LEVEL OF AGREEMENT

MOST DISCUSSED PARAGRAPHS

P10 Member states should develop a regulatory fr
14 26
P12 Government/regional and EC should support in
13 17
P17 The EC should encourage partnerships between
12 28
P18 CCS campaigns with potentially high positive
11 26
P6 The EC should facilitate a European conferen
11 0
P16 The EC should further develop the Crowdfundi
10 0
P1 Organisations that support creatives and cul
10 25
P7 The EC should stimulate the process of setti
10 15
P4 The EC should further develop the Crowdfundi
9 15
P23 The EC should incentivize financial institut
9 0
P15 Similar to the Capacity Building programme o
8 12
P22 The EC should foster the visibility of succe
8 18
P19 The EC should provide guidelines for local a
7 0
P20 The EC should identify and tackle the bottle
7 12
P11 Member States and the EC should provide clea
6 0
P13 Member States should integrate financial lit
6 25
P2 In promoting access to finance for the CCS,
5 23
P8 In order to bring transparency and good code
4 27
P5 The EC should support the launch of an EU
4 21
P21 The EC should encourage investment in crowdf
4 15
P3 The EC should facilitate the exchange of pra
3 22
P9 The industry should stimulate clear communic
2 20
P14 The EC should support the development of an
2 17

LATEST COMMENTS

What would be the best actions to take in order to give crowdfunding the place it deserves as a financial tool?
The EC should promote a pan-European tax deduction scheme for any donation to any CCS projects. This scheme would be available to any cross border donation within the EU.
I think that the best label is given by the crowd.
I don't see how this would be possible with the EU bureaucracy.
If part of a larger event on crowdfunding or alternative finance - yes. If a separate event - not so sure.
This is already done, as some commentators mention, at national level by associations in different countries or cities. If there should be a European one, there's no need for a new open competition from scratch - probably some very good campaigns and projects already selected, which could go on to compete for a European prize.
This is already done, as some commentators mention, at national level by associations in different countries or cities. If there should be a European one, there's no need for a new open competition from scratch - probably some very good campaigns and projects already selected, which could go on to compete for a European prize.
I also agree with Joost - it's about financing in a broader sense. Also, it's more about giving crowdfunding the place it deserves as financing tool along with other schemes and available solutions for businesses, CCS or other sectors.
There are as previously mentioned existing repositories - it real depends on scope and scale of project. Should crowdfunding4culture point to these sites, so people can learn of their existence and go there to find relevant information? I think so. Should a new proprietary digital library or resource be built ? I'm not so sure about that.
There is a need for more info on different matchfunding models, the results of matchfunding and the obsyacles for governments and funds to ally with f.e. one platform, as this can be seen as interfering with the market
there is a difference in more market-based initiatives that look for finance and the more non-profit initiatives that often combine subsidy, crowdfunding and f.e. loans, and where matchfunding (by governments and regional funds f.e.) is growing. Most small cultural initiatives do not have the resources to develop all necessary knowledge on these sources of finance. An access2finance tool and a directory of further sources for advice could be very helpful.
In Germany a number of crowdfunding platforms have set transparency rules that go further that the legal obligations, that is one area. A quality label could include ares like information before you start the the crowdfunding campaign on the kind of platform, support to the crowdfunder, costs and risks; on transparency of results and on the financial situation of the platform itself.
Well you say "websites" (plural) "like" CF4C implying there are others tangentially related. It is much too loose an endorsement for me to give and I still dont see a role for EC in this
Dear Twintagibles, thank you so much for your interesting and useful input. In most circumstances you remain skeptical of the proposed actions. According to you, while keeping in mind the needs of the CCS sector, is there anything local/regional government and the EC should do in order to better accommodate the use of crowdfunding? Be that in campaign management, awareness raising, skills, matchfunding etc? Please feel free to propose new actions. No-action is always a possibility too :)
Indeed the idea is not to replicate but to gather what already is there. In that case you would agree that the EC should continue to support websites like crowdfunding4culture to aggregate such pool of resources?
To clarify my comment which is probably not well worded my point is that there are certainly financial institutions and funding bodies already looking more favourably at, and investing in, successfully crowdfunded initiatives so, as I say it is already happening without any incentivisation from Europe. On a broader point - it is very pproblematic for governemtnal and quasi governmental bodies liek EC to intervene direclty in marketplaces through icentivisation "programmes" without falling foul of beinn accused - righty - of market manipulation.
