We were invited as speakers to the InvestMT event organised by the Malta Development Bank in April 2022 to present lessons and approaches of the implementation of Financial Instruments in Hungary. The presentation and the following Q&A session focused on giving an overview of the 70+ instruments introduced in Hungary over the past decades and analysing the key arising challenges and the proven success factors, which prove to be useful lessons for other Member States. The event was powered by Deloitte Malta and supported by the Technical Support Instrument of DG REFORM1.
We are participating, as national experts for Hungary, in the Strategic coordination and financial complementarity of CPR funds with other EU instruments led by t33, in consortium with ÖIR, Spatial Foresight and Oxford Group. The work will include, among other deliveries, a thorough analysis of all related operational documents and a chain of in-depth interviews with the key stakeholders. The effective work has just been launched and deliveries are expected during the autumn months of 2023.2
2. Advising EU policy makers
In 2022, we put extensive emphasis on our national policy advisory and advocacy-support activities, including their traversion to the international level. We continued to be attentive to European Union (EU) policy developments, and have chosen to provide expert advice on a number of fields by directly taking part in public consultations launched by the European Commission.
In May, we submitted our views to the Commission’s public consultation on the New European Innovation Agenda.3 In our submission we pointed out the implications of the innovation divide within the EU, given the developmental differences between the EU-15 and the EU-12. Finally, while stressing the need to decrease overall innovation and digital society development, the importance of “collaboration between innovation actors”, and how the global innovation divide, if not well targeted and helped, could weaken long-term innovation in Europe. We highlighted, that there is no blanket solution for improving the EU innovation ecosystem – and therefore a customary approach must be developed: different EU regions need self-tailored solutions. A key instrument in this policy could be easier access of innovation actors from emerging innovation regions to Horizon Europe programs and to existing networks of innovation. University hubs, think tanks and SMEs from Central Eastern Europe need to be involved even more in the pan-European initiatives in order to achieve the desired results on EU-level.
In August, we submitted an extensive response to the Commission’s consultation on the recast of the EU’s waste framework directive. While generally supporting the executive’s aim to refresh the general framework, we argued for workable and executable regulations that are based on traceable and specific data sources – there is a need to have exact data sources concerning the amount of waste resulting from public, residential and industrial use –, and pointed out that the planned recast of the framework should give certain suppleness in this respect, especially for consumers. We emphasized that waste related data and pattern changes should further be reorganised through comparative behavioural research of the emitters, addressing different problems in different parts of the continent and using international examples. Among other specific suggestions, we recommended that – though paradigmatic change is welcome – disruptive regulation should be carefully assessed in order to cater for the avoiding of unreasonable shifts in costs or interruption of waste collection services.
In early December, we also focused on the polluter pays principle’s fitness check, highlighting the need to adequately account for historical-economic costs and advantages and the geographical distribution of responsibility. In our submission, we emphasized that the rules related to prevention should be reinfroced among the content elements of the principle – i.e. prevention, damage relief, restoration – in order to avoid unwanted externalities and, indirectly, the apparence of social costs (or their externalization by the polluter). This must be reflected not only in the Environmental Liability Directive and their national implementation, but also in individual cases, in particular in the appropriate imposition of related costs on the polluter. We recommended that the indicators validated by the PPP must be precisely defined, and their criterion values must be established based on consensus, without distorting competition or causing a disadvantage, while keeping an eye out for fairness.
3. Webinars and events
In 2022, we also hosted two international webinars with a wide range of participants: from companies, think thanks, the European Commission and national administrations. Attendees came from the academia, private and public sector and various media outlets.
The first of such events, in June 2022, focused on the New European Innovation Framework.4 We discussed the capabilities, experiences and initiatives promoting innovation in CEE, and the developing new European Innovation Agenda: corresponding frameworks, challenges, and proposed ways to go forward. The event’s conclusion fed into the EU-wide discussion on the New EU Innovation Agenda, in particular that it was key to strengthen innovative ecosystems, especially at local levels, and to go beyond the focus of financial support. The role of education must always include pushing young people to take risks when innovating, and that it is key to reach out to local entities – companies with no national, but only a local presence, especially SMEs, who are not aware of the benefits and the potential of innovation, and therefore bear the largest potential for corresponding growth. Tailored acceleration and mentoring are needed to reach these companies.
In October, we hosted a webinar on the review of the European Union’s Waste Framework Directive.5 The discussion focused on waste related consumer behaviour and touched upon how waste collection and sustainability objectives could further be streamlined with manifested consumer behaviour – and how this could be better reflected in EU-level sectoral rules. Our webinar sat well in with the European Commission’s ongoing revision of the Directive and also with the recent modifications of municipal waste collection and management in Hungary. Participants to the panel agreed that there was a gap between declared consumer attitude and manifest consumer behaviour concerning waste management and recycling. One of the reasons is the lack of information, the other is the lame financial incentives. Also, it came up that while Hungary had made progress regarding the goals of the WFD, such as banning single-use plastics, introducing a Food Rescue Centre, a more effective municipal waste management is yet to be seen. Expectations, on all sides, are high regarding the new concession system. Finally, attendees were keen to learn that future modifications of the EU Waste Framework Directive would likely include critical raw materials as the pressure on global supply chains negatively impacted the Member States. The Critical Raw Materials Act, among others would address the issue of recyclability and separate collection of goods including critical raw materials. The Commission promised to try to address this through a single intervention to the Directive in conjunction with introducing food waste targets and provisions for extended producer responsibilities for textiles.
4. Policy paper series
But long-term advocacy must be traceable and retractable. Therefore we also published our policy paper on the recast of the EU Waste Framework6. We presented a cross-cutting, consumer-focused and behaviour-based policy approach, which carefully assesses the level of current economic development and pay attention to existing sectoral laws on waste collection. For example, we believe that regulatory changes must be evidence-based with growing emphasis on, and the use and analysis of behavioral testing of the planned measures (see our above reference to various biases and incentives). Another crucial point is, we believe, that the regulators must have better ideas about what consumers consider as low-quality products. While industry standards and science do provide us with rather specific indicators for product and service quality, consumers may perceive quality otherwise because of the financial sacrifice they have to make. We will continue with our policy papers in 2023.
5. Next year’s plans
Perceiving the interest around our workshops and the wide appreciation of bringing regular first-hand Eastern European experience directly to EU policymakers, we plan on continuing our international webinar series in 2023. Our scheduled events will, once again, focus on our primary research interests and assignments, in particular on those that run in parallel with ongoing European policy initiatives.
We will also take advantage of the more relaxed public health situation and are planning our first in-person, international workshop in Brussels – bringing experience directly to the helm of the policymakers.
We aim to continue our attendance to public consultations, specifically in those where we have first-hand primary research experience.
Benefitting from our vast in-house research capabilities and policy capacities, we will keep participating in international initiatives and pursue i.e. DG REGIO, Horizon Europe and BEREC opportunites, aiming to further broaden our European project outreach. Building on our opportunity to conduct primary research projects throughout Europe, we are confident that we will have ever more opportunities to share and build upon the knowledge our company and its experts have acquired over the past years.