EN Official Journal of the European Union C 74/57

Opinion of the European Economic and Social Committee on the ‘Communication from the Commission to the Council, the European Parliament and the European Economic and Social Committee on the Integration of Environmental Aspects into European Standardisation’

COM(2004) 130 final

(2005/C 74/11)

On 25 February 2004, the Commission decided to consult the European Economic and Social Committee, under Article 262 of the Treaty establishing the European Community, on the abovementioned communication.

The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 6 July 2004. The rapporteur was Mr Pezzini.

At its 411th plenary session of 15 September 2004, the European Economic and Social Committee unanimously adopted the following opinion:

1. Introduction

1.1 The integration of environmental aspects into the European standardisation process is one of the priorities set out in the European Strategy for Sustainable Development, adopted by the Commission in 2001 (1), on which the Committee issued an opinion in November 2001, as well as a more recent opinion assessing sustainable development in April 2004 (2). The strategy aims to strike a balance between economic, social and environmental considerations, and to strengthen the principle established by the EC Treaty (3) that environmental considerations should be integrated into other Community policies. The Sixth Community Environment Action Programme (4), specifies that technical standardisation programmes should take into account the need to protect the environment.

1.2 The technical standardisation process is able to provide substantial support to the establishment of a fully integrated European internal market that respects the environment. It reconciles the commitment to becoming the most competitive economy in the world by 2010, capable of sustainable economic growth with more and better jobs in an enlarged Europe with greater economic and social cohesion, as specified in strategy adopted by the Heads of State and Government of the European Union in Lisbon in 2000.

1.3 Furthermore, technical standardisation, which is founded on the consensus of all interested parties, is an essential aspect of the implementation procedures of Community policies, and in particular, of integrated product policies, an area that has already been the subject of a number of EESC opinions (5), considering the standardisation process itself to have the potential to limit the environmental impact of products and services.

1.4 The Council Conclusions on standardisation of 1 March 2002 reaffirmed the adequacy of standards applied in sectors currently included in the new approach. The Council stressed that it was important that all stakeholders play an active role in the standardisation process and welcomed the Commission's intention to develop a paper on standardisation and the protection of the environment.

1.5 Following this Council, the Commission identified a series of key areas in a working document entitled the Role of standardisation in the framework of European legislation and policies, which set out the following objectives:

1.5.1 to make more extensive use of European standardisation in EU policies and legislation to foster, in line with the needs of both society and enterprises, the expansion of standardisation into new areas such as services, ICT, transport, consumer and environment protection;

1.5.2 to continue to raise awareness of business leaders and other stakeholders of the benefits of standardisation for business through measures that facilitate their participation in the standardisation process, and to involve SMEs in particular;

1.5.3 to review and to amend the current legislative framework dealing with standardisation so that it can respond to the latest developments and challenges in European standardisation, and to simplify legislation and develop a ‘better regulation package’ to align European legislation (6) with the needs of an enlarged Europe (7), and with the internal market strategy priorities for 2003-2006 (8);

1.5.4 to put financial support for European standardisation on a solid legal basis thereby ensuring that Member States and the Commission co-finance standardisation procedures, European infrastructure and the intensified synergy between CEN, Cenelec and ETSI;

1.5.5 to support the efforts of European standards organisations in their drive to increase the efficiency of the standardisation process by promoting the development and implementation of international standards in order to facilitate access to markets and international trade, and to avoid creating unnecessary obstacles to trade and to ensure the international dimension of standardisation.

1.6 The establishment of a European technical standardisation culture is vital for an efficient and balanced internal market in the EU-25. It is therefore important, particularly in the environmental sector, to take steps to train experts and to create and use databases that integrate environmental data in to the European standardisation system, with the full participation of the new Member States through their standardisation institutions. Given the structure and size of enterprises in those countries, the Committee believes that in order to participate fully in the standardisation process and to apply existing European technical standards, small and medium-sized enterprises in all the new Member States will require support.

