EUROPEAN UNION LOBBYING
Introduction
Today we are going to look very superficially at lobbying the European Union institutions. We'll begin with a quick run through the basic policy making structures of the EU (but it is only very much an introduction; if you want more detailed information on any of the topics raised there are several useful textbooks in the Library) and then in the second half I'll discuss how these processes impact upon the practice of public affairs and how lobbyists are regulated in the EU. To begin with an idea about the scale of lobbying that goes on in the EU institutions - in 1992 the European Commission estimated that there were perhaps 10,000 people representing 3,000 groups who were involved in lobbying the Commission, Parliament and Council of Ministers.
The European Parliament
In its early days, the European Parliament was made up of appointed Members, but it has been entirely directly elected since 1979. The Parliament holds its full plenary sessions in Strasbourg (for one week a month), meetings of its committees take place in Brussels (over two weeks a month), and its administrative departments are based in Luxembourg. The 626 MEPs are generally elected as party politicians, although a few independents will always manage to get elected. However, once elected the MEP will usually join a particular political grouping within the Parliament. So, for instance, Labour MEPs from the UK are members of the European Parliament's Socialist Group. Other major grouping include the Greens, the European People's Party, and the Liberal and Democratic Reformists. These broad coalitions allow like-minded MEPs from across all EU nations to coalesce on policy issues. They are less cohesive and disciplined than parties in national parliaments, but do nevertheless allow some co-ordination to take place. (Do also keep in mind that under the EU's plans for enlargement which we will deal with in more detail later, the size of the Parliament will increase as new nations join the Union; however, it is the intention at the minute to cap the number of MEPs at 700, so clearly the existing countries' representation will have to be decreased - for instance, Ireland has 15 MEPs at the minute but this will eventually fall to perhaps 11 or 12.)
While the Parliament does engage in general debates in the Chamber, much of its detailed policy work in undertaken in committees. The Parliament has 19 major standing committees which are responsible for initiating policy proposals and for providing the first scrutiny of proposals which emerge from the Commission. The committees also undertake investigative inquiries into particular problems, taking oral evidence from Commission officials. Each standing committee has a wide remit - such as Agriculture, Fisheries and Rural Development; Social Affairs, Employment and the Working Environment; Culture, Youth, Education and the Media. Perhaps the most important and effective are the Committee on the Environment, Public Health and Consumer Affairs and the Committee on Economic and Monetary Affairs and Industrial Policy. Clearly, MEPs who sit on relevant committees often develop considerable expertise in particular policy areas and will consequently become a target for lobbyists.
This is even more true of certain MEPs - known as rapporteurs - who are appointed by the committees to co-ordinate the Parliament's response to Commission proposals. When a rapporteur is appointed, each of the political groupings in the Parliament will themselves appoint shadow rapporteurs to monitor the work which is being undertaken. Rapporteurs essentially provide the first draft of the Parliament's detailed thinking on a particular policy issue, and hence they are an obvious focus for interest groups and lobbyists working in that area. Reports will be presented to the full Parliament for debate and amendment, after which they are sent to the Commission and Council of Ministers for decision.
Just as the Westminster Parliament has a number of All-Party Groups which allow MPs who share an interest in a topic to meet regularly, so the European Parliament has what are known as intergroups. Intergroups are essentially unofficial - to the point where there is no definitive list of them all - and receive no funding or resources from the Parliament centrally. Each intergroup relies upon the support of its members and of any external interest groups which take an interest in their work. Indeed, there is some concern that some of the intergroups are becoming too closely identified with sectional lobbies. Because they are wholly unofficial, the intergroups vary in their activity and effectiveness, with some meeting regularly and producing reports and others largely dormant. Some only allow MEPs to join while others encourage outside interests to become members. There are thought to be around 50 intergroups ranging across subjects such as Airport Regions, Ageing, Consumer Affairs, Cuba, Gene Splicing Technologies, Minority Languages and Cultures, Rugby League, Shipbuilding, Tourism, and Welfare and Conservation of Animals.
One textbook has suggested that the value of intergroups has been largely underestimated. It asserted that they, "permit members to specialise, make contacts with outside interest groups on a more informal basis than in committee meetings, and last but not least to make close political contacts outside their own political groups. Intergroups thus not only help to form cross-group coalitions on specific issues, but to forge wider political friendships which can be useful in other circumstances and can help to build that wider consensus which is essential in the European Parliament on certain issues."
