"The Study focuses heavily on the CTM, whereas the volume of trade mark applications and registrations is of course more significant at national level. The emphasis of the Study thus risks leaving out relevant experience and opportunities that a more comprehensive study into European trade marks might have brought forward. The justification for an eventual distribution of half of the CTM renewal fees could perhaps have been advanced further by closer observation of the functioning of trade marks in a broader European context. "
Moreover,this study focuses also on some aspects oh OHIM governance and financial agreements.
"Payment of fees is the correct mechanism in the case of a public operation targeted at a specific economic community – trade mark owners – and there is good reason not to have the general tax payer pick up the bill for that. The condition of course, less well respected in the past, is that fees reflect the real cost of the operation and do not introduce a quasi-taxation on trade mark owners. "