European Standardisation Strategy

Position

European Standardisation Strategy

BDI Position European Standardisation Strategy

Federation of German Industries e.V.

Date: 16.03.2022

BDI Position European Standardisation Strategy

Contents Summary .................................................................................... 3 Introduction ................................................................................ 4 1. Need for standardisation for a green and digital transformation of the European Union ....................................... 5 Need for action in standardisation ............................................ 5 High-Level Forum ................................................................... 5 EU excellence hub on standards ............................................. 6 Process upgrade for the development of standards................... 6 Non-technical standardisation.................................................. 6 2. European Standardisation Organisations............................. 7 Legislative Proposal amending Regulation (EU) No 1025/2012.. 7 Modernising the governance structures of the ESOs ................. 7 Peer-Review-Process ............................................................. 8 Technical Specifications .......................................................... 8 3. International Standardisation ............................................... 8 Coordination and analysis of international standardisation activities................................................................................. 9 Development and dissemination of international digital standards ............................................................................................. 9 Trade agreements, cooperation and standardisation projects in African countries..................................................................... 9 4. Standardisation and innovation are interrelated in many ways 10 5. Promoting young talent and strengthening the business location..................................................................................... 10 About BDI ................................................................................. 11 Imprint ...................................................................................... 11

BDI Position European Standardisation Strategy

Summary A strong European standardisation system is central to Europe's technological sovereignty. With the published standardisation strategy, the European Commission provides good approaches to take account of the international challenges and to eliminate weaknesses in the area of European-wide harmonised standards.

A strategic analysis and prioritisation of international and European standardisation needs can increase Europe's competitiveness in international standardisation and coordinate priorities more efficiently. With the establishment of the High-Level Forum, the Commission is taking into account the increasing strategic importance of standardisation and the increased awareness at the political level. The explicit involvement of the standards organisations is not expedient from the industry's point of view. The linking of the forum to existing formats, such as the industry alliances, is expressly to be advocated.

Redundant structures should be avoided at all costs.

Stronger coordination and communication within the Commission is to be welcomed. A critical review and adaptation of the framework conditions for the commissioning, evaluation and citation of harmonised European standards is needed quickly. Against this background, we regret the lack of concrete proposals for process optimisation. The proposed procedure for the introduction of "Technical Specifications" contradicts the principles of the New Legislative Framework and considerably weakens the position of harmonised standards. A clear regulatory separation of legal requirements and technical implementation in the form of standards is needed.

From the point of view of German industry, the three European Standardisation Organisations are doing a very good job and their processes are well adapted to the corresponding sectoral needs. We see no reason to revise the governance structures of the standards organisations. Likewise, no deficits can be identified for industry-relevant committees.

We expressly welcome the proposed measures to secure the global competitiveness as well as the security and open strategic autonomy of the European Union. An increasing strategic orientation requires the analysis of the geopolitical situation and coordination of European interests in relevant international standard-setting bodies.

Federation of German Industries

German Lobbyregister Number R000534

Address Breite Straße 29 10178 Berlin Postal Address 11053 Berlin Germany Contact Simon Weimer, M.Sc. T: +49 30 2028 1589 F: +49 30 2028 2589 E-Mail: s.weimer@bdi.eu Internet www.bdi.eu

BDI Position European Standardisation Strategy

Introduction The BDI welcomes the fact that politicians are recognising the economic and increasing strategic importance of technical standardisation. Ever faster innovation cycles, single-minded ambitions of individual countries in international standardisation and increasing bureaucratisation in the drafting of harmonised European standards posed new challenges for business and politics.

The European Standardisation Strategy takes these challenges into account, heralds a new era of European standardisation and pursues three primary goals: 1. Strengthening the global competitiveness of the European Union 2. Shaping the transformation towards a digital, climate-neutral and circular economy 3. Anchoring democratic values in technology applications The European Standardisation System is internationally competitive and appreciated by industry. Standardisation is a tried and tested tool for relieving the legislator and promotes practical, lean and thus innovation-friendly regulation. The clear regulatory separation of legal requirements, which are formulated in legal acts, and standardisation, through which the technical implementation of legal requirements is defined on a voluntary basis, has manifested itself as a central element of the common European Market. The international body of standards via ISO and IEC is essentially free of contradictions and enjoys a high level of acceptance. This, too, is an important building block of the strong position of the German and European economy on the world market.

Standardisation is business-driven and business-supported. The economic stakeholders ensure that the right content is standardised at the right time. For companies, technical standardisation is becoming increasingly important, especially in view of the increasing networking in the context of digitalisation. Standardisation makes an irreplaceable contribution to the dissemination of technological knowledge and to ongoing economic growth at the location.

The BDI e.V. comments below on the proposals announced in the strategy.

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BDI Position European Standardisation Strategy

1. Need for standardisation for a green and digital transformation of the European Union A solid European Standardisation System (ESS) is central for Europe’s technological sovereignty. Objectives of the European Union, like the development of a resilient, green and digital economy. European Union objectives, such as building a resilient green and digital economy, require practical and relevant standards developed by business. To identify these and improve underlying processes, the Commission proposes various measures.