European Commission
Each EU member state appoints either one or two European Commissioners, depending on the size of the nation - France, Germany, Britain, Italy and Spain each appoint two Commissioners, while the remaining ten nations (Ireland, Denmark, Greece, Portugal, Austria, Finland, Sweden, Belgium, Luxembourg and the Netherlands) appoint one each. The Commissioners are appointed en masse for five-year terms. The European Commission is headed by a President (currently Romano Prodi, a former Italian Prime Minister), nominated by the 15 national governments and approved by the European Parliament. The President of the European Commission is automatically one of the most significant and senior statesmen in the world. He must be consulted by national governments when they are deciding who to nominate to the Commission, and he allocates portfolios of responsibility to each Commissioner. The President also now has the power to 'reshuffle' portfolios in the middle of a five-year term. In addition, as a member of the European Council (see below), the President can influence the agenda which is set for the EU institutions. According to the Amsterdam Treaty, "The Commission shall work under the political guidance of its President." This reflects the President's key role in providing a sense of direction to the entire EU system.
Usually Commissioners are fairly senior party politicians - so the UK's two Commissioners are Neil Kinnock (a former Labour Party leader) and Chris Patten (former Governor of Hong Kong). On appointment, Commissioners swear an oath that they will now act as a servant of the EU as a whole independently of their home country's national interest. However, this is a little unrealistic: one reason why most Commissioners are nominated by their national government is because it is believed that they will be able to defend the national interest. If they fail to do so, it is unlikely that ...
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Usually Commissioners are fairly senior party politicians - so the UK's two Commissioners are Neil Kinnock (a former Labour Party leader) and Chris Patten (former Governor of Hong Kong). On appointment, Commissioners swear an oath that they will now act as a servant of the EU as a whole independently of their home country's national interest. However, this is a little unrealistic: one reason why most Commissioners are nominated by their national government is because it is believed that they will be able to defend the national interest. If they fail to do so, it is unlikely that they will be nominated for a second term - Mrs Thatcher decided not to re-nominated Lord Cockfield as one of Britain's Commissioners in 1989 in part because she felt that he had 'gone native'.
The 20-member Commission (which is based in Brussels), headed by a President, essentially acts as the EU's executive branch. Its function is to prose legislation and regulation and to ensure that member states comply with EU laws and treaties. The Commission must "formulate recommendations or deliver opinions" on policies for which the EU has responsibility. In essence, it is the Commission which proposes and initiates policy changes and which introduces legislation to give effect to those changes. Each Commissioner is given responsibility for a policy area - such as Agriculture, Industry, External Relations, Transport, and so on. They are supported by their personal 'cabinet', a group of around half a dozen senior advisors selected personally by the Commissioner. The 'cabinets' are intended to provide each Commissioner with specialist counsel about the policy areas for which he or she is responsible, and to keep the Commissioner well informed about the overall work of the Commission. The Commission meets weekly in Brussels and takes its decisions by majority vote.
Each Commissioner oversees the work of at least one of the 24 Directorates General, which are something akin to civil service departments. The Directorates deal with all those subjects in which the EU has policy making powers - including External Relations, Industry, Competition, Transport, Agriculture, Telecommunications, Financial Services, Energy, Consumer policy, Education and Training, and so on. They are generally referred to by number rather than title - so DGIII deals with industrial policy and DGVI handles agriculture policy. It is in the Directorate Generals that most of the detailed work involved in devising and implementing policy takes place. One academic has stated that: "Frequently portrayed as the civil service of the EU, in reality the Commission is rather more and rather less than that: rather more in the sense that the treaties and political practice have assigned to it much greater policy-initiating and decision-making powers than those enjoyed, in theory at least, by national civil services; rather less in that its role in policy implementation is greatly limited by the fact that agencies in the member states are charged with most of the EU's administrative responsibilities." We will examine the role of the Commission and the Directorate Generals shortly when we consider the policy making processes which operate in the European Union.
