KANBrief 2/15

Frequently underrated: informative elements in standards

Standards and similar documents are characterized in the first instance by their normative elements. The informative elements also contained in a standard however may not only considerably facilitate application and understanding of the document, but also enable the background to it to be presented, and its proper function within the body of standards, and where applicable also within the statutory framework, to be explained (Provisions on the presentation of standards and similar documents can be found in the ISO/IEC-Directives Part 2:2011, adopted in modified, trilingual form in the CEN/CENELEC Internal Regulations, Part 3:2011 and DIN 820-2:2012-12).

The normative elements include, firstly, the scope, which defines the topic, the content addressed, and the limits of the document's applicability. Beyond the scope, all provisions that must be satisfied in order for compliance with a standard (conformity) to be declared are of course also normative. Finally, any special national conditions and A-deviations – which where present are always relevant only for one particular country – are also normative (see KANBrief 2/15).

The informative elements are, besides the informative annexes, the foreword, introduction, notes and footnotes. Although compliance with all these elements is not required for satisfaction of the requirements of the document itself, the information they contain may be very important, for a number of reasons.

Information on the document's statutory status

A crucial characteristic of the European standardization system is its freedom from contradictions. This applies at individual Member State level, but also and in particular to the body of European standards. European standards must also be adopted unchanged by all CEN and CENELEC members. Any national standards in conflict with them must be withdrawn at the same time. This is the principle upon which the harmonizing function of European standardization is based.

Within the areas fully harmonized in legislation under the European Treaties (e.g. product safety, electromagnetic compatibility), European standards and statutory provisions are normally perfectly complementary. A particularly important informative element in this context are the Annexes Z of a standard, which cross-reference the normative provisions of the standard and the requirements of the relevant Single Market directives (presumption of conformity) (See KANBrief 1/2010).

In the areas not subject to full harmonization, a direct relationship does not normally exist between statutory provisions and European (much less international) standards. European standards may therefore have to be adopted in some cases in the national body of standards even though they impact upon the remaining regulatory freedom of the individual Member States. In the worst case, European standards may even contradict national legislation or bodies of subordinate regulations. In such cases, it is useful for the user to be provided with clarification of the status of a standard's content in the national foreword and where appropriate also in national footnotes.

Informative elements must not contain provisions

Informative elements must contain nothing that could be demanded at a later stage from users of the standard making a declaration of compliance with it.

The authors of a document must therefore ensure that everything required for conformity is contained within the normative provisions, whether requirements or merely recommendations. The sole and special exception are alternative requirements, which may also be contained in an informative annex, for example as part of an alternative test method.

Sadly, "provisions" on which a full consensus was not reached are sometimes formulated in the informative parts of a document. However, this not only impairs the coherence of the body of standards. Much more seriously, it also creates uncertainty: users of a standard could for example mistakenly accord the same status to passages stating requirements or recommendations in comments or informative annexes as to the sections that are in fact normative. Conversely, users of standards who – still in compliance with the rules – do not observe such sections could subsequently face the charge of having ignored publicly available expertise. Despite (or in this case, effectively because of) the informative nature of this content, this could then have unpleasant consequences.

In short, informative elements have considerable potential. They must however be formulated carefully, and read with equal care.

Corrado Mattiuzzo

mattiuzzo@kan.de