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European Qualifications Framework

The European Qualifications Framework (EQF) is an eight-level, learning outcomes-based meta-framework developed by the to serve as a tool for comparing and referencing national qualifications systems across , encompassing formal, non-formal, and in terms of descriptors for , skills, and responsibility/autonomy. Formally recommended by the and Council on 23 April 2008 under Recommendation 2008/C 111/01, the EQF aims to promote transparency, mutual trust, and cross-border mobility of learners and workers by inviting countries to align their national qualifications frameworks (NQFs) or systems to its levels, without mandating standardization of content or curricula. By 2024, all EU member states had completed EQF referencing for their NQFs, extending to over 40 countries including some non-EU participants, and integrating with tools like for qualification documentation. Despite these structural achievements, the EQF's causal impact on enhancing labor mobility, , or actual practices remains empirically limited and contested, with independent evaluations noting persistent barriers in and , alongside critiques of its level descriptors as overly vague and insufficiently validated against real-world variances. Further scrutiny from policy analysts highlights the framework's non-neutral foundations, arguing it advances unproven assumptions about learning outcomes' universality without robust evidence, potentially prioritizing bureaucratic harmonization over substantive .

History and Development

Origins in EU Policy

The origins of the European Qualifications Framework (EQF) trace back to broader EU policy objectives aimed at fostering a knowledge-based and enhancing labor mobility amid rapid technological and economic changes, as well as an ageing population. The European Council in March 2000 identified the need for greater transparency in and emphasized as essential for improving employment quality and adapting to a competitive global environment. Subsequent milestones, such as the European Council in March 2002, called for the development of transparency instruments in education and training systems by 2010 to support these goals. A 2002 Council Resolution further encouraged cooperation across formal, non-formal, and informal learning sectors to bridge gaps in qualification recognition. These efforts converged in sector-specific initiatives that laid the groundwork for a comprehensive framework. The , initiated by the 2002 Copenhagen Declaration on enhanced European cooperation in and training (VET), evolved through communiqués like the Maastricht Communiqué of December 2004, which prioritized the creation of an open and flexible EQF to promote transparency, comparability, and mutual trust in qualifications. Complementarily, the for , particularly the Bergen Communiqué of May 2005, developed a Qualifications Framework for the (QF-EHEA) and highlighted the potential for alignment with a wider framework. These processes addressed fragmentation in national systems, where diverse qualification structures hindered cross-border mobility and validation of learning outcomes. The formalized the EQF concept through a proposal adopted on September 5, 2006 (COM(2006) 479 final), envisioning an eight-level, learning-outcomes-based meta-framework to serve as a "translation device" for comparing qualifications across member states without imposing uniformity. This non-binding recommendation, supported by an EQF Expert Group, built on consultations and aimed to integrate general, higher, and vocational qualifications under the Open Method of Coordination. It was endorsed by the and Council on April 23, 2008, as Recommendation 2008/506/EC, marking the policy's operational launch while respecting national competences in .

Formal Adoption and Early Implementation

The European Qualifications Framework (EQF) was formally adopted on 23 April 2008 via Recommendation 2008/C 111/01 of the and of the Council, establishing a common European reference framework for qualifications based on learning outcomes across eight levels. The recommendation emphasized transparency, comparability, and mobility of qualifications, inviting Member States, EEA countries, and other partners to relate their national qualifications frameworks (NQFs) or systems to the EQF by 2010 through a voluntary referencing process governed by 10 . This adoption followed years of consultation involving Member States, social partners, and stakeholders, building on earlier initiatives like the 2000 for . Early implementation focused on developing referencing reports to map national levels to EQF descriptors, with the establishing the EQF Advisory Group in to oversee coherence and trust-building. Initial progress was uneven, as many countries lacked comprehensive NQFs, requiring prior development of national systems; by 2010, preliminary referencing efforts had begun in select nations, including , which integrated EQF elements into its qualifications as early as 2009, and , whose Scottish Credit and Qualifications Framework (SCQF) produced its first EQF referencing report in 2009 (published 2010). completed one of the earliest full referencing processes in 2011, followed by countries like and . In the years immediately following adoption, implementation emphasized pilot projects and guidance documents from bodies like Cedefop, which supported the shift toward learning outcomes-based descriptors in vocational education and training (VET). and became pioneers in embedding EQF level references directly into VET certificates starting in 2012, marking a practical step toward widespread application. However, challenges emerged, including resistance to outcome-based approaches in tradition-bound systems and the need for buy-in, resulting in only a handful of countries achieving formal referencing by the 2010 target, with broader uptake accelerating post-2012 through revised EQF implementation reports.

Evolution and Referencing Processes

The European Qualifications Framework (EQF), formally recommended in 2008, evolved through iterative national implementations and culminated in a revision via the 2017 Council Recommendation. This update retained the core eight-level structure based on learning outcomes while introducing enhanced provisions for in qualifications and the validation of learning from non-formal and informal contexts, aiming to address gaps in transparency and adaptability to diverse learning pathways. The revision reinforced member states' commitments to ongoing development, including the systematic referencing of national qualifications and the indication of EQF levels on certificates, to improve comparability with third-country qualifications and support initiatives. By 2024, an evaluation confirmed the framework's sustained relevance, with all states having integrated referencing, though challenges in consistent application across sectors persisted. Referencing national qualifications frameworks (NQFs) or systems to the EQF involves a structured, transparent process where countries prepare detailed self-certification reports mapping their levels to the EQF's descriptors of , skills, and /. These reports must adhere to ten criteria outlined in Annex III of the 2017 Recommendation, covering the legal basis for the process, clear correspondence between national and EQF level descriptors, alignment with national systems, stakeholder involvement, and mechanisms for public accessibility and periodic review. Reports undergo and endorsement by the EQF Advisory Group, which includes national coordinators, social partners, and bodies like Cedefop and the European Training Foundation, ensuring mutual trust and comparability. This process, initiated post-2008 and formalized further in 2017, has enabled over 40 countries—including all 27 member states plus nations like and —to link their systems by late 2024, facilitating qualification mobility without mandating harmonization of national standards.