Not the EC because "crossborder" is global not 28 states, and mostly because of the complexity more is achieved bilaterally anyway. Such pan european initiatives and provisions that exist Mifid, Prospectus Directive etc. are not useful to crowdfunding platforms in large part as there are so many local provisions to deal with which and can enver be harmonsied - nor would you want them to be. However, in the cultural sector it is largely unconstrained and open models of crowdfundig such as Reward which dominate and the EU did its best to mess that up with VATMOSS
Local authorities I work with on these issues are receiving many enquries from other groups for advice so a network is already emerging. It emerges because a local authority will simply look for examples of where it has been doen before and approach them. In essense the the demand is beign met and beign met by the actors which is the natural emergent model for thsi tyoe of netwrok. The effort required to create and publicise "non local authority" hub is highly unlikley to yield results IMHO. If you feel the need to intervene build on what is already happening. Perhaps more importantly guidelines suggest delivering a prescriptive approach which is higly unlikely to be very effective and counter to innovation - at least in my experience.
But of course they are scattered - that is how the internet works. Linking dispersed resources not replicating them. There are many ways of linking this sort of material and adding value without simply replication so I would strongly discourage replication.
And not all financiers familiar with crowdfunding see it as proof of concept either in my experience. Whilst you and I might have faith in the idea that it can indicate some valifdation of an idea concept it is not a universally shared view nor should we insist that it is as it is not flawless, it is gameable and far from infallible. The fact that some, like us, accept it has some application and have we have recognised this suggests that these things are emerging and will continue to do so organically but to strive to insist on it as for uniformity of view or as an unshakeable truth is just wrong IMHO
There will never be uniform uptake, that is simply a reflection of the diversity of europe and the world, and is a function of a whole range of factors. I would argue that there is no structural inequality so no intervention is needed
Possibly, but, even then, would it not make more economic sense to add a finance theme into a wider cultural conference? That way you widen it out, expend less resource and enhance the opportunity. I think my biggest issue with this is that there has always been a perception that culture always needs more finance, so this situation is not novel so does not requeire exceptional action IMHO
Our interviews showed that many local authorities do not know how to approach or adapt matchfunding. What could be done to assist them to better implement matchfunding for CCS?
If not the EC, which other is better positioned to help reduce bottlenecks?
Is it emerging at EC level? If so please provide us with some more information.
yes, but they are scattered around the internet. Is there a need to have resources under one European website?
There are some initiatives between platforms and banks, where the latter use the success of a campaign as a proof of concept for future loans. This could be potentially very beneficial for CCS. However, not all financiers are familiar with using crowdfunding as proof of concept.
This is happening in some regions/countries more than others. What could be done to harmonise these actions across the EU?
Is there an added value to gather all the updates from member state and put them together one specific location, i.e. crowdfundign4culture website?
If the conference would cover access2finance for culture broadly (including crowdfunding), then would the organisation of a European conference be useful?
Thanks guys. I am not sugggesting that it shouldnt be encouraged I am simply saying that I think its already happening so I am not sure any further encouragement is needed and I cite the Scottish case merely to illustrate the point without any suggestion that it is not happeing elsewhere or should be constrained to Scotland
This is emerging anyway
It is already happening - but - as with my comment above care must be taken in this as the danger is you reduce the distinctiveness and advantages of crowdfunding and simply lump it in with old world capital - this would be a mistake
Again this is already happening. However it has the danger of distorting the specific and unique advantage of crowdfunding.
This is a well understood problem. I do not see the EC as a body to reduce bottlenecks in this space
This is already happening why is there a need for a further intervention and, in particular, guidelines?
Some highly subjective terms included there. One of the attractions of crowdfunding its speed of operation and another is its sense of control for the fund raisers. slow and bureaucratic application are not well aligned with this.
These type of activities are already emerging without the need for interventions.
Resources already exist
What evidence is there that crowdfunding platforms and financiers dont understand this?
Depends on what you mean by financial literacy, but Scotland already does include some financial teaching elements into its core curriculum
Thanks twintanglibles! Do you think it is a good idea to encourage such guidance beyond Scotland?
They already do - I see no point in this recommendation when it already happening anyway.
