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OECD Competition Assessment ReviewsGREECEOECD Competition Assessment ReviewsGREECEOECD Competition Assessment Reviews GREECE2013Co-financed by Greece and the Eurpean Union Co-financed by Greece and the European UnionOECD Competition Assessment Reviews: Greece COMPETITION ASSESSMENT OF LAWS AND REGULATIONS IN GREECE PRELIMINARY VERSIONwith the support of Photo credits: Cover: Image #42524727 - Seamless gold Greek elements Copyright: © Gregor Buir/Fotolia.comThis work is published on the responsibility of the Secretary-General of the OECD. The opinions expressed and arguments employed herein do not necessarily reflect the official views of the Organisation or of the governments of its member countries. This document and any map included herein are without prejudice to the status of or sovereignty over any territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area.© OECD 2013 Foreword Greece is going through the deepest recession in the euro area. Since the onset of the crisis it has had a sharp contraction in GDP and an increase in joblessness, especially among youth. Steps have been taken to strengthen public finances and to implement the structural reforms that are needed to restore growth and competitiveness over the longer term. Enhancing competition is essential to this end. Despite recent reforms, Greek product markets remain among the most strictly regulated in the OECD area, hindering competition and preventing the price adjustments needed to support the recovery. This lack of competition is holding back the growth of productivity by limiting the entry and expansion of more productive and efficient firms, inhibiting foreign investment and holding back innovation. The project on Competition Assessment of Laws and Regulations in Greece was signed between the Greek government and the OECD in November 2012 to address these problems by targeting regulatory barriers to competition in four key sectors of the Greek economy: food processing, retail trade, building materials and tourism. These four sectors together account for 21% of GDP and almost 27% of employment, and are important drivers of future growth. Through the scrutiny of legislation in key sectors of the Greek economy, the OECD Competition Assessment Project identified 555 problematic regulations and 329 provisions where changes could be made to foster competition. Although it was not possible to quantify all the benefits arising from enhanced competition, OECD calculations estimate the total effect from rising expenditure, increased turnover and lower prices for the Greek consumer at around EUR 5.2 billion annually, or about 2.5% of GDP. The benefits of reform in this area are sizeable! By proposing concrete policy options for removing regulatory restrictions to competition, the Project contributes to the Greek government’s structural reform agenda. Full implementation of the Project’s recommendations can do much to enhance the competitiveness of the Greek economy, stimulate productivity and promote economic growth and job creation in the years to come. I congratulate the Greek authorities on the efforts they have undertaken since 2010 to reinforce competition law and the work of the Hellenic Competition Commission, to simplify business administration and to liberalise professional services should also be acknowledged. These are courageous, necessary steps towards building a better future for all Greeks.Angel Gurría Secretary-General, OECD OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 20133 ACKNOWLEDGEMENTSThis report is the result of a collective effort which started several years ago, but came to fruition when the Competition Assessment of Laws and Regulations in Greece project was formally launched in December 2013 in Athens, Greece under the auspices of the Minister of Development and Competitiveness, HE Kostis Hatzidakis. This project was financed by the European Social Fund, and was organised in the context of the technical assistance provided by the Task Force for Greece. Our thanks go to the European Union Task Force for Greece which provided support and contributed to the very difficult task of co-ordinating a project of this magnitude.Our particular thanks go to the Hellenic Competition Commission (HCC) which supported the project from its inception and contributed staff to work full-time for ten months with the project team. In addition to the seconded HCC staff members we would like to thank Dimitris Loukas, ViceChairman, Dionysia Xirokosta, Director-General, Lefkothea Nteka and Kelly Benetatou, Directors, and Evi Chrysanthopoulou, Head of Unit, for all their preparatory work and for the follow-on support by the HCC throughout the project. We would like to thank the members of the High-level Committee (HLC) who participated in meetings to discuss the findings of the report and who will be responsible for the dissemination and advocacy of the recommendations in this report. The HLC was chaired by Serafim Tsokas, Secretary General of the Ministry of Development and Competitiveness. The members were Socratis Alexiadis, Secretary General of Urban Planning, Ministry of Environment, Energy and Climate Change; Athanasios Bousios, Secretary General of the Ministry of Maritime Affairs and Aegean; Spyros Efstathopoulos, former Secretary General of Industry, Ministry of Development and Competitiveness; Stefanos Komninos, Secretary General of Commerce, Ministry of Development and Competitiveness; Anastasios Liaskos, Secretary General of the Ministry of Tourism; Dimitrios Melas, Secretary General of Agricultural Policy and International Relations, Ministry of Rural Development and Food; Christina Papanikolaou, Secretary General of Public Health, Ministry of Health; Georgios Stergiou, Secretary General of Consumer Affairs and Secretary General of Industry, Ministry of Development and Competitiveness; Harris Theocharis, Secretary General of Public Revenue, Ministry of Finance. The following high-level officials also participated in meetings: Anastasia Markatou, Director of Tourist Ports, Ministry of Tourism; and Yannis Pyrgiotis, Secretary General of Tourist Infrastructure and Investments, Ministry of Tourism. For outstanding co-ordination throughout the project we would like to thank Persa Pantermaraki, government co-ordinator for the OECD Competition Toolkit Project who worked tirelessly to ensure the co-ordination of the various and disparate bodies involved in the project; Effie Ioannou, Adviser to the SG of Commerce who also participated in the co-ordination efforts; and Dimitrios Kolyvas, Advisor to the SG of the Ministry of Development and Competitiveness who was in charge of coordinating the meetings of the High-level Committee, and who helped support the project from within the Secretary General’s office. 4OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 2013 In addition, we would like to thank the following ministerial experts who participated actively in the project by providing information, advice and feedback throughout the project: Giota Anastasopoulou, Secretariat General of Public Works, Ministry of Infrastructure, Transport and Networks; Nikolaos Arvanitis, Maritime Affairs, Ministry of Maritime Affairs and Aegean; Roubini Bakopoulou, Secretariat General of Tourism, Ministry of Tourism; Stella Banteka, Secretariat General of Public Revenue, Ministry of Finance; Georgia Bei, Secretariat General of Industry, Ministry of Development and Competitiveness; Dimitris, Bourikos Secretariat General of Tax and Customs, Ministry of Finance; Apostolos Daflos, Secretariat General of Consumer Affairs, Ministry of Development and Competitiveness; Athanasios Dimakis, Secretariat General of Commerce, Ministry of Development and Competitiveness; Georgios Dionysopoulos, Secretariat General of Consumer Affairs, Ministry of Development and Competitiveness; Georgios Drosos, Secretariat General of Industry, Ministry of Development and Competitiveness; Chrysoula Galakou, Secretariat General of Commerce, Ministry