SBS comments on the future European Standardisation Strategy

SBS comments on the future European Standardisation Strategy

Key points

• The standardisation Strategy should aim at improving the system for the development,
assessment, and citation of harmonised standards. The blocking factors for the citation of
harmonised standards should be solved by defining clear roles for all actors within the
standardisation system and criteria for the assessment of harmonised standards. Future needs for
standardisation should also be better anticipated.

The improvement of inclusiveness at national, European and international levels should also be
addressed. Although there have been considerable advances towards inclusiveness there is still
room for improvement to ensure effective participation of stakeholders and Annex III organisations
at the European level. Inclusiveness at the international level remains an important challenge that
should be addressed since European standards are increasingly being developed at the
international level.

• Rather than looking for alternatives to the existing system, the European Commission should
continue supporting the capacity building in the ESOs to deliver more home-grown standards.

The European Commission should support the development of tools for the monitoring of
standards. Being able to identify those standards that are particularly relevant for SMEs is a
prerequisite to be able to represent the interest of SMEs and to be further involved in

The ambition to increase the European influence in international standardisation should also be
accompanied by the necessary resources. A system for coordination among the different national
and European stakeholders should also be put in place. Already existing European SME networks,
such as the one provided by Small Business Standards (SBS) should also be used.

• SME friendly standards are essential for a successful twin transition. The Commission should help
to promote existing tools to achieve this objective, such as the CEN-CENELEC Guide 17 or the SME
Compatibility Test for standards developed by SBS.

The future strategy should also focus on the uptake of standards and not only on the prenormative and standards development phases.
Funding and support schemes should be available to help SMEs with the implementation of standards. SMEs associations, such as SBS are also well
placed to support the development of practical guides supporting the implementatiton of standards. The availability of standards in the national language and special favourable pricing
schemes for SMEs are also important to this respect.

• From the perspective of SBS, there is no need to revise the standardisation Regulation
(1025/2012). There is rather the need to implement its provisions effectively.



The Communication on an updated Industrial Strategy presented by the Commission in May 2021, included
as one of its key actions the development of a Standardiation Strategy for the third quarter of 2021. The
Commission has also recently published a roadmap asking for feedback on the future standardisation
Strategy to stakeholders.

Small and medium-sized enterprises (SMEs) can significantly contribute to achieving the EU economic
recovery and digital and green transition goals outlined in the above-mentioned Communication. SMEs
represent most of all EU businesses and are essential to ensuring economic growth, innovation, and job
creation in Europe. But to do so, it is essential that the right environment, also concerning standardisation,
is created. Therefore, it is key that the interests and needs of SMEs are fully considered in the future
standardisation Strategy.

Improving the development, assessment, and citation of harmonised standards

The roadmap points out that the main goal of the future standardisation Strategy is to consolidate and
improve the European standardisation system. In this context, one of the most important aspects the
strategy will need to focus on is the improvement of the system for the development, assessment, and
citation of harmonised standards. This is essential for the well-functioning of the Single Market, Europe’s
recovery and competitiveness. Timely delivery of standards is also fundamental if Europe is to reach the
objectives it has set in relation to the green and digital transitions.

Harmonised standards are extremely important, especially for SMEs. To be able to keep their
competitiveness and scale-up, SMEs need up to date standards that allow them to benefit from the
presumption of conformity with EU legal requirements. SMEs normally have more limited financial and
other resources than larger companies. Therefore, they heavily rely on the availability of standards to show
the conformity of their products with EU legislation, since using an alternative to standards would often be
too costly for them.

In recent years, major issues have emerged linked to the assessments of harmonised standards and their
referencing in the Official Journal of the EU (OJEU). While the situation varies from sector to sector, major
concerns are particularly prevalent in some areas such as in the construction sector, notably following the
decisions of the James Elliott court case (ECJ, C-613/14). This situation has led to a slowdown and, in some
cases, a stop in the technical work of some Technical Committees within the European Standards
Organisations (ESOs) and the citation of harmonized standards. The effective implementation of the
standardisation strategy requires that the blocking factors of the harmonised standards citation are
resolved, and regulatory certainty is re-established. To achieve this, it is important that:

• All actors- European Commission, European standardisation Organisations, industry and all other
stakeholders- within the European standardisation system work together to ensure there is a
common understanding of the role of each of them. The setting up of the joint task force between
the Commission and the European standardisation Organisations is a step in the right direction.

• The standardisation strategy confirms and reinforces the New Approach/New Legislative
Framework (NLF). This approach has been central to the achievement of the Single Market and to
the provision of a flexible framework allowing to cope with technological developments.

• Clear objectives for the timely delivery and citation of standards are specified and measured. This
should help to evaluate progress and identify areas for improvement.