Given that EC made such a mess of VATMOSS I think this is unlikely to be achieved at a supra national level
This is already happening
Once again this supposes there is a problem with lack of transparency or bad actors here - I see no evidence for it. It also presumes that it is possible to find sufficient consensus about what good practice is, or what is appropriate transparency, IMHO this is unlikely to produce a useful set of metrics which won't militate against innovation
This supposes there is a "trust issue" that needs to be addressed - I see no evidence of that
This feels all too narrow and self serving. Broader consideration of finance in Culture maybe but why would organisations short of funding want to spend it on a jolly to a conference?
I don't see this as a useful or cost effective approach.
This requires lessons to be learned first - I am not confident that they are as it is much harder than people think
This is problematic at a supranational level because of the diversity of local circumstance and given the colossal mess that VATMOSS introduced to crowdfunding and many small cultural and creative businesses I doubt that there is sufficient expertise and understanding at EU level to deal with this well
This is already in place with some groups like Cultural enterprise Office in Scotland and is yielding good results. the challenge is some cases is the quality of the advice and support available - this can be very variable
Would you discourage completely a European label setup? If so, what alternative would you recommend?
This might rule out smaller platforms that do not have the financial means to apply for the label. Whilst they are doing a good job in the crowfunding sector.
Interesting idea but this needs to be carefully designed. Potentially a way to facilitate participation to EU programmes from smaller players and SMEs who have practical difficulties to find the right angle to take part in EU projects while their activities are in line with the objectives of the programme.
Guidelines, case studies, data on benefits & impacts would be helpful and make sense at EC level. Another option would be to test a pilot project on interregional cooperation (for example via Interreg).
'Early stage' is a bit too much in my opinion - though some basic elements/skills could be integrated early... But that would make sense in lots of higher education curricula, whereas it's not so much the case at the moment.
I fully agree with Joost on this one - see also comment on the very first proposal.
Not following this closely but in many Member States you have tax exemptions for many donations depending on their purpose (e.g: social impact). A similar system would be logical for crowdfunding - if it's not the case already. A general exemption for all donations does not sound very reasonable however.
I feel this could be a bit broader - access to finance remains a key issue for the sector, generally speaking. A yearly meeting reaching out to the different stakeholders involved in access to finance and the CCS would be highly beneficial over the long-run. Including but not limited to crowdfunding. That would also facilitate partnerships across different funding & investment vehicles.
I generally agree - though I would advocate for a more finegrained approach depending on the needs of the entrepreneurs they work with, and the resources of these organisations (many are very small).
Perhaps in the MEDIA strand, but for the Culture strand of Creative Europe it would be highly problematic. It would benefit big, stablished operators than can support the investment of a European-wide campaign, both in terms of time and resources, which the majority of the cultural sector do not have in the first place.
It is also very important to integrate all EC initiatives in communicating about financing for culture, where this website is one element in.
I was thinking of mentors as people of the CCS who succesfully used crowdfunding (success=reaching their funding objectives). The role of the EC could be that of enabling these contacts (mentor-mentoree) and give them visibility.
Should the EC support such "mentoring" system? Who do you foresee as mentors? Crowdfunding advisors? Platforms? Please specify
I do think the website could be the right place to show best practices and lessons learned (as suggested in the previous question). Actually I was missing more of that when checking the website. Also, and sorry if this exists already, a peer-to-peer exchange or "mentoring" system might be helpful for those hesitating of embarking a crowdfunding endeavour.
Could it be useful to insert this as part of an already existing event for the CCS? Not that I think that crowfunding is not important enough to have its own event, but calendar is already packed with events, so it could be useful to join efforts so that cultural and creative people do not have to choose. Just an idea!