of Development and Competitiveness; Konstantinos Georgoulakis, Secretariat General of Energy and Climate Change, Ministry of Environment, Energy and Climate Change; Irini Gogou, Secretariat General of Energy and Climate Change, Ministry of Environment, Energy and Climate Change; Natassa Kalogeropoulou, Secretariat General of Commerce, Ministry of Development and Competitiveness; Athina Kalyva, Secretariat General of Public Revenue, Ministry of Finance; Loukas Kapolos, Secretariat General of Tourism, Ministry of Tourism; Maria Karathanasi, Secretariat General of Commerce, Ministry of Development and Competitiveness; Maria Kiposoglou, Maritime Affairs, Ministry of Maritime Affairs and Aegean; Andrianni Kokkini, Secretariat General of Consumer Affairs, Ministry of Development and Competitiveness; Aggeliki Koskina, Secretariat General of Consumer Affairs, Ministry of Development and Competitiveness; Eleni Kostopoulou, Secretariat General of Tourism, Ministry of Tourism; Aristomenis Kotsakis, General Secretariat of Public Revenue, Ministry of Finance; Eleni Koufosotiri, Maritime Affairs, Ministry of Maritime Affairs and Aegean; Nikolaos Kouretas, Secretariat General of Environment, Ministry of Environment, Energy and Climate Change; Vicky Kourou, Secretariat General of Public Works, Ministry of Infrastructure, Transport and Networks; Aggeliki Kypreou, Secretariat General of Agriculture, Ministry of Rural Development and Food; Angela Ladopoulou, Secretariat General of Industry, Ministry of Development and Competitiveness; Aggeliki Michalopoulou, Secretariat General of Tourism, Ministry of Tourism; Dionysia Mintza, Secretariat General of Agriculture; Alexandra Nassou, Secretariat General of Commerce, Ministry of Development and Competitiveness; Christos Nikolsky, Secretariat General of Consumer Affairs, Ministry of Development and Competitiveness; Dimitra Panteleaki, Hellenic Food Authority (EFET), Ministry of Rural Development and Food ; Panagiota Papadaki, Secretariat General of Agriculture, Ministry of Rural Development and Food; Chrysoula Papadimitriou, Secretariat General of Agriculture, Ministry of Rural Development and Food; Ioannis Poulos, Secretariat General of Consumer Affairs, Ministry of Development and Competitiveness; Antonios Rapatzikos, Maritime Affairs, Ministry of Maritime Affairs and Aegean; Penny Stamouli, Secretariat General of Agriculture, Ministry of Rural Development and Food; Evangelia Stavropoulou, Ministry of Infrastructure, Transport and Networks; Dionysia Stefanitsi, General Chemistry Laboratory of the State, Ministry of Finance; Dimitris Tsaglakis, General Secretariat of Tax and Customs, Ministry of Finance; Paraskevi Tsami, Secretariat General of Consumer Affairs, Ministry of Development and Competitiveness; Paraskevas Tsiklidis, Secretariat General of Commerce, Ministry of Development and Competitiveness; Spyros Tzimas, Secretariat General of Energy & Climate Change, Ministry of Environment, Energy and Climate Change; Anastasia Varagouli, Hellenic Food Authority (EFET), Ministry of Rural Development and Food; Anastasios Xanthopoulos, Secretariat General of Commerce, Ministry of Development and Competitiveness; and Thalia Xiromeritou, Secretariat General of Public Works, Ministry of Infrastructure, Transport and Networks. We also thank Kalliope Sampani, Director of EYSED (Special Co-ordination and Implementation Office for co-founded actions in the field of Commerce),OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 20135 General Secretariat of Commerce and Theodore Papageorgiou, President of the Monitoring and Acceptance Committee of the Project, from the Ministry of Development and Competitiveness. We are especially grateful to the Supreme Council for Civil Personnel Selection (ASEP) which provided us with office space for the duration of the project. In particular our thanks go to the following staff members: Georgios Veis, President of ASEP; Kalliopi Stagka, Director; Dionisios Alexandropoulos, Georgia Aravantinou, Andreas Christofidis, Alexandros Christopoulos, Ioannis Georgiadis, Konstantinos Gotsis, Panos Deriziotis, Olga Klouvatou, Theocharis Stamatis, Dimitris Strotos, Maria Tsalla and Charalambos Vougiouklis. We would also like to thank the Hellenic Federation of Enterprises (SEV), its member companies and all affiliated sectoral associations for their constructive collaboration and help. Namely we would like to convey our thanks to the Federation of Hellenic Food Industries (SEVT), the Hellenic Association of Chemical Industries, the Hellenic Steel Association, the Aluminium Association of Greece, the Hellenic Association of Chemicals Industries and the Greek Industry of Detergents and Soaps (SEVAS). Moreover, we would like to acknowledge the input of the Greek Association of Branded Products and Manufacturers (ESVEP), the Institute of Retail Consumer Goods, Greece (IELKA), the Technical Chamber of Greece (TEE), the Association of Greek Tourism Enterprises (SETE), , , the Hellenic Retail and Business Association (SELPE), the Association of International Freight Forwarders and Logistics Enterprises of Greece (SYNDDEL), the Association of Pharmaceutical Companies of Non-Prescription Medicines (EFEX), the Hellenic Petroleum Marketing Companies Association (SEEPE), the Efficient Consumer Response Association (ECR), the Hellenic Association of Travel and Tourist Agencies (HATTA), the Association of Advertising & Communication of Greece (EDEE), Small Enterprises’ Institute of the Hellenic Confederation of Professionals, Craftsmen and Merchants (IME GSEVEE), the Central Markets and Fishery Organisation (OKAA), Piraeus Port Authority, McKinsey & Company, Fragiskos Armaos and Nikos Manias. The opinions expressed in the report do not necessarily reflect the views of the above mentioned organisations or individuals. The Competition Assessment Toolkit was developed by the Working Party no. 2 of the Competition Committee with the input of members of many delegations to the OECD, both from member and non-member jurisdictions. The materials were drafted at the OECD Secretariat under the leadership of Sean F. Ennis, Senior Economist at the Competition Division. The Competition Assessment Project in Greece was initiated by Frank Maier-Rigaud and Fiorenzo Bovenzi, both formerly of the Competition Division. The present report was edited by Ania Thiemann, Project Leader, and Federica Maiorano, Senior Economist, at the OECD Competition Division in the Directorate for Financial and Enterprise Affairs. The project team in Athens consisted of Federica Maiorano, Senior Economist, Ania Thiemann, Project Leader, Christos Genakos, Economist, Themis Eftychidou, Lawyer, Junior Competition Expert, all OECD Competition Division; and Anna Gatziou, Lawyer, Evi Karkani, Lawyer, Nikolaos Lionis, Economist, Fotis Papadopoulos, Economist and Giannis Stefatos, Economist, under secondment from the Hellenic Competition Commission. Also participating were Svet Danchev and Nikos Paratsiokas from IOBE who worked full time with the project team for six months. The project team was led by Ania Thiemann and Federica Maiorano, with office support from Christina Anagnostopoulou, OECD Competition Division. Everybody on the team contributed to the report, with additional research carried out by Elias Demian, Konstantinos Peppas, Sophia Stavraki, Fotini Thomaidou, Aggelos Tsakanikas and Michail Vassileiadis from IOBE. 6OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 2013 Specialist advice on competition assessment was provided by; John Davies, Head of the Competition Division; Patricia Hériard-Dubreuil, Deputy Head of Division and Sean Ennis. Special thanks go to those who took the time to review the text and provided useful comments and feedback. The reviewers were Claude Giorno and Alain de Serres, the Economics Department; Peter Avery, Consumer Policy Division and Alain Dupeyras, Tourism Policy Division, all OECD. The report was edited for publication by Barbara Zatlokal, and prepared for publication by Ania Thiemann; Erica