OPINION OF THE EUROPEAN CENTRAL BANK on a proposal for a regulation of the European Parliament and of the Council establishing an exchange, assistance and training programme for the protection of the euro against counterfeiting (the Pericles 2020 programme).
The ECB reiterates its view that the Pericles programme is a useful contribution to the activities already deployed by the ECB, Europol and national authorities in the fight against euro counterfeiting. The ECB is confident that the Pericles 2020 programme will continue to contribute to preserving the integrity of euro banknotes, including the second series of euro banknotes.
The ECB makes the following observations :
Evaluation of the specific objective of the Pericles 2020 programme: the ECB considers that the programme should be evaluated against all the aspects that influence euro counterfeiting and fraud. Therefore, the ECB recommends full involvement of the ECB and Europol in evaluating the Pericles 2020 programme as provided in the proposed regulation.
Third countries: while acknowledging the benefits for euro counterfeit and fraud deterrence worldwide by including third countries in the Pericles 2020 programme, third country involvement should be sensible and proportionate.
Grants for the purchase of equipment: the ECB agrees with the proposal to make grants for the acquisition of general laboratory equipment, such as microscopes, infrared readers, callipers, densitometers, micrometers, readers of conductivity and magnetism that aid the investigative process and are not specifically designed or marketed as counterfeit detecting equipment. The ECB considers that the only reliable counterfeit detection machines and devices are those listed on its website as having performed satisfactorily in tests involving a batch of topical counterfeit types and genuine banknotes with a range of wear and tear characteristics. Such machines and devices are, however, aimed at the professional cash handling industry and are in general beyond the scope of the specialised anti-counterfeiting authorities defined as the target group in the proposed regulation. Therefore, the ECB is of the opinion that it is not appropriate to consider financing the purchase of counterfeit detectors with funds of the Pericles 2020 programme or using counterfeit detectors by specialised anti-counterfeiting authorities.
Examination of initiatives to be funded: it would be beneficial for the Commission, the ECB and Europol to jointly examine initiatives to be funded under the Pericles 2020 programme, thus avoiding duplication and overlap between the Pericles 2020 programme and other relevant programmes and activities and ensuring the development of a common strategy against euro counterfeiting and fraud. Accordingly, the proposed regulation should be amended to provide for: (a) timely consultation of the principal parties involved by the Commission in relation to the annual work programme; and (b) obtaining the ECBs and Europols agreement on the annual work programme for the purpose of its adoption. In this regard, the ECB and Europol should be given sufficient time to examine the draft annual work programme and to submit their views prior to its discussion within the appropriate advisory committee.
Implementation of the programme: the ECB welcomes the fact that the Commission is to implement the Pericles 2020 programme in cooperation with the Member States, through consultations at different implementation stages, taking into account relevant measures undertaken by other competent entities, in particular the ECB and Europol. While the proposed regulation ensures a sufficient level of cooperation at Union level as well as consistency between the Pericles 2020 programme and other relevant programmes and activities, the ECB recommends that the Commission allow for sufficient time for familiarisation with the documentation in relation to the annual work programme before consulting the ECB and Europol on it within the appropriate advisory committee.
Evaluation of the programme: the ECB recommends amending the proposal to allow for the involvement of the ECB and Europol in the evaluation of the effectiveness and efficiency of the Pericles 2020 programme and of its possible renewal, modification or suspension.