I aggree and outlined one approah to this in my new book: The JOBS Act: Crowdfunding for Small Businesses and Startups https://www.amazon.com/JOBS-Act-Crowdfunding-Businesses-Startups/dp/1484224086/
sometimes banks see crowdfunding success as an indication for more funding, i.e lending, but this is still in the begining, especially in the CCS this hardly ever happens, so yes, this could be stimulated
not within the CCS
In my opinion there is not enough information on how to organise matchfunding in a effective way since there are many existing models of matchfunding and many public bodies and funds are not aware of the possibilites
i can see a case for a repository of free resources and reference to paid services as to not interfere to much with teh market for such services
making info accessible on the availability of good training programs can be done at a EU-level, the training programs themselves should be at national or regional level
I would broaden the scope to financial literacy, not only crowdfunding, because crowdfunding is often part of a financing strategy that mixes subsidy, crowdfunding and lending. Which steps to follow, what comes first, who has the rights to collateral, these are all questions most crowdfunders have no clue for an answer
I think it would be wise of the EU to stimulate such a process by bringing parties together, but not by developing such a label by themselves, that will not work. And use the experience of existing quality labels where ever they exist
if we want crowdfunding be more developed for the CCS, not only in size, but also in types of crowdfunding ( almost all is reward/donation based in CCS), I think it would be great to have such an event
I do not see any website that makes info available on a European level for the CCS on the possibilities of crowdfunding and the availability of platforms EU-wide
should policy makers feel responsible for informing on crowdfunding models and practical technicalities of is it the platfrms hoe are responsible? Ik think there could be a need for transcending info that the platforms do not provide
so there are two levels here: on which level (national/regional/local) should support structures adopt and adapt to crowdfunding support, and how can regulatory bodies of funding schemes adapt their regulations as to not exclude combinations of crowdfunding and other funding
Great! How do you foresee this awareness raising to take shape?
Not sure, if the crowdfunding campaign is successful financial institutions should already be incentivised. Further, this could reduce available public resources for cultural organisations.
How would matchfunding increase the financial gap? Please do elaborate.
Indeed, but this is a difficult and lengthy process since public authorities and/or private organisations are not aware of the benefits of crowdfunding. Should the EC do anything to encourage matchmaking between crowdfunding platforms and local, national and regional (public or private) funds?
In the sense of sharing of best practices.
Given the different stakes and magnitude of implied stakeholders, it is not clear the EC's role.
Can you please name a few?
In what capacity?
Bottlenecks are already identified. They should be tackled in terms of laws and regulations, and their implementation.
I think the first desirable effect would be to increase awareness among local authorities and regions.
Hi Elisabetta, can you please further elaborate on the reason why you think a European Quality Label might crystallise the development of crowdfunding?
The associated risk would be to possibly increase the financial gap of some still culturally good/excellent organisations/projects.
The website has been running already for more then 1 year, so it would not be a new action. The idea would be to further improve the website. According to you, what features would make this website more effective?
A good crowdfunding platform should already include or foster this matching.
I am not sure whether to add another informative website, and the effectiveness and opportunity costs of a truly interactive one.
So how could it best be tackled? Do the cultural and creative organisations need to be trained on the type of support they could provide with regard to crowdfunding? If so, who is best positioned to train them?
There are already enough initiatives in this sense.
Ideally something could be done and it would be helpful, although - in terms of effectiveness of such an initiative - the cultural context is more fragmented than the business one as targeted by the mentioned EU platform for access to finance.
I would leave financial technicalities of crowdfunding to specialists.
Especially because such reality is not equally distributed across the EU, exchange of best practices could be more effective.
See my comment above.
Yes, although this depends on more general harmonisation issues (fiscality, on-line transactions, etc.).
Totally agree. Such a communication is not always fully effective.
There are already some existing initiatives on more general crowdfunding of which cultural crowdfunding - although with its own idiosyncrasies - could benefit of. Consider also related opportunity costs. See also my comment above.
I am not sure whether the EU is already ready for this. See for instance the issue of harmonisation. Further, to "crystallise" such an existing process might hamper its full development.
To create an international opportunity of confrontation and debate is useful. I would also open to non-EU countries, especially those where the crowdfunding experience is more mature.
Given the heterogeneity of the application and practice of cultural crowdfunding, such a prize competition should be carefully design to equally support culturally domains relatively more or less in need of crowd's financing and commitment.
I am not sure to which extent a further dedicated website would be effective in this sense. Furthermore its effectiveness would crucially depend on its design, development, outreach, network and update.
See my comment above.
Margins of intervention by national and EU policy makers may include the promotion of initiatives incorporating best practices of crowdfunding.
Although this is not equally straightforward for all types of organisations, given, for instance, their different degree of autonomy, scope and cultural domains of intervention.
This is a more democratic way of creating support: first show that there is a community interest - then receive taxpayers money.
These website all ask fees for their services. Is there not a need of a free tool CCS can use to understand how to make use of crowdfunding and how to run a successful campaign?
