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Europaudvalget 2009-10
EUU Alm.del Bilag 385
Offentligt

NOTE

Response from the Danish Government to the public consultation on

the review of the European Standardisation System

The Danish Government generally supports a review and evaluation of

the existing European standardisation system since there could be a need

for updating and adapting the legal framework and the standardisation

process in light of new demands and opportunities in a globalised world

with comprehensive technological developments. A service check of the

standardisation system is also in line with the initiatives envisaged by the

Commission in relation to the Commission’s EU2020 Strategy, which

aims at creating framework conditions and provide a basis for future

growth and employment in Europe. In addition, it is the government's

position that standardisation could be an important tool in implementing

public policy and avoiding barriers to trade in a global world. In a possi-

ble revision of the European standardisation system, it is crucial to main-

tain the national delegation principle, improve the efficiency of the Euro-

pean standardisation organisations, and to ensure an open and transparent

standardisation system in which all stakeholders, including consumers,

have the opportunity to participate in the standardisation process.

Standardisation could furthermore be an important tool in cases where

EU-regulations (in shape of e.g. new approach directives) should be filled

out with more detailed specifications. However, in line with decision

2008/768/EC the application of the new approach – and thereby standard-

isation – can be waived in order to ensure adequate consumer protection,

public health and the environment or other aspects of public interests

where it is more appropriate to set out the essential and detailed require-

ments in the Community harmonisation legislation concerned. Due to

earlier experiences with the use of the new approach in the area of envi-

ronment it is important that the environmental objectives and require-

ments are determined in a political process.

Q1: Do you think that service standards (including process standards)

and alternative standardisation documents should be included in the

scope of Directive 98/34/EC or its successor?

In order to ensure the free movement, service standards should be includ-

ed in the scope of Directive 98/34/EC or its successor. Standardisation

could be an important policy instrument to support the development of an

internal market for services. As for alternative standardisation documents,

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however, there might be obstructive difficulties in establishing notifica-

tion requirements followed by a standstill procedure.

Q2: Are you aware of specific cases where national service standards

and alternative standardisation documents have caused technical barri-

ers to trade?

National standards can have a counter-competitive effect in service sec-

tors operating on a global market, e.g. maritime services. Hence, stand-

ards in sectors operating on a global market should be international/ glob-

al in order to establish fair competition as well as similar costs for busi-

nesses across borders and regions.

On behalf of the Danish Enterprise and Construction Authority, Tech-

nopolis (a British consultancy company) is currently carrying out an

analysis and preparing a report on the state of affairs regarding standardi-

sation in services in selected countries. The report is due in June 2010.

When the results are published, the conclusions may provide further im-

portant information, e.g. regarding barriers for service standardisation.

Q3: For areas other than Information and Communication Technology

(ICT), should it be possible to refer to documents developed by fora and

consortia in legislation and public policies? If it should, how should it be

implemented?

Direct reference to documents that are not implemented in the European

Standards Organizations (ESOs) should not be pursued, in particular not

for areas outside the ICT area. The strength of the European Standardisa-

tion System is the coherence and cohesion of the system and the openness

to all stakeholders according to the WTO principles. Documents devel-

oped by fora and consortia should when necessary be implemented by the

ESOs, and hence not referred to independently as documents with specif-

ic status of their own. However, more emphasis on cooperation between

the ESOs and fora and consortia could be pursued, given that the views

and interests of all stakeholders, including consumers, are taken into ac-

count.

Q4: How could ESOs and NSOs be encouraged to accelerate their stand-

ards development process? Should for example the Community financing

for standardisation be subject to conditions in terms of speed of delivery

whilst maintaining the openness of the process?

Speed of delivery is of great importance. ESOs and NSOs should contin-

uously be encouraged to develop and improve their working methods,

tools and processes in accordance with the needs expressed by stakehold-

ers, e.g. through professional support to technical committees and in-

creased use of ICT opportunities. It is, however, important to balance

speed against transparency, consensus and quality.

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Furthermore, it is of great importance to ensure that the Commission’s

mandates to ESOs are precise and sufficiently specific, in particular with

regards to environmental specifications in NLF-directives. Speed of de-

livery should be monitored and benchmarked in order to provide and dis-

tribute best practices across standardisation committees and sectors.

