REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of the Regulation (EU) No 1025/2012 from 2016 to 2020
Date: 2022-02-02
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: Cenelec, ETSI, EU financing, European Committee for Standardisation, application of EU law, institutional cooperation, standardisation

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 2.2.2022  COM(2022) 30 final  Standardisation package REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of the Regulation (EU) No 1025/2012 from 2016 to 2020  
 
 
1 

Introduction 

Regulation (EU) No 1025/20121 (hereinafter ‘the Regulation’) provides the legal framework 
for allowing the Commission  to  request  European  Standardisation  Organisations (ESOs)2 to 
draft  standards  and  standardisation  deliverables  for  goods  and  services  in  support  of  EU 
policies  and  EU  law,  for  EU  support  to  the  functioning  of  the  European  standardisation 
system (ESS) and sets out key criteria for the functioning of the ESS.  

Under  Article  24(3)  of  the  Regulation,  the  Commission  shall  report  on  its  implementation 
every five years. A first report was published in 2016, covering the period 2013 – 20153. This 
report  mainly  covers  the  period  2016-2020,  with  limitations  that  some  data  were  only 
available until 2019, but, where possible, includes also updated facts and figures until 2021. 
Articles 24(1) and (2) of the Regulation require the ESOs and other organisations that receive 
EU financing to submit annual reports on their activities. These reports have been taken into 
account  in  preparing  this  report.  In  support  of  data  collection,  an  independent  study4  was 
commissioned. 

2 

 Implementation of the Regulation 

launched  a  number  of 

initiatives  and  measures 

The  Commission 
the 
implementation of the Regulation. In support of the 2015 Single Market Strategy5 and as part 
of  the  2016  Standardisation  Package6,  the  Commission  launched  a  Joint  Initiative  on 
Standardisation (JIS). In a multi-stakeholder and partnership approach, this initiative aimed to 
modernise the ESS, to maintain its attractiveness, effectiveness and efficiency. The initiative 
was  broken  down  into  15  different  sub-measures,  and  documents  are  publicly  available7.  A 
state-of-play  was  provided  in  January  20188.  Taking  into  account  also  these  initiatives  and 
actions, the current implementation of the Regulation can be summarised as follows. 

to  support 

Transparency between standardisation bodies (Article 4) 

2.1 
Article  4  of  the  Regulation  sets  out  requirements  regarding  the  transparency  of  standards 
between the ESOs and the national standardisation bodies (NSBs), and between these entities 
and the Commission.  

1  Regulation  (EU)  No  1025/2012  of  the  European  Parliament  and  of  the  Council  of  25  October  2012  on 
European  standardisation,  amending  Council  Directives  89/686/EEC  and  93/15/EEC  and  Directives  94/9/EC, 
94/25/EC,  95/16/EC,  97/23/EC,  98/34/EC,  2004/22/EC,  2007/23/EC,  2009/23/EC  and  2009/105/EC  of  the 
European  Parliament  and  of  the  Council  and  repealing  Council  Decision  87/95/EEC  and  Decision  No 
1673/2006/EC of the European Parliament and of the Council, OJ L 316, 14.11.2012, p. 12. 
2  The  three  European  standardisation  organisations  within  the  meaning  of  the  Regulation  are  the  European 
Committee  for  Standardisation  (CEN), 
the  European  Committee  for  Electrotechnical  Standardisation 
(CENELEC), and the European Telecommunications Standards Institute (ETSI). 
3 COM(2016) 212 final. 
4  Study 
the  Regulation 
implementation 
https://doi.org/10.2873/504681 and https://doi.org/10.2873/593923  
5 COM(2015) 550 final 
6 COM(2016) 358 final 
7 https://ec.europa.eu/growth/single-market/european-standards/notification-system_en#jis  
8 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52018SC0015  

(EU)  No. 