The Council of Ministers
The 15-member Council of Ministers is composed of representatives of each of the national governments. In fact, its membership rotates according to subject under discussion. When major items of general EU policy are under discussion, the governments are represented by their Foreign Ministers - this General Affairs Council of Ministers tends to meet at least once a month. The Council operates in sectoral format the rest of the time so that there is a Council of Health Ministers, a Council of Transport Ministers, and so on, to debate and resolve particular policy matters in those fields. You can see the full list of Council of Ministers sectoral groups in all the textbooks but it also includes Economic and Finance, Labour and Social Affairs, Environment, Telecommunications, Energy, Education, Consumers, Justice and Home Affairs, and so on. Proposals are sent by the Commission to the Council of Ministers for final decision. The Council of Ministers is the forum in which most substantial policy and legislative decisions are made, on the basis of the recommendations provided by the Commission. In addition, the Council is given power to influence the recommendations made by the Commission. According to an EU Treaty, "The Council may request the Commission to undertake any studies the Council considers desirable for the attainment of the common objectives, and to submit to it any appropriate proposals." The Council of Ministers also frequently adopts opinions and resolutions which have no legal weight but which undoubtedly serve political notice on the Commission about measures the Council would like to see undertaken.
Some issues can be settled by a qualified majority system under which the vote of some countries counts for more than that of other smaller nations, but (at present) if a member state regards any issue as being of "vital interest" then a unanimous vote is required. This is one of the thorniest issues which the governments have been considering since last year's Nice summit. If the European Union is to pursue its strategy of enlargement over the next decade by admitting new members from Eastern and Central Europe, then it may well be that the EU ends up with 28 to 30 members. A Commission of this size would be impractical, and so a number of reforms have been suggested. To begin with, the five largest nations may have to give up their second Commissioners. Even that, though, may not be enough: some are suggesting that the Commission's size should be held down to 20, with the effect that each nation would have a Commissioner for five out of every seven terms of office. Unsurprisingly, this proposal is being rejected by most governments. The smaller nations in particular tend to view their Commissioners as symbols of national prestige. One possible compromise might be to develop a two-tier system of Commissioners under which each nation would be guaranteed a powerful Vice-Presidency of the Commission for a certain period, and all nations would at least have an ordinary Commissioner.
However, because the larger nations look likely to lose one Commissioner each, they are believed to want a greater proportion of the votes cast by the Council of Ministers. At the minute, the system of qualified majority voting (QMV) applies for most votes taken. Under this, each nation is given a certain number of votes, and any decision taken by QMV requires 62 out of a possible total of 87 votes in order to be passed. Currently the UK, France, Germany and Italy have 10 votes; Spain has eight votes; Belgium, Portugal, Greece and the Netherlands have five votes each; Sweden and Austria hold four votes each; Ireland, Finland and Denmark each have three votes; and Luxembourg has two votes. Therefore the system at the minute gives proportionately more power to the smaller nations - for instance Ireland with perhaps 4 million people has three votes while Germany with 82 million people only has ten votes. So this element of the system will certainly be reformed. Also at issue is the list of subjects which require unanimity for decisions to be made. Any one nation can presently exercise a veto over policies relating to, for instance, transport, industrial issues, financial regulation, taxation, asylum and immigration, social security and some trade matters. It seems unlikely that in the future each of the possibly 30 members of the EU can apply a national veto to as many issues as are currently the case.
European Council
The European Council meets twice a year with the purpose of co-ordinating EU activities and setting priorities for future work. It is composed of the heads of government or heads of state - although the only governments which nominate their Presidents rather than Prime Ministers are France and Finland - of each member state (assisted by their foreign ministers), as well as the Presidents of the European Parliament and European Commission. Often, meetings of EU finance ministers will be held in parallel with European Council meetings so that the finance ministers can join the more senior grouping when discussions about economic matters are taking place. European Council meetings are chaired by the Prime Minister of the nation which holds the Presidency of the Council of Ministers at that time. These occasions essentially serve two main purposes. Most obviously, the Council will have an agenda for its meetings, which ensures that the heads of government debate inherently important issues affecting the future direction of the European Union and have an opportunity to discuss the policies which the Union's institutions will be pursuing over the next six months. But in addition to this formal agenda, the gatherings provide heads of government with an opportunity to meet each other in bilateral sessions to resolve matters of importance to their own individual nations - for instance, at these events the British and Irish Prime Ministers will invariably have a one-to-one session to go over developments in Northern Ireland.