Q6: Should the WTO principles of transparency, openness, impartiality,

consensus, efficiency, relevance and consistency be integrated in the le-

gal framework of European Standardisation (especially in EU Directive

98/34/EC or in its successor)? How should this be implemented?

The WTO principles may be integrated in the legal framework. If the

principles are integrated, specific rights for stakeholders to participate

should be emphasized and explicated further.

Q7 (1): How could the participation of consumer organisations, envi-

ronmental NGOs, trade unions and social partners, and SMEs be best

promoted? What should be the role of public authorities (European

Commission and Member States) in supporting such a participation in a

transparent, open, impartial, consensual, efficient, relevant and con-

sistent European standardisation system?

National (mirror) committees provide the best platform for the participa-

tion of stakeholders with limited resources. The role of national public

authorities should first of all be to support the stakeholders with limited

resources, so that they can participate in the standardisation processes.

Furthermore, national public authorities should when relevant participate

directly in the European standardisation process. In countries in which

national stakeholder participation is low, it may be necessary to assure

and support further stakeholder involvement at the European level.

Q7 (2): How should NSOs (National Standards Organisations) deepen

their cooperation, and mutualise their activities? Could the following

tasks be shared amongst several NSOs?

1. Management of the Secretariats of Technical Committees?

2. Notification of new national standardisation projects?

3. Promotion/sales of standards?

4. Other?

The NSOs already cooperate and share knowledge and best practices.

More systematic use of benchmark studies may enhance the dissemina-

tion of best practices, but at the same time it is important to notice that

the NSOs are adapted to their local markets and conditions.

Q8: Without prejudice to the national delegation principle, how could the

European Standards Organisations (ESOs) manage directly, on a case by

case basis, some standardisation activities, especially some Technical

Committees?

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That should be for the ESOs to decide and manage.

Q9: What support should the European Commission provide to facilitate

the use of European standards as a means to open global markets? What

would be the operational means that the Commission should use? (Sup-

port experts’ participation in international standardisation activities,

translation of European standards into extra-community languages?)

The Commission should promote standardisation as a common policy

tool in international trade negotiations and agreements, and through regu-

latory dialogue with third countries, e.g. in the TEC (Transatlantic Eco-

nomic Council). Furthermore, the Commission has an important task in

ensuring global implementation of international standards.

Q10: Under which conditions do you think the European Commission

could launch, on a case by case basis, calls for tenders, open to the ESOs

and to other organisations, to develop standards supporting EU policies

and legislations?

This is not a sustainable method. The European standardisation system is

coherent due to the fact that initiatives are handled in one coordinated

system. It is of utmost importance to ensure an open and transparent

standardisation process and to ensure the participation of all stakeholders,

including consumers.

Q11: What is, in your view, the most efficient level of participation in the

process of standards development: national, European, international?

All three levels of standardisation have their advantages: National

standardisation is relevant for specific and local needs and for

coordinating positions and input for the European and international level

while European standardisation provides support for EU legislation and

helps to reach the goals of the Single Market, i.e. free movement of goods

and services etc. Finally, international standardisation enables a common

understanding at global level, which could be implemented into regional

and local standardisation, and thereby limit the number of national

deviations at the global market place.

Q12: In your opinion, where is the major added value in European

standardisation with respect to national standardisation?

The major added value in European standardisation with respect to

national standardisation is to help eliminate barriers to trade within the

internal market.

Q13: What are, in your view, the most serious barriers to the use of

standards by enterprises: costs of standards (purchasing price)? Costs of

operational implementation? Access to information? Knowledge of exist-

ing standards?

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In general there is not sufficient knowledge about the possible economic

gains that the application of standards can provide for the specific com-

pany (especially in SMEs).

Furthermore, the costs of updating and implementing the standards are

burdensome, in particular for SMEs. Businesses, in particular SMEs,

must have access to standards at a reasonable price and, if necessary ac-

cess to assistance in order to understand them and implement them cor-

rectly. Standardisation organizations could provide further knowledge to

SMEs, i.e. through clear communication, e.g. easy-to-read handbooks,

guidelines, etc.

Q14: What could the standards organizations do, in addition to their cur-

rent practice, to facilitate the access to standards, especially by SMEs?

See answer to Q13.