Erhvervsudvalget 2019-20
ERU Alm.del Bilag 9
Offentligt
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NOTAT
23. september 2019
19/04931-6
The Danish Government’s response to the public consultation on the
Commission's proposal on a new guidance on the practical aspects of
the implementation of the European Standardisation Regulation
International standards are vital to the better regulation agenda
Denmark welcomes the opportunity to comment on the Commission's pro-
posal on a new guidance on the practical aspects of the implementation of
the European Standardisation Regulation.
The Danish Government is a strong supporter of the better regulation
agenda and acknowledges that the European Commission is likewise de-
termined to ensure that its’ proposals meet policy goals at minimum cost
and deliver maximum benefits to citizens, businesses and workers while
avoiding all unnecessary regulatory burdens. This is key to support and en-
sure competitiveness in the global economy and continued job growth in
the EU while maintaining social and environmental sustainability.
European standards, including harmonised standards, play a key role in
simplifying EU regulation and reducing burdens and costs for businesses
and is thus integral to the better regulation agenda. For this reason, Euro-
pean standardisation is an important tool in relation to the better regulation
agenda.
European standards replace potentially contradictory national standards in
Member States, thus decreasing burdens for businesses, especially SMEs.
Businesses are able to sell their products or services throughout the single
market with almost 500 million consumers without further customisation
through the use of the CE mark. European businesses can in general choose
to use a harmonised standard to document that their products to comply
with a given European law (presumption of conformity). Furthermore,
standards are regularly updated to include and disseminate new knowledge
and technology, which stimulates innovation and competition.
ERU, Alm.del - 2019-20 - Bilag 9: Orienteringsnotat om oplæg til nye rammer for udarbejdelse af mandater for de såkaldte harmoniserede standarder, der udarbejdes som led i fælleseuropæisk lovgivning for produkter
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For these reasons, it is essential that the European standardisation system
is able to keep pace with the technological development and that standards
continue to be a relevant, useful and attractive tool for European busi-
nesses.
Concerns about the proposed new guidance
The Danish business and industry sector have expressed concern that the
Commission’s
proposal on a new guidance on the practical aspects of the
implementation of the European Standardisation Regulation threatens to
undermine the efficiency of the current European standardisation system
and thus cause significant burdens to businesses across Europe.
The Danish government acknowledges the relation between harmonised
standards and European legislation but encourages the Commission to
maintain and respect the original division of roles within the New Ap-
proach. This division ensures that the Commission sets the overall goals
whereas participants from businesses and organisations are responsible for
developing and setting frames and requirements for the more specific and
concrete technical aspects of international standards.
The Danish government encourages the Commission to engage in a con-
structive dialogue with member states in order to work on a solution, which
does not undermine the European standardisation system.
It remains unclear how the new working methods and processes introduced
in the Commission’s new guidance will be implemented in the standardi-
sation system and what their implications might be.
Among other things, the following aspects are of special concern for the
Danish government:
Expiry dates
From a Danish perspective, it is problematic that all future harmonised
standards currently being developed are based on temporary mandates with
a fixed expiry date. In practice, this will imply that when the mandate ex-
pires, the standards covered by the mandate becomes invalid. This creates
general uncertainty about the status of the standard. It is crucial that there
are valid standardisation mandates on which standards can continuously be
ERU, Alm.del - 2019-20 - Bilag 9: Orienteringsnotat om oplæg til nye rammer for udarbejdelse af mandater for de såkaldte harmoniserede standarder, der udarbejdes som led i fælleseuropæisk lovgivning for produkter
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harmonised, developed, and revised. It is currently unclear what the conse-
quences are for the presumption of conformity with the relevant regulation
if a mandate for the harmonised standards expires. In addition, it remains
unclear what will happen with the standards. This needs to be clarified
moving forward.
Degree of detail
Mandates in the new format are very detailed and in some cases have in-
cluded very specific technical details or an exhaustive list. It is problematic
if the mandates become too detailed and rigid, as this might result in the
standards being irrelevant for industry to adopt. It is important to ensure
that there is a certain degree of freedom in the development of standards in
order to ensure market and consumer relevance.
The new set-up requires mandates to be developed for revision and updat-
ing of existing standards. Together with the introduction of expiry dates,
this will potentially create major pressure and work-load on the Commis-
sion and the standardisation system that will be very burdensome for all
stakeholders and potentially make international standards a less attractive
and effective tool for businesses.
Handling of formal objections
The Danish government would also invite the Commission to look into the
process regarding formal objections on specific standards. This should be
addressed which might be in the form of a more formal procedures and
deadlines in handling objections, to ensure an efficient and timely handling
of these.
Planning of meetings
The Danish government would also ask the Commission to take into con-
sideration optimal and efficient use of the resources of the members of
standardisation committees, when planning meetings regarding standardi-
sation. Specifically, the current approach to writing of eco-standards, where
one meeting covers several non-related issues cause considerable pressure
on national standardisation experts.