Agostinho, Communications Assistant; Edward Smiley, Publications Officer; and Kate Lancaster, Editor.OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 20137 Table of Contents Preface by HE Kostis Hatzidakis, Minister for Development and Competitiveness......................11 Preface by Horst Reichenbach, Head of EU Task Force for Greece ...............................................13 Acronyms and Abbreviations ..............................................................................................................15 Executive Summary .............................................................................................................................17 Assessment and Recommendations ....................................................................................................21 The benefits of competition ................................................................................................................22 Key findings from the Competition Assessment project in Greece ....................................................25 Main restrictions identified in the four sectors ...................................................................................27 Recommendations and expected benefits ...........................................................................................32 Horizontal legislation with a bearing on the four sectors ...................................................................35 Recommendations for horizontal legislation ......................................................................................36 Conclusion: Overall benefits from removing the regulatory barriers to competition in Greece ........36 Notes ...................................................................................................................................................38 References...........................................................................................................................................39 Chapter 1. Food Processing ................................................................................................................43 1.1 Sector overview ....................................................................................................................44 1.2 Milk and other dairy products ..............................................................................................46 1.3 Bakeries ................................................................................................................................57 1.4 Code of Foodstuffs and beverages .......................................................................................63 1.5 Packaging and other issues related to food processing ........................................................66 1.6 Conclusions on the sector findings .......................................................................................70 Notes ...................................................................................................................................................71 References...........................................................................................................................................76 Chapter 2. Retail Trade.......................................................................................................................79 Sector overview ....................................................................................................................80 2.1 2.2 Sunday trading......................................................................................................................82 2.3 Promotions, seasonal sales and discounts ............................................................................86 2.4 Over-the-counter medicines and dietary supplements .........................................................93 2.5 Pharmacies .........................................................................................................................106 2.6 Street markets and outdoor traders .....................................................................................113 2.7 Retail sale of fuel................................................................................................................116 2.8 Books ..................................................................................................................................119 2.9 Maximum pricing, detergents and other issues related to retail trade ................................125 2.10 Conclusions on the sector findings .....................................................................................131 Notes .................................................................................................................................................132 References.........................................................................................................................................137 Annex 2.A1 Annex 2.A2Sunday Trading ........................................................................................................142 Over-the-Counter Medicines....................................................................................149OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 20139 Chapter 3. Building Materials ..........................................................................................................155 3.1 Sector overview ..................................................................................................................156 3.2 Cement ...............................................................................................................................158 3.3 Mines & quarries ................................................................................................................160 3.4 Harmonised European standards for construction products ...............................................164 3.5 Non-harmonised European standards for construction products........................................166 3.6 Other restrictions in national legislation.............................................................................171 3.7 Conclusions on the sector findings .....................................................................................173 Notes .................................................................................................................................................174 References.........................................................................................................................................178 Chapter 4. Tourism............................................................................................................................181 4.1 Sector overview ..................................................................................................................182 4.2 The marinas sector..............................................................................................................185 4.3 Cruises ................................................................................................................................189 4.4 Recreational vessels ...........................................................................................................194 Car rental with a driver.......................................................................................................198 4.5 4.6 Car rental activity – minimum parking spaces ...................................................................201 4.7 Motorcycle rental activity – background............................................................................201 4.8 Tourist coach activity – background ..................................................................................203 4.9 Barriers to entry into the tourism sector .............................................................................207 4.10 Price approval and submission of price lists in the tourism sector.....................................210 