• Clear and stable criteria for the evaluation of harmonised standards are developed so that delays
in their development and subsequent citation are avoided. While we acknowledge the
Commission has certain responsibility and a role to play in relation to initiating and checking that
harmonised standards are fit for purpose, there must be a stable and clear criteria against which
the standards are assessed. It is also important that there is a common understanding and
harmonised views on these criteria from all the relevant stakeholders: experts, Harmonised
Standards (HaS) consultants and Commission desk officers.

• It is also important to better anticipate future standardisation needs to support the
competitiveness of our companies at the European and international levels. This should also include
possible new standards related to new legislative proposals. In this respect, it is also important to
keep SME needs in mind.

Increasing inclusiveness at the national, European and international level

Inclusiveness is a key principle of Regulation 1025/2012 and the European standardisation system. SMEs
represent the core of Europe’s economy and are potentially the biggest user of standards, it is, therefore,
essential to ensure they are around the table when developing standards. Nevertheless, SMEs and
especially micro-enterprises cannot always play a leading role in developing standards and may find it
difficult to get involved in standardisation processes. This is due to many factors such as lack of awareness or lack of resources (technical, financial, language…).

Although there have been considerable advances towards inclusiveness (especially in the case of CEN and
CENELEC) there is still room for improvement. Moreover, European standards are increasingly being
developed at the international level, which represents an additional challenge forthe participation of SMEs.
The future strategy should propose actions to improve the de facto inclusiveness, by ensuring solid
support to the further enhanced participation of SMEs in the standardisation process at the European and
international level.

Increasing further SME participation at the national level is essential to be able to shape European and
international standards. The role of professional organisations is key to bridge the gap between SMEs and
standardisation and represent the collective interests of SMEs in a specific sector. SBS through its members
has been very active in trying to raise awareness and encouraging participation at the national level
through, for example, the organisation of national seminars. Some National Standards Organisations
already have in place measures to facilitate the access of SMEs to the standardisation work, and it is
important to share best practices in this regard through for example the CEN-CENELEC SME Working Group.
In addition to the lack of awareness, another important obstacle to the participation of SMEs is the
availability of resources. To this respect, national governments support for the participation of SMEs and
SME associations in national standardisation is key, for example, by providing financial support.

At the European level, there is a need for the ESOs to evaluate their internal regulations and current
practices to further ensure the effective participation of all stakeholders including Annex III

ETSI has set up the 3SI programme as a vehicle to implement and promote inclusiveness. The 3SI
programme should drive forward inclusiveness through concrete proposals, for example, to anchor the
programme in ETSI directives and attribute more rights to take Annex III organisations’ input into account
(i.e., the right to directly comment on European Standards under Enquiry instead of commenting through
the National Standards Organisations). To implement inclusiveness-related issues, there is however a need
for concrete projects or concrete activities (workshops, events, trainings, etc.), so that ETSI could truly reach
out and provide services to a larger SME community. ETSI has so far not dedicated substantial resources
and budget to increase its inclusiveness. Therefore, the European Commission should consider tying future
funding to concrete achievements around inclusiveness.

Regarding CEN and CENELEC some areas could be looked at to further improve and ensure the effective
participation of SMEs in standardisation work. For example, experts participating in technical bodies
drafting standards do not always have automatic access to the normative references used in the standard
under development. This situation may also apply to any organisation or SME wishing to submit comments
during the Enquiry at the national level. Purchasing the normative references is very costly and not having
access to these external standards makes it often difficult to fully understand the content of the standard
and effectively participate in the process. This is a problem that is faced by SBS experts during their work in
Technical Committees and Working Groups.

Moreover, although SBS as a partner organisation can participate in the governing bodies of CEN and
CENELEC and submit comments on proposals, comments from Annex III organisations are just made
available to all the National Standards Bodies once the vote has already been cast (e.g. on the creation of a
new Technical Committee, on the adoption of international standards in the case of no corresponding
European Technical Committee). Further consideration should be given to reinforcing the rules around
the consultation of weaker stakeholders so that their opinions are duly considered in the process.

Effective participation in standardisation work at the international level continues to be a major
challenge. The conditions to participate in the development of international standards are different from
the European ones, especially concerning access for Annex III organisations. At ISO and IEC, to get access to
documents and fully participate in Technical Committee and Working Groups meetings, a liaison agreement
needs to be set up. This procedure takes several months and depends on the positive vote of the members
of the Technical Committee. As a result, SBS may lose the opportunity to contribute to key phases of the
development of the standard. Moreover, contrary to the European level SBS cannot participate in the
governing bodies of ISO and IEC and is not always aware of new proposals for new fields of standardisation.
To improve the situation, we propose to:

Improve the availability of information. Information on proposals for the creation of new
Technical Committees should be made available on the ISO and IEC website in the same way they
publish other information (e.g. ISO update). This could help SMEs and other stakeholders to flag
new initiatives and proactively contact their National Standards Bodies and get involved in the
process from the beginning.

