Internal Market: Criteria for common specifications

Published: 27 September 2022

Policies & Issues: Internal Market - Compliance, Standards & Enforcement

Orgalim, Europe’s Technology Industries, represents manufacturers in a dynamic and competitive sector that relies heavily on the success of European Union harmonisation legislation. Our industries’ experts drive the work on state-of-the-art standards within the European Standardisation Organisations (ESOs) to develop the technologies which enable the EU’s digital and sustainability objectives. The efficient functioning of the European standardisation system is a key priority to deliver these objectives.

The European Commission stated in the Standardisation Strategy of 2 February 2022 that common specifications – also designated as ‘technical specifications’ in some pieces of EU harmonisation legislation – should be treated as a fallback solution to ensure that the public interest is served, based on the development of a horizontal approach for the establishment of common specifications. We remain convinced that harmonised standards are the best and most effective tool to support harmonised legislation. We are doubtful that common specifications developed outside the well-established and recognised processes for standardisation would successfully achieve the desired result and could be implemented in a workable and competitive way.

Our experts feel strongly that the empowerment of the Commission to draft common specifications should be used with the utmost caution to avoid undermining the Standardisation System, which is, and should remain, market driven, i.e. relevant for use by economic operators. Therefore, we support the initiative of developing a horizontal approach for the establishment of common specifications.

Orgalim has developed a list of horizontal criteria to govern the development process and ensure the applicability of common specifications which we hope will constructively contribute to the dialogue between the EU regulator and the end users of such specifications and ensure that the procedure for the new framework remains inclusive and consensus-based.

We suggest that the Commission considers amending Regulations where these specifications are already provided for to align with the horizontal criteria once they are developed.


To read our recommendations in full, please download the document above.


Le Goff-Jedrzejowicz
Helena Le Goff-Jedrzejowicz
Adviser - Internal Market

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