1.7 The European technical standardisation system, which is based on consensus between all parties involved in drafting new standards and on their willingness to apply them, has proved to be extremely workable, and sufficiently efficient and flexible to permit extensive standardisation. In 2003, the total number of standards was around 13,500. This had a positive impact on the economy by reducing the transaction costs, facilitating trade, increasing competition and encouraging innovation. Another important aspect of standardisation is the reduction of obstacles to trade in the internal market, as well as the world market.

1.8 The Committee believes that these successes must be consolidated and further developed as underlined in the Council Conclusions on standardisation of March 2002. Nevertheless, however desirable it may be to take economic, social and environmental issues into consideration, this must not, in the Committee's view, vitiate the fundamental nature of the standardisation process, which must remain free, voluntary and consensual. These are after all the characteristics that have made the process successful in the internal and international markets.

2. Summary of the Communication

2.1 The objectives of the Communication from the Commission may be summarised as follows: — to raise awareness of the need to systematically integrate environmental issues into the European standardisation process, in a voluntary way, substantially driven by the stakeholders; — to establish permanent dialogue between standardisation players in order to draw up a specific action plan on 1) training and awareness-raising activities; 2) the organisation and support of stakeholder participation in the standardisation process; 3) systematic use of all available tools in order to take environmental issues into account in standards; 4) redefinition by the Commission of the framework for the standardisation mandates and the specific mandates for environmental policy and the environmental aspects of products; — to continually assess and monitor the integration of environmental aspects into European standardisation, in the light of the results obtained in the four areas mentioned above.

2.2 In order to achieve these objectives, the Commission intends, to proceed as follows: — at stakeholder level: put forward proposals to promote awareness-raising activities; share best practice and experience in training and awareness-raising; initiate broad-based stakeholder consultation on the formulation of standardisation mandates; set priorities for the integration of environmental concerns into European standards; identify indicators to assess the level of integration of environmental requirements into standards; identify and coordinate the environmental aspects dealt with by European standardisation institutions; provide Community support to European stakeholder groups that are active in the sector; report regularly on the ways in which the various tools used to integrate environmental concerns into the standardisation process are being used; — in the Member States, particularly the new ones: take steps to promote training and awareness-raising activities; ensure the gathering and dissemination of information by standardisation bodies; help and assist all stakeholders, particularly those representing civil society groups and public institutions active in the environmental sphere, to ensure that they participate fully in the standardisation process; report on the support measures applied in order to promote the exchange of experience and best practice; — at Community level: earmark Community funds to support awareness-raising and training programmes promoted by European standardisation institutions; continually monitor ongoing training and awareness-raising programmes; include, with consultation of stakeholders wherever necessary, environmental issues into the formulation of standardisation mandates; support stakeholders on a European scale in the identification and coordination of the environmental aspects of standardisation; organise meetings to facilitate the exchange of experience and best practice and the adoption of indicators to assess the progress of European standards that are relevant to the environment; develop a permanent assessment system to monitor progress in the sectors indicated, with consultation of stakeholders at least once a year.

3. General comments

3.1 The Committee welcomes the Commission's initiative involving in-depth consideration of the possibilities, opportunities and means whereby concerns relating not only to environmental protection but also to the sustainable use of natural resources and raw materials required in the production, packaging, distribution, maintenance, and end-of-life treatment of products can be included in the standardisation process.

3.2 In this regard, the Committee underlines that developing its own authentic European culture of technical standardisation is vital for the efficient and balanced functioning of the European internal market and to ensure that steps are taken to train experts and to create suitable databases for the environment in particular. This will facilitate the assessment of the possibilities and opportunities for integrating environmental aspects into the European standardisation system, including the new Member States in the process.