Core Structure and Descriptors

Eight Levels and Learning Outcomes

The European Qualifications Framework (EQF) structures qualifications across eight levels, each defined by descriptors of learning outcomes in three categories: , skills, and —specifically framed as and . These descriptors emphasize a progression from basic abilities at Level 1 to advanced and at Level 8, enabling comparison of qualifications from formal , vocational , and non-formal learning contexts. involves theoretical and/or factual elements; skills include cognitive aspects (such as logical, intuitive, and creative thinking) and practical ones (such as manual dexterity and use of methods, materials, tools, and instruments); reflects the capacity to apply and skills autonomously and responsibly. This outcome-based approach, established in the 2008 EQF Recommendation, facilitates transparency and mobility by focusing on what learners know, understand, and can do, rather than input measures like duration of study.) The levels demonstrate cumulative complexity: lower levels prioritize routine tasks under supervision, while higher levels demand problem-solving in unpredictable environments, innovation, and strategic oversight. For instance, Level 1 suits foundational for simple supervised tasks, whereas Level 8 requires frontier-level expertise for redefining fields through or professional . National qualifications frameworks reference these descriptors to align their levels, with many European countries mapping bachelor's degrees to Level 6, master's to Level 7, and doctorates to Level 8, in coordination with the . Empirical referencing reports from over 40 countries by 2023 confirm broad adoption, though variations in interpretation persist due to differences in sectoral applications.
LevelKnowledgeSkillsResponsibility and Autonomy
1Basic general knowledge.Basic skills required to carry out simple tasks.Work or study under direct supervision in a structured context.
2Basic factual knowledge of a field of work or study.Basic cognitive and practical skills required to use relevant information to carry out tasks and to solve routine problems using simple rules and tools.Work or study under supervision with some autonomy.
3Knowledge of facts, principles, processes and general concepts, in a field of work or study.A range of cognitive and practical skills required to accomplish tasks and solve problems by selecting and applying basic methods, tools, materials and information.Take responsibility for completion of tasks in work or study; adapt own behaviour to circumstances in solving problems.
4Factual and theoretical knowledge in broad contexts within a field of work or study.A range of cognitive and practical skills required to generate solutions to specific problems in a field of work or study.Exercise self-management within the guidelines of work or study contexts that are usually predictable, but are subject to change; supervise the routine work of others, taking some responsibility for the evaluation and improvement of work or study activities.
5Comprehensive, specialised, factual and theoretical knowledge within a field of work or study and an awareness of the boundaries of that knowledge.A comprehensive range of cognitive and practical skills required to develop creative solutions to abstract problems.Exercise management and supervision in contexts of work or study activities where there is unpredictable change; review and develop performance of self and others.
6Advanced knowledge of a field of work or study, involving a critical understanding of theories and principles.Advanced skills, demonstrating mastery and innovation, required to solve complex and unpredictable problems in a specialised field of work or study.Manage complex technical or professional activities or projects, taking responsibility for decision-making in unpredictable work or study contexts; take responsibility for managing professional development of individuals and groups.
7Highly specialised knowledge, some of which is at the forefront of knowledge in a field of work or study, as the basis for original thinking and/or research; critical awareness of knowledge issues in a field and at the interface between different fields.Specialised problem-solving skills required in research and/or innovation to develop new knowledge and procedures and to integrate knowledge from different fields.Manage and transform work or study contexts that are complex, unpredictable and require new strategic approaches; take responsibility for contributing to professional knowledge and practice and/or for reviewing the strategic performance of teams.
8Knowledge at the most advanced frontier of a field of work or study and at the interface between fields.The most advanced and specialised skills and techniques, including synthesis and evaluation, required to solve critical problems in research and/or innovation and to extend and redefine existing knowledge or professional practice.Demonstrate substantial authority, innovation, autonomy, scholarly and professional integrity and sustained commitment to the development of new ideas or processes at the forefront of work or study contexts including research.

Comparison with National Frameworks

The European Qualifications Framework (EQF) functions as a meta-framework enabling comparisons between national qualifications frameworks (NQFs) through a voluntary referencing process, in which countries produce detailed reports their qualification levels to the EQF's eight levels based on learning outcomes in , skills, and and autonomy (or competence). This process adheres to ten referencing criteria—ensuring , demonstrable links, , and —and ten quality assurance principles, with peer reviews involving international experts to verify consistency and transparency. As of 2024, 37 of 41 participating countries, including all 27 EU member states and select non-EU nations, have completed referencing, allowing tools like the comparator to display alignments between national qualification types and EQF levels. Structural comparisons reveal variations in the number of levels and granularity: the EQF's fixed eight levels provide a common anchor, but NQFs often feature more levels for finer distinctions, particularly at stages, while maintaining mapped equivalences. For instance, Germany's Deutscher Qualifikationsrahmen (DQR) comprises eight levels that directly correspond to the EQF, with referencing completed in 2012 following a comprehensive consultation process. In contrast, 's National Framework of Qualifications (NFQ) has ten levels, with levels 1 through 8 referenced to EQF levels 1 through 8, and levels 9 and 10 accommodating advanced qualifications exceeding EQF 8; was among the first to reference in 2009. Scotland's Scottish and Qualifications Framework (SCQF), with twelve levels incorporating values for modular learning, maps levels 1-4 to EQF 1-3, levels 5-6 to EQF 4, and higher levels up to 12 (doctoral) to EQF 8, with initial referencing in 2009 and updates confirming ongoing alignment.
CountryFrameworkLevelsKey Alignment FeaturesReferencing Completion
DQR8Direct level-to-level match; integrates VET and .2012
NFQ10Levels 1-8 to EQF 1-8; levels 9-10 for post-EQF advanced awards.2009
SCQF12Progressive mapping with credit system; SCQF 12 equates to EQF 8.2009 (updated)
Descriptor comparisons show broad congruence in outcome-based categories—knowledge (theoretical/practical), skills (cognitive/practical), and (autonomy/)—yet national frameworks may employ additional sub-descriptors or contextual emphases, such as Scotland's of credit accumulation for pathways. , for example, revised its framework from five to eight levels in 2019 to better align with EQF descriptors, reducing prior mismatches in VET progression. While referencing establishes formal s, substantive differences persist in areas like qualification density per level, validation of non-formal learning, and methodologies, potentially constraining full cross-border beyond the structural . NQFs also vary in scope, with some (e.g., emerging ones in partner countries) extending to pre-primary or informal sectors more explicitly than the EQF's focus on formal and non-formal outcomes from level 1 upward.