The European Council provides a forum in which not only the internal development of the Union can be discussed but also the EU's relationship with external bodies. So the meetings will allow the EU to devise a common negotiating position when dealing collectively with, for instance, the United States or Japan, the United Nations or World Trade Organisation. While the European Council is in a sense the place where the EU's most senior politicians arrive at decisions, if these require European legislation it is unable to simply insist that the policies be adopted and implemented immediately because any necessary legislation must go through the normal process which we will consider next week. However, the heads of government are obviously able to make final political decisions and implement those unilaterally if they do not require legislative backing.
One academic has concluded that, "The record of the European Council is mixed. On the one hand there have been failures, or at least the non-fulfilment of hopes. This was particularly true in the period from about 1980 to 1988: summits became rather routinised and immersed in detail; too much time was devoted to policy detail rather than to mapping out the future; and disputes about distributional issues were seemingly always on the agenda. On the other hand there have been positive achievements: understandings between national leaders have been furthered; important goals have been identified/given an impetus/brought to a conclusion (such as on enlargements, the internal market, the social dimension, institutional reform, and EMU); and agreements have been worked out on matters that were either unsuitable for, or could not be resolved by, the Council of Ministers."
The EU legislative process and lobbying
Broadly speaking, formal proposals for EU legislation are initially made by the European Commission (although some proposals may have started out as recommendations to the Commission by the Parliament). So the Commission issues a proposal which is subject to consultation by the Parliament and the Council of Ministers. Both these institutions will then become subject to protracted lobbying by interest groups seeking to influence the proposal. Obviously, it is easier for a lobbyist to persuade half a dozen Commission officials to include or delete any individual references than it is to achieve a majority of MEPs and national governments, so at this stage it is very important to ensure that the people who will be driving forward the proposal in both the Parliament and the Council of Ministers support your view. Again, this comes back to good monitoring and research. Once any proposal has been sent to the Parliament, it is referred to whichever standing Committee deals with the issue. That Committee's Chairperson will appoint the rapporteur - the MEP who is a member of the Committee and who is given responsibility for devising the Committee's official response. It is key that you initiate contact with the rapporteur as early as possible so that you have a chance of influencing his or her first draft of their report. The next stage is to contact all the Committee's members to inform them of your position because the full Committee will have to approve the report when it is finalised. Of course, you should additionally be communicating with your local MEPs and any others whom you know to take an interest in the subject so that they can in effect become lobbyists for you by themselves getting in touch with the rapporteur. Apart from this, though, when the rapporteur has had his or her report agreed by the Committee, it then goes on to the full Parliament for ratification and any MEP can table amendments at this stage.
The proposals will also be considered by an advisory body known as the Economic and Social Committee, which will appoint its own rapporteur and issue its own report. While many lobbyists dismiss ECOSOC as being increasingly powerless, it does represent yet another opportunity to influence thinking on an issue, and therefore should not be ignored. The truth is that ECOSOC is less highly thought of outside Brussels than among EU policy makers - for instance, it will usually have published its report in advance of that being produced by the Parliament's Committee, and hence its findings may influence the Committee's rapporteur when finalising his or her own report. At the same time as a proposal is going through the Parliament and the Economic and Social Council, keep in mind that it is also being considered by the Council of Ministers. Most EU institutions are reasonably open and transparent, but meetings of the Council of Ministers are held in private. You must therefore ensure that you have communicated well in advance with all the national governments in an effort to persuade their Ministers to support your case in the Council. Here, though, two avenues are open to organisations - if you are interested in aviation policy, you can approach the relevant government departments in each nation and make your case to them. Alternatively, every member states maintains a number of civil servants in Brussels, known as the Committee of Member States Permanent Representatives (COREPER). Given that these are national civil servants, they act on behalf of their respective governments; if an organisation can persuade COREPER to support a particular position, the final decision by the Council of Ministers is virtually a foregone conclusion.
Lobbying the Council of Ministers and COREPER obviously requires a great deal of research to establish the likely position which will be taken by each of the 15 National governments and to identify the arguments which will hold most weight with each administration. It then becomes necessary to ensure that a sufficient coalition of support will be built up within the Council of Ministers. To reach this point in the policy making process may have involved substantial work, but all too often a well-argued case can be lost if it gets caught up in a barter as a result of which some national governments reverse their position on one issue in order to secure additional support for another issue. Once the Parliament, ECOSOC and the Council of Ministers have scrutinised the original draft proposal - and probably amended them to some degree, the final draft of the proposal is then prepared by the Commission and submitted to the Council of Ministers for its binding decision. On average, it may take perhaps two years between the Commission beginning work drafting a proposal and it reaching the Council of Ministers for final decision.
