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1. Bulgarian Industrial Association www.bia-bg.com Regulatory Impact Assessment of the Low Voltage Directive Implementation in Bulgaria Borislav Georgiev General Director “International economic relations” Bulgarian Industrial Association INCOLAB Conference, 2-3 December 2004

2. Bulgarian Industrial Association www.bia-bg.com Regulatory Impact Assessment of the LVD for BG The directives on free movement of goods defend the safety of people, animals and environment but they are also non-tariff barriers to trade. The related services – certification, accreditation, standardization, etc. form a significant market. We are trying to assess the balance between requirements and barriers. The assessment is based on the combination of data from reports prepared by BIA for AENOR in 2003, CEPS - Brussels study and expert estimates.

3. Bulgarian Industrial Association www.bia-bg.com Regulatory Impact Assessment of the LVD for BG NTB market assessment in USD millions in BG Year 2001 2002 2003 2004 Export (FOB)5099 5578 7522 9100 NTB services (2%) 102 98 150 182 no Approach share(38 %) 39 37 57 69 Old Approach (20 %) 20 19 30 36 New Approach (42 %) 43 42 63 77 Import (CIF)7230 7706 1083414020 NTB service (2%) 145 154 217280

4. Bulgarian Industrial Association www.bia-bg.com Regulatory Impact Assessment of the LVD for BG About 400 companies form almost 75 % of Bulgarian export to EU.One fourth (100) are registered in Sofia, about 40 in total in Plovdiv and Pazardjik,about 40 in totalin Petrich, Sandanski and Blagoevgrad, about 35 in Varna and in Bourgas, 20 in Pleven and in Sevlievo, etc…More then a half of the top Bulgarian exporters to EU are registered in 10 biggest Bulgarian cities. Only 20 % of the firms or 80 have QMS certified in compliance with ISO 9000, and even less - 2,5 % or 10 have EMS ISO14000 certified.

5. Bulgarian Industrial Association www.bia-bg.com Regulatory Impact Assessment of the LVD for BG The average annual Bulgarian foreign trade data in USD millions for 2000 –2003 (expert estimates) in goods subject to Bulgarian regulations, corresponding to EU gas, law voltage and machine directives, are: Export ShareImport Share Gas 19 0,3 %130 1,6 % Law Voltage 293 5 % 890 10 % Machine 44 0,7 90 0,9 %

6. Bulgarian Industrial Association www.bia-bg.com Regulatory Impact Assessment of the LVD for BG Bulgarian import of LVD products comes from EU– 54,23 %; other countries -20,54 % (Turkey - 5,93 %, US – 4,95 %, China – 4,17 %, etc.).The major imported groups of goods are household and similar electrical appliances - 56,49 %; audio,video and multimedia subsystems and equipment – 21,04 %; cables – 6,69 %. The major part of LVD import enters Bulgaria through 20 border crossing points (BCP). The Customs offices of the top ten BCP process 80 % of the total import.

7. Bulgarian Industrial Association www.bia-bg.com Regulatory Impact Assessment of the LVD for BG The Bulgarian exporters of LVD products with 80 % cumulative export share are 20 out of all 2000 exporters. The importers with 80 % cumulative share are 15 out of all 6000 importers. The average annual value of the national production sales compared to the value of export is 19 % and case of import is about 6 %.

8. Bulgarian Industrial Association www.bia-bg.com Regulatory Impact Assessment of the LVD for BG The data about assessment of the market were made based on 3 indicators: CE marking of LVD products; availability of the documentation to find the importer/producer and Bulgarian made products in 2002. CE marking results form three groups. The first group, with more than 70 % share, includes the town of Blagoevgrad, V.Tarnovo, Vidin, Gabrovo, Kjustendil, Pernik, St.Zagora, Haskovo, Jambol. Second group is with CE marking in the range of 40 to 70 % like Bourgas, Varna, Vratza, Montana, Pazardjik, Pleven, Rousse, Sliven, Sofia, Targovishte, Shoumen. The last group, where the CE marking is below 40 % - Dobrich, Kardjali, Lovetch, Plovdiv, Razgrad, Silistra, Smolian.

9. Bulgarian Industrial Association www.bia-bg.com Regulatory Impact Assessment of the LVD for BG Documents availability in %, which defines that the first importer/producer can be easily identified, forms two groups – the first one, with more than 50 % of the cases and 25 cities and second group with 3 cities – Varna, Dobrich and Shoumen where such documents are not available. Most of the managers, including the ones of the big stores, were not aware on the safety regulations (year 2002). Most of the managers were reluctant to supply information, although there were also many respondents with open and cooperative reaction.

10. Bulgarian Industrial Association www.bia-bg.com Some comments: 1. LVD products and companies subject to control represent a significant share of Bulgarian foreign trade and production. Regulatory impact assessment in this area has to become regular annual activity; 2. Business awareness, capacity and knowledge is lagging behind the expectation and potential of this important sector of economy. Management training by competent professionals has to be planed for about 500 companies on biannual basis; 3. Bulgarian LVD regulation (SG 62/2001, SG 74/2003) has special provision – art.14 (2) it.2. It stipulates that accreditation in compliance to EN 45011 for certification of products has to be issued by EA “BAS”. What is the EU member countries experience in assigning administrative competence to the state agencies in the directives?