1025/2012 

(Article 

24) 

the 

on 

of 

1 

 
 
                                                           
Online  tools  have  facilitated  access  to  draft  standards  and  transparency  of  standards  to  the 
other  ESOs,  NSBs  and  the  Commission,  as  required  by  Article  4.  The  access  to  draft 
standards and transparency of standards, under Article 4 of the Regulation at European level, 
has been facilitated by the online tools implemented by the ESOs in 2015, as they introduced 
a  mechanism  that  gives  ESO  members/participating  stakeholders,  the  Commission  and  the 
European Free Trade Association (EFTA) direct online access to the draft European standards 
and  standardisation  deliverables.  As  regards  NSBs,  in  2019,  approximately  70%  had  online 
tools  facilitating  access  to  draft  national  standards  to  relevant  stakeholders.  Nevertheless, 
based  on  the  reporting  from  civil  society  organisations  and  small  and  medium  enterprises 
(SMEs), access to NSB activities remains a challenge. 

2.1.1  Guidance  
As an additional task to promote transparency, in 2015, the Commission, in cooperation with 
the  ESOs,  prepared  a  Vademecum9  providing  guidance 
to  ESOs’  representatives, 
Commission  officials,  EU  Member  States  and  stakeholders  on  the  role  of  standardisation 
requests from the Commission10, how to prepare and adopt standardisation requests11 and how 
to execute them12. In 201613, the Commission also issued a general checklist for the ESOs’ to 
carry out a self-assessment when preparing and delivering HENs in support of EU law, so to 
promote  the  quality  of  standards  and  deliverables  and  successful  citation  in  the  OJEU.  In 
some  cases14,  for  certain  policy  fields,  the  checklist  was  adapted  to  the  specificities  of  the 
pieces of legislation and other sectoral requirements.  

As part of the Commission’s comprehensive guidance on the implementation of EU product 
rules, the “Blue Guide”15 includes a specific section on standards (Section 4.1.2 and Annex 
VI). 

2.2 

Inclusiveness and stakeholders’ participation, including research bodies 
(Articles 5 and 9) 

Article  5  of  the  Regulation  requires  the  ESOs  to  encourage  and  facilitate  an  appropriate 
representation  and  effective  participation  of  all  relevant  stakeholders,  including  SMEs, 
consumer organisations, and environmental and societal stakeholders in their standardisation 
activities.  The  identified  stakeholder  organisations  currently  receiving  EU  financing  (also 
known as  the  ‘Annex  III organisations’)  are Small  Business Standards  (SBS),  the European 
consumer  voice  in  standardisation  (ANEC),  the  Environmental  Coalition  on  Standards 
European Environmental Citizens Organisation for Standardisation (ECOS) and the European 
Trade  Union  Confederation 
representing  SMEs,  consumers, 
environmental and workers’ interests.  

respectively 

(ETUC), 

9 SWD(2015) 205 final of 27/10/2015 
10 https://ec.europa.eu/docsroom/documents/13507/attachments/1/translations  
11 https://ec.europa.eu/docsroom/documents/13508/attachments/1/translations  
12 https://ec.europa.eu/docsroom/documents/13509/attachments/1/translations  
13 Ares(2016)6548298 of 22/11/2016 
14 e.g. Directives 2014/30/EU and 2014/53/EU 
15 https://ec.europa.eu/growth/single-market/goods/building-blocks_en#blue-guide  

2 

 
 
                                                           
At  European  level  (Article  5(1)  of  the  Regulation),  Annex  III  organisations  are  eligible  to 
participate at policy level in the governance bodies of all ESOs and at the technical level in 
the technical bodies of CEN-CENELEC and the technical committees of ETSI. Since the last 
report,  new  initiatives  have  been  taken  to  further  improve  their  inclusion  and  effective 
participation. 

In 2017, CEN and CENELEC implemented a change through which non-industrial Annex III 
organisations (ANEC, ETUC and ECOS) can submit formal opinions on draft standards (the 
so-called  “right  of  opinion”).  If  there  is  a  non-favourable  opinion,  the  technical  committee 
responsible for drafting the standard in  question shall consider the justification provided for 
the opinion and provide feedback. It may also lead to revisions of the draft standard. Overall, 
76% of all the formal opinions provided by the societal stakeholders were favourable.  