3.3 The Committee believes that it is essential that the voluntary, consensual, open and transparent nature of a standardisation process, which is freely applied by and for stakeholders, and which has made European technical standardisation so successful, is not marred but strengthened by the inclusion of socio-economic and environmental considerations.

3.3.1 The Committee draws attention to the fact that there are already a substantial number of technical standards that concern the environment directly or that take it into account. These include standards concerning the essential aspects of the life-cycle of products, standardised methods for measures and tests, technical standards on environmental technologies and environmental management such as EMAS eco-management, which is based on EN/ISO 14001.

3.3.2 Moreover, the Committee notes with satisfaction that the European standardisation institutions already possess a set of tools that are suitable for the optimal integration of environmental considerations into the standardisation process. For instance, the IEC 109 (9), successfully introduced as early as 1995 and updated recently, on technical standards for electrotechnical and electronic products; ISO/TR 14062 (10), ratified in 2002, on the design and development of products; the 100 and more ETSI/Cenelec Emissions and immunity quality standards; and finally the ISO/64 code of conduct promoted by the CEN Environment Help Desk.

3.4 The Committee reaffirms its conviction that, as demonstrated above, the effective integration of environmental concerns into the technical standardisation process will more easily be achieved, especially in the case of small and medium-sized firms, through codes of conduct, technical reports and more flexible tools, or through training workshops and handbooks that facilitate the transfer of knowledge and raise awareness of this issue, from the planning stage of new products, manufacturing processes and services. In this context, the simplified procedures adopted for EMAS and for health and safety standards in small and medium-sized enterprises could be used, as repeatedly stressed in the relevant EESC opinion (11).

3.5 The Committee strongly emphasises that the ongoing process must not weigh down or slacken the pace of standardisation. The very act of increasing the cost and red tape involved in the process would, in itself, contradict the EU principle of simplifying standardisation. The Committee is therefore in full agreement with the Council Conclusions on standardisation of 1 March 2002, according to which ‘the viability of the overall standardisation system in Europe remains far from secure in the light of rapidly changing European and international sources of income’ (12). The Committee believes that standardisation must be made increasingly attractive and useful to enterprises and their experts, who have the technical skill to integrate environmental considerations into their product innovations at a sustainable cost.

3.6 In order to optimise the overall performance of enterprises, mechanisms for the improvement of the environmental expertise of all stakeholders should be developed to ensure that the interested parties play an active role in the development of standards from the very outset. Technical, economic and social issues must be considered alongside health, safety and customer satisfaction. In recent years, it has become apparent that we need to pay close attention to reducing and rationalising the consumption of natural resources and energy, to reducing waste and emissions, and above all to enhancing the quality of the process of voluntary technical standardisation itself so that new standards can be applied easily at an international level.

3.7 The Committee considers that, in the light of the ongoing democratic process, which is predominantly based on national structures, it would be appropriate to avoid a top-down approach by entrusting stakeholders, with appropriate recourse to expertise and advice, with the responsibility of identifying the methods for the integration of environmental considerations into the standardisation process.

3.8 The Committee considers that the pace of standardisation cannot exceed the pace of cultural change that will enable various sectors to understand the role they play in sustainable development. The Commission's role takes on particular importance in the awareness-raising process and the cultural ‘foresight’ that must be implemented through the dissemination of know-how and best practice.

3.9 The high-quality of voluntary technical standards is an essential aspect of their added value at European level and, in the Committee's opinion, can only be ensured through the active participation of all stakeholders in the standardisation process, i.e. experts and representatives from the various sectors of industry, including small and medium-sized enterprises, employees, consumers and NGOs. The diversity of the stakeholders involved constitutes a fair balance of economic, social and environmental considerations, without neglecting health and safety priorities.

3.10 In compliance with the principle of subsidiarity, stakeholder participation must, first and foremost, be applied at national level, particularly in the case of new Member States. It is essential to support NGOs, to ensure their active and competent participation, but also and above all, SMEs, whose structure and size make their improved access to the standardisation process particularly important. It is therefore worth remembering that European institutions specifically created for SMEs, such as NORMAPME, should be strengthened and used to the best effect.