Should the distribution of the training programmes be done at EU level?
We are aware of the EC guidebook, but no VAT or Tax clarifications per member state are given there.
Please do provide the links :)
some of the databases mentioned are not for free. Do you think there is a need for an accessible and free data observatory? You also mention that it is better to link the existing databases. Should the EC facilitate this process as well as help establish a common data gathering standard?
Can you please share a few examples?
We agree, but such event do not focus on culture. Do you think there is a need to create events tailored specifically for CCS? I am not sure about the Zagrab event, but the Crowdfunding Day in Amsterdam is very expensive event and not many CCS can afford to join this event.
Indeed there are many websites, but not focused on CCS. When it comes to European level we notice that there is fragmentation and hence the proposal for a EU website. Can you please further elaborate on your answer?
Thank you Karsten! According to you, who is best positioned to clarify how existing schemes for cultural and creative projects can be used to cofinance crowdfunding projects? Is this the responsibility of organisations that support creatives? Or the responsability of the schemes themselves (i.e. Creative Europe)? or any other?
great to hear! Can you please share some examples?
Should the EC not even have a role in sharing regional/local best practices?
Hi Karsten, what do you think would be the most effective way to share results with stakeholders? Also, please feel free to share with us the tenders you mention.
Indeed! However, can the EC do anything to encourage such partnerships? I.e. share best practices, facilitate interaction between public and private funds and crowdfunsing platforms, organise conferences etc...?
I think there are plenty of good training programs in the market right now - public authorities should help with the distribution of these training programs and reducing the barriers of accessing these training programs.
I think these types of partnerships have to be created at the local level, otherwise they are not effective.
yes, good idea!
There are a number of EC tenders right now addressing this exact issue. The results should be shared with the stakeholders.
I really don't think that there is a role for this for the EC because plenty of national, regional and local actors are already doing this.
The EC is already doing that ;-)
A successful CF campaign is a good indicator of market readiness and public interest. Some financial institutions in Germany are already including CF campaigns in assessing creditworthiness.
For cultural Crowdfunding, it would be important to include aspects of financial literacy at university level in arts universities.
There are plenty of incubators which support Crowdfunding or work close with Crowdfunding campaigns - there is no market failure in this area. Initiatives such as the Crowdfunding Hub in Amsterdam exist and are already working well.
The EC has done so already - please have a look at the EC Guidebook for Crowdfunding. Some member states, for instance Germany, have done so as well.
For reward-based CF, crossborder financing is no problem at all. For equity and lending-based CF , crossborder financing is impeded by national goldplating of existing European framework.
Yes, several people have researched tax schemes and there are a number of EU funded projects with data on tax schemes regarding Crowdfunding. I can provide the links here if necessary.
Equity- and lending-based CF already has a national and a European legislative framework and the European Capital Market Union is providing a good framework already. For reward- and donation-based Crowdfunding, this process is on its way across all membership.
This is what the Crowdfunding industry is doing already.
There are data observatories, such as Crowdsurfer (which has previously received EC money to support their business model) - there is no market failure of providing data. The national Crowdfunding Assocations, research institutions and private intiatives are collecting data. There are probably about 15 EU-funded projects which have gathered data on Crowdfunding or will be gathering data on Crowdfunding, it might be better to use the existing databases and link them, facilitate a common data standard.
In general a good idea, but as far as I know in all member states the Crowdfunding platforms are currently developing quality labels to support the market.
There are conferences such as the Zagreb Crowdfunding Convention or the Crowdfunding Day in Amsterdam which are quite established and a good meeting point for the Ecosystem. There is no market failure here - plenty of events all across Europe.
In general, this is a good idea. CF prizes in Berlin (local level) and Slovenia (national level) help to promote the idea of Crowdfunding. Instead of creating a European Crowdfunding prize, an initiative could be to co-fund regional or national Crowdfunding prizes, because in the spirit of subsidiarity, such Crowdfunding prizes can only work if local networks promote the prize as well. A European Crowdfunding prize could be easily distorted because of the different development of Crowdfunding ecosystems across Europe.
There are already a number of websites who are exactly doing this - there is no market failure in this area and it does not make sense to replicate existing initiatives.
Very good idea.
I think this is already done to quite some extent, there is no need for action on behalf of the European Commission here.