There are significant differences in how legislative proposals emerge in the EU institutions compared with in the UK, and the effective lobbyist needs to be aware of these. In the UK, for instance, the Government sets out its legislative agenda very clearly at the start of each parliamentary session in the Queen's Speech. While the Commission does also detail its legislative plans at the beginning of each year, this can by no means be taken as a definitive announcement. For one thing, the Presidency of the Council of Ministers rotates among member states every six months, and each new presidency is used by the relevant national government as a way of promoting those issues which it favours. Again, the twice-yearly European Council summit meetings will invariably produce yet another list of priorities for action. It is also important to realise that individual Director Generals (the most senior officials in the Directorate Generals) can play a very significant role in policy initiation as a result of their contacts across all 15 member states. Several years ago for example, the EU proposed legislation on environmental auditing which was an idea inspired by a Director General's visits to a number of companies which had instituted such schemes voluntarily.
One feature of the EU institutions which can create difficulties for lobbyists is simply the sheer mass of paperwork which they produce - an enormous amount in its own right then multiplied by the nine official languages of the EU. So, here, monitoring is if anything even more important than in the UK. In addition, EU proposals often begin life very loosely drafted and are revised substantially before a final draft is produced. Hence it becomes very important to access any document near the start of its journey through the policy making process when it can still be amended in line with your interests or position. Essentially, though, the purpose of monitoring in the EU is no different to monitoring in the UK - you need to learn who has responsibility for your areas of interest, what activities they are generating, and what their attitude to your organisation and your concerns are.
It is of course possible to plot the relevant people in structural terms within the EU bureaucracy in exactly the same way as you can do in the UK using the Civil Service Yearbook. Similar publications are available in the EU. So, for instance, if you happen to be interested in airlines you would start as this acetate shows with Directorate Generate VII which deals with Transport issues, and move down the hierarchy to those officials in its Directorates A and C to identify the people most directly concerned with different aspects of policy relating to airlines. This highlights one important similarity between the EU and the UK - the importance of making your representations and establishing your network of contacts at the most appropriate level. Only on very major policy matters should organisations need to approach a European Commissioner or even a Director General - always begin building effective relationships with the officials within a Directorate General who actually work on your issues on a daily basis. One European lobbyist has written thus: "See what happens when you send a written submission to a Commissioner. The Commissioner will in most cases not even see it; it will be sent to the Director-General then passed to the Director of the appropriate Directorate, who will in turn pass it down, via the Head of the relevant division, to the desk of the official responsible. Replies to your submission will follow the same course in reverse. The official responsible for the relevant dossier will conduct the bulk of the work and evaluate its importance. Failing to understand how decisions are made can delay any positive response to your case. Much time can be saved by accessing power where it is exercised."
You will find that many issues straddle more than one Directorate General, and in these cases the Commission will authorise one of them to take the lead on the issue and to consult with officials from the others. Yet another way in which outside interests and lobbyists can gain entry to the policy making process is through the Commission's tendency to establish advisory committees such as the Scientific Committee for Food which is consulted about food additives. If your issue is referred to one of the committees, then you obviously have another opportunity to make your arguments.
It doesn't require a great deal of thought to realise that when lobbying the British Government, for instance, it helps if you can demonstrate how your position would be of benefit to Britain. By contrast, the European Commission generally has little sympathy for lobbies which are based upon one nation's self-interest - it is absolutely essential to be able to make your case on the basis of what will benefit all EU member states. In practice, this means that lobbyists have to build coalitions - if the road haulage industry in the UK wants a particular policy to be adopted by the EU, it should start by persuading its counterparts in other member states to support the proposal.
It might be useful for you to realise that there are a number of different types of EU legislation. In certain areas the Commission and the Council of Ministers are empowered to issue regulations binding on all member states without the need for any ratifying national legislation. These generally involve the implementation of an existing policy rather than an entirely new policy per se. Both institutions can also make regulations which are binding only on specific member states. The most common form of EU legislation is known as Directives. These are binding on all member states in the sense that they are obliged to implement that legislation, but it is left up to each national government to decide how and when to do so.
