KANBrief 4/21

Annex III organizations: representatives of social stakeholders in European standardization activity

European standards help to raise European industry's competitiveness, and serve an important purpose in many areas of European legislation. They may also have far-reaching impacts on society, for example on consumers, the environment and the safety of workers. In accordance with the basic principles of standardization, it is therefore important for all stakeholders to be appropriately involved in standardization processes at national and European level and able to contribute their expertise.

The structure and processes of the European Standards Organizations (ESOs) are governed by private law. They do not therefore automatically represent the interests of wider society. In standardization, the principle of national delegation applies (See CEN Internal Regulations Part 1, 2.4): stakeholder participation is channelled through the national standards bodies, whose delegates represent the consensus of all stakeholders in their respective countries. But are these stakeholders actually represented adequately in the standardization processes of all the Member States? In 2009, the European Commission noted that in many Member States, representation in standardization of certain significant parties in society was weak or fragmented (EIM study: Access to standardization, March 2009).

For this reason, the ESOs were mandated by the EU in the Standardisation Regulation, which came into force in 2012, to "encourage and facilitate an appropriate representation and effective participation of all relevant stakeholders". Annex III of the Regulation sets out clearly that the only bodies suitable for this purpose are permanent, non-profit European associations mandated by national organizations in at least two-thirds of the Member States to represent stakeholder interests in the European standardization process. A body recognized as an Annex III organization is eligible to apply for EU funding and participate directly in standardization activity at European level. These bodies are: ANEC ( Association Normalisation Européenne pour les Consommateurs) for consumers' interests, ECOS (Environmental Coalition on Standards) for environmental interests and ETUC (European Trade Union Confederation) for workers' interests. But: are these in fact the only groups whose expertise is at risk of being neglected during standardization activity? The EU Regulation answered this question by also including small and medium-sized enterprises (SMEs) in Annex III, since adequate participation by SMEs in the European standardization process is essential, particularly in the interests of the EU's technological progress. SMEs are represented in European standardization activity by Small Business Standards (SBS).

The EU Regulation does not however grant voting rights to Annex III organizations. The actual form taken by their participation is at the discretion of the European standards organizations. In practice this means that, as set out in the Regulation, the Annex III organizations may for example propose new work items, submit comments on draft standards and participate in the revision of existing European standards. The ESOs grant them various different further modes of participation. These include delegating observers to the technical committees and experts to the working groups.

Appropriate involvement of these social stakeholders has been a long-running issue, not least because European standardization is becoming increasingly political. The great EU objectives of strategic autonomy, technological leadership and the digital and green transformations require strong standardization and greater influence by the EU on standardization activity at international level. But what does this actually mean for civil society's stake in standardization, both at European and international level? Against this background, we intend to present the four organizations stated, in no particular order, in greater detail in forthcoming issues of the KANBrief. What specific opportunities do they have for participation at European and international level? What have they been able to achieve so far? Do they consider the European standardization system in its current form to be sufficiently inclusive?

Should you also have questions you would like to ask about these organizations or put to them, we would like to hear from you.


Angelika Wessels