Evaluate the possibility to simplify the procedures related to liaisons in technical committees. If
an organisation already has a liaison with a Technical Committee and has passed the pre-screening
from the ISO/IEC Central Secretariat access should be granted automatically.

Designate a specific person within ISO and IEC (preferably at the level of the governing bodies)
dedicated to champion the participation of SMEs and societal stakeholders in the standards
development process and act as a facilitator of inclusiveness.

Finally, standardisation organisations at the national, European, and international levels should make the
most of digital technologies beyond the COVID -19 crisis to facilitate participation in meetings and
support the use of online authoring systems. Digital solutions may potentially help further the involvement
of SMEs by facilitating their participation in the standards development process. Although physical
meetings continue to be important and have many advantages, online meetings have removed several
major thresholds for SME participation, including the cost and time required for travelling, which can be
rather important especially in relation to international standardisation. It is important to find the right
balance between the number and format of meetings to facilitate the participation of all stakeholders.

Finally, there is also a need to enhance the participation of Annex III organisations in the strategic
discussions related to standardisation and the European standardisation system taking place between
the European Commission and the ESO.

Improving access to information and monitoring of standardisation work

The number of standards developed or revised each year is constantly increasing. Considering the variety
of sectors in which SMEs are involved and the increasing number of standards, it is important to develop
efficient tools for the monitoring of standards. Being able to identify those standards that are particularly
relevant for SMEs is a prerequisite to be able to represent the interest of SMEs and to be further involved
in standardisation.

There is a lot of information available online (new work items, work items under Enquiry, under Formal
vote, etc.). This overflow of information without filtering or being structured in an easy way leads to a de
facto lack of information amongst SMEs. Currently, there are some projects at the national level, e.g., led
by DIN in Germany, to develop tools to facilitate the monitoring of standardisation developments relevant
to SMEs in a sector. The European Commission should support the development of a similar monitoring
system at the European level, in collaboration with the ESOs, as a one-stop shop for the monitoring of
standardisation related developments.

The monitoring of developments at the international level is even more challenging. This system should, if
feasible, ideally be extended to the international level. Ensuring accessto the right information at the right
time about developments at the international level is essential for safeguarding European SME interest
in international standards.

Increasing European influence in international standardisation


The Commission Roadmap refers to the need for coordination of European stakeholders and available
resources to ensure that international standards meet European needs and values. SBS agrees with the
need to have a more strategic approach to ensure the influence of European stakeholders at the
international level. Nevertheless, the ambition to increase the European influence in international
standardisation should also be accompanied by the necessary resources. Participation at the international
level implies additional resources due to, for example, the additional cost and time required for
international travel. As a result, the participation of European stakeholders and SMEs is insufficient at the
international level. It is therefore essential that the European Commission provides additional financial
support to ensure the representation of SMEs at the international level.

But as important as the availability of resources it is the need to ensure appropriate coordination
between the different national and European stakeholders. There is a need for overarching strategic
coordination among Europe’s industrial stakeholders and with the different governments. The European
Commission could evaluate the appropriateness of using existing structures, such as the Committee on
Standards or the European Multi-Stakeholder Platform on ICT standardisation, or of creating a new one to
ensure coordination at the European level. Regarding SMEs, it is important to use already existing
networks, such as the one provided by SBS and its members, to understand the European SME needs and
interests, setting goals and agree on strategies on how to achieve those goals within international
Standards Developing Organisations (SDOs).

Developing SME compatible standards in support of the twin transition

Standards will be essential to support the uptake of new digital technologies and more sustainable
products. Access to data is a key element for SMEs. Standards should ensure interoperability and that
access to data is technically possible. Standardised data formats and interfaces that ensure access to data
are a precondition to enable faster innovation by independent companies, in particular SMEs and start-ups.
Ensuring connectivity between different systems is also essential to SMEs. Interoperability-by-design offers
the possibility to connect systems from different providers, which is crucial for platforms in many industries,
such as the automotive or energy sectors. Interoperability and the development of open standards (in
contrast with proprietary solutions) are also a safeguard against vendor lock-in. The development of
standards to ensure interoperability contributes to an important industrial objective that is a free and
sovereign ICT sector, by which Europe can grow its own innovation champions to counter vertically
integrated big players.