Regulation of lobbyists in the EU
Until the late 1980s, public affairs work in Brussels was relatively uncontentious and attracted very little criticism. However in May 1991 a Belgian MEP, Marc Galle, was asked by the European Parliament to "submit proposals with a view to drawing up a code of conduct and a public register of lobbyists accredited by Parliament". In October the following year, Galle made a number of recommendations:
* the establishment of a very minimalist code of conduct;
* a ban on lobbyists having access to certain parts of the Parliament building such as Members offices and the Library;
* further scrutiny of the extent to which the intergroups were being lobbied;
* the registration of lobbyists annually; and
* annual disclosure by MEPs of their financial connections with outside bodies.
However, his report was never voted on by the full European Parliament, and in fact its opponents made little difficulty in delaying its consideration. For one thing, Galle defined a lobbyist as "anybody who acts on the instructions of a third party and sets out to defend the interests of that third party to the EP and other Community institutions". Hence, he was only considering commercial lobbyists and entirely excluding in-house public affairs specialists. More significantly, the European Commission itself did not support Galle's efforts. The Commission took the view that lobbying in itself is entirely legitimate and that the pressure for the registration of lobbyists could be eased if lobbyists would themselves enact some voluntary code of practice. At that stage, lobbyists had no representative bodies in the EU but over the next few years a number of associations were formed - among them the European Federation of Lobbyists, the European Parliamentary Affairs Lobbyists, the European Lobbying and Public Affairs Federation, and the Society of European Affairs Practitioners.
Eventually, in September 1994 a number of lobbying companies in Brussels did adopt a voluntary code, under which they made relatively scanty promises such as not to bribe any EU officials, not to propagate any false information knowingly, not to obtain information dishonestly and to avoid professional conflicts of interest. The European Parliament then used this as the fundamental basis for a scheme under which those who adhered to this code could receive passes to the Parliament building. However, the system quickly gained an academic reputation as being of more symbolic than practical value. In November 1994, therefore, the Parliament appointed a British Labour MEP, Glyn Ford, as rapporteur of a new report into lobbying. Mr Ford took as his starting premise the notion that this kind of voluntary self-regulation was essentially meaningless. He concluded that access to Parliament should be matched by disclosure - Parliament would "issue permanent passes to persons who wish to enter Parliament frequently with a view to supplying information to members.... In return, these persons shall be required to sign the register listing, in particular, their name and trade name and the nature of the activities which they wish to carry out in the Parliament.... The persons listed in the register shall draw up on a yearly basis a declaration of their activities, detailing, in particular, any benefits, subsidies, gifts or services of any nature rendered to Members, officials or assistants."
Ford's report quite consciously avoided providing any rigid definition of who constituted a lobbyist - rather anyone who had occasion to visit the Parliament building on a regular basis would be covered by his register. The idea here was that the less complex was the scheme suggested, the more chance it would have of being accepted. However after the report was drafted (on behalf of the Committee on Rules of Procedure), it was submitted to a number of other standing Committees for their consideration. One of these - the Committee on Social Affairs and Employment - decided that the report should include provisions relating to the acceptance by MEPs of financial assistance from outside groups. Once these two issues became linked - lobbying and the regulation of members' interests - the Ford report was in serious trouble. In January 1996 the Parliament debated Ford's report and referred it back to the CRP committee for revision. Finally in July 1996, a compromise of sorts was reached so that MEPs now have to declare their outside interests while lobbyists would be registered by the Parliament in return for obtaining a pass provided that they signed a code of conduct.
This scheme came into force in June 1999. The code of conduct which lobbyists must adhere to is fairly basic. In fact, though, the code does not define lobbying. It simply states that the register and code will apply to all those who are issued passes to the European Parliament on the basis that they "wish to enter Parliament's premises frequently with a view to supplying information to Members within the framework of their parliamentary mandate in their own interests or those of third parties". Among its provisions are that lobbyists shall:
* "state the interest or interests they represent in contact with Members of Parliament, their staff or officials of Parliament;
* refrain from any action designed to obtain information dishonestly;
* not claim any formal relationship with Parliament in any dealings with third parties;
* not circulate for a profit to third parties copies of documents obtained from Parliament".