4.11 Preferential treatment of the state.......................................................................................213 4.12 Conclusions on the sector findings .....................................................................................214 Notes .................................................................................................................................................215 References.........................................................................................................................................219 Chapter 5. Horizontal Obstacles to Competition ............................................................................221 5.1 Introduction ........................................................................................................................222 5.2 Advertising .........................................................................................................................222 5.3 Licensing and urban planning provisions ...........................................................................227 5.4 Transport ............................................................................................................................231 Notes .................................................................................................................................................234 References.........................................................................................................................................235 Chapter 6. Conclusion: Benefits from Removing Regulatory Barriers to Competition in Greece ..............................................................................................237 6.1Safeguarding competition impact assessment for the future ..............................................239Annex A. Methodology .....................................................................................................................241 Annex B. Legislation Screening by Sector ......................................................................................24710OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 2013 PREFACE BY HE KOSTIS HATZIDAKIS, MINISTER FOR DEVELOPMENT AND COMPETITIVENESSThe Greek crisis was largely caused by both the adverse international economic environment, following the collapse of Lehman Brothers in 2008, and by the chronic weaknesses of the Greek economy, high debt and dwindling competitiveness. During the crisis both citizens and businesses have endured enormous sacrifices, but it is thanks to these sacrifices and the efforts of the Greek government that we can now say that significant progress has been made, as the economy is stable and set to grow again. We know we still have a long way to go, but we are on the right track and moving forward fast. It is true that our economy has been plagued by bureaucracy, protectionism and market distortions for a long time. Our efforts have focused on generating growth by implementing and enhancing structural reforms, and not just by fiscal consolidation. Two necessary conditions for these structural reforms are to improve our competitiveness and to build a new, investment friendly, business environment. One of the foremost priorities set by the government is to remove barriers to entrepreneurship and competition and to strengthen the hand of healthy market forces, so that both consumers and businesses may reap the benefits. Our aim is to make Greece more competitive, extroverted and friendlier to investment and entrepreneurship. This, of course, includes improving the smooth functioning of the market by ensuring and enhancing competition. The Greek Government has worked closely with the OECD in order to identify market distortions and propose recommendations in four key areas of the Greek economy: food processing, retail, construction materials and tourism. We expect that the reforms adopted by these recommendations will benefit our economy in two ways: First and foremost, all citizens will have access to cheaper and better goods and services. Second, sound companies that respect consumers will be reinforced. By removing entry barriers young people, now tormented by unemployment, will have more opportunities to work and create new wealth. In this way, the necessary foundations for constructing a new national economy and sound production base are laid. Using the OECD Toolkit, regulatory distortions to competition were identified, mapped and evaluated. Among them were: •restrictions in opening new businesses,•barriers to entry and exit from an industry,•regulation of business behaviour, and•set maximum and minimum prices.OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 201311 Our intention is to act quickly and achieve tangible results very soon. We persistently support, adopt and drive structural reforms that have the potential to compel change and initiate high-impact investment projects so as to accelerate economic growth. Our aim is to become internationally competitive as a society, because our desire is to encourage investment and jobs and thus create prosperity for all Greek citizens. Our plan includes: •reinforcing production,•improving the conditions for growth,•addressing the behaviour that affects competition,•encouraging investment,•stimulating exports,•enhancing price-based competition, and•increasing choices for consumers.During this entire project, continuous training was provided to the competent personnel of the civil service. We have therefore gained essential know-how on the techniques and methods for measuring constraints to competition. I would like to express my appreciation for the OECD’s contribution and warmly thank everyone who participated in and supported this effort.HE Kostis Hatzidakis, Minister for Development and Competitiveness, Hellenic Republic12OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 2013 PREFACE BY HORST REICHENBACH, HEAD OF EU TASK FORCE FOR GREECEFor five years, Greek society has been undergoing a painful transition process, driven by the need to restore public finances and tackle other macroeconomic imbalances. Lasting stability and a return to prosperity also require deep structural reforms in the economy. Only in this way can we deliver sustained growth and better living conditions for the people of Greece. And exactly here lies the importance and value of this report. Much seemingly innocent legislation hinders the transition to a healthier economy. This report identifies a large number of regulatory obstacles limiting competition in key sectors of the Greek economy: food processing, retail trade, building materials and tourism. Most of the barriers identified ostensibly serve some public good. However, poorly designed regulation restricts competition and consumer choice and thus has adverse consequences. It is not a question of blindly striking down regulations; it is about correcting disproportionate interventions in the economy which benefit a few at the cost of many. These problems are not unique to Greece – far from it. But this report identifies many such instances in Greece. Greek businesses, consumers and citizens and society pay a very heavy price for this situation – according to this report a total of EUR 5.2 billion in lost efficiency and higher prices for goods and services. Removing these obstacles will have significant effects. For one, it will help bring benefits to consumers by lowering prices. Removing these barriers will also help to improve labour productivity and create more jobs in Greece. Moreover, this transition will equip Greek companies to compete more effectively on the European and global markets. The report provides the Greek authorities with extensive and detailed recommendations on how to deliver these benefits. Attention must now focus on the second part of the job – adoption and implementation of these recommendations. This will require courage and determination to make tough decisions. Changing legislation will also have to