3.11 The Committee emphasises the need for urgent Community support measures for capacity-building activities promoted by the standardisation institutions and NGOs of the new Member States, including projects for training experts. The Committee recommends the establishment of a network of databases that is fully interoperable, decentralised and easily accessible by the end user. In practice, this means permanent and improved access to information and the knowledgeable participation of all enterprises in the standardisation process.

3.12 With regard to setting priorities for the standardisation process, the Committee considers that a consensual and voluntary process that involves the free participation of all stakeholders should continue to be used to identify priorities. Priorities that are entirely politically motivated and that fail to take into account the specific characteristics of products and the enterprises that produce them are to be avoided.

3.13 With regard to the Commission using compulsory mandates in the context of the new approach, the Committee believes that promoting the use of environmental technical standards should not be subject to top-down decisions but should be effected through widespread acceptance of eco-compatible products in order to respond as effectively as possible to the needs and interests of citizens and consumers.

3.14 The Committee believes that clearly-defined mandates based on the new approach have contributed to the success of the internal European market and that this should not be jeopardised by using mandates to transfer difficult political decisions within standardisation institutions.

3.15 The Committee considers that transposing international standards into European standards is essential to ensure that our products are fully present and competitive on the international market. At present, due to the Dresden and Vienna Agreements, over 83 % of Cenelec standards and approximately 40 % of CEN standards are based on international ISO, IEC and ITU standards. The Committee believes that it is necessary to prevent environmental standards from becoming barriers to trade under the terms of the World Trade Organisation's TBT Agreement. Nor should standards make European enterprises uncompetitive on the world market. It is therefore necessary to assume a proactive stance within the context of the trans-Atlantic dialogue (TABD), the Japanese (EJBD) dialogue and the Mercusor Forum (MEBF) in order to prevent the gap between European and international standards from widening.

4. Specific observations

4.1 Participation: It is important to ensure that broader participation does not slow down the process of approving and revising standards, which already takes an average of three to five years. The principle of subsidiarity must be fully applied. At national level, the participation of all stakeholders, particularly employers and workers, must be ensured, whereas at European level, the representatives of national standardisation institutions must present the consensual national positions achieved. The Community-level representatives of small and medium-sized enterprises and NGOs concerned should also participate, bringing the consensual positions achieved by their institutions to the debate.

4.2 Cooperation: The Committee considers the organised exchange of technical know-how and the development of voluntary codes of conduct and of best practice to be particularly important. However, the latter should be implemented through existing tools (cf. 3.3.2.), which need to be strengthened and developed, particularly where the new Member States are concerned.

4.3 Culture: The development of a European technical standardisation culture that takes economic, social and environmental issues into account is essential for enterprises and organisations thereof, and, in particular, for SMEs', employees' and stakeholders' organisations. Consumer and environmental protection groups should have sufficient access to financial support at both national and Community level in order to reinforce their training in technical standardisation and ensure their qualified and competent participation.

4.4 Funding: There is a need for both national and Community multiannual budget resources to develop training and awareness-raising activities. These funds should be allocated, in particular, to national and European standardisation bodies, to the social partners and to organisations representing the various civil society bodies.

4.5 Priorities: Where new technical standards are to be drafted, priorities should be established by consensus of all the participants, since they are directly involved in the standardisation process and therefore have to bear full responsibility for it. Under no circumstance should priorities be decided through a top-down process imposed from above. Tools: The systematic use of the tools - as described in points 3.3.1 and 3.3.2 - necessary for the integration of environmental aspects into the standardisation process should be seen as an opportunity offered to those involved in the technical standardisation process, which is a voluntary undertaking, rather than as a requirement imposed on them.

