FEE has reviewed the Third Report of the Inter-Institutional Monitoring Group and supports the conclusion that timely Member State transposition of Directives will be key to maintaining momentum and that further attention will need to be given to setting appropriate implementation deadlines in the future.
FEE notes that a careful balance is needed in selecting the issues to be addressed at Level 1 Framework Directive, Level 2 implementing measures and Level 3 guidance, given the difference in the status and authority of each of the three levels. Sufficient time should be allowed for consultation at all levels, including consultation on revised proposals that are substantially modified compared to the original draft proposals.