be accompanied by changes in administrative practice and the behaviour of civil servants, so that businesses really benefit from the removal of restrictive rules. One of the most pleasing aspects of this project for the Task Force is that it is the result of very fruitful co-operation between the OECD and Greek civil servants, drawn from the Hellenic Competition Commission, the Ministry of Development and Competitiveness and other ministries. These collaborative working processes have proved very rewarding and will leave a lasting legacy for the Greek administration in terms of increasing the capacity to understand and mitigate the unintended consequences of regulation on competition and market functioning. The task of improving Greek regulation does not end here. This may only be the first step on a long but important journey. Obstacles such as those identified in the sectors evaluated in this report may be equally prevalent in other areas of the economy. Greek regulatory culture and practice must also change so as to prevent this type of obstacle reappearing in the future. Draft legislation should be OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 201313 checked more rigorously in its preparatory phases to avoid any unintended consequences for new businesses and consumers. It was our pleasure to accompany this project from its inception. The Task Force for Greece stands ready to assist the Greek authorities in harvesting the fruits of this important work.Horst Reichenbach Head of EU Task Force for Greece14OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 2013 ACRONYMS AND ABBREVIATIONSAEPO AESGP AFSE AFSSAPS art. ASA ASEP ASBOF CE CEN CENELEC DEKPA DID EC ECC ECR EDEE EFET EFEX MEP EKEBI ELOT ELSTAT EOF EOT ESVEP ETSI FIBC FMCG FSA GCSL GDP GSL GVA HATTA HCC ICAP IELKA IGMEapproval of environmental conditions Association of the European Self-Medication Industry Association Française de Science Economique French agency for the safety of health products article (of law) Advertising Standards Authority (UK) Supreme Council for Civil Personnel Selection Advertising Standards Board of Finance (UK) Conformité Européenne European Committee for Standardization European Committee for the Electrotechnical Standardization Private Pleasure Maritime Traffic Document difference-in-differences study European Community European Cruise Council Efficient Consumer Response Association Greek Advertising and Communication Agents Association Hellenic Food Authority Association of Pharmaceutical Companies of Non-Prescriptions Medicines Member of the European Parliament National Book Centre of Greece Hellenic Organisation for Standardisation Hellenic Statistical Authority National Organisation of Medicines Greek Tourism Organisation Greek Association of Branded Products and Manufacturers European Telecommunications Standards Institute flexible intermediate bulk container fast-moving consumer goods Food Standards Agency (UK) General Chemical State Laboratory gross domestic product General Sales List (UK) gross value added Hellenic Association of Travel and Tourist Agencies Hellenic Competition Commission Intercapital Institute of Retail Consumer Goods Institute of Geology and Mineral ExplorationOECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 201315 IMDG IOBE IOC KED L MARAD MD NACE OAE OFT OTC par. PD KTEL PGEU PL PMR PVSA RAE RIA R&D RD RPM S.A. SEEDDE SEEPE SELPE SETE SEV SEVAS SEVT SGEI TAIPED TEE TEEA TEOM TSPEATH UHT16International Maritime Dangerous Goods (Code) Foundation for Economic and Industrial Research International Olive Council Public Real Estate Corporation litre US Maritime Administration Ministerial Decision Statistical Classification of Economic Activities in the European Community Federation of Greek Bakers Office of Fair Trading (UK) over-the-counter (medicines) paragraph (of article of law) Presidential Decree Joint Bus Receipts Funds (coach co-operative) Pharmaceutical Group of the European Union private label (products) Product Market Regulation (index) Passengers Vessels Services Act (US) Regulatory Authority of Energy regulatory impact assessment research and development Royal Decree retail price maintenance Société Anonyme Confederation of Greek Enterprises for Rented Villas & Apartments Hellenic Petroleum marketing Companies Association Hellenic Retail and Business Association Association of Greek Tourism Enterprises Hellenic Federation of Enterprises Association of the Greek Industry of Detergents and Soaps Federation of Hellenic Food Industries service of general economic interest Hellenic Republic Asset Development Fund Technical Chamber of Commerce Bakers' Supplementary Insurance Fund Tourism Road Transport Company Pension Fund of Personnel of Athens and Thessaloniki Newspapers ultra high temperature (milk)OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 2013 CHAPTER 3 BUILDING MATERIALSThe building materials sector covers many categories of economic activity. This assessment studied legislative restrictions in categories such as cement production and mines and quarries, and evaluated both harmonised and non-harmonised European standards for construction products. Specifically, transport and distribution centres for cement and exploitation rights for mines and quarries were studied with evaluation of existing harm to competition and potential benefits if restrictions are lifted. The categorisation of harmonised, nonharmonised and national specifications, which are set to ensure a uniform level of quality of products and constructions standards, is discussed for a variety of materials used in construction, among them plastic tubes, steel and chemicals and paints. The non-harmonisation of these specifications creates a double standard and constitutes a barrier to entry for manufacturers and suppliers to operate. The cumulative effect of the recommended changes will make building materials markets more open and competitive to the benefit of consumers.OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 2013155 3.1Sector overviewThe building materials sector cuts across a number of categories of economic activity. 1 It is made up of companies involved in mining, quarrying, manufacturing and the wholesale trade of materials for construction, such as cement, paint, window and door frames, steel reinforcements, tiles, roofing materials, wood and plumbing materials. The manufacturing of building materials2 generated EUR 5.3 billion of Gross Value Added (GVA) in 2010, accounting for 27.2% of total manufacturing in Greece. Non-metallic products was the largest subsector in 2010, accounting for 28.6% of the GVA of the building materials manufacturing sector, followed by fabricated metal products (26.1%) and basic metals (22.1%). Employment in mining and manufacturing of building materials reached about 109 300 in the third quarter of 2012. Job losses in the sector, since the corresponding period in 2008 when employment stood at about 160 600, reached 53 100 or 32.7% of the total. The performance of the building materials sector is tightly linked with construction activity. Construction did exceptionally well until 2006 due to extensive public works and growing housing activity, but since then it has been declining. In particular, the index tracking the useful floor area of new buildings has contracted in Greece with an annual average rate of 33.2% between 2008 and 2012. The contraction accelerated in 2012, when building construction declined by 37.8%. The fall is even greater in the current year, as in the first five months of 2013 the index has fallen by 55.4% year-on-year. Using the methodology outlined in OECD (2011a and 2011b), the OECD examined the legislation pertaining to building materials. Given that a number of categories of economic activity belong to this sector, a broad range of framework regulations was reviewed, among others establishing and licensing of companies, transportation, quality controls, warehousing and public works. In addition, the OECD reviewed specific regulations according