Key Components: Knowledge, Skills, and Competence

The European Qualifications Framework (EQF) structures learning outcomes across its eight levels using three interrelated components: , skills, and , which emphasize what individuals know, can do, and are able to demonstrate responsibly. These descriptors facilitate comparison of qualifications by focusing on outcomes rather than duration or inputs of and . constitutes the theoretical and/or factual foundation assimilated through learning, comprising bodies of facts, principles, theories, and practices relevant to a field of work or study. In the EQF, it is delineated progressively from basic, everyday applications at lower levels to advanced, specialized command requiring critical awareness of frontiers in highly complex or abstract domains at higher levels. Skills represent the capacity to apply and know-how to perform tasks and problems, divided into cognitive elements—involving logical, intuitive, and creative thinking—and practical elements—encompassing manual dexterity alongside the deployment of methods, materials, tools, and instruments. EQF descriptors specify skills' increasing sophistication, from routine execution under guidance to innovative problem-solving in unpredictable, multidisciplinary contexts. Competence denotes the validated ability to integrate knowledge, skills, and personal, social, or methodological capacities within professional, educational, or developmental settings, articulated through dimensions of responsibility and autonomy. Responsibility entails managing or supervising activities, while autonomy covers independent action, adaptation, and oversight of others; these evolve from supervised task fulfillment at entry levels to strategic leadership and innovation under partial information at advanced levels.

Scope and Application

Coverage of Qualifications Types

The European Qualifications Framework (EQF) is structured to encompass qualifications derived from formal education and training systems, as well as those validated from non-formal and informal learning experiences, spanning eight levels based on learning outcomes in knowledge, skills, and responsibility/autonomy. This broad scope applies to awards issued by competent authorities or bodies, including school-leaving certificates, vocational diplomas, higher education degrees, and professional certifications, enabling comparability across European countries. Adopted via Council Recommendation 2008/C 111/01 on 23 April 2008, the EQF explicitly references "all types and levels of qualifications," without mandating exclusion of any validated learning pathway, though implementation relies on national processes for assessment and referencing. In terms of sectoral coverage, the EQF integrates qualifications from general education (e.g., upper secondary completion at levels 3-4), and (VET, such as or certificates at levels 3-5), and (bachelor's, master's, and doctoral degrees at levels 6-8). Professional qualifications, including those in regulated occupations like or healthcare, are mapped through sectoral referencing where applicable, ensuring alignment with national frameworks. The framework's learning outcomes approach—focusing on what learners know, understand, and can do—facilitates inclusion of VET-specific outcomes, such as practical competences in trades, alongside academic knowledge in fields like sciences or . While primarily operationalized through formal qualifications in national systems, the EQF supports validation of non-formal learning (e.g., training certificates) and (e.g., self-directed skill acquisition) via procedures outlined in the Council Recommendation on validation, allowing outcomes to be described at EQF levels without formal . As of 2023, over 40 countries have referenced their frameworks to the EQF, predominantly mapping formal awards, but with growing provisions for non-formal validation in contexts, such as adult upskilling programs. This inclusivity aims to promote , yet practical coverage varies by country, with fuller integration of informal outcomes limited by assessment infrastructure.

Integration with Mobility and Recognition Tools

The European Qualifications Framework (EQF) serves as a meta-framework that links national qualifications frameworks (NQFs) to a common European reference scale, thereby enhancing the transparency and comparability of qualifications to support cross-border of workers and learners. By referencing qualifications to one of the EQF's eight levels based on learning outcomes, it facilitates the mutual understanding of credentials across member states and associated countries, reducing barriers to labor market entry and . As of 2023, 41 countries, including all members, have referenced their NQFs to the EQF, enabling systematic comparisons that underpin recognition decisions. A primary integration point is with the Europass digital platform, where EQF levels are embedded in tools such as the Profile, , and to standardize the presentation of qualifications for employers and institutions abroad. This allows users to self-certify their qualifications' EQF equivalence, promoting self-directed while institutions verify claims through referencing reports. The platform's EQF further maps levels to EQF descriptors, aiding quick assessments for job applications or admissions. The EQF also aligns with recognition networks like ENIC-NARIC, which provide advisory services on academic and professional qualifications; these centers routinely reference EQF levels in their equivalence evaluations, ensuring consistent application of the principles across Europe. For instance, when assessing foreign degrees, ENIC-NARIC experts compare learning outcomes to EQF benchmarks, streamlining processes for regulated professions under Directive 2005/36/EC. This integration has supported over 1 million recognition decisions annually through the network, though outcomes vary by sector due to national implementation differences. In and vocational training, the EQF complements credit transfer systems: it maps to the European Credit Transfer and Accumulation System (ECTS) for , where EQF levels 5-8 align with short-cycle, bachelor's, master's, and doctoral qualifications, facilitating Erasmus+ mobility for approximately 10 million participants since 1987. Similarly, for , EQF integration with the European Credit System for Vocational Education and Training (ECVET) enables the accumulation and transfer of units of learning outcomes, particularly in apprenticeships and short-term training, to address skills mismatches in mobile workforces.

Sectoral and Lifelong Learning Dimensions

The European Qualifications Framework (EQF) accommodates sectoral dimensions by serving as a meta-framework that enables the creation of sectoral qualifications frameworks (SQFs), which align specific standards with its eight learning outcome-based levels to facilitate cross-border comparability within fields. SQFs have been developed in sectors including , air and , building, banking and , , and communication (), professions, , and . For example, the SQF for the officer profession, established in 2018, references EQF levels 5 through 8 to define competences in areas such as , leadership, and strategic operations. Similarly, the SQF for , finalized in 2022, mirrors the EQF's eight-level structure to standardize qualifications in , policy-making, and crisis response. These SQFs emphasize sector-specific descriptors for , skills, and while ensuring linkage to national qualifications frameworks (NQFs) referenced to the EQF, thereby supporting labor mobility without supplanting national systems. In the realm of , the EQF, adopted via the 2008 European Parliament and Council Recommendation and revised in 2017, explicitly targets all learning activities across an individual's lifespan by defining qualifications in terms of outcomes rather than inputs, thus enabling the validation and recognition of formal, non-formal, and experiences. This approach spans levels 1 () to 8 (advanced mastery demonstrating ), covering , and training (VET), , and professional development to promote continuous upskilling and reskilling amid labor market changes. By integrating with tools like the supplement and NQF referencing—achieved by 36 countries as of January 2024—the EQF enhances for workers and learners, facilitating and without mandating uniform curricula. However, its effectiveness in practice depends on national implementation, with Cedefop noting ongoing challenges in coherently incorporating outcomes across diverse systems.