In  2017,  ETSI  launched  a  ‘3SI  programme’  to  engage  with  Annex  III  organisations.  This 
programme includes roundtables with ETSI officials and a representative of the stakeholders 
within ETSI (the ‘3SI Advocate’) to discuss inclusiveness issues. ETSI has not introduced any 
mechanisms  similar  to  those  of  CEN  and  CENELEC  for  giving  non-industrial  Annex  III 
organisations  a  more  structural  role  in  the  standards  development  process,  such  as  a  formal 
right  of  opinion.  SBS  dissatisfaction  with  ETSI’s  inclusiveness  was  expressed  in  summer 
2021  in  the  public  consultation  on  the  roadmap16  for  a  future  Commission  standardisation 
strategy, commenting that “ETSI has so far not dedicated sufficient resources and budgets to 
increase its inclusiveness”17, as echoed by another SME association18. Similar opinions have 
been transmitted in the relevant Article 24 reporting by other organisations financed under the 
Regulation. For instance, ANEC’s report for  201919 quotes: “ETSI is reluctant to deepen its 
provisions on inclusiveness,  believing  itself to  be in  conformity to  the Regulation.  However, 
Annex  III  organisations  believe  ETSI  not  to  be  in  conformity”.  Similarly,  ECOS  states20: 
“Annex  III  participation  in  ETSI  remains  more  complex  compared  to  the  other  two  ESOs”. 
One  of  their  points  is  that  the  inclusiveness  of  the  process  cannot  be  separated  from  voting 
rights,  because  in  ETSI,  the  voting  rights  of  industrial  stakeholders  are  higher  than  the 
combined voting rights of any other category of stakeholders or Authority. The share of ETSI 
voting  rights  from  NSBs  coming  from  EU  Member  States  is  at  circa  2%.  The  voting  rights 
from  other  non-industrial  stakeholders  (civil  society,  academia,  research),  this  is  barely 
countable in case of a vote. 

These  concerns  have  been  echoed  by  certain  categories  of  stakeholders,  particularly  in  the 
case  of  accessibility,  where  some  representatives  of  people  with  disabilities  struggled  to 
perceive  the  process  as  inclusive  and  had  to  rely  on  liaisons  with  consumers’  associations. 
While,  strictly  speaking,  such  liaison  through  consumers’  associations  is  not  against  the 

16 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13099-Standardisation-strategy_en.  
17 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13099-Standardisation-
strategy/F2665680_en 
18 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13099-Standardisation-
Strategy/F2665677_en 
19 https://ec.europa.eu/docsroom/documents/44748  
20 https://ec.europa.eu/docsroom/documents/44749  

3 

 
 
                                                           
Regulation,  the  concerns  of  different  categories  of  stakeholders  question  whether  sufficient 
attention is being reserved to inclusiveness..  

2.2.1  Research bodies  

With respect to the implementation of Articles 5(2) and 9 of the Regulation, the reports of the 
ESOs21  highlight  that  there  were  different  activities  involving  research  organisations. 
However, the reports are not fully clear on the effectiveness of the activities, e.g. on its effects 
on the adoption of specific standards or increased participation.  

In  a  related  development,  in  October  2016,  and  as  renewed  in  October  202122,  CEN, 
CENELEC  and  the  Joint  Research  Centre  of  the  European  Commission  (JRC)  signed  a 
cooperation  agreement  to  bridge  research  and  innovation  with  standardisation,  to  help  to 
anticipate standardisation needs and to align on strategic priorities. 

The JRC also engaged with the COST Association through the JIS in informing and training 
on the benefits of standardisation to the research and innovation carried out in COST Projects. 
Through this link CEN-CENELEC provided several training modules since 2019. 

2.2.2  ICT tools 

The ESOs reported on investment  and the use of  ICT tools to  enhance the efficiency of the 
ESS and facilitate standardisation activities (such as cooperation between members, meetings, 
drafting  work,  accessing  working  documents  and  standardisation  deliverables,  and  remote 
communication and approvals).  

2.3 

Cooperation between NSBs and ESOs  

The  NSBs  and  the  ESOs  have  put  mechanisms  in  place  to  facilitate  exchanges  of  best 
practices,  such  as  advisory  groups,  monitoring  committees,  meetings  and  guidelines.  The 
three  ESOs  use  a  number  of  tools  to  facilitate  and  improve  the  exchange  of  best  practices 
among  each  other  and  between  national  delegations  (such  as  through  the  heads  of  national 
delegations  meetings  held  by  ETSI).  The  ESOs  also  cooperate  on  activities  including 
education,  training,  and  research  and  development  in  different  standardisation  related  areas, 
such as joint training activities on standardisation carried out by CEN-CENELEC. 