to the type of material manufactured, such as concrete and steel. As a result of this extensive screening process, the obstacles to competition were identified in the following categories of building materials: • manufacture of cement (sector 23.5.1 in NACE Rev. 2) • aluminium production (sector 24.4.2 in NACE Rev. 2) • manufacture of plastic products (sector 22.2 in NACE Rev. 2) • manufacture of paints, varnishes and similar coatings, printing ink and mastics (sector 20.3 in NACE Rev. 2) • mining and quarrying (sector B in NACE Rev. 2) • quarrying of ornamental and building stone (sector 08.1.1 in NACE Rev. 2) Cement production constitutes one of the major manufacturing industries contributing to the Greek economy, with positive net exports mainly to countries outside the European Union (EU). However, over the past five years the cement industry in Greece has contracted dramatically as a result of the decline in private building activity and the halt of public works. In 2011 the volume of production fell by 63% compared with its peak in 2006. Meanwhile, the volume of exports in 2011 fell by 45% year-on-year, which is mainly attributed to the intense competition from exporting countries outside the EU and the ongoing crisis in the construction sector in major markets both in Western Europe and in the Middle East (e.g. Egypt and Libya). 156OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 2013 Table 3.1. Cement production, imports and exports (in 1000 tonnes) 20032004200520062007200820092010201115 38415 03615 39715 88014 41913 97810 9929 4175 861% change3.6-2.32.43.1-9.2-3.1-21.4-14.3-37.8Imports565153106118166222288221Production volume%change-33.6-8.75.098.911.441.033.529.7-23.4Exports3 3303 1434 0973 4013 7854 3364 2613 9502 159%change21.1-5.630.4-17.011.314.6-1.7-7.3-45.3Source: Bank of Greece, Eurostat, International Trade (database), http://epp.eurostat.ec.europa.euThe aluminium sector is also important for Greek manufacturing. In 2012 Greece exported about EUR 1.2 billion worth of aluminium products. The sector generated 2.2% of the turnover of Greek manufacturing (about EUR 1.7 billion) in 2008, with its share expected to have risen during the recession, as it has been less affected by the economic downturn. Between 2008 and 2012, the index tracking the volume of aluminium production rose by 4.0% annually, growing further in the first seven months of 2013 by 1.5% year-on-year. The plastics industry in Greece accounted for 3.1% of GVA in Greek manufacturing in 2010. The industry employed on average about 8 900 people in the first nine months of 2012, having contracted 18.9% year-on-year. The severe contraction from 2012, when the volume of production declined by 9.2%, has eased significantly, as in the first seven months of 2012 the volume of production declined by only 0.8% year-on-year. Paints contributed about 0.9% of GVA of Greek manufacturing in 2010. About 1 370 people were employed in the sector in the third quarter of 2012. Employment was up year-on-year by 46.8%, yet it remained significantly below its 2008 peak (about 4 150 employees). The recovery of this branch has carried over to the first seven months of 2013, when the index tracking the volume of production increased by 7.0% year-on-year. The Greek mining industry makes a relatively small contribution to the country’s GVA (approximately 0.3% in 2011), yet it is a strategic sector for the country, providing raw materials to other industries, such as cement manufacturing, construction and basic metals production. Greece is also a leading bauxite producer in the EU, with total production of 1.8 million tonnes in 2012. The mining and quarrying of building materials employed about 5 900 people in the third quarter of 2012, lower by 30.2% than in the same period of 2008 (about 8 500 employees). The index tracking the volume of production declined in the first seven months of 2013 by 0.3% year-on-year in the quarrying of stone, sand and clay and by 1.9% year-on-year in the mining of non-ferrous metal ores. Specific contractions were also identified in the marble and natural ornamental stone industry, which is a subsector of mining and quarrying. In 2011 Greek marble exports reached 830 800 tonnes with a total value of EUR 205 million, which represents an increase of 32% (10% respectively in terms of volume) year-on-year. China is the largest trading partner for the Greek marble industry, absorbing almost half of total exports (45% or 377 000 tons). Other significant trading partners are Saudi Arabia, Mexico, Qatar, Hong Kong and Russia. Almost 40% of the 200 active quarries are located in Northern Greece, across the wider area of Drama, Kavala and Thassos, producing over 70% of the total. The second largest production centre is in the Cyclades (mainly on the islands of Naxos, Paros and Tinos) with about 20 active quarries, whereas Attica is an important marble production centre mainly due to the large number of cutting and processing units. OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 2013157 The restrictions identified in these branches and the harm to competition from the current restrictions are presented in more detail below. 3.2Cement3.2.1National provisions on the distribution of cementAccording to national legislation, 3 the distribution in Greece of bulk cement or cement in big bags, 45 either produced by EU member states and distributed by intermediaries 6 or produced in third countries, should take place through dispatching centres7 located in Greece.8 National legislation 9 defines the conditions to be fulfilled for the establishment and operation of a dispatching centre so that the intermediary can ensure the quality, traceability, composition and compliance of the cement that has already been certified by the producer. 10 The quality control of cement is very important to ensure the safety of constructed structures. Cement is also considered to be dangerous to health. The objective of the legal requirement for a dispatching centre is to ensure the proper use of the Conformité Européenne (CE marking), to facilitate controls by the authorities, to protect the environment and to enable traceability of the product. The same conditions are imposed for cement packaged in big bags as for bulk cement and the same objectives are expected to be achieved. Bulk cement can be transported by sea in special or ordinary cement carriers. The first type of ship has special equipment to ensure the quality of the cement and its proper transportation and unloading in ports. In this case, it is usually the transporter who has the responsibility for using the proper external equipment for unloading bulk cement in port. The transport of bulk cement by road is by silo trucks which have waterproof and sealed silos, again to ensure the quality of bulk cement. A dispatching centre should have sufficient capacity for a minimum of 500 tonnes per silo 11 to be able to store the total of the bulk cement received using the same means of transport, i.e. the same ship or truck. The objective of this provision is to avoid segmentation of the quantity received into many smaller silos because problems of homogenisation may arise. Finally, Greek legislation imposes a fee of 2% on the retail price of cement, whether it is produced in Greece or originates in another EU member state, is traded in Greece or imported from a third country. This fee is collected in favour of the Subsidiary Pension Fund of the Employees of the Cement Industry. 