Need for action in standardisation The strategic analysis and prioritisation of international and European standardisation needs are to be supported in principle. The same applies to the recording of standardisation projects in the Annual Work Programme. In order to maintain the successful interaction of national, European and international standardisation, the analysis and prioritisation must take into account ongoing and planned projects at national, European and international level.

De-prioritisation of important standardisation projects must not take place.

The task of analysis and prioritisation is reserved for the High-Level Forum and sufficient participation of industry must be ensured.

High-Level Forum With the establishment of a High-Level Forum, the Commission is taking into account the increasing strategic importance of standardisation and the heightened awareness at the political level. We support the establishment of the Forum and welcome the initiative to effectively combine the successful bottom-up driven European approach with the top-down approach, which is moving more into focus. It is essential to have adequate representation of industry in the Forum, as a key player in standardisation. The forum must start work quickly and specify its areas of responsibility. The explicit involvement of National and European Standardisation Organisations is incomprehensible. From the point of view of German industry, Standardisation Organisations primarily have the task of effectively organising standardisation processes and relieving the standardisation experts of formal tasks.

The affiliation of the High-Level Forum to existing formats, such as the industrial alliances or the European Security Research Forum, is to be evaluated positively. From the point of view of German industry, the effective and efficient interaction between all organisations and stakeholders involved in

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BDI Position European Standardisation Strategy

standardisation is important. Redundant structures must be avoided at all costs in view of the limited availability of experts.

Furthermore, the BDI renews its demand to include industry in the Committee on Standards. Sector-specific expert groups such as the ICT Multi-Stakeholder Platform on ICT Standardisation must continue to exist and provide qualitative support to the High-level Forum. Otherwise, it would be highly questionable if corresponding sector-specific knowledge and expertise were no longer directly available.

EU excellence hub on standards The intended stronger coordination and communication within the Commission, especially among the Directorates-General, is to be welcomed. A further bureaucratisation of the standardisation system or the creation of a parallel standardisation system via the "EU excellence hub on standards" as a nucleus for an EU standardisation agency must be prevented.

Process upgrade for the development of standards Improvements in the processes of recognition of harmonised European standards are necessary. We expressly welcome the action point to continue working on process improvements with all institutions involved. A concrete announcement of a critical review and adaptation of the framework conditions for the commissioning, evaluation and citation of European harmonised standards would have been desirable. In addition to the Commission and ESOs, other stakeholders, such as industry, must be included in the process.

We expressly support the proposals from the "Joint Industry Recommendations for effective harmonised Standardisation" from July 2021. Efforts at European level to support industry in its standardisation efforts are to be welcomed but must be more clearly named and implemented.

Non-technical standardisation The field of non-technical standardisation has increased dramatically in recent years. When developing non-technical standards, it is important to observe the principle of market relevance. A purely quantitative consideration of the ratio of the number of existing technical and non-technical standards to identify the need for non-technical standardisation must be strictly rejected.

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BDI Position European Standardisation Strategy

2. European Standardisation Organisations At European level, three Standardisation Organisations 1 (ESOs) are responsible for organising the standardisation processes. According to Regulation (EU) No 1025/2012, only these three ESOs are empowered to handle standardisation Requests issued by the Commission. In order to safeguard their strategic and political interests, the Commission proposes the establishment of new principles for the management and good governance of the ESOs, the amendment of Regulation (EU) No 1025/2012, a peer review procedure and the possibility to develop Technical Specifications.

Legislative Proposal amending Regulation (EU) No 1025/2012 German industry will comment in a separate position paper on the legislative proposal to amend Regulation (EU) No 1025/2012.

Modernising the governance structures of the ESOs From the point of view of German industry, the three ESOs are doing a very good job and their processes are well adapted to the corresponding sectoral needs. This enables the targeted development of high-quality European standards based on deep expert knowledge. Furthermore, the European standardisation processes have efficient structures for international and national cooperation. This ensures that European requirements and values are successfully incorporated into international and national standards, and that international standards can be adopted for Europe.

Technical experts from all sectors of the economy make significant contributions to standardisation at national, european and international level. The circumstance of a fundamental dominance of standardisation experts from industry over those from SMEs cannot be observed. The Commission does not provide quantitative data. The central challenge is limited human resources.

This challenge must be addressed through appropriate measures, such as the targeted promotion of standardisation work in projects and committees, and consideration of standardisation in business and technology-related courses of study.

1

European Committee on Standardisation (CEN), European Committee for Electrical Standardisation (CENELEC) and European Telecommunications Standards Institute (ETSI)

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BDI Position European Standardisation Strategy

Peer-Review-Process German industry has always advocated SME-friendly conditions and a strong involvement of SMEs in standardisation. At national level, German industry will continue to actively campaign for more SME-friendly conditions. The BDI and its member associations are therefore happy to get involved in the Commission for SMEs (KOMMIT) at DIN. At the same time, it is the task of the national standardisation coordinators to ensure that the composition of the standardisation committees is balanced. No deficits can be identified for industry-relevant committees. If deficits are identified in other economic sectors, German industry will be happy to support proposals to remedy them.