In  late  2021,  some  NSBs  voiced  concerns  about  their  role  within  ETSI.  There  are  ongoing 
discussions  between  ETSI  and  some  European  NSBs  about  their  recognition  as  strategic 
partners to standardisation.  

2.4 

Access of SMEs to standards (Article 6) 

Under Article 6(3) of the Regulation, NSBs shall prepare an annual report on their activities 
to  encourage  and  facilitate  the  access  of  SMEs  to  standards  and  the  standard  development 
procedures. This also includes reporting on the exchange of best practices aimed to enhance 

21 https://ec.europa.eu/growth/single-market/european-standards/notification-system_en#article24  
22 https://www.cencenelec.eu/news-and-events/news/2021/pressrelease/2021-10-21-jrc-cen-cenelec-renewed-
cooperation/  

4 

 
 
                                                           
SME participation  (i.e. Article 6(2) of the Regulation). The study supporting this report has 
precise  statistics  on  this  subject23,  and  shows  the  number  of  NSBs  that  allow  the  related 
category of stakeholders to be represented , as per the table below. For instance, the first value 
of the table (29/33) indicates that 29 NSBs allowed SMEs to be represented in CEN, out of 
the 33 that were associated to that ESO. 

Stakeho
lders / 
ESO / 
year 
SMEs 

Consu
mers 
Environ
mental 
stakeho
lders 
Social 
stakeho
lders 

CEN 

CENELEC 

ETSI 

2016 

2017 

2018 

2019 

2016 

2017 

2018 

2019 

2016 

2017 

2018 

2019 

29/33 

30/34 

31/34 

31/34 

29/33 

30/34 

31/34 

31/34 

28/39 

29/39 

29/39 

30/39 

25/33 

24/34 

25/34 

25/34 

20/33 

20/34 

22/34 

22/34 

26/39 

27/39 

27/39 

27/39 

24/33 

24/34 

26/34 

26/34 

18/33 

20/34 

23/34 

23/34 

22/39 

23/39 

23/39 

23/39 

21/33 

20/34 

23/34 

22/34 

17/33 

18/34 

20/34 

20/34 

19/39 

20/39 

20/39 

20/39 

It is worth noting that in some cases the total number of associated NSBs is much higher than 
the number of EU and EEA Countries. This is because ESOs include non-EU and non-EEA 
NSBs in their development processes.    

One striking piece of information coming  in the study is that NSBs in CEN and CENELEC 
“have  been  granting  more  and  more  special  rates  to  SMEs  for  participating  in 
standardisation activities between 2015 and 2019, while ETSI NSBs faced a decreasing trend 
in  such  special  rates  provided”.  On  this  matter,  the  2019  ETSI  report  24  also  reads:  “ETSI 
does  not  operate  under  the  national  delegation  principle  so  their  [SMEs]  participation  in 
ETSI’s  technical  organisation  and  work  is  direct  through  their  membership  of  ETSI  […]. 
Only during the public approval process do these stakeholders need to submit their comments 
via the ETSI NSBs”. 

2.5 

Participation of Public Authorities in European Standardisation (Article 7) 

For  the  implementation  of  Article  7  of  the  Regulation,  there  is  little  systematic  and  official 
information  in  the  reports  to  the  Commission  on  the  involvement  of  Public  Authorities  in 
standardisation  activities.  Reports  from  the  ESOs25  typically  refer  to  actions  4  and  9  of  the 
JIS26 as suitable exercises. As precise data are not available, a monitoring instrument may be 
considered in the future. 

23 https://doi.org/10.2873/504681  
24 https://ec.europa.eu/docsroom/documents/44751  
25 https://ec.europa.eu/growth/single-market/european-standards/notification-system_en#annual  
26 Action 4: Improvement of standardisation awareness in national public authorities; Action 9: Inclusiveness, 
transparency & effective participation of all stakeholders in the European Standardisation System; 

5 

 
 
 
                                                           
2.6  Annual Union Work Programmes (Article 8) 

In accordance with Article 8, the Commission has adopted Annual Union Work Programmes 
(AUWP)  for  European  standardisation27.  With  the  AUWP,  the  Commission  gives  the  ESOs 
an  orientation  to  work  on  standards  and  standardisation  deliverables  and  also  how  to 
strengthen the involvement of small  and medium-sized enterprises and societal  stakeholders 
in  the  process.  This  document  has  been  progressively  shaped  to  provide  prioritisation  with 
regard  to  EU  policies  as  to  provide  a  sense  of  orientation  and  expectation  from  the  policy-
maker perspective, and  also  providing better  guidance to  the standardisation  stakeholders in 
terms of delivery.   

