COMMENTS AND STATEMENT PAPER ON THE PUBLIC CONSULTATION ON THE REVIEW OF THE EUROPEAN STANDARDIZATION SYSTEM (ESS) BY THE EUROPEAN COMMISSION

Antwort für das Portal der EU-Kommission:   http://ec.europa.eu/enterprise/policies/european-standards/public-consultation/non_registered_organisations_de.htm

Auszug aus der Stellungnahme:

Final Conclusions

From our perspective the revision of the legal framework in Europe should neither put the basic principles of the European standardization system nor the approved and established structures in the Member States into question. Rather, it is within the system a main target to develop profound solutions and additionally addressing clearly and transparentely the challenges for the standardization policy of the future. It must be also of high priority to address the special needs of SMEs within the reform ideas. All together, they participate actively in the development of setting technical standards. This effectively proven way has for our understanding to continue.

1. It would be a highly appreciated by a vast number of SME to promote, advance and create a limited number of basic standards which can be further improved and if necessary conduct corrections. In many cases the canon “More is less” might also help to apply standards properly and easily than the inflationary development of standards projects. Standardization must reflect the state of the technology and not the State of research where substantiated results are still missing. The state of research and science may never set the basis for standards. Only the state of technology can provide a practical application for the end user. It is therefore crucial to limit standardization to a minimum and its essential function to promote competitiveness, provide specifications for the benefit of all market players and to ensure high architectural quality.

2. Subsidiarity as a main principle of the EU means in the field of standardization to display levels which are suitable and capable to administrate the coordination and the formation of opinion. By the national delegation principle the European standardization system this claim is perfectly embedded: The decentralized organisation of the European standardization work enables also representatives of SMEs to participate in the European standard development. Without language barriers professionals of SMEs can use "mirror committees" at national level to contribute with their expertise and technical knowledge directly to the standardization process. In Germany, more than 28 000 experts work actively within in the bodies of the DIN. The elimination of national platforms for instance would directely lead to the result that European standards meet less and less national requirements and cause considerable legal uncertainty for the majority of the economic actors.

3. In the context of the convergence program FLES3 the process of a close cooperation of the European standardization organisations among each other, for instance by harmonization and alignment processes, the joint use of infrastructure and personnel – e. g. merger of the General Secretariats of CEN and CENELEC - should be pursued consistently.

In view of the existing fora or consortia in some industry sectors in which specifications with global relevance and influence outside of the traditional Standardization processes are developed the European standardization system must develop better ways and mechanisms of interaction. In any case, an uncontrollable competition between the European standardization organisations, forums and consortia have to be avoided, otherwise a fragmentation and inconsistency the European standardization will take place. Needs of SMEs and social groups could not be considered sufficiently. In our opinion standardization organisations are the most adequate bodies to participate within fora and consortia. Therefore, the Commission should focus on how a suspected fragmentation by fora and consortia can be avoided and its clear commitment to be involved within the standardization structures. The formal process of standardization, in which the principles of openness, participation, transparency and coherence finds full attention and of a consensus between all national positions and interested circles must remain the first choice and must be further developped.


Aufgestellt: Barbara Chr. Schlesinger/Thomas M. Haas 7^th May 2010 BAK-Berlin/Brüssel