimentation with other, more innovative ways of providing product
       information, it is possible to arrive at more sustainable solutions with smaller
       packages and less paper labels (i.e. a product book, a printout from the register, a
       digital information column, using an app for a smart phone);
   ■   relevant for many sectors, from small traditional food manufacturers to chemistry
       (which is confronted with a quick succession of changes like VOS2010 and
       REACH).
               SIRA Consulting BV | Edisonbaan 14G-1 3439 MN Nieuwegein | www.siraconsulting.nl
SIRA Consulting
Edisonbaan 14 G-1
3439 MN Nieuwegein
Netherlands

Tel: 0031 30 602 4900
Fax: 0031 30 602 4919
www.siraconsulting.nl

Contact
Peter Bex, managing director
SIRA Consulting
Edisonbaan 14 G-1
3439 MN Nieuwegein
Netherlands

Tel: 0031 30 602 4900
Fax: 0031 30 602 4919
www.siraconsulting.nl

Contact
Peter Bex, managing director

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Conference_20130305_Peter Bex

  • 1. The Cost driven Approach to Regulatory burdens (CAR) “What will the Nordic business environment look like in the future?” 06-03-2013 Conference organized by the Swedish Ministry of Enterprise, Energy and Communications and Nordic Innovation, within the framework of the Swedish Presidency of the Nordic Council of Ministers in 2013 Presentation Peter Bex, managing director SIRA Consulting
  • 2. The Cost driven Approach to Regulatory burdens (CAR) Introduction The Dutch government identified 10 business sectors in which the Dutch Economy is most competitive internationally; so called Top Sectors. The Top Sectors are: ■ Chemical industry; ■ Horticulture; ■ Water; ■ Agri & food; ■ Gmo; ■ Life sciences & health; ■ High tech; ■ Energy; ■ Logistics; ■ Creative industry (design, media & entertainment, fashion, etc.). The intention of the “top sector approach” is to strengthen the international lead of Dutch companies by – amongst others – reducing their regulatory burdens and coordinating investment in R&D and innovation. The Dutch Cabinet aims to achieve €2,5 billion in regulatory burden reduction. The Dutch Ministry of Economic Affairs asked SIRA Consulting to develop the CAR methodology in order to support the top sector approach. SIRA Consulting BV | Edisonbaan 14G-1 3439 MN Nieuwegein | www.siraconsulting.nl
  • 3. The Cost driven Approach to Regulatory burdens (CAR) Working principles Perspective of business: “Any approach should focus on the real costs (i.e. compliance costs) as much as possible (VNO NCW, MKB Nederland)”. Responsive government: The CAR methodology integrates the perspective of the end-user (business) in a cyclical better regulation program. Better Regulation Program Sector Sector Reduction Analysis Plan Business Analysis The CAR methodology takes the financial administration of a business as its starting point and makes all regulatory burdens visible. The focus on real costs enables scoping of new reduction measures that directly increase competitiveness, innovation and employment opportunities. SIRA Consulting BV | Edisonbaan 14G-1 3439 MN Nieuwegein | www.siraconsulting.nl
  • 4. The Cost driven Approach to Regulatory burdens (CAR) Stepwise approach In this step we get an Result : Step 1 understanding of the main An overview of the Identify cost characteristics of the business organisation and an outline centres and how it is structured. of its cost structure. Business Analysis We take as our starting Step 2 In this step we quantify the Result: point the business Step-down cost flows in the business, its A (macro) understanding of administration. Through it allocation of turnover, and (in)direct and the business economics based we identify and quantify costs conversion costs. on annual accounts. the costs of legal obligations. These regulatory burdens are Step 3 In this step we measure the Result: then expressed as % of Quantify costs of legal obligations per A (micro) understanding of the total business costs. regulatory cost centre and express these costs of legal obligations based burdens as % of (non)personnel costs. on invoices and accounting. The goal is to scope solutions and identify measures that lead to a tangible burden reduction . Step 4 In this step we trace legal Result: Findings are summarised in Trace origin obligations to their codifying A (genealogic) understanding a sector specific reduction of regulatory laws, including EU directives of the origin and original form plan that leads to increased burdens and/or regulations. of legal obligations. profitability, competitiveness, and employment opportunities. In this step we report our Result: Step 5 findings, and make A report summarising step 1- 4 Report recommendations on a sector including graphs, figures, specific reduction plan. tables and recommendations. SIRA Consulting BV | Edisonbaan 14G-1 3439 MN Nieuwegein | www.siraconsulting.nl