2.7 

Standardisation requests (Article 10) 

In 2015-2019, the Commission issued 35 SRs, with an additional nine in 2020. Out of these 
44 SRs, six were rejected (13.6%). The ESOs have often reported the following reasons for 
rejecting:  disagreement  on  certain  requested  standards;  disagreement  on  some  requirements 
contained in the SR; disagreement that certain requested technical specifications are needed in 
support of a specific essential requirement; or disagreement with deadlines set for the delivery 
of requested standards.  

The  rejection  of  SRs  can  have  significant  impacts  on  the  (i)  implementation  of  a  fair  and 
effective  Internal  Market;  (ii)  competitiveness  of  industries;  (iii)  participation  of  societal 
stakeholders; and (iv) technological sovereignty of the Union. It may also lead to relying on 
non-EU standards, where it may not  be  clear to  which extent an inclusive process  has  been 
followed.  

On the execution of SRs, it has also happened that, despite the acceptance by CEN of a SR, 
only a part of it was implemented28. 

2.7.1  Commission support to the execution of the standardisation requests (HAS)  

Before 2018, there was a service contract (“New Approach Consultants” – NACs) to help the 
ESOs  verify  the  compliance  of  draft  HENs  with  the  Commission’s  request.  Under  that 
contract, the success rate of standardisation deliverables cited in the OJEU was limited and a 
substantial  backlog  in  non-cited  standards  accumulated.  In  March  2017,  the  Commission 
internal  database  listed  596  unprocessed  HENs  submitted  by  the  ESOs.  In  order  to  have  an 
effective service for the implementation of the Regulation, the Commission called for a new 
service contract29 (“HAS”). In implementing the new system, the Commission paid attention 
to resolve some identified problems of the past and to ensure the: 

  voluntary  nature  of  the  service  for  the  ESOs,  also  in  line  with  the  previous  NAC 

scheme; 

27 https://ec.europa.eu/growth/single-market/european-standards/notification-system_en#annual  
28 in the case of the Marine Equipment Directive 2014/90/EU, despite the acceptance by CEN of the SR M/557, 
the  responsible  Technical  Committee  has  not  progressed  with  its  implementation,  as  far  as  hoses  were 
concerned. 
29 https://ec.europa.eu/growth/content/technical-assistance-area-harmonised-standards_en  

6 

 
 
                                                           
  clear separation of roles – consultants do not draft or negotiate the content of HENs, 

they focus on assessing whether HENs satisfy the requirements of EU law; 

  availability of sectoral services to guide on new doubts, questions or issues that may 

occur in drafting HENs; and 
role of the Commission for the final decision to cite HENs in the OJEU. 

 

The  Commission  structured  the  work  of  the  HAS  consultants  in  a  manner  that  would  not 
delay the production of HENs. 

Since the operation of the HAS consultants system, as of December 2021, the backlog of non-
assessed  and  processed  HENs  submitted  by  the  ESOs  for  citation  in  the  OJEU  has  been 
reduced to only two standards from 2018 and five from 2019, which are currently pending a 
Commission decision. 

As  of  9  December  2021,  the  Commissions’  contractor  managing  the  HAS  consultants,  has 
received 3312 requests for assessments of draft HENs from the ESOs, under 21 pieces of EU 
legislation,  of  which  2944  have  been  processed  and  368  were  non-eligible30.  Across  all 
sectors,  only  27,58%  of  the  HAS  assessments  came  out  as  positive31,  mainly  due  to 
inadequacy  with  EU  law,  showing  that  more  work  is  to  be  invested  in  the  development 
process of standards – e.g. within the technical committees – so that the work is more aligned 
with the policy and legal requirements. 

2.7.2  Production and citation of HENs 

In  2016  and  2017,  stakeholders  had  been  raising  the  issue  of  delayed  citations  of  certain 
HENs. As a result, the Commission has been monitoring the different stages of the process as 
of 2018 and the related results are herein reported also for the year 2020.  