Implementation Challenges

National Adaptation and Referencing Issues

The referencing of national qualifications frameworks (NQFs) or systems to the (EQF) is a voluntary process established by the 2008 EQF Recommendation, requiring countries to submit reports demonstrating alignment with the EQF's eight levels through adherence to ten specific criteria, including transparent methodologies, involvement of stakeholders, and linkage to arrangements. By the end of 2012, only 16 European countries had completed referencing, with just four (, , , and the ) meeting the initial 2010 target, primarily those with pre-existing NQFs; progress accelerated thereafter, reaching 39 countries (EU Member States plus associated nations) by 2018, though updates are required as national systems evolve, leading to periodic revisions such as Lithuania's 2025 report. National adaptation challenges arise from the diversity of qualification systems across , where countries must integrate the EQF's learning outcomes approach—emphasizing , skills, and responsibility/autonomy—into existing structures without supplanting them, often resulting in uneven implementation. For instance, sectors in countries like exhibit resistance due to institutional autonomy and preferences for input-based traditions, complicating the shift to outcomes descriptors, while resource constraints in nations such as hinder comprehensive alignment across formal, non-formal, and pathways. Adaptation is further impeded by "academic drift," where vocational qualifications are elevated toward academic standards rather than labor-market relevance, as observed in Switzerland's NQF, which prioritized domestic positioning over transnational comparability, disconnecting it from practical EQF goals. Referencing issues stem from interpretive flexibility in applying EQF criteria, lacking centralized , which permits inconsistencies in level mapping and reduces cross-border trust; for example, debates persist over placements like Germany's at EQF Level 4 or 5, and upper secondary vocational qualifications in toggling between Levels 4 and 5, with Level 5 posing difficulties for 21% of surveyed stakeholders due to poor fit with intermediate qualifications. Some countries, such as , reference only professional qualifications, excluding certain formal education levels, while others like and operate NQFs with non-standard level counts (more or fewer than eight), straining comparability. Low , particularly from employers and social partners, exacerbates these problems, with awareness remaining limited in countries like and , and early reports (e.g., Malta's 2009 submission) criticized for opaque methodologies, though later iterations improved transparency through expert involvement. Empirical evidence indicates that while referencing enhances formal , it has yielded limited tangible improvements in or , as systems often retain silos between subsystems, and validation of non-formal/—intended to broaden EQF scope—exists in only about half of countries, mostly confined to vocational areas without clear EQF linkage. Studies across multiple countries highlight that NQF adaptation to EQF frequently fails to underlying or labor-market , with frameworks serving more as symbolic tools than drivers of systemic change, particularly where economic priorities or entrenched interests prevail over outcomes-based .

Technical and Methodological Flaws

The descriptors of the European Qualifications Framework (EQF), particularly for and , exhibit limitations in and applicability. The progression from "basic general " at level 1 to " at the most advanced " at level 8 fails to adequately accommodate tacit or transdisciplinary forms of , which may distort alignments with national or sectoral frameworks that emphasize such elements. is defined as the "proven to use , skills and personal, social and/or methodological ," yet the accompanying indicators prioritize responsibility and —such as "take responsibility for managing "—over verifiable , leading to interpretive confusion in applications like the e-Competence Framework (e-CF) and EQUALIFISE projects conducted in 2010. Level descriptors suffer from insufficient detail, totaling only 572 words across eight levels, in contrast to more expansive national frameworks like Scotland's at 3,272 words, which hampers precise allocation to individual qualifications. Empirical testing through international projects, including TRAVORS2 and ISOQUAM, reveals inconsistent mappings; for instance, comparable qualifications such as junior secondary certificates vary between EQF levels 2 and 3, while Scottish Advanced Highers align at against English equivalents at level 4. These discrepancies arise from vague phrasing, prompting reliance on single indicators for "best-fit" judgments that span multiple levels (e.g., levels 3-6 in TRAVORS2 outcomes). The referencing process to the EQF, intended to link national qualifications frameworks (NQFs), introduces methodological inconsistencies, as rapid NQF development often necessitates post-referencing revisions or marginalization of frameworks. Sectoral mappings exacerbate this, with frameworks like EQF-Sports showing divergent level assignments depending on versus direct sectoral routes, undermining cross-border comparability. Qualification design efforts using the EQF as a template, as in Certi.MenTu and EQUALIFISE, frequently overemphasize formal knowledge or conflate skills with , yielding outputs misaligned with practical validation needs. Overall, while the EQF functions adequately as a meta-framework for broad , its technical shortcomings render it unsuitable for granular leveling or development of specific qualifications without supplementary national elaboration, risking erosion of if applied directly. These flaws, evidenced in project-based validations since 2010, highlight a need for descriptor revisions to enhance clarity and empirical robustness.

Empirical Evidence on Effectiveness

By 2022, 39 European countries had referenced their national qualifications frameworks to the European Qualifications Framework (EQF), demonstrating widespread adoption as a tool for aligning qualifications across diverse systems. This figure rose to 41 countries by 2024, including non-EU participants like , , and , indicating the EQF's role in extending comparability beyond EU borders. Official evaluations attribute this progress to the EQF's facilitation of learning outcomes-based descriptions, which 80% of countries applied in at least one vocational education and training subsystem by 2012, with sustained use reported in subsequent reviews. Empirical data on practical effectiveness remains sparse, with stakeholder surveys showing positive perceptions of enhanced transparency—63% of respondents in a 2012 assessment confirmed national coordination points' efforts to promote EQF visibility—but low public and employer awareness persisting into the 2020s. In vocational training, Cedefop analyses of 72 initial vocational education and training qualifications linked to EQF levels 3 and 4 reveal that level 4 credentials lead to skilled employment in 95-100% of cases across studied countries, often enabling managerial autonomy and higher education access in 51-66% of instances, compared to level 3's predominant semi-skilled outcomes (61%) and limited mobility requiring further training. However, these labor market alignments predate full EQF implementation in many nations and do not isolate causal effects from the framework itself, as national variations in skill definitions undermine cross-border portability.
EQF LevelIVET Types Analyzed% Leading to Skilled Work% with Higher Education AccessKey Limitation
33139%6.5%Often requires additional learning; overrepresentation of learners
44195-100%51-66%Higher transversal skills coverage but inconsistent national recognition
Data from Cedefop case studies (e.g., car qualifications) indicate improved trust in level 4 outcomes due to detailed learning descriptors, yet quantitative of EQF-driven gains—such as increased cross-border job placements or reduced barriers—is absent, with only qualitative reports of for . A 2024 evaluation notes the EQF's contribution to addressing skills shortages by bridging formal and non-formal learning, but highlights inconsistencies, with 21% of stakeholders reporting challenges in leveling qualifications (e.g., level 5 in and ). Overall, while referencing metrics suggest structural effectiveness in , direct empirical links to enhanced worker or economic outcomes remain unproven, constrained by uneven and interpretive flexibility across jurisdictions.