  • 5. The Cost driven Approach to Regulatory burdens (CAR) Results The CAR methodology quantifies The CAR methodology traces the regulatory burdens in relation to a origin of all regulatory burdens company’s real costs. (administrative burdens and compliance costs). The methodology examines the impact of regulation from the But rather than emphasizing perspective of business. It provides abstract reduction targets, the factual information and hard data focus is on growth and freeing up about the cost of legislation. creative energy for innovation. 40% 35% 30% 25% Business expenses 20% Regulatory burdens AB 15% Business expenses CC 10% IN 5% 0% Non-personnel Personnel costs Material costs costs From: Comparison regulatory burdens SMEs in four EU member states (2013) From: Comparison regulatory burdens SMEs in four EU member states (2013) SIRA Consulting BV | Edisonbaan 14G-1 3439 MN Nieuwegein | www.siraconsulting.nl
  • 6. The Cost driven Approach to Regulatory burdens (CAR) Results The CAR methodology allows for a The CAR methodology identifies comparison over multiple years. tangible burden reductions. This makes it possible to assess However, the objective is never to the impact of one-time, periodical change or delete certain policy and annual regulatory burdens goals, but rather to make sure that and expands the scope of these policy goals are reached at possible reduction measures. lower costs. Business expenses Food Safety (Food Hygiene) Regulations CBA/CEA pension obligations Employment Law Food Labeling Regulations Control and traceability From: Top Sector Chemistry (SIRA Consulting 2012) From: Comparison regulatory burdens SMEs in four EU member states (2013) SIRA Consulting BV | Edisonbaan 14G-1 3439 MN Nieuwegein | www.siraconsulting.nl
  • 7. The Cost driven Approach to Regulatory burdens (CAR) Pilot studies Chemical industry – “Top Sector Chemical Industry” ■ in this study the CAR methodology was applied in the Chemical Industry; ■ the focus was on “formulators” (these are blenders of chemical products, producing paint, pigments, glue, detergents etc.); ■ results of the pilot are used to draw up a specific ‘Regulatory Burden Reduction Plan’ for the chemical industry; ■ the Dutch Branch organization for the Chemical Industry (VNCI) is enthusiastic about the CAR methodology, and therefore a second project is planned for March; ■ the new project will focus on chemical production plants (more specifically, plants involved in the production of plastics); ■ both projects will be included in the policy initiative “Top Sector Chemical Industry”. Bakery Sector – “Comparison Regulatory Burdens small and medium-sized enterprises (SMEs) in four EU member states” ■ an international comparison of the regulatory burdens experienced in the bakery sector of four EU member states: the Netherlands, Lithuania, Ireland and Spain; ■ provides an insight into the regulatory burdens (= administrative burden and compliance costs) of micro, small and medium sized bakeries; ■ reduction measures aimed at SME bakeries carry over and benefit other sectors too; ■ study is SIRA Consultingstage and the report will be published in March. in its final BV | Edisonbaan 14G-1 3439 MN Nieuwegein | www.siraconsulting.nl
  • 8. The Cost driven Approach to Regulatory burdens (CAR) Examples of possible burden reduction measures Fees for permits: ■ a bakery in the Netherlands serves ready-to-eat sandwiches for lunch; ■ provides clients with a small seating area outside like an outdoor café; ■ the municipality charges €5.000,- for a permit for this “outdoor terrace”; ■ the bakery has to literally sell thousands of breads just to pay for the permit. Reliable sampling: ■ a bakery in Lithuania is required to sample food and water for microbiological examination in a laboratory and has to pay an up-front fee for the privilege; ■ as there is no supervision of how or where samples are taken, Lithuanian bakers have no confidence in the credibility of the results as there are no safeguards build in to prevent cheating (if results are unreliable all costs are too high); ■ independent sampling by the inspectorate or an auditor would be such a safeguard. Labeling requirements: ■ allow different ways of labeling; ■ by allowing experimentation with other, more innovative ways of providing product information, it is possible to arrive at more sustainable solutions with smaller packages and less paper labels (i.e. a product book, a printout from the register, a digital information column, using an app for a smart phone); ■ relevant for many sectors, from small traditional food manufacturers to chemistry (which is confronted with a quick succession of changes like VOS2010 and REACH). SIRA Consulting BV | Edisonbaan 14G-1 3439 MN Nieuwegein | www.siraconsulting.nl
  • 9. SIRA Consulting Edisonbaan 14 G-1 3439 MN Nieuwegein Netherlands Tel: 0031 30 602 4900 Fax: 0031 30 602 4919 www.siraconsulting.nl Contact Peter Bex, managing director
  • 10. SIRA Consulting Edisonbaan 14 G-1 3439 MN Nieuwegein Netherlands Tel: 0031 30 602 4900 Fax: 0031 30 602 4919 www.siraconsulting.nl Contact Peter Bex, managing director