SBS position on the preliminary analyses prior to acceptance of new standardisation requests(mandates)

SBS position on the preliminary analyses prior to acceptance of new standardisation requests(mandates)

Standardisation results from voluntary cooperation between industry, businesses, public authorities, and other stakeholders. About a fifth of all European standards are developed on the basis of standardisation requests (mandates) from the European Commission to the European standardisation Organisations (ESOs). These are requests to draw up and adopt European standards or European standardisation deliverables in support of European policies and legislation. The construction sector in CEN covers more than 3000 work items on product standards and test methods
(for use in building and civil engineering). Of these, about 600 standards started to be prepared under the Construction Products Directive (CPD) and are or will be harmonised under the Construction Products Regulation (CPR), along with about 1 500 supporting standards (test methods)1. Moreover, the International Standards and standards-type documents published to 2015 in the construction sector were 528, for a total of more than 20 000 pages2.

Participation of SMEs

The testimonies of the actors involved in the construction sector (i.e. contracting authorities, project managers, craftsmen, contractors and even part of the manufacturing industry) converge: it is impossible for them to comprehensively follow all working groups (technical committees, sub-groups, task groups) that cover construction standardisation relevant to them. Such difficulties are amplified for companies that employ less than 20 employees and represent about 97% of European companies in the construction sector.

With this regard, the European Economic and Social Committee (EESC) called in its Opinion on European standardisation (INT/783) for close monitoring of the efforts of the key standardisation players, in order to increase the inclusiveness of the European standardisation System. Relevance of new mandates in the construction sector Article 12 of Regulation (EU) No 1025/2012 on European standardisation requires the Commission to establish a Notification System for all stakeholders in order to ensure proper consultation and market relevance prior to certain policy actions related to European standardisation. This system’s purpose is to deliver information as foreseen by the Regulation to notify stakeholders also on possible future mandates
to ESOs, providing a four weeks “deadline for feedback”. Construction stakeholders consider that the transparency of this system can still be improved, as for new mandates the wide consultation of all interested parties to assess the economic and societal impact of standardisation requests (and, consequently, of standards) together with their market relevance, is not enough promoted.
In order not to prejudice eventual results of any decision related to new mandates, the EESC has already stressed the importance of the preparation process of European mandates, calling on the Commission to make this process even more transparent and inclusive, particularly for Annex III organisations, in order to properly assess at an early stage the relevance of new standardisation activities.

Specific comments and recommendations

Neither the need for standards nor the principles of standardisation (independence, transparency, impartiality, consensus) are challenged by the actors involved in the construction sector. On the other hand, all stakeholders in the construction supply chain deem it necessary to overcome shortcomings in the system and promote concrete actions for the improvement of processes connected to standardisation in the field of construction. Five proposals have been identified aiming to validate the interests on the basis of technical and economic
justifications prior to the start of the standardisation works.

1. In-depth studies to be carried out for new standardisation activities – Any new mandate and/or product/process to be standardised must be the subject of an in-depth feasibility study carried out by the requester, justifying the demand from both technical and economic perspectives for all the identified stakeholders and in particular for micro, small and medium-sized enterprises. This study should be also based on CEN-CENELEC Guide 17 ‘Guidance for writing standards taking into account micro, small and medium-sized enterprises (SMEs) needs’

When standardisation is used in support of European public policies, this feasibility study should take the form of an impact assessment of the mandates drawn up by the European Commission.

2. Creation of a checkpoint on the initiative for new standardisation requests – Feasibility studies for newstandardisation requests should be presented to the interested parties which will gather in a dedicated European ad-hoc platform and will be consulted before the launching of the standardisation work. For this purpose, SMEs that are likely to be impacted by the standard should be actively sought out and invited. Such a checkpoint is important because currently the vast majority of requests for new standards are not initiated by the broader group of stakeholders and there is no effective filter to prioritise work towards those standards that are most important to the widest group of actors. The creation of a checkpoint would directly impact on the reduction of costs that are currently incurred by construction stakeholders and their representative organisations at all stages of development of standardisation activities.

3. Ensure transparency of preparatory activities for new mandates – When standardisation supports European public policies, in particular through mandates drawn up by the European Commission, the initiative and the preparation of these mandates should be transparent for all the economic actors concerned. These mandates should also take into account the needs of standard users, in particular those that are likely to be impacted by the standards, and should not have as their sole objective the removal of possible obstacles to trade.

4. Verify the compatibility of finalised standards with their original purposes – In case the product which is under the scopes of a given standard changes during the writing process the standard itself, then this evolution must be the subject of a new consultation of the interested parties and of a new validation process by the ad-hoc sectoral body. Once the standard is finalised, a verification of the conformity of the result with the initial request is essential.

5. Verify the votes submitted by ESOs members on standardisation activities – It is necessary to rapidly implement a European system to verify that the positive/negative votes of ESOs’ members are truly the fruit of a mobilisation of the stakeholders and the consultation of the interested parties. Both the existence of national standardisation committees and the balance of their composition should be criteria of this verification.


1 CEN website:

2 ISO Annual Report 2015:


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.