Impact and Reception

Measured Achievements and Mobility Outcomes

The European Qualifications Framework (EQF) has seen substantial uptake in terms of national referencing, with 41 countries participating in the process as of 2024 and 37 having formally linked their national qualifications frameworks (NQFs) to the EQF's eight levels. This referencing enables systematic mapping of domestic qualifications to EQF descriptors of , skills, and , facilitating cross-system comparisons. By 2013, an interim documented initial progress, with 21 European countries having initiated referencing and over 20 developing comprehensive NQFs compatible with the EQF, though full implementation varied by sector. In terms of transparency as a measured achievement, the 2024 evaluation affirms the EQF's establishment as a core reference instrument, particularly for vocational qualifications, with heightened stakeholder awareness and integration into tools like profiles. This has supported qualification readability, as evidenced by its alignment with over 10,000 vocational qualifications in select countries' inventories, though aggregate EU-wide data on referenced qualifications remains decentralized across NQFs. The framework's learning outcomes approach has also informed sectoral initiatives, such as in via compatibility with the Qualifications Framework of the . Mobility outcomes, however, lack robust causal directly attributable to the EQF. While official assessments claim indirect contributions to learner and worker through reduced barriers—such as smoother credential validation in cross-border contexts—no large-scale quantitative studies demonstrate statistically significant increases in intra-EU labor or study exchanges linked to EQF . Independent analyses of NQFs, including those aligned with the EQF, report limited impacts on transitions or , with factors like language barriers and economic disparities exerting stronger influences on actual flows. For example, broader labor data show annual cross-border worker movements stabilizing around 2-3% of the workforce post-2010, but without disaggregated metrics isolating EQF effects. The 2013 noted early signs of improved portability perceptions among stakeholders but emphasized that tangible gains required complementary measures like validation of non-formal learning, which remain unevenly implemented.

Criticisms from Stakeholders and Research

Research critiques have highlighted the EQF's insufficient empirical foundation, noting that it draws from qualifications frameworks (NQFs) with documented implementation failures and limited transformative effects on education systems. Stephanie Allais's analysis of NQFs across 16 countries, including cases, concluded that such frameworks often fail to deliver promised reforms, exhibiting weak impacts on , , or labor market alignment due to overambitious scopes and inadequate institutional support. Similarly, Pia Cort argued that the EQF is not a , -based tool, as its promotion ignores evidence from NQF experiments in countries like and , where frameworks led to bureaucratic overload and unintended inequalities rather than enhanced mobility or equity. These studies emphasize causal disconnects, where outcome-based descriptors oversimplify diverse educational inputs and fail to address systemic barriers like entrenched traditions. Technical evaluations have identified flaws in the EQF's descriptors and referencing processes, particularly at intermediate levels. International testing projects revealed inconsistencies in applying level criteria, such as overlaps between vocational and qualifications at EQF Level 5, complicating accurate placement and comparability. A 2013 EU-commissioned reported that only 4 of 28 countries met the initial 2010 referencing deadline, with widespread issues in methodological and national interpretations of descriptors, eroding cross-border trust; less than half of surveyed experts believed referencing enhanced comparability. Stakeholder consultations in this report underscored low awareness among employers and social partners, who often viewed the framework as disconnected from practical needs, limiting its utility for validation of non-formal learning. Employers and professional bodies have expressed concerns over the EQF's limited relevance to labor market demands and skills verification. In a 2024 European Commission evaluation informed by public consultations, stakeholders criticized gaps in bridging formal qualifications with non-formal skills, arguing this hampers addressing shortages in upskilling and cross-border , with s questioning the framework's adaptability to evolving job requirements. Engineers Europe, representing sectoral interests, warned that the EQF's credibility hinges on buy-in, yet implementation often prioritizes bureaucratic alignment over demonstrable competence validation, potentially undermining trust in qualifications. on framework ineffectiveness attributes these issues to institutional inertia, where national and structures resist , resulting in superficial adoption without measurable mobility gains.

Broader Policy Implications and Sovereignty Concerns

The European Qualifications Framework (EQF), established via a 2008 Council recommendation and updated in 2017, serves as a meta-framework for aligning national qualifications systems, ostensibly to foster labor mobility and lifelong learning across the EU without mandating direct harmonization.)) In policy terms, it exemplifies "soft" EU governance, where voluntary referencing by member states to EQF levels 1-8 encourages convergence in outcomes-based descriptors, indirectly advancing economic integration by reducing barriers to cross-border recognition. This approach aligns with broader EU objectives under the Europe 2020 strategy, prioritizing employability and competitiveness, yet it embeds standardization tools that subtly extend supranational influence into education policy, traditionally a national domain under Treaty on the Functioning of the EU Article 165. Sovereignty concerns arise from the framework's referential mechanism, which, while non-binding, incentivizes national adaptations through and funding linkages, potentially eroding member states' in defining rigor and content. Official discourse emphasizes preserving national as a limit on prescriptiveness, yet empirical observations indicate that referencing processes often prompt revisions to domestic frameworks, fostering alignment that dilutes country-specific standards. For instance, analyses note that EQF-leveling contributes to partial of content, raising fears of a "" effect where higher-performing systems concede distinctiveness to facilitate EU-wide comparability. Critics, including European student organizations, argue that such dynamics risk prioritizing bureaucratic uniformity over substantive quality, with rushed implementations exacerbating inconsistencies and undermining local educational priorities. In causal terms, the framework's outcomes-focused paradigm may incentivize superficial adjustments—such as broadening access at lower levels—over rigorous input-based assessments, potentially weakening incentives for excellence in vocationally oriented systems. Post-Brexit, the UK's partial from EQF referencing illustrates reclamation, highlighting how tools can constrain flexibility during realignments. These implications underscore tensions between EU-wide goals and the preservation of diverse competencies, with limited empirical data on long-term erosion due to the framework's recent and uneven adoption.