Access to data and information is also essential in the context of a more sustainable and circular
economy. This is important so that we do not have obstacles to repair, refurbishment and upgrading for
independent suppliers and service providers. Only if independent companies that perform repair and
maintenance services have access to the products’ data, we can have a competitive secondary market,
where many SMEs can thrive and drive economic growth and employment, with consumers spending less,
and products’ lifecycles extended. It is important to keep this aspect in mind when developing standards to
ensure that they enable, rather than hamper the sharing of information.

But to achieve the digital and green transition, it is also essential that standards are written with SMEs in
mind because it will not be possible to have a successful recovery and twin transition without them. The
European Commission must encourage the SDOs to develop standards that are SME compatible in terms
of content and fair costs and that support the use of existing tools such as the CEN-CENELEC Guide 17
Guidance for writing standards taking into account micro, small and medium-sized enterprises (SMEs) needs
or the SME Compatibility Test for standards recently published by SBS. Making standards more
SMEcompatible can only lead to better uptake of standards amongst smaller businesses.

Finally, from the point of view of SMEs, it is important to avoid the proliferation of standards. When new
topics emerge, e.g., circular economy, sometimes there is a tendency to immediately create new standards.
It is not always easy for SMEs to have an overview of what exists and what standards can be used.
Sometimes there are gaps and new standards are needed but sometimes the right standard already exists
and/or there is just the need to adapt existing standards to consider these new aspects rather than
creating new ones. This aspect must be carefully considered both when issuing standardisation Request to
the ESOs and during the development of standards by Technical Committees.

Cooperation with fora and consortia

In the last years, there has been an increase in the number of fora and consortia developing specifications
outside the European standardisation system, especially in some sectors characterised by rapid
technological developments such as ICT. There is a risk that this model may be extended to other areas in
the future.

For SMEs, it is not easy to have an overview of all standardisation activities and what already exists and
what standards can be used. Moreover, while the European standardisation system needs to operate
within the framework of a clear set of principles established by Regulation 1025/2012 such as openness,
inclusiveness, consensus and transparency, this framework does not apply to specifications developed in
fora or consortia. Extending this model to other areas may lead to increased difficulty in raising awareness
and involving SMEs in the development of standards due to the more limited resources available to SMEs.

Rather than looking for alternatives to the existing system, the European Commission should continue
supporting the capacity building in the ESOs to deliver more home-grown standards. The ESOs have also
put in place mechanisms to cooperate with existing fora and consortia (e.g. oneM2M) and in this way
respond to emerging needs. These efforts should continue. Only in exceptional and duly justified cases,
recognition of standards developed by fora and consortia may take place and as long as there is proof that
European and SME and other interests were duly taken on board.

Supporting the implementation of standards

The roadmap highlights the need for action in relation to the pre-standardisation activities. From the point
of view of SBS, the future strategy should also focus on the uptake of standards, especially among SMEs.

The use of complex standards remains a challenge for SMEs, which hinder their ability to competitively
provide their services. This is especially important concerning the use of new technologies. Most SMEs need
assistance and training on the application of standards and adapting those to their specific needs. As most
SMEs suffer from limited resources, they need adapted instructions and practical guides to help with the
implementation of standards. Funding and support schemes should be available to help SMEs with the
implementation of standards. SMEs associations, such as SBS are also well placed to support the
development of such guides as they have already done for example on the ISO 26000 standard on social
responsibility, the ISO/IEC 27001 standard on IT security management or the recent Guide on Industrial
Internet of Things.

In this context, it is also important to consider the cost of acquiring the standard (when they are not
available for free as in the case of ETSI). This is not only related to the cost of the standard itself but also
the cost of all the normative references included in the standard. For example, it has been estimated that
the cost of buying the normative references in EN 81-20 amounts to approximately € 5,000 in addition to
the cost of buying the standard itself. It is important to develop pricing schemes that provide special more
favourable conditions for SMEs.

Furthermore, being able to access documents and standards in their language is an important aspect for
SMEs to be able to benefit from them and participate in the process. In some countries for reasons of
simplification and speeding up the process of making the documents available once adopted, National
Standards Bodies (e.g., in France) are considering limiting themselves in the future to a partial translation
of the documents into the national language. This is a source of concern. The further development of
machine-readable standards and automated machine translation systems can help to develop improved
tools for the translation of standards for SMEs. The development of such tools should be supported by the
European Commission.

Implementation of Regulation 1025/2012

According to the roadmap, the Commission will assess whether amendments to the standardisation
Regulation are required. SBS supports the Regulation and believes there is no need to amend the main
provisions of the Regulation, there is rather the need to implement them effectively, for example in
relation to articles 5 and 6 on stakeholder participation and access of SMEs to standards.


Views and opinions expressed are those of Small Business Standards (SBS) only and do not necessarily reflect those of the European Union or EFTA. Neither the European Union nor EFTA can be held responsible for them.