4.6 Monitoring: Monitoring and assessing results achieved through training and awareness-raising activities and strengthening national and European standardisation institutions not least as regards the knowledgeable participation of NGOs and bodies representing SMEs, should provide the Commission, the Council, the European Parliament and the European Economic and Social Committee with the basis for biannual reports and five-yearly reviews of Community measures and policy in the field.

5. Conclusions

5.1 The EESC is convinced of the need to speed up the standardisation process without weighing it down, thereby ensuring development and high quality in all spheres of the internal market, including the environment. The aim must be to make the process efficient and inexpensive and to minimise red tape, whilst building the capacity of Member States' institutions as a preparatory measure.

5.2 The EESC believes that the process of integrating environmental aspects into the European standardisation system should fully respect the principle of subsidiarity, and must involve the full participation of all stakeholders, particularly SMEs and NGOs, at national and regional levels especially, since they are closest to the interested parties.

5.3 The development of the global market and the opening-up of large markets such as China, India, and Russia to world trade, make it a priority to transpose current international standards into European standards, in accordance with the Dresden and Vienna Agreements, so as to turn standardisation to the commercial advantage of European enterprises.

5.4 The EESC considers that the objective must be to achieve maximum compatibility between environmental regulations and non-binding standards, which are based on greater awareness of environmental considerations and quality.

5.5 The EESC stresses that forums for the exchange of experience, best practice and dialogue amongst stakeholders should be strengthened through expertise from European and national standardisation institutions, industry, SMEs, employee representatives, consumers and NGOs, in order to support the development of standardisation procedures, in accordance with the Lisbon Strategy and the principle of sustainable, competitive development.

5.6 In particular, it is necessary to: — promote a technical standardisation culture for the EU; — take steps to train experts and develop appropriate, widely-used databases; — increasingly integrate environmental protection into the European standardisation system; — raise consumer awareness to increase demand for a market which favours the sustainable use of natural resources, raw materials and finished and packaged products; — strike a balance between key health and safety concerns and global environmental issues, with due consideration for the Kyoto Protocol; — apply the principle of subsidiarity fully by promoting the participation of all stakeholders at national and regional levels; — develop more flexible codes of conduct that result in eco-friendly standardisation processes that primarily enable SMEs to develop technical processes that facilitate the economically-viable development of new products, processes and services; — provide a forum for discussion between the Lisbon Strategy for developing the internal market and the European Environment and Health Action Plan 2004-2010 in order to encourage an exchange of expertise amongst all stakeholders in the standardisation process: CEN, CENELEC, ETSI, NORMAPME, ANEC (consumers), TUTB (workers' union), ECOS (environmental body), Industry, distribution and services; — support the development of basic technical standardisation for quality products and processes in the agriculture and food sector.

Brussels, 15 September 2004 The President of the European Economic and Social Committee Roger BRIESCH

(1) COM(2001) 264 final.

(2) Opinion CESE 1494/2001 of 29 November 2001 and CESE 661/2004 of 29 April 2004

(3) EC Treaty Articles 2 and 6 (consolidated version)

(4) Decision 1600/2002/EC of 22 July 2002

(5) EESC Opinion on the Green Paper on Integrated Product Policies (OJ C 260, 17.9.2001 and Opinion CESE 1598/2003 of 10.12.2003 on the Communication from the Commission on Integrated Product Policy - Building on Environmental Life-Cycle Thinking.

(6) Communication from the Commission COM(2002) 278

(7) Communication from the Commission : Industrial Policy in an Enlarged Europe COM (2002) 714

(8) Communication: Internal Market Strategy – Priorities 2003-2006 COM(2003) 238 final

(9) IEC/109 on Environmental aspects – Inclusion in electro-technical product standards

(10) ISO/TR 14062 on Environmental management – integrating environmental aspects into product design and development

(11) Opinion CESE 560/1999 of 29 May 1999 (OJ C 209, 22.7.1999)

(12) OJ C 66, 15.3.2002