Controversies and Debates

Overemphasis on Outcomes vs. Inputs

The European Qualifications Framework (EQF), established by Council Recommendation in 2008, defines qualification levels exclusively through learning outcomes—statements of knowledge, skills, and competence/responsibility—without reference to inputs such as curriculum content, instructional duration, or pedagogical methods. This outcomes-centric methodology has drawn criticism for overemphasizing demonstrable end results at the expense of the foundational processes and inputs that ensure educational depth and rigor. Scholars argue that true competence arises not merely from what learners can perform post-assessment, but from structured exposure to disciplinary knowledge and guided practice, elements sidelined in the EQF's design. Stephanie Allais, in analyses of outcomes-based systems influencing EQF-adopting nations, contends that such frameworks reduce complex educational aims to fragmented, ostensibly measurable units, fostering a "false clarity and precision" that masks underlying epistemological weaknesses. By treating outcomes as standalone descriptors detachable from curricula or institutional contexts, the EQF risks equating qualifications from rigorous, input-heavy programs (e.g., those mandating years of supervised study) with superficial ones achieved via accelerated or unregulated paths, potentially eroding trust in cross-border . Allais's of 16 countries implementing similar qualifications frameworks (NQFs) aligned to EQF principles found negligible improvements in skills or , attributing this to the approach's neglect of causal links between teaching processes and outcome durability. Michael Young and Allais further critique the shift as ideologically driven toward , where overreliance on self-reported or assessor-verified outcomes bypasses verifiable inputs like faculty expertise or content standards, leading to credential proliferation without proportional quality gains. In continental European contexts, such as and , national referencing reports to the EQF have hybridised by retaining input criteria (e.g., program duration and institutional accreditation) to mitigate these flaws, revealing the framework's tension with tradition-bound systems prioritizing process integrity over output abstraction. Empirical parallels, like England's 2010-2015 Qualifications and Credit Framework (QCF)—an outcomes-only model prefiguring EQF influences—saw unit accumulation without depth, prompting its overhaul amid employer complaints of mismatched skills and diluted standards. Proponents of critique emphasize that unmeasurable aspects, such as cultivated through iterative classroom discourse, defy reliable outcomes assessment, yet are indispensable for long-term adaptability in volatile labor markets. This overemphasis, per Allais, inverts causal realism by assuming outputs can be engineered independently of inputs, a methodological flaw evident in stalled EQF adoption rates: by 2023, only 40% of EU states fully referenced all qualifications, often due to unresolved process-outcome mismatches. Such debates underscore demands for EQF revisions incorporating descriptors to balance with substantive quality controls.

Potential for Standardization and Quality Erosion

Critics of the European Qualifications Framework (EQF) argue that its emphasis on common outcome-based descriptors across diverse national systems risks fostering a "lowest common denominator" approach to standardization, where comparability is achieved by diluting rigorous standards to accommodate weaker systems rather than elevating all to higher benchmarks. This concern stems from the EQF's broad, abstract levels—defined by learning outcomes in knowledge, skills, and competence—which lack sufficient specificity for precise mapping, leading to inconsistent national referencing reports as of 2017, with 39 countries linking their frameworks but varying interpretations evident in cases like Nordic senior secondary certificates placed at EQF levels 4 or 5 depending on the country. Such methodological flaws, including vague domains, have been highlighted as particularly problematic, potentially enabling disparate conclusions in sectoral leveling and undermining the framework's reliability for cross-border . For instance, projects like EU in Motion have documented "different interpretations to the level indicators" resulting in "widely disparate conclusions," which could erode public trust in if perceived as artificially harmonized at reduced rigor. Furthermore, the shift toward outcomes-focused design in the EQF, critiqued by scholars such as Michael Young and Stephanie Allais, may distort traditional input-based systems emphasizing disciplinary knowledge, incentivizing a "" where practical or vocationally specific qualifications are reframed in generic terms, potentially compromising their fitness for purpose and overall . Poorly considered adoption of EQF principles risks "undermining the quality and credibility of existing systems," as national adjustments to align with level 8 descriptors (advanced expertise) might prioritize superficial comparability over substantive depth, absent robust validation mechanisms. While the EQF remains a voluntary tool without direct enforcement, these dynamics could indirectly pressure member states to lower thresholds for , as evidenced in broader efforts where has aligned durations and outcomes at the expense of varying national strengths.

Political and Ideological Critiques

Critics of the European Qualifications Framework (EQF) have argued that it advances a neoliberal ideological agenda by emphasizing learning outcomes oriented toward labor flexibility, employability, and economic competitiveness, rather than broader educational or goals. This approach, rooted in EU policies from the early 2000s such as the , promotes the marketisation of education through standardization and individual responsibility for skill acquisition, which some scholars contend undermines public welfare models and traditional input-based assessments in favor of competency-driven metrics that align with capitalist demands. Such critiques, often from educational researchers, highlight how the EQF's discourse blends inclusion rhetoric with neoliberal imperatives, masking an underlying push to dismantle barriers to labor mobility and enhance EU-wide without robust empirical validation of its benefits. From a political perspective, the EQF has been faulted for eroding national in by requiring member states to their qualification systems to the EU's eight-level grid, effectively pressuring reforms that harmonize curricula and standards under supranational oversight. This process, initiated with the EQF's adoption in 2008, is seen by integration skeptics as part of broader "soft" governance mechanisms—like the Open Method of Coordination—that subtly compel convergence without formal treaty changes, leading to a gradual relinquishment of control over domestic educational priorities. For instance, referencing reports submitted by countries since 2017 must demonstrate alignment with EQF descriptors, which critics argue imposes external benchmarks that prioritize cross-border portability over national cultural or vocational specificities, exacerbating tensions in states wary of federalist tendencies. Ideological opposition also stems from concerns that the EQF reinforces a technocratic, outcomes-focused that depoliticizes , portraying qualifications as commodified assets in a single European while sidelining debates on , teacher , or state-funded comprehensive systems. Academic analyses, potentially influenced by institutional biases against market-oriented reforms, contend that this framework's proliferation—evident in over 40 countries referencing by 2023—serves EU strategic goals of geopolitical competitiveness rather than , with limited independent data confirming reduced barriers to . Proponents of , including voices in Brexit-era discussions, have echoed these points, viewing the EQF as emblematic of EU overreach that could dilute member states' ability to tailor to local economic and social needs.

