Internal Market: For a restored mutual trust in a market-relevant European Standardisation System

Published: 24 September 2019

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

Much of the activity of the technology industries represented by Orgalim is governed by EU-level harmonisation legislation - making these sectors major users of harmonised standards and important voluntary contributers to the European standardisation system, both in terms of expertise and financial resources. To support the application of EU law, the European Commission requests ‘harmonised standards’ that are made officially available for use following publication of their titles in the Official Journal of the EU (OJEU). However, in recent years the procedure prior to publishing these standards in the OJEU has become overly bureaucratic and legalistic, impacting the smooth operation of the Internal Market. 

For this reason Orgalim has responded to a Commission consultation regarding implementation of the Regulation on standardisation with a request for an independent assessment of the legal basis, proportionality and impact on stakeholders of the Commission’s formal decisions for the citation of harmonised standards in the OJEU. We  are calling on the Commission to launch a thorough discussion among the key stakeholders – including the European technology industries – to restore mutual confidence and trust in the European standardisation system, to bring value to and perspective for all parties involved.

In addition to answering the questions raised in the consultation, this position paper presents in an annex our detailed analysis of the Commission's role and responsibility at the various steps of the European standardisation process to support the application of EU law, from the standardisation requests to CEN, CENELEC and ETSI until the final checks of harmonised standards prior to their citation in the OJEU. We conclude by putting forward 15 constructive recommendations towards finding common ground on the legal prerequisites for the application of Regulation 1025/2012 on European standardisation.

Download the paper to read our comments in full. 

Authors

Portalier
Philippe Portalier
Director - Better Regulation, Compliance and Standards

Related Position Papers

Internal Market: Orgalim comments on the Draft Guidelines for the practical implementation of Article 4 of Regulation 2019/1020 on market surveillance and compliance of products [22 April 2020]

Internal Market: Shaping a New Deal for the Single Market: Harmonised standards in support of a competitive European industry [27 January 2020]

Internal Market: Suggestions for a revision of the Blue Guide on the implementation of EU product rules 2016 [27 January 2020]

Internal Market: For a restored mutual trust in a market-relevant European Standardisation System [24 September 2019]

Towards effective, efficient EU market surveillance: all for a level-playing field without additional burdens for legitimate manufacturers [6 December 2018]

For simpler compliance with and smarter enforcement of EU harmonisation legislation: Orgalime comments on the amendments of the European Parliament to the Commission proposal on Compliance and Enforcement [6 July 2018]

For simpler compliance with and smarter enforcement of EU harmonisation legislation: comments on the Commission proposal for a Regulation laying down rules and procedures for compliance with and enforcement of Union harmonisation legislation on products [5 April 2018]

Orgalime calls for improved enforcement of harmonisation legislation for safe and compliant products [21 February 2018]

Simpler and more effective market surveillance of products is urgently needed [21 September 2017]