12 3.2.2Harm to competitionThe obligation for a non-producer to establish a dispatching centre located in Greece in order to trade cement in bulk or in big bags limits competition both in supply and trade, and indirectly may influence the price of the product. In addition, the requirement for a dispatching centre applies to all bulk or cement packaged in big bags, regardless of a) its origins, i.e. from a member state or from a third country; b) the means of transport, i.e. whether the means of transport is sealed (sealed ship or silo truck) or non-sealed; and c) the use of the product, i.e. for own use or for supply to a third party. As it is formulated, the requirement prevents companies using cement for construction products from using other suppliers and blocks the entry of potential competitors into the market, i.e. companies wishing to operate as suppliers of bulk cement with sealed means of transport and direct delivery to their clients or in supplying cement bagged in big bags as it is, without unpacking or further repackaging. Additionally, the provision requires that the dispatching centre be located in Greece. This further restricts competition since it limits the suppliers to companies using cement for the production of other construction products and increases their costs. A company operating in Greece and wishing to buy cement for its own use from an intermediary located in another member state, is obliged to transfer the product through another dispatching centre located in Greece (or to establish a dispatching centre in Greece). It cannot transfer the product directly to its premises. Taking into consideration that 158OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 2013 producers of other construction materials already have certified silos for storing the quantities of cement they receive from national producers, the requirement for establishing a dispatching centre imposes extra operational and investment costs. Additionally, the requirement imposed by the draft ministerial decision to have a minimum capacity of 500 tonnes per silo in a dispatching centre goes beyond paragraph 9.2.1. of the ELOT Standard EN 197-2, which rules that the quality test carried out on cement upon delivery has to be one per delivery but at least one for every 500 tonnes. The ministerial standard defines the minimum frequency of tests on cement without imposing a minimum capacity for silos. Such a restriction constitutes a barrier to entry for small suppliers and potentially limits their number; the market may be dominated by large incumbents and lead to higher prices. The provision also increases costs for companies using or trading smaller quantities of cement who require silos with a smaller capacity. The dispatching centres have the obligation to test the quality of the product received in any delivery, even if the cement is received in smaller quantities. Finally, the additional fee of 2% on the retail price of cement in favour of employees of the cement industry (article 3 of Law 895/1937) creates extra costs for both producers and importers of cement, and reduces their ability to set market prices freely. From an economic perspective, a fee on cement is a form of tax and raises the marginal cost of the raw material. This higher cost hurts consumers in multiple ways. First, it adds to the costs of the producers which will be partly or entirely incorporated in the end-user price. Second, if producers reduce their output because of the higher costs created by this fee, this translates into lower revenues and fewer jobs in the cement market. Additionally, the fee (a form of payment to the pension fund) contributes nothing to the companies which import cement and who do not employ people insured by the fund; this creates extra, empty costs for them and puts them at a disadvantage in relation to companies whose employees are insured by the fund. This constitutes unequal treatment for producers and importers. 3.2.3Recommendations and benefitsIn the case of transfer of bulk cement in a sealed transport originating in an EU member state, irrespective of the dispatcher (producer or an intermediary in another member state), where the product is destined for own use and is not supplied to a third party, we recommend abolishing the requirement for a dispatching centre. In this case, the safety of the product, the protection of its characteristics from the moment of dispatch to delivery to the end user, as well as the protection of the environment are all assured through other means. These are: the means of transportation, the fact that the product has already been controlled by the intermediary before dispatch and has obtained a CE marking, and the fact that the end user has certified silos to store the product. The benefits of removing the requirement under the specific circumstances listed above would create more entries of cement into the Greek market, since transport by intermediaries from other member states would be unobstructed. This would enhance competition among suppliers, and would promote market growth. Additionally, we recommend removing the requirement for a dispatching centre to test cement bagged in big bags when these are sealed; whether the cement is destined for own use or for further supply. 13 In this last case, the big bag should not be unpacked and repacked, since any further processing, i.e. repackaging, constitutes intervention in the quality of the cement and breaches the quality chain. Any such rebagging would again require passage through a dispatching centre. The objective of the provision is assured by the packaging itself and the CE marking which indicates that it complies with all technical and legal requirements and cannot be related to the weight of the package, for example, if it is a bag of 50 kg, 1 tonne or 2 tonnes. In all cases, further transport along the supply chain should only be allowed if the big bag remains sealed. As a result of lifting this requirement, theOECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 2013159 anticipated benefits would lower barriers to entry into the Greek market, and reduce costs, potentially resulting in increased competition and lower prices. We recommend repealing the minimum storage capacity of 500 tonnes for a silo for bulk cement. This would give suppliers the option to adapt the capacity of their silos to their financial, technical and commercial needs. This would encourage new, smaller suppliers to enter the market, enhancing competition and leading to potentially lower prices. As defined in ELOT Standard EN 1971 and 197-2 on cement, the quality of the cement is assured through regular tests and different storage of the product in different silos according to the type of cement; its producer should not be dictated by the capacity of the silo. The fee of 2% should be abolished for both producers and importers; this would reduce costs for producers and importers and potentially lower prices of cement, as well as being perceived as being more equitable for all working in the industry. We recommend abolishing the requirement for dispatching centres for bulk cement in certain cases: where a) the bulk cement is transferred by an intermediary of another member state through a silo truck or a sealed ship and b) the bulk cement is destined for own use by a producer of other building materials. Recommendation: on dispatching centres for cement bagged in big bags: The requirement for a dispatching centre should be abolished in cases where a) the big bag is sealed, irrespective of the country of origin, i.e. EU member state or third country, b) the big bag is destined for own use by a producer of other building materials, c) the big bag is destined for further supply, provided that it is not unpacked and repackaged. Recommendation: the requirement to have an imposed minimum capacity for silos should be lifted: the relevant provision should be repealed Recommendation: the 2% fee on the retail price of cement should be abolished. 3.3Mines & quarries3.3.1Description of the legal framework3.3.1.1Marble quarriesThe exploitation of a marble quarry requires an exploitation licence which is issued by the state upon application, irrespective of the status of ownership of the quarry, i.e. whether it is public, municipal, communal or private.14 In areas where there was previously exploitation of marble or areas that have already been explored by public bodies, the lease of a municipal or communal marble quarry is awarded through a public tender and is accompanied by the exploitation licence. 