References

  1. [1]
    The European Qualifications Framework (EQF) - Europass
    The EQF is an 8-level, learning outcomes-based framework for all types of qualifications that serves as a translation tool between different national ...Description of the eight EQF... · National Qualifications... · EQF Referencing Reports
  2. [2]
    European Qualifications Framework (EQF) - ESCO
    The EQF is an 8-level, learning outcomes-based framework for comparing national qualifications, making them more understandable across Europe.
  3. [3]
    European qualifications framework (EQF) - Cedefop
    The European Qualifications Framework (EQF) is a common European reference framework whose purpose is to make qualifications more readable and understandable.
  4. [4]
    State of play of the European Qualifications Framework ...
    Oct 2, 2013 · The European Qualifications Framework (EQF) was adopted by the European Parliament and the Council on 23 April 2008 (OJ C 111, 6.5.2008, p.
  5. [5]
    The European qualifications framework - Publications Office of the EU
    Sep 10, 2019 · The European qualifications framework for lifelong learning (EQF) aims to improve the transparency, comparability and portability of people's qualifications.
  6. [6]
    [PDF] Explaining the European Qualifications Framework for Lifelong ...
    The core of the framework consists of 8 qualifications levels described through learning outcomes (knowledge, skills and competence). Countries are invited to ...
  7. [7]
    European Qualifications Framework for lifelong learning (EQF)
    Dec 12, 2024 · The EQF is a translation tool making national qualifications comparable, enabling better understanding and cross-border mobility of learners ...Missing: criticisms | Show results with:criticisms
  8. [8]
    European Commission publishes evaluations of Europass and ...
    Mar 27, 2024 · It Is clear from the evaluation that the existing EQF structures and processes are to be maintained – ensuring trust among countries requires ...
  9. [9]
    Ten years after: the 'success story' of the European qualifications ...
    More than 10 years after, it is time to re-address these expectations and to question whether and, if so, in which ways the EQF has actually provided an impetus ...
  10. [10]
    [PDF] The European Qualifications Framework: a technical critique
    Use of the EQF as a tool for allocating levels to individual qualifications or to aid qualification development has been conspicuously less successful, due both ...
  11. [11]
    Why are qualifications frameworks so ineffective? The role of ...
    The new policy began due to criticism that the country's VET system was not sufficiently labour-market-oriented and accessible to the poorest (European ...
  12. [12]
    (PDF) Stating the Obvious: The European Qualifications Framework ...
    Aug 7, 2025 · The argument may seem obvious: the EQF policy is not neutral (policies never are), nor is there evidence to substantiate the claim that the EQF ...<|control11|><|separator|>
  13. [13]
    The European Qualifications Framework is "Not" a Neutral Evidence ...
    The aim of this article is to denaturalise the EQF discourse through a discursive reading of the EQF policy and a review of research on national qualifications ...
  14. [14]
    Stakeholders discuss how to put the European Qualifications ...
    Jun 1, 2008 · The Recommendation establishing the EQF was formally adopted in April 2008 and sets a target date of 2010 for countries to relate their ...
  15. [15]
    [PDF] The European Qualifications Framework
    Countries that have referenced to the EQF are invited to make the results of the process publicly available within six months, both at national and European ...
  16. [16]
    [PDF] THE EUROPEAN QUALIFICATIONS FRAMEWORK
    Ireland was the first country to implement the EQF in 2009 and now qualifications in Ireland enjoy European currency and recognition throughout Europe and ...
  17. [17]
    Update of the Referencing of the SCQF to the EQF
    Jun 5, 2019 · The EQF aims to relate different countries' national qualifications systems to a common European reference framework. Individuals and ...
  18. [18]
    [EPUB] Qualifications frameworks in Europe - Cedefop
    Denmark and Lithuania were the first to include references to EQF/NQF levels in their VET certificates in 2012. By November 2016, 20 countries had introduced ...
  19. [19]
  20. [20]
    [PDF] 090506 EQF Referencing Criteria
    The EQF Recommendation invites countries to refer their national qualifications levels to the EQF by 2010.
  21. [21]
    [PDF] Referencing criteria - ETF (europa.eu)
    The national quality assurance system(s) for education and training refer(s) to the national qualifications frameworks or systems and are consistent with the ...
  22. [22]
    Description of the eight EQF levels - Europass - European Union
    Each of the 8 EQF levels is defined by descriptors of learning outcomes, including knowledge, skills, and responsibility/autonomy.
  23. [23]
    National Qualifications frameworks (NQFs) online tool | CEDEFOP
    In addition, through the EQF users can compare qualification types between two countries (NQF comparison), and have an 'Overview' of the main features of all ...
  24. [24]
    Compare Qualifications | Europass - European Union
    With the help of the European Qualifications Framework (EQF) you can see how National Qualifications Frameworks (NQF) and systems relate to one another.
  25. [25]
    DQR and EQF - Deutscher Qualifikationsrahmen
    The eight levels of the DQR were referenced to the eight EQF levels within the so-called referencing process. The results of the referencing process can be ...Missing: alignment | Show results with:alignment
  26. [26]
    Germany | CEDEFOP - European Union
    The DQR was referenced to the European qualifications framework (EQF) in 2012. The qualifications framework for higher education – now an integral part of the ...
  27. [27]
    [PDF] Qualification frameworks to facilitate comparison and recognition of ...
    Why a qualifications framework? • QFs improve transparency and comparability of qualifications. • QFs are instrumental for. ✓ recognition of all forms of ...
  28. [28]
    [PDF] Qualifications frameworks in Europe: modernising education and ...
    For example, Ireland's NQF has 10 levels. The UK (Scotland) NQF has 12. The French. NQF is being revised from a 5 to an 8-level structure. Of the newer ...
  29. [29]
    National qualifications frameworks: strengthening transparency and ...
    Mar 10, 2025 · Spain: EQF referencing officially completed · National news. Image. recognising_all_learning_nqfs.jpg. News. 13 Jun 2025. Recognising all ...Missing: differences | Show results with:differences
  30. [30]
    National Qualifications Frameworks (NQFs) - Europass
    The EQF to make it more effective in facilitating the understanding of national, international and third-country qualifications by employers, workers and ...
  31. [31]
  32. [32]
    [PDF] The European Qualifications Framework - Europass
