Report of Deputy Head of the Federal Service for accreditation Sergey V. Migin on “Approaches to the economic analysis of the market of conformity assessment in the framework of technical regulation”

11 March 2015

This report is devoted to the economic analysis of accreditation issues and outlines the research program aimed at clearing the features of conformity assessment market (services of certification bodies and laboratories) in Russia. The paradigm of the analysis (fig. 1) in the methodical terms is based on the modified classical scheme "structure-behavior-result", according to which the market behavior depends on the market structure but it is not determined only by this. Herewith, application of price theory proceeding from regularities of optimizing decisions in our case has the known restrictions associated with pricing model in this market, up to the present in many cases this application is carried out according to the principle "expenses plus profit".

Fig. 1. Paradigm of the sectorial market analysis

On the supply-side, basic conditions of functioning of the conformity assessment market are determined by technological and organizational parameters. Technologically certification bodies are noted for low costs of entrance to the market (a problem of "the color printer") that in its turn influences a curve of long-term average expenses. And the minimum efficient scale of a company (MES) was small historically. Thus, there is quite a large number of certification bodies. It is significant that today the Federal Service for accreditation activity, dealing with  introduction of the requirement for the regular personnel, has led to increasing of MES of certification bodies. It is clear that from the point of view of technology and market structure there is another situation with laboratories. It is required investments into specific assets, processing equipment, sometimes very expensive equipment. Thus, MES index for them is higher than for certification bodies.

Demand for conformity assessment in the obligatory sphere is generated administratively, so its feature is a low elasticity. At the same time, implementation of technical regulation reform is urged to create prerequisites for primary development of the sphere of voluntary confirmation of compliance with international standards. Growth of economically caused demand for services of certification bodies is provided by replacement of obligatory certification with declaring of compliance with participation of the third party, which can be a certification body.

Currently, there are no researches that allow to estimate with a satisfactory accuracy the scales of the market of services rendered by the accredited entities. Approximate idea of its capacity is provided by the estimates on the basis of separate empirical researches and available open data given in table 1.

Table 1. Scale of market of services rendered by accredited entities

Turning to the structure of the market, on January 1, 2014 in the register of the accredited entities included 1755 certification bodies and 9515 testing laboratories. Degree of production concentration is characterized by results of survey among the heads of certification bodies and the accredited testing laboratories (centers) which was carried out a few years ago and included a question concerning assessment of organizations, carrying out similar works on confirmation of compliance in the market where their company works, and this assessment was provided by respondents. The generalized results of poll are as follows: in Russia an average number of certification bodies in one market taking into account geographical and product boundaries is 7–9 firms and 6–7 testing laboratories. Similar estimates without taking into account Central Federal District (wherein the competition is higher) include 5–6 certification bodies and the similar number of laboratories.

As for the level of products differentiation, they are standardized in the obligatory sphere. Herewith the accompanying services are rendered.

Now about entrance barriers. Average cost and temporary costs for accreditation procedure have been calculated according to results of poll of heads of certification bodies mentioned above and the accredited testing laboratories (centers). Average value of the total expenses was 144 thousand rubles (2008) that at adjustment and considering inflation counts 205 thousand rubles in current prices. Those measurements, which we do using an expert way, allow to formulate a hypothesis that costs of accreditation procedure have not been changed significantly. This hypothesis demands a statistical check. Let me remind, that  accreditation law, coming into force in the second half of the year 2014, provides the Federal Service for accreditation with authority to monitor amounts of payment.

Average terms of passing accreditation procedure in 2008 were approximately five months (151 days), for certification bodies – 136 days and for testing laboratories – 157 days. In 2013 the similar indicator was 122 and 112 days respectively. Consequently, we establish a reduction of accreditation terms and observance of the established standards as well.

The behavior of firms is still influenced by such fundamental factors as high transaction costs and unfair competition. However, now it is possible to say that the main result of supervision activity of the Federal Service for accreditation, influencing behavior of participants of the market, is reduction of a share of certificates which are issued without carrying out testing. For laboratories it means additional demand for testing and also opportunities for investments into modernization of the equipment. The costs of violations of the mandatory requirements have increased sharply. Only an administrative fine on one episode counts 400 thousand rubles and more (for example, in case of recurrence) without taking into account costs of missed profit caused by accreditation suspension. Besides, we have to note that negative effects of strategic interaction of affiliated certification bodies remain. So, there is a very significant field for work.

In terms of direct result the hypothesis, demanding check within future researches, is that the market power exists, the behavior of firms often has quasi-monopoly character and requires appropriate regulation. The social and economic effect of changes in functioning of the market within the formation of unified national accreditation system is generalized in table 2.To sum it up, it is necessary to emphasize that regarding the mechanism of supervision we proceed from requirement to increase the efficiency of enforcement due to expense of elimination of errors of the first and second sort. In many respects it depends on the correct configuration of the incentives that take into account the effects of decisions for the public welfare. One of the basic recommendations is "transition from quantitative criteria of assessment of activity of executive authority and its employees (number of carried-out inspections, revealed violations, applied fines, etc.) to assessment of activity on the basis of  enforcement effects", that is the results of functioning of controlled market.

Table 2. Social and economic effect

Conclusions:

1. Shift of the regulating influence vector is observed: accreditation from the mechanism of regulation of the market structure turned into the instrument for regulation of firm behavior. This thesis is some sense consonant with the issue of the choice a form for creation of national accreditation body - it is not an agency, providing services for admission to the market, but it is the service, exercising control of activity of participants of the market and influencing their strategic behavior. 

2. In further researches it is advisable to apply models of oligopolistic behavior to the certification service markets. In particular, it is important to test the hypothesis, that the markets of certification services are well described by the model of price leadership, when on the local regional markets there exist a major  player and other participants of the market work at residual demand and behave as followers. Herewith, the market share with certain assumptions can be determined by the number of issued certificates.