KANBrief 3/10

Evolution rather than revolution

The European Commission and the Council are seeking to reform the European standardization system (Communication COM(2008) 133 final, 11 March 2008; Council conclusions of 25 September 2008). The system should be better able in future to respond to innovative developments and to support the competitiveness of companies. For this purpose, the standards organizations should revise their business models and gear the system more closely to the needs of small and medium-sized enterprises (SMEs)..

In 2009, at the request of the European Commission, the Expert Panel for the Review of the European Standardisation System (EXPRESS) issued a series of recommendations on the basis of which the European standardization system should be revised. Certain options were subsequently presented by the European Commission for discussion during a public consultation in the spring of 2010. These options however extend far beyond the proposals of the EXPRESS group. One consequence of this has been strong criticism from DIN (DIN-Mitteilungen, March 2010, article Dr. Bahke „European standardization system under threat“ (in German)).

In the view of the stakeholders represented in KAN, the existing system should indeed be optimized, but its integrity should not be placed in doubt by the creation of new structures. KAN therefore lobbies for points including the following:

  • Legal instruments and public measures which affect the safety of products or workplace safety and health should not make reference to any documents developed by fora or consortia. Consortium documents (even where produced under the auspices of the European standards organizations) are not suitable for this purpose, since the scope for participation is limited and they are not based upon a full consensus.
  • Financing of standardization should not be linked to conditions such as swift completion of the work. Such a measure would result in an excessive increase in the bureaucracy associated with financing. The time pressure upon the standards committees, which is already high, would increase even further. It may be feared that in consequence, standards would increasingly contain results which are not mature. Although rapid processes are desirable, they should not be achieved at the cost of the consensus and of quality, since the results could impair safety.
  • The impression should not be given that national and European standardization are in contradiction to each other; on the contrary: they complement each other exceptionally well. National standardization activity and the principle of national delegation ensure that a broad base of stakeholders are able to participate in the standardization process in their native languages. This would otherwise be difficult.
  • The addition of institutions to the standards organizations already recognized, i.e. CEN, CENELEC and ETSI, would make it harder to implement the principle of national delegation. In addition, the freedom from contradictions of the European standardization system would be at risk if Europe adopted the American approach and multiple standards organizations existed which could not be co-ordinated effectively. For the development of standards in support of EU legislation, the issuing of invitations to tender by the European Commission to other organizations would not therefore be beneficial. It would also inevitably result in greater bureaucracy.
  • The European Commission should develop a procedure for exceptional cases in which the standards organizations have declined a mandate or have failed to present a result despite having received a mandate. This procedure should be accorded legitimacy on a case-by-case basis, for example by the Committee under Directive 98/34/EC or a special directive.

A key question of the consultation was how the stakeholders can be involved effectively in the standardization process. In their comments, the German government and DIN cited the model of KAN as a good example of how this can be achieved without the underlying principles of standardization being placed in question.

Following consideration of the numerous comments in response to the public consultation and an impact assessment, the Commission is expected to present the Council and the Parliament with a proposal for the new “standardization package” in autumn 2010.

Corrado Mattiuzzo
mattiuzzo@kan.de