    Accompanying level descriptors show how expectations of knowledge, skills, autonomy and responsibility increase as learners progress from level 1 to level 8.
  33. [33]
    European qualifications framework for lifelong learning (EQF)
    its eight levels cover the entire span of qualifications from those recognising basic knowledge, skills and competences to those awarded at the highest level of ...
  34. [34]
    [PDF] EQF Consultation - Engineers Europe
    The development of an EQF is of direct relevance to the proposal for 'a Framework for qualifications of the European higher education area' (EHEA) adopted by ...
  35. [35]
  36. [36]
    [PDF] European guidelines for validating non‐formal and informal learning
    This publication presents the conclusions of more than two years of intensive exchange of experiences - involving representatives from more than 20.
  37. [37]
    Qualifications Frameworks: Level of Qualifications - ENIC-NARIC
    On the website of the European Union the Europass platform offers an instrument to compare the levels of National Qualifications Frameworks across Europe with ...
  38. [38]
    Recognition Tools and Projects - ENIC-NARIC
    ENICs and NARICs have developed tools and projects to facilitate recognition, foster mobility and enhance internationalisation of higher education.
  39. [39]
    ENIC-NARIC - gateway to recognition of qualifications
    This website aims to help interested organisations and individuals find information on current issues in international academic and professional mobility.France · USA · ENIC-NARIC Networks · Slovenia<|separator|>
  40. [40]
    European Credit Transfer and Accumulation System (ECTS)
    A 'first cycle' (or bachelor's) degree consists of either 180 or 240 ECTS credits and a 'second cycle' (or master's) degree equates to 90 or 120 ECTS credits.
  41. [41]
    [PDF] Information about ENIC and NARIC centres
    You might work with an ENIC NARIC… • When seeking an expert and practitioner's view on recognition instruments (EQF, Europass Documents,. ECTS, ECVET). • To ...
  42. [42]
    sectoral qualifications framework | CEDEFOP - European Union
    A sectoral qualifications framework aims to ensure that staff of businesses operating at international level meet the qualifications standards of the industry; ...Missing: dimensions | Show results with:dimensions
  43. [43]
    [PDF] Sectoral Qualifications Framework – Military Officer Profession
    Oct 29, 2018 · This document describes the context, governance and stages for the development, validation and implementation.
  44. [44]
    [PDF] Sectoral Qualifications Framework for Public Health - Profibaza PZH
    Jun 3, 2022 · The PQF has eight levels of qualifications, like the European Qualifications. Framework. Each PQF level is described by general statements1 ...<|separator|>
  45. [45]
  46. [46]
    [PDF] Evaluation of the Implementation of the European Qualifications ...
    Oct 17, 2013 · This evaluation report provides an overview of progress made in the implementation of the EQF. Recommendation between 2008 and 2012.
  47. [47]
    Publication of the updated report on the referencing of the ... - Cedefop
    Jan 9, 2025 · The report provides updated answers to the criteria and procedures for referencing NQFs to the EQF, identifies the challenges related to the ...Missing: adaptation issues
  48. [48]
    [PDF] Problems with National Qualifications Frameworks in practice. The ...
    The EQF provided momentum for member states to consider introducing NQFs, although decisions about the value, development and implementation of a NQF are also ...
  49. [49]
    Study supporting the evaluation of the Council Recommendation of ...
    Mar 25, 2024 · Study supporting the evaluation of the Council Recommendation of 22 May 2017 on the European Qualifications Framework for Lifelong Learning.
  50. [50]
    [PDF] Research paper - European qualifications framework - Cedefop
    levelling, reflecting NQF descriptors in learning outcomes can improve the ... descriptors of the European qualifications framework. European journal of.
  51. [51]
    [PDF] Evaluation of the Implementation of the European Qualifications ...
    Oct 17, 2013 · This evaluation report provides an overview of progress made in the implementation of the EQF. Recommendation between 2008 and 2012.
  52. [52]
    (PDF) The European Qualifications Framework: a technical critique
    Aug 5, 2025 · The EQF serves as an inclusive reference point for national qualifications frameworks (NQFs) of member countries, allowing for the comparison of ...
  53. [53]
    Labour mobility and labour market adjustment in the EU
    Nov 10, 2016 · Results indicate that labour mobility absorbs about 25 % of asymmetric shocks after 1 year and about 50 % at peak, after about 5 years. It is ...
  54. [54]
  55. [55]
    Full article: Standardization of (higher) education in Europe – policy ...
    Feb 3, 2017 · Elken, M. (2016b). Standardizing education? The development of the European Qualifications Framework and national qualifications frameworks.<|separator|>
  56. [56]
    [PDF] The European Qualifications Framework: supporting learning, work ...
    The EQF is a framework to make skills and qualifications more easily understood and recognized, aiming to improve transparency and comparison of qualifications ...
  57. [57]
    [PDF] QUALIFICATION STRUCTURES IN EUROPEAN HIGHER ...
    Oct 5, 2003 · One could, of course, see the EHEA framework as a synthesis or a lowest common denominator of the frameworks of its constituent higher education ...
  58. [58]
    [PDF] Final Report: The European Qualifications framework
    Oct 12, 2006 · But a common denominator is the tendency of governments to move into rushed and merely formal implementations of national qualifica- tions ...
  59. [59]
    Impact of the Europeanisation of education: Qualifications ...
    Oct 25, 2016 · This article examines the influence of the European qualifications framework – a key European lifelong learning policy instrument for improving employability.
  60. [60]
  61. [61]
    [PDF] The shift to outcomes based frameworks. Key problems ... - peDOCS
    Young, Michael/Allais, Stephanie (2011): The shift to outcomes based frameworks: Key problems from a critical perspective. In: Austrian Open Access Journal of ...
  62. [62]
  63. [63]
    Competence across Europe: Highest Common Factor or Lowest ...
    Aug 5, 2025 · Competence across Europe: Highest Common Factor or Lowest Common Denominator? ... (EQF). Emphasising transversal competencies ...
  64. [64]
    Vindicating Ethics in the European Qualifications Framework (EQF)
    In this sense, the EQF is often deemed "reductionist as it is the lowest common denominator EU member states could agree upon" (Markowitsch and Luomi-Messerer, ...<|control11|><|separator|>
  65. [65]
  66. [66]
  67. [67]
    How the EU strangles scholarship - spiked
    Apr 14, 2016 · Inevitably, as with all attempts at standardisation, the danger is a race to the bottom – in this case other European countries have had to come ...
  68. [68]