No C 120/28 Official Journal of the European Communities 6. 5. 91 
ILO Convention and the code of practice on safety and 
health in construction which that organization is now finalizing contain many valuable, relevant provisions 
which one should expect to find in this Annex. 
Done at Brussels, 20 March 1991. 
The Chairman 
of the Economic and Social Committee 
Francois STAEDELIN 
Opinion on the commission Green Paper on the development of European standardization: 
action for faster technological integration in Europe 
(91/C 120/09) 
On 8 November 1990, the Commission decided to consult the Economic and Social Commit­
tee, under Article 198 of the Treaty establishing the European Economic Community, on the 
commission Green Paper on the development of European standardization: action for faster 
technological integration in Europe. 
The Section for Industry, Commerce, Crafts and Services, which was responsible for preparing 
the Committee's work on the subject, adopted its Opinion on 8 March 1991. The Rapporteur 
was Mr De Knegt. 
At its 285th plenary session (meeting of 20 March 1991), the Economic and Social Committee 
adopted the following Opinion by a majority. There were seven votes against and 
12 abstentions. 
1. Introduction 
1.1. Standardization is of great improtance for realiz­
ing the single Market through the abolition of technical 
barriers to trade and makes possible higher pro­
ductivity, a more competitive economy and a wider 
choice for the consumer. Related to this are also 
improvements in product safety and workers' health 
protection. 
1.2. Standardization offers economic advantages 
through the avoidance of costs involved in having to 
produce differing series of products for different mar­
kets. These costs were too opaque to be assessed in the 
Cecchini report, but they are undoubtedly high. 
1.3. The EEC Treaty establishes the legal authority 
of the Council and the Commission to regulate, inter 
alia, the free movement of goods in the Internal Market. 1.4. The so-called 'old approach' to the removal of 
technical barriers to trade contained detailed specifi­
cations to harmonize the provisions of Member States. 
This concentration on detail was dropped with the 
'new approach'^), which lays down only 'essential 
requirements'. These are incorporated into the laws of 
the Member States via Community Directives. 
Standards, whether national or 'harmonized', 
n^iy ensure that products respect those essential 
requirements: reference to a 'harmonized' standard pro­
vides presumption of conformity with the essential 
requirements. 1.4.1. 
help ensure 
1.4.2. Standards which are shown not to conform 
with the essential requirements need to be withdrawn 
and replaced. 
(!) OJ No C 136, 4. 6. 1985. 
6. 5. 91 Official Journal of the European Communities No C 120/29 
1.5. Standards based on the essential requirements 
of the 'new approach' Directives, which cover a wide 
range of products, are drawn up at European level by 
the European Committee for Standardization (CEN), 
the European Committee for Electrotechnical Standard­
ization (Cenelec) and the European Telecommuni­
cations Standards Institute (ETSI) under mandates from 
the EC Commission. 
1.6. The lack of European standards does not necess­
arily mean the absence of rules. But some standards are 
so directly linked to considerations of safety and health 
that in practice trade in products of this kind for which 
no harmonized standards have been laid down could 
be difficult and even dangerous. 
1.7. For this reason, European (and if possible inter­
national) standards for the improvement of health, 
safety and environment are important for the success 
of the Internal Market. The present situation with 
regard to the laying down of European standards, 
although improved, is unsatisfactory in terms of realiz­
ing the Single Market. 
1.8. Since 1985, as foreseen by the White Paper on 
Completion of the Single Market, several significant 
Directives have been adopted by the Council (e.g. for 
machines, toys, pressure vessels, personal protective 
equipment). 
1.9. These Directive underpin the need to draw up 
standards, e.g. on the design of products, in order to 
achieve the high level of protection of health, safety 
and environment required by the Single European Act. 
Standards, however, are voluntary, unless made manda­
tory through specific binding measures. The Committee 
stresses the need for further voluntary standardization 
in the 'non-regulatory sector'. These standards are 
necessary for better productivity, proper development 
of the economy and a wider choice for the consumer. 
2. The Commission's initiative 
2.1. Over the last few years, the Commission and 
the Economic and Social Committee have emphasized: 
— support for the new approach as a factor for the 
development and realization of a Community 
market, 
— the need for a balanced representation of the 
interests of producers and users of products (includ­
ing final consumers and workers), undoubtedly a 
requirement for removing trade barriers and a 
guarantee of a high level of safety. 
2.2. In its Opinion C) (27 September 1989) covering 
the report on the implementation of Directive 83/189/ 
EEC(2), the Committee said it was expecting a com-
0) OJNoC298, 27. 11. 1989. 
(2) OJ No L 109, 26. 4. 1983. munication from the Commission taking account of 
progress in the field of standardization in the Internal 
Market and relations between the Commission and the 
European standardization organizations. 
2.3. The Economic and Social Committee therefore 
welcomes the Commission's initiative to promote a 
debate in Europe on the development of European 
standardization. Indeed, five years after the adoption 
of the Council Resolution on standardization, and on 
the basis of the 'new approach', the time is now ripe 
to review at European and national levels the role and 
work of the standardization organizations, the decision­
making procedure on standards and the role of the 
parties involved in that procedure. It is also time to 
make a closer assessment of the current financial and 
working relationships between the Commission and the 
standardization organizations. 
2.4. This initiative appears even more important in 
the light of the practical implementation of the Direc­
tives adopted on the basis of Article 100A in the context 
of the Council Resolution on the 'nex approach'. 
2.5. These Directives start from the assumption that 
European standards are in keeping with the EEC 
Treaty; these standards are of the utmost importance 
for the optimal realization of the Internal Market. 
2.6. Directives and European standards provide the 
framework for product development and product 
safety, without which standards might be of a lower 
level or Member States could develop their own stan­
dards, which would not always correspond to the 
desired development at the European level. 
2.7. The Green Paper expresses the wish that all 
'future European standards should exist in their own 
right and should not have to be transposed at national 
level before they can be used' (point 83). This is legit­
imate. However, countries should still be able, within 
the limits of the Treaty, to lay down standards concern­
ing safety, the protection of workers and consumer and 
environmental protection which are stricter than those 
in force at European level, provided that such standards 
do not bring about unfair competition. 
2.8. It is important that standardization be organized 
primarily at an international level. This would prevent 
countries protecting themselves artificially form inter­
national level. This would prevent countries protecting 
themselves artificially form international competition, 
as abusive standardization practised at national level 
may lead to protectionism. It is also at international 
level that one must establish where justifiable standard­
ization ends and protectionism begins. 
No C 120/30 Official Journal of the European Communities 6. 5. 91 
3. Assessment of the existing situation 
3.1. The ESC endorses the Commission's assessment 
of the activities developed by CEN and Cenelec, which 
are described by the Commission as insufficiently flex­
ible. In the Committee's view, in order to create as soon 
as possible the standards called for by the Commission, 
CEN/Cenelec must be given the chance to work more 
efficiently. 
3.2. National authorities expect openness from 
national standardization organizations, and expect 
agreement on this among all the parties concerned. 
3.3. The Committee takes the view that these 
requirements must also apply at the European level, 
(where openness in the formulation of European stan­
dards is at present insufficient), bearing in mind the 
fundamental role which European standards play in 
implementing European legislation. It should also be 
noted that a number of areas which will be covered by 
standards in the future are at present regulated in a 
number of Member States by laws or by joint bodies, 
representing employers and workers. 
3.4. In addition, the Committee refers to 
Article 100A, which requires the Commission to take 
as a base a high level of protection, providing for high 
quality standards, which would guarantee a progressive 
level of safety for workers and consumers—in other 
words, standards which ensure progress. 
4. Coordination and reporting 
4.1. In view of the lack of an integrated document­
ation system and of coordinated progress reporting, it 
is at present impossible for any interested party to 
have an overall view of the work of the European 
standardization bodies. 
4.2. There should therefore be an effort to coordi­
nate the work programmes of CEN, Cenelec and ETSI 
in the short term, in order to avoid duplication and 
incompatible standards. The available instruments 
could be improved in order to speed up the adoption 
of standards. 
4.3. In this context it can be important to set up 
a European standardization data bank, including for 
example an index of available sources, bibliographical 
data on national and European standards and surveys 
of current standardization activities. It is to be rec­
ommended that the data bank use a standard 'user-
friendly' language for interrogation or search. The con­
tent of the data bank should as a general rule be 
available in all Community working languages. 5. Participation in drawing up standards 
5.1. In view of the need for agreement on standards, 
the Committee feels that the Community should call on 
the standardization committees to reach an agreement 
among all parties involved in standardization (including 
consumers and the social partners), based on effective 
participation. 
5.2. This need for the participation of the social 
partners is emphasized in a number of EC Directives 
adopted by the Council. 
5.3. In this connection the Committee is seriously 
concerned about the almost total absence of the social 
partners from the process, the lack of consumer rep­
resentation in the large majority of Member States, and 
the current impossibility for the standardization bodies 
to involve all interested parties in their work. The 
Committee therefore urges the Commission and the 
Member States to devote more attention to strengthen­
ing the role of all interested parties, thus counteracting 
any possible one-sided influence and helping to achieve 
the right balance in standardization work. 
5.4. In view of the above, the Committee feels there 
is an urgent need to draw up standards, but stresses 
that they must be of good quality and (as mentioned 
above) must provide a progressive level of protection. 
It therefore regards the participation of all interested 
parties as a necessary priority, and stresses the starting-
point of complete transparency, to make it possible for 
all parties to participate. 
5.5. The principle of 'openness' should be applied to 
the standardization procedure. The Committee there­
fore thinks that before the results of the work of the 
European standardization organizations are published 
in the Official Journal of the EC, the Commission 
and the Member States should ascertain whether the 
standards are in line with the protection aims of the 
EC Directives. 
The drawing up of European standards in order to 
achieve the aims of protection laid down in the EC 
Directives is a task of public importance carried out 
by standardization organizations under Commission 
mandates, which arise from the Commission's political 
responsability for this matter. As a matter of principle, 
the publication of the results of standardization cannot 
therefore be protected by copyright. However, this does 
not mean that standards in the public domain can be 
freely used by all and sundry. In this respect the holder 
of the industrial property right for a product or process 
covered by a standard has a right to protection. 
6. 5. 91 Official Journal of the European Communities No C 120/31 
6. Commission proposals 7. Adequacy of standards 
6.1. The Committee supports the aim of those Com­
mission proposals which seek to speed up the procedure 
for European standards. However, it would draw atten­
tion to the fact that shortening the timescale for public 
consultation should not be done at the expense of the 
quality of standards or without all interested parties 
being able to take an effective part in the process. 7.1. The Committee feels that it would be fair if the 
Commission, in proper consultation with the Member 
States, were to make proposals on the future role of 
the standardization bodies in relation to the adequacy 
of standards. The standardization bodies should inform 
the Commission and the Member States of the progress 
of work and the adequacy of the standards which have 
been and are being developed. 
6.2. In addition, the Committee takes the view that 
the general application of the qualified majority rule at 
all stages of the process, and particularly at the level of 
the working group and the technical committee, should 
obstruct consensus as little as possible. 
6.3. The Committee has sympathy for the Com­
mission's proposals to strengthen the role of European 
industry in the European standardization process. How­
ever, in the present situation, where experts come gener­
ally only from industry and government, the partici­
pation of workers and consumers at an early stage is 
important in the development of standards. 7.2. As regards changing the procedure for drawing 
up standards, the Committee sympathises with the 
Commission's call for the use of the qualified majority 
rule at all stages to speed up the process, but would 
regret it if this were to push the important principle of 
'consensus on standards' into the background. 
7.3. In this context, the Committee has noted that 
up to now hundreds of standards have been requested 
from the European standardization bodies with a view 
to implementing the internal Market. But the develop­
ment and adoption of standards will not cease on 
1 January 1993, since it is an ongoing process. 
6.4. It is important for standards to be in the langu­
age of the country concerned. It is not only of great 
importance for enterprises but also for workers and 
consumers, so that there can be no ambiguity as to 
interpretation of the standards. The translation of stan­
dards can only be done by specialists, who can however 
only be found through the national standardization 
organizations. The Committee realizes that this is not 
an easy problem to solve, bearing in mind also that the 
EFTA countries are involved, but wishes at least to 
raise the subject. 
6.5. Health and safety measures are not just a matter 
of establishing standards. It is important for workers 
and consumers to be consulted at the time when the 
Commission is drawing up the essential safety pro­
visions. Workers in particular must be invited to make 
a greater contribution than hitherto through existing 
bodies. Regarding consumers the Economic and Social 
Committee is therefore thinking in terms of the setting 
up of a specific consumer body for standardization, 
where problems of standardization in general can be 
discussed and from which the representatives in the 
CEN can be designated. In this respect the Committee 
endorses the proposals submitted to the Commission 
by the CCC (Consumers' Consultative Council) in its 
Opinion on the Green Paper on European standardiz­
ation. 
6.6. The Green Paper does not give enough details 
on the process of checking compliance of products on 
the market with standardization rules. It would be 
useful in particular to provide a procedure for the 
distribution of reports on compliance with product 
standardization rules. 8. Testing and certification 
8.1. The Committee approves in principle a separ­
ation between standardization (including specification 
of testing methods where appropriate) and testing and 
certification. 
The setting up of a European Organization for Testing 
and Certification (EOTC) is a first step in this direction 
and is welcomed by the Committee. 
Besides the transfert of certification agreements from 
CEN/Cenelec to the EOTC and the strengthening of 
this organization, the Community should release suf­
ficient funds from the budget to help those Member 
States whose certification and testing structures lay 
furthest behind (as indeed is proposed in the Com­
mission communication Doc. COM(89) 209 on a global 
approach to certification an testing). 
8.2. The Member States should ensure a guarantee 
of quality linked with the use of the European mark. 
The Committee points out the basic role of the national 
governments here, since, if this is not undertaken prop­
erly, the success of the whole European standardization 
process would be undermined. 
8.3. Time will tell to what extent a European certifi­
cation procedure can ensure that producers conform to 
the requirements, and show the ultimate value of such 
a procedure for the final consumer. 
No C 120/32 Official Journal of the European Communities 6. 5. 91 
9. No increase in the number of full members 
9.1. The Committee also sympathizes with the Com­
mission's view that a rapid increase in the number of 
full members of the European standardization bodies 
could obstruct the aim of developing European stan­
dards rapidly. 
9.2. Nonetheless, the Committee urges the Com­
mission to ensure that central and eastern European 
countries remain or become closely involved in the 
development of European standards. This is important 
not only for those countries themselves but also for 
possible economic growth in the Member States of the 
Community. Therefore the Committee welcomes and 
supports all efforts to achieve the objectives of the 
European standardization process in European 
countries outside the EC and EFTA. The Commission 
is urged to reinforce its efforts in this context. 
93. In addition, the Committee calls for attention 
to be given to the worldwide standardization which 
takes place in the Internation Organization for Stan­
dardization (ISO) framework. The Committee therefore 
proposes that ISO standards and European standards 
be harmonized as far as possible with a view to avoiding 
(technical) trade barriers vis-a-vis non-Community 
countries. This could also remove the current apprehen­
sion in non-Member countries about the development 
of a 'fortress Europe' in the standardization sphere. 
10. Future structures 
10.1. The Committee welcomes the idea of an organ­
ization such as the European Standardization Council 
proposed by the Commission to improve coordination 
and coherence, propose priorities and encourage par­
ticipation and transparency in the field of European 
standardization, including the national level. This in 
no way means that the Committee also endorses the 
composition of the Council as indicated in the Green 
Paper. 
10.2. The Committee stresses the need for a balanced 
representation of the European organizations con­
cerned; in this context, it must be assumed that the 
national structure plays a crucial role in the application 
and future development of the standards. 
10.3. As to the future role of the national bodies, the 
Committee reiterates that the national level must be in 
the forefront in enabling all interest groups to partici­
pate. 10.4. The Committee feels that the proposal to 
strengthen the role of the ASB {l) may lead to a different 
approach, for example in the sphere of safety; not all 
interested parties may be involved in the standardiz­
ation process. The Committee is worried that this could 
lead to more red tape. 
10.5. Taken together with the direct financing by 
industry, this proposal could endanger the necessary 
balance between producers and consumers as the latter 
would no longer be involved. 
10.6. The Committee urges the Commission and the 
Member States to do their utmost to support the partici­
pation of all parties, and especially that of trade unions 
and consumer organizations. 
10.7. In this connection the Committee welcomes the 
support given by the Commission to the trade union 
movement's technical committee on safety and health, 
responsible for providing information and technical 
assistance to trade union representatives in European 
standardization work. 
10.8. Account must also be taken, in the context 
of further discussions, of the proposed creation of a 
tripartite standardization committee under the auspices 
of the advisory committee on safety, hygiene and health 
protection at work. 
11. The need for a signal form the Council of Ministers 
11.1. The Committee supports the idea of strength­
ening the links within the European standardization 
system through a clear Decision of the Council of 
Ministers. Such a Decision would indeed have political 
significance. 
11.2. On the Commission's idea of following this up 
with a promise of financial support from the Com­
munity, no position can yet be taken. The Committee 
would first like to be better informed on the basis for 
the financing, which should benefit not only industry 
but also all bodies within the Community which are 
involved in standardization. 
12. Final comments 
12.1. The Committee would ask the Commission to 
follow the technical work of the European standardiz­
ation bodies closely, particularly at the crucial stages, 
and to give them the necessary technical and legal 
(*) ASB = Associated Standardization Bodies. 
6. 5. 91 Official Journal of the European Communities No C 120/33 
information to enable them to concentrate the scope of 
their work on the essential requirements for implement­
ing the basic safety provisions of the Directives. 
12.2. The Committee calls on the Commission to 
provide, where applicable, interpretations of the essen­
tial requirements more quickly, as, until this is done, 
the standard setting process cannot begin. 
12.3. Bearing in mind, then, that in the field of 
protection of citizens' health it is the role of govern­
mental bodies to lay down, for example, maximum 
exposure levels to dangerous substances, the Committee 
would ask the Commission, once the relevant decisions 
have been taken, to supply the European standardiz-
Done at Brussels, 20 March 1991. 
I. Preliminary comments 
1. The Commission proposal does not affect process­
ing aid or the other mechanisms governing the common 
organization of the market in processed fruit and veg­
etables. 
1.1. The proposal merely makes some technical 
adjustments to take account of a) the new combined ation bodies with the relevant values and to inform 
them that the laying down of such values falls outside 
the Commissions's terms of reference. 
12.4. The Committee agrees with the Commission's 
view that it can be of great importance in the context 
of European standardization for industrial sectors to 
second experts for standardization work. Medium and 
small-sized firms, particularly in specific sectors, usually 
do not have this possibility, although they undoubtedly 
have the interest and expertise to amke a contribution. 
The Committee therefore urges the Commission and 
public authorities in general to give small and medium-
sized enterprises such support as will enable them to 
make their own contribution to standardization work. 
The Chairman 
of the Economic and Social Committee 
Francois STAEDELIN 
nomenclature following the adoption of Council Regu­
lation (EEC) No 2658/87 of 23 July 1987, and b) the 
amendments which Commission Regulation (EEC) 
No 2472/90 of 31 July 1990 made to Annex I of this 
Regulation. 
1.2. The main purpose of the proposed Regulation 
is to amend Regulation (EEC) No 426/86 of 24 February 
1986 in order to include the product codes and descrip-Opinion on the proposal for a Council Regulation (EEC) amending Regulation (EEC) No 426/ 
86 on the common organization of the market in products processed from fruit and vegetables 
(91/C 120/10) 
On 22 February 1991 the Council decided to consult the Economic and Social Committee, 
under Article 198 of the Treaty establishing the European Economic Community, on the 
abovementioned proposal. 
The Economic and Social Committee appointed Mr Pricolo as Rapporteur-General with the 
task of preparing its work on the subject. 
At its 285th plenary session (meeting of 20 March 1991), the Economic and Social Committee 
adopted the following Opinion unanimously.