Technical Specifications German industry shares the Commission's concerns that harmonisation legislation without existing harmonised European standards stands in the way of the free movement of products on the European internal market and is associated with legal uncertainties. The procedure proposed here is contrary to the principles of the New Legislative Framework and considerably weakens the position of harmonised standards. A delay in the standardisation process often results from complicated content-related procedures in the harmonisation process and not from the content of the standards. For the definition of technical specifications, comprehensive technical and long-standing experience in relevant industrial sectors is required. It remains questionable which experts the Commission would like to call upon for the preparation of the Technical Specification.

We advocate an orderly procedure and a clear framework that is in line with the principles of the NLF. We will present our proposals in a separate position.

3. International Standardisation With the increasing complexity of our modern economy, international standardisation is receiving growing attention. Internationally harmonised standardisation forms the basis for an efficient, export-oriented and internationally competitive economy. In the context of industrial and trade policy shifts of global dimension, its political and strategic importance is clearly increasing.

In order to ensure global competitiveness as well as the security and open strategic autonomy of the EU, the Commission proposes several measures.

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BDI Position European Standardisation Strategy

Coordination and analysis of international standardisation activities An increasing strategic orientation of standardisation requires the analysis of the geopolitical situation and coordination of European interests in relevant international standardisation committees. We welcome the strategic analysis of international standardisation activities - especially in the field of future technologies. Any results should be made available to all stakeholders involved in a low-threshold and speedy manner. If international standardisation projects that run counter to the European approach of promoting a green and digital economy are identified, appropriate measures must be initiated. As the Commission itself is not a stakeholder in standardisation, any measures need to be discussed at national level. The introduction of a national standards exchange platform between politics and economy is a suitable instrument. At the same time, the platform can serve to coordinate the priorities of standardisation more efficiently and to streamline its objectives and results.

Development and dissemination of international digital standards German industry welcomes the proposals and sees potential for establishing uniform standards worldwide. Only internationally harmonised standards promote a free, open, accessible and secure global internet.

Trade agreements, cooperation and standardisation projects in African countries In view of the interconnectedness of European value chains and the threat of fragmentation of technical market access conditions, international cooperation must be supported. There needs to be a preference for active cooperation in the development and subsequent adoption of international standards. German industry, which is dependent on exports, is particularly dependent on an international perspective of the European standardisation strategy and the European standardisation system. Only in this way can European initiatives such as "Global Gateway" be implemented effectively and successfully. The promotion of standardisation projects in African countries benefits, for example, the German hydrogen strategy, which relies on imports from the Sahra. Only technical rules that are recognised throughout Europe and internationally guarantee the success of the hydrogen strategy. The BDI therefore proposes to make standards an integral part of European trade strategies and agreements in the future. This is a prerequisite for expanding the

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BDI Position European Standardisation Strategy

pioneering role in standardisation and shaping the transformation towards a green and digital economy.

4. Standardisation and innovation are interrelated in many ways The stronger involvement and use of Europe's RDI base for the identification and transformation of standardisation projects makes sense and is to be welcomed. With the "Standardisation Booster", for testing the relevance of scientific results for standardisation, the Commission is striking the right balance. This makes it possible to realistically analyse the interrelationship between standardisation and RDI in the run-up to each activity with regard to its market relevance. In particular, however, Standardisation Organisations must be cautious about assessing the innovation potential of possible standardisation projects.

5. Promoting young talent and strengthening the business location With the proposed measures, the Commission aims to make an important contribution to the recruitment and training of standardisation experts. Raising awareness among students of business and technology-related courses of study lowers the hurdles to dealing with standardisation. It makes sense to take standardisation into account in the university education of business and technology-related courses of study. At the same time, the EU Academy, with the development and dissemination of online training materials, provides simple and low-threshold opportunities to teach the basics in the context of standardisation. For the implementation of these measures, the Commission should build on already available findings from relevant studies 2.

2

Motivation for and barriers against the inclusion of standardisation in European aca demic research and education and European market needs for education in standardisation/standardisation-related com-petence

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BDI Position European Standardisation Strategy

About BDI The Federation of German Industries (BDI) communicates German industries’ interests to the political authorities concerned. She offers strong support for companies in global competition. The BDI has access to a wide-spread network both within Germany and Europe, to all the important markets and to international organizations. The BDI accompanies the capturing of international markets politically. Also, she offers information and politico-economic guidance on all issues relevant to industries. The BDI is the leading organization of German industries and related service providers. She represents 40 inter-trade organizations and more than 100.000 companies with their approximately 8 million employees. Membership is optional. 15 federal representations are advocating industries’ interests on a regional level.

Imprint Federation of German Industries e.V. (BDI) Breite Straße 29, 10178 Berlin, Germany www.bdi.eu T: +49 30 2028-0 Germany Lobby Register Number: R000534 Contact Simon Weimer, M.Sc. Senior Manager T: +49 30 2028 1589 s.weimer@bdi.eu BDI document number: D 1529

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