This is important - more important is to clarify how existing schemes for cultural and creative projects can be used to cofinance crowdfunding projects. Sometimes, it is not possible to combine public funding for movies and crowdfunding, for instance.
There are plenty of alternative websites which are better suited to reach out to creatives, such as www.ikosom.de, www.crowdfunding-services.com, www.crowdfunding-campus.de, www.crowdcamp.de. There is no market failure for Crowdfunding for Cultural Organisations.
Are your proposing that, as a first step, we should create an inventory of favourable tax schemes across Europe so that member states can learn from one another?
In certain regulatory aspects the EC has no authority. That is why we address potential actions at Member State level. Please feel free to propose an EU regulation you find necessary.
is there a study wih an inventory overview of favourable tax schemes of different member states? that could help other countries to come up with good ideas
national regulations which permit crossboder financing would help in the meantime
harmonising will take a long time to arrive, clear guidelines might help in the meantime
in art curriculia and creative industry education there is hardly any attention to financial literacy. But most students do not have any interest in that stage. 2 years after graduation this interest will have grown, so there also should be a alumni program on financial literacy.
besides making these projects visible (who will decide which projects are succesful enough?) the EC could faclitate developng networks between financiers (funds, angel networks, investor networks, banks, the EU-guarantee facility) and (networks of) crowdfunding platforms
Guidelines, examples and different models of matchfunding should be available, not only to local and regional authorities, but also to intermediaries and private funds which look into possibilities of matching crowdfunding projects
projects that use crowdfunding as a means to reach an audience and raise funds could get extra points within certain Creative Europe applications
The EC is already active in this sector, by launching the Guarantee Facility in order diminish the risk of loans towards the cultural and creative sectors. Given that many CCS face problems in accessing traditional finance, should their successful crowdfunding campaign act as a 'proof of concept' for further financing opportunities? If so, should the EC incentivise financial institutions to take this on board?
Only if you really see a necessity to get involved. If this is already increasingly happening than just relax.
Actually, I think it is a strong proof of concept to run a successful crowdfunding process that endorses the project to banks, VCs, BAs etc. So I don´t see any necessity for an EC involvement. The people behind the project are obviously able to take care of their project themselves. That´s just fine.
Mentoring, i.e. having experts to talk to a all stages of a crowdfunding campaign might be an important ingredient in support strategies.
This is about attracting financing outside crowdfunding, i.e. from banks, Venture Capital or Business Angels. Should a successful crowdfunding be considered as a "proof of concept" for other types of financiers?
Not sure exactly, but every year there are thousands of projects that get EU funding for cultural projects that are important for European society. The questions really is: Should the EC look into channeling EU funds (i.e. Creative Europe) to co-finance cultural projects backed by the crowd in the form of matchfunding?
How long does it take to get the basic working of crowdfunding across? half a day seems sufficient. Learning how to run campaigns may need a wee with a lot of "hand on" work but - this is my first guess - not much more.
Indeed, regulating crowdfunding at European level should be envisaged in the near future.
Partnerships in the form of matchfunding are occurring more and more between crowdfunding platforms and public/private funds. Should the EC do anything to promote such partnerships in order to benefit the Cultural and Creative Sectors?
How would you envision the courses to look like and who should provide them?
What is the rationale for this and why should the EU be active here?
Actually, successful project have already demonstrated that they are able to raise support. I would not worry about these but those interesting projects that did not manage their crowdfunding campaigns properly.
E.g. European and not national regulatory framework for crowdfunding.
Instead of matchfunding, traditional support measures for creative and cultural industries might resort to crowdfunding mechanism/platforms for selecting projects.
Can you please give an example of such a CCS campaign that would merit matchfunding.
What does this aim at?
This seems a little bit over the top. A downside of crowdfunding are to be seen in the rather costs of capital, i.e. you have to be able to run a quite demanding campaign to successfully compete for crowdfunding money. Of course, there are "side effects" but still the costs might be high. Courses on crowdfunding taking place in incubator type of places might be appropriate.
That´s something to be harmonised overall not just for crowdfunding campaigns. Complex VAT and tax guidelines are a hampering factor for operators in the culture sector as well as SMEs in general. Clear guidelines are a weak substitute for a harmonised internal market.
Why is the crowdfunding regulation national. Is´nt this a good case for European regulation?

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