ERU, Alm.del - 2021-22 - Bilag 23: Notat samt høringssvar vedr. køreplan (roadmap) for kommende europæisk standardiseringsstrategi, fra erhvervsministeren

Erhvervsudvalget 2021-22
ERU Alm.del Bilag 23
Offentligt

The Danish Government’s response to the public consultation on a

roadmap for the upcoming standardisation strategy

The Danish Government welcomes the Commission’s initiative to

launch a horizontal standardisation strategy, that spans from a large-

scale strategic approach to global standard-setting to the technical de-

tails of working methods and processes within the European Standardi-

sation System (ESS).

The Danish Government agrees with the Commission that the ESS is a

cornerstone in the single market and that it must be agile, robust and

efficient to support the competitiveness of European businesses as well

as advance political priorities such as the green and digital transitions.

In this context, we strongly support the Standardisation Regulation, the

core principles of the New Legislative Framework and the public-pri-

vate partnership between legislators and industry that constitutes the

ESS. The Standardisation Regulation ensures that European standards

are built on European values of transparency, inclusiveness and consen-

sus-building.

The Danish Government appreciates that the Commission has taken note

of the concerns expressed by member states, including Denmark, and

other stakeholders regarding the current challenges facing the system of

harmonised standards.

In the following, we will address the 3 questions on which the Commis-

sion has requested feedback.

1. Is the current European standardisation system fit for purpose to

support European strategic interests?

The Danish Government believes that the problems identified in the

roadmap can be addressed without introducing fundamental changes to

the system, since the ESS and the Standardisation Regulation are essen-

tially fit for purpose. We believe the NLF is the best instrument to sup-

port European strategic interests through standardisation.

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This is not to say that the ESS is without flaws. Indeed, the system can

be improved, and with regards to harmonised standards there is an ur-

gent need to put the ESS back on track. While we believe that the pro-

posals in the roadmap’s section B (1) constitute a good starting point,

please refer to question 3 for our comments on governance and working

methods of the ESS.

As for services standardisation, the Danish Government looks forward

to the Commission’s analysis of the potential for standardisation for a

number of services, as outlined in the updated industrial strategy.

2. How can EU leverage and promote global leadership in stand-

ards-setting?

The Danish Government agrees with the Commission’s problem analy-

sis with regards to the protection and promotion of European values and

freedoms in global standard-setting on artificial intelligence and other

new digital/online technologies. Other actors on the global scene have

already mobilized in this area, and the Danish Government welcomes

the Commission’s initiative to launch a strategic and coordinated effort

to ensure the EU’s role as a standard-setter

rather than a standard-taker.

In addition to a focus on areas of strategic importance to the EU, a co-

ordinated approach can promote the “European signature” on interna-

tional standardisation, i.e. values such as inclusion, transparency safety,

environmental protection etc.

Of course, the EU will be better equipped to influence standardization

on the global level, if the ESS is well-functioning, robust and agile.

Therefore, it is important that these different dimensions of European

standardisation are addressed jointly in this strategy.

3. Are changes in governance and working methods required to im-

prove the performance of the European standardisation system?

The Danish Government believes that the performance of the ESS can

be improved through changes in the working methods of the system,

particularly in the processes within the Commission services and the re-

lations between the Commission and other parties and stakeholders in-

volved in standardisation activities. We believe that the current prob-

lems in the system of harmonised standards can be solved with adjust-

ments at the working level through a truly collaborative effort without

any fundamental amendments to the legal framework for European

standardisation.

The problems regarding harmonised standards are of particular concern

to the Danish government. The current challenges are rooted in a Com-

mission decision to regard all harmonised standards as European law,

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based on an ECJ ruling on construction products, which is not men-

tioned in the roadmap. Since this decision has given rise to criticism and

confusion, it would be useful if the Commission could elaborate on its

interpretation of the ECJ ruling and its implications as part of the stand-

ardisation strategy.

The Danish Government welcomes the Commission’s intention to de-

velop a closer cooperation between national standardisation bodies, the

European industry, European standardisation organizations and the

Commission. We believe that an inclusive dialogue and joint solutions

are vital to addressing the bottlenecks within the ESS. In this respect, it

is encouraging that the joint task force between the Commission, CEN-

Cenelec and ETSI is already up and running to tackle these issues.

The Danish Government finds that the initiatives outlined in the

roadmap are good starting points and recommends that the Commission

reports to the Committee on Standards (CoS) on the progress, using key

performance indicators (KPIs).

The problem definition in the roadmap’s section A (2) mentions the pre-

scriptive standardisation requests and delayed citation, but it is im-

portant to add that a lack of clear criteria for approval contributes also

to delays. Streamlining Commission practices, so that the same clear

criteria are applied across different Commission services will increase

the chances that standards fulfil the quality requirements and reduce de-

lays. An efficient standardisation process requires clear criteria for the

approval of harmonised standards by the Commission and subsequent

citation in the Official Journal of the European Union

–

without delay,

as it is phrased in the Standardisation Regulation. It is our hope that the

efforts proposed in the roadmap will also lead to a better solution with

regards to the format of standardisation requests, e.g. by introducing

some element of flexibility without compromising legal certainty. These

suggestions were part of the member states’ non-papers

on harmonised

standards, which were also directly referenced in the roadmap.

The Danish Government is looking forward to working with the Commis-

sion and other stakeholders to make sure European standardisation can

reach its full potential and stands ready to contribute throughout the pro-

cess.