15 The contracting authority defines the fixed and minimum variable rent, subject to article 20, i.e. a maximum variable rent of 8% of the sale price of the extracted marble and 10% of the sale price of the raw sub-products and any other waste. In municipal or communal areas where no prior exploration has taken place, if a company wants to initiate exploration works, the first to apply for exploration obtains the licence – provided it fulfils the criteria defined by law.16 The company that has obtained the exploration licence also obtains the exploitation licence through direct assignment. The municipality or the community defines unilaterally the annual fixed and proportional rent, as described in articles 20 and 33 of Law 669/1977. As noted above, there are two types of rent for exploitation of a marble quarry: a maximum annual fixed rent per m2 17 and a maximum variable rent amounting to 8% of the sale price of the 160OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 2013 extracted marble and 10% of the sale price of the raw subproducts and any other waste.18 The variable rent is due only when it exceeds the fixed rent and also applies to private quarries. In the case of a municipal or communal quarry, the above provisions aim to safeguard the procedure of direct assignment and, in the case of a private marble quarry, to limit possibly excessive and unjustified lessors’ claims, which could render the exploitation of a marble quarry less efficient and the products less competitive abroad. The exploitation of public quarries takes place either through a public tender or through direct assignment. 19 The public tender takes place when there was previous exploitation of the marble quarry or previous explorations were carried out by the Institute of Geology and Mineral Exploration (Ινστιτούτο Γεωλογικών και Μεταλλευτικών Ερευνών, IGME). 20 The contracting authority defines the fixed rent and the minimum variable rent, subject to article 20 of Law 669/1977. 21 The variable rent of article 20 is both for public tenders and direct assignment of the maximum variable rent. The lease of a public marble quarry takes place through direct assignment when a) no previous exploitation or exploration has taken place in the quarry, b) no offer was submitted in a public tender or c) a company has submitted an application to explore an area. 22 In this case, the rent is defined by the prefecture which sets both the fixed and variable rents. The prefect issues an assignment decision, following advice from the Prefectural Committee of Industry. This committee has wide discretionary powers within article 5 of Presidential Decree 285/1979 when proposing terms in contracts of direct assignment. 23 Article 4 par. 3 of Law 669/1977 on the exploitation of quarries24 states that, for a company to obtain an exploitation licence for a marble quarry, the quarry should have a minimum surface of 20 000 m2 and a maximum surface of 100 000 m2. This restriction of the maximum exploitation area aims to limit hoarding of large areas, especially in cases where exploration work is planned. The minimum exploitation area ensures that a company has a minimum amount of land for efficient exploitation. The exploiter of a marble quarry or other industrial mineral quarry also has an obligation to submit annually to the Ministry of Environment a report on the production and distribution of the extracted materials abroad and in the national market, their sale price and its maximum annual production capacity. 25 According to the competent ministry, this annual collection of data serves mostly statistical purposes. 3.3.1.2Quarries of aggregatesThe exploitation of raw materials from public, municipal, communal and private quarries is allowed upon issuance of an exploitation licence issued by the prefecture. The lease of public and municipal/communal quarries of aggregates takes place through public tender.26 The exploitation licence also constitutes the lease agreement between the exploiter and the state or municipality. 27 Additionally, an operating licence is required for the operation of machinery in a quarry; its duration is 15 years and it cannot be extended upon expiration of the lease agreement or the exploitation licence.28 The right to exploit raw materials belongs to the owner of the land in which aggregates lay or to the person to whom the owner of the land has assigned the relevant right. 29 The lessees of public, municipal or communal quarries are subject to both a fixed and a variable rent. The variable rent is calculated based on the sale price of raw materials and the annual minimum production of raw materials, as offered by the lessee. Accordingly, the sale price is calculated as a percentage of the reference price of crushed material (Code 622) of the Centrally Agreed Price List (Ανάλυση Τιμών και Περιγραφικό Τιμολόγιο Έργων Οδοποιίας, ΑΤΕΟ). 30 In addition, the variable rent for public, municipal and communal quarries is based on the quantities of aggregates sold annually and is calculated based on invoices or any other method that the prefect considers appropriate. 31 Moreover, the rent for private quarries, fixed, proportional or both, is freely defined by the parties.OECD COMPETITION ASSESSMENT REVIEWS: GREECE - PRELIMINARY VERSION © OECD 2013161 Aggregates that are extracted during the exploitation of any other category of minerals can be sold by the exploiter.32 In this case, the exploiter has the obligation to pay a variable rent to the owner of the quarry of minerals – irrespective of its ownership status – amounting to 10% of the sale price of the aggregates or 5% of the sale price of the processed materials. The objective of the provision is to limit potentially excessive and unjustified claims by the owners of the quarries of minerals, which may render those materials produced in Greece less competitive and reduce incentives to exploit the quarries. Finally, the exploiter has the obligation to submit annually to the Ministry of Environment an operation report (or a detailed report in case of inactivity) on the production and distribution of the products. 33 According to the ministry, the data collected serves mostly statistical purposes. 3.3.1.3MinesExploration and exploitation rights on mines are always granted by the state. The ownership of the land is not extended to mining minerals, either on the surface or in the subsoil. The ownership of a mine, which is separate from the ownership of the soil, is always granted by the state, upon prior issuance of an exploration licence. 34 The person granted an exploration licence has the right to apply for an exploitation licence which is granted through a contract notice and the issuance of a presidential decree. 35 The lease of exploitation rights is subject to a maximum rent defined by the law as a percentage based on the sale price of the ores or the products of their processing. 36 Nevertheless, articles 85A and 85B define that the minister has the power to oblige the exploiters of the mine to sell part of their production to the metallurgy industry in Greece and the sale price will be the current sale price in Greece. Additionally, the Ministerial Council has the authority to decide the compulsory leasing of a mine to a metallurgy company if the exploiter of the mine does not already supply the metallurgy company with the products of the mines. To benefit from the above provisions, the metallurgy companies should be Greek-owned companies registered in Greece. The aim of the provisions is to ensure the continuous supply of metals to metallurgy industries, taking into consideration the high cost of the investment, the fact that mining exploitation rights are always granted by the state and that such industries serve public policy objectives and are of national importance. 37 3.3.2Harm to competitionBecause of the lack of a definition for land use in a large part of the country, the provision concerning minimum and maximum exploitation surfaces of marble quarries may impose
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