In 2018-2020, the Commission received 1247 HENs in support of EU legislation. Of these, 
238  were  resubmissions  of  existing  HENs  under  new  Regulations.  Therefore,  the  newly 
submitted standards were 1009, including 76 corrigenda and 267 amendments.  

In the following analysis, this report focuses on the new submissions, which were distributed 
per year and per ESO as follows: 

Delivered HENs 
CEN 
CENELEC 
ETSI 
Total 

2018 
231  
134  
8 
373  

2019 
216 
161 
11 
388 

2020 
129 
104 
15 
248 

Total 
576  
399  
34 
1009  

By 9 December 2021, 576 HENs have been cited in the OJEU, 17 are in the process of being 
cited, 371 have not been accepted and 45 are pending decision.   

30 e.g. because not relating to HENs or because of redundant requests 
31 Note: a single standard is assessed from 2 to 4 times, and each time is counted separately in this statistics. The 
shown number is therefore not indicative of the negative assessments that appear at a late stage.  

7 

 
 
 
                                                           
Based on Commission internal databases, which interacts with the ESO’s IT-tools, the median 
time between the adoption of a HEN by CEN, CENELEC or ETSI, and the formal delivery to 
the  Commission  for  citation  in  the  OJEU  is  100  days.  This  means  that  the  ESOs  may  take 
over  three  months  to  submit,  to  the  Commission,  a  standard  after  it  was  made  publicly 
available  (i.e.  available  for  purchase),  before  the  Commission  can  start  assessing  and 
processing  the  HEN  for  citation  in  the  OJEU32.  The  average  time  (in  brackets  in  the  table 
below) is much higher, due to some extreme cases33.   

Median (and average) time (days) 
between ESO’s adoption and delivery 
to the Commission 
CEN 
CENELEC 
ETSI 
Total 

2018 

2019 

2020 

Total 

105 (199) 
75 (115) 
218 (424 )  189 (1374 ) 

29 (27) 
109 (224 ) 

49 (58) 
117 (683 ) 

70 (91) 
82 (481) 
20 (29) 
75 (251 ) 

83 (141) 
186 (822) 
28 (38) 
100 (407) 

With respect to the processing of HENs by the Commission itself, the median (average) time 
from  delivery  by  the  ESOs  to  the  Commission  to  citation  in  the  OJEU34  has  steadily 
decreased, as per table below. The longer processing time needed by the Commission in 2019 
was due to the change of publication method (from the C-series of the OJEU to the L-series of 
the OJEU), which required a transitional adaptation period.  Since then, the Commission has 
substantially  reduced  the  duration  of  its  own  processes.  In  2020  and  2021,  the  Commission 
performed better than in 2018 (when citation of HENs in the OJEU was still done under the 
procedures for the publication in the C-series of the OJEU).  

Median (and average) time (days) 
between delivery to the Commission 
and citation in the OJEU 

2018 

2019 

2020 

2021 

238 (298) 

292 (322)  

228 (231) 

108 (121) 

2.8 

Formal Objections (Article 11) 

In  2015-2019,  a  total  of  20  formal  objections  against  specific  HENs  were  presented  in 
accordance to  the provisions  in  Article 11 of the Regulation.  Three more were presented in 
202035.  The  average  duration  of  a  formal  objection  (intended  as  the  time  between  its 
presentation and resolution) is 1084 days, i.e. 3 years. 

32 The Commission cannot start its own internal processing of HENs until they have been formally delivered by 
the ESOs to the Commission.  
33 The big discrepancy for CENELEC is due to the bundled submission of certain old standards and related more 
recent  amendments.  As  some  of  those  old  standards  dated  back  to  the  1990’s,  the  average  takes  into  account 
delays in the submission, and hence results are biased. In particular, most standards leading to these big delays 
can be ring-fenced to deliverables under Commission standardisation requests of the Ecodesign legislation. 
34 This covers the whole time needed by the Commission to first evaluate the HENs received from the ESOs and 
then carry out the internal procedure leading to citation of the HENs in the OJ. 
35 https://ec.europa.eu/growth/single-market/european-standards/notification-system_en#objections  

8 

 
 
 
 
 
                                                           
2.9 

Notification of stakeholder organisations (Article 12) 

The  Commission  has  established  a  dedicated  webpage36  for  the  notifications  referred  to  in 
Article 12.  

2.10 

ICT specifications (Articles 13 and 14) 

Many of the most common ICT technical specifications have been produced lately by private 
forums  and  consortia.  Article  13  of  the  Regulation  allows  the  Commission  to  identify  ICT 
technical specifications to be eligible for referencing in public procurement. This allows for 
more competition in the field and reduces the risk of lock-in to proprietary systems. A suitable 
list has been published on the Commission website37.  

In  addition,  having  common  ICT  standards  ensures  interoperability.  This  has  become 
increasingly  important  as  many  more  devices  are  being  connected  to  each  other.  With  the 
Communication on ICT Standardisation Priorities38 of 2016, the Commission has proposed to 
focus  standard-setting  resources  and  communities  on  five  priority  areas.  The  importance  of 
ICT standards was stressed again in the Industrial Strategy of 202039. 

A European Multi-Stakeholder Platform  on  ICT Standardisation40 has  been set  up to  advice 
the  Commission  on  matters  relating  to  the  implementation  of  ICT  standardisation  policy, 
including priority-setting, and the identification of specifications. More than 150 actions were 
identified and grouped into thematic areas. 

3  Financing the ESS (Article 15, 16 and 17) 

The EU financing to the ESOs and the Annex III organisations for activities is defined under 
Articles 15, 16 and 17 of the Regulation. 

In 2015-2019, the grants for standardisation activities from the EU totalled around EUR 105.3 
million  (EUR  85  million  allocated  to  the  ESOs  and  EUR  20  million  to  the  Annex  III 
organisations).  EU  and  EFTA  co-finance  part  of  the  organisations'  costs  and  activities.  The 
grants are provided in the form of operating and action grants. The operating grants contribute 
to  the  operating  budget  to  carry  out  annual  work  programmes,  which  specify  the  planned 
activities  for  each  year,  in  line  with  the  Commission’s  standardisation  objectives.  The 
operating grants for the period 2015-2019 covered a broad range of everyday activities. The 
action  grants  financed  specific  activities  in  support  of  EU  legislation  and  policies.  In  2019, 
action  grants  made  up  66%  of  EU  financing  to  the  ESOs  and  Annex  III  organisations.  The 
Commission follows up on the execution of the funded activities via reporting from the ESOs. 

36 https://ec.europa.eu/growth/single-market/european-standards/notification-system_en 
37 https://ec.europa.eu/growth/single-market/european-standards/ict-standardisation/ict-technical-
specifications_en 
38 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52016DC0176 
39 https://ec.europa.eu/growth/industry/policy_en - industrial-strategy-2020 
40 https://ec.europa.eu/transparency/expert-groups-register/screen/expert-
groups/consult?do=groupDetail.groupDetail&groupID=2758  

9 

 
 
                                                           
Among the ESOs, CEN has been the main recipient, receiving approximately 71% of the total 
funding provided to the ESOs in 2015-2019, followed by ETSI (22%) and CENELEC (7%). 
The  overall  shares  of  the  total  EU  funding  to  the  ESOs  provided  for  operating  grants  and 
action grants have remained generally stable over the reporting period. 

The financial support to the Annex III organisations aims to improve the inclusiveness of their 
respective  interest  groups  in  the  development  of  standards,  and  has  increased  overall  in  the 
last 5 years. SBS and ANEC have received the largest shares (42.5% and 34.5%, respectively) 
of the total EU financing provided to Annex III organisations between 2015 and 2019. ECOS 
received 15.7% of the total financing and ETUC 7.3%. 

Regarding  the  simplification  of  the  financing  of  the  ESS  and  the  reduction  of  the 
administrative  burden,  in  2015,  the  Commission  introduced  a  lump-sum  mechanism  for 
financing certain  costs within their grant  agreements, such as person-days required or travel 
costs incurred. This mechanism helped reduce the administrative burden of having to justify 
and  record  each  individual  case  of  such  costs.  However,  an  analysis  revealed  that 
beneficiaries  continued  to  have  uncertainties  regarding  the  records  required  for  potential 
audits.  

As  regards  reporting  requirements,  the  stakeholders  perceive  some  of  these  reporting 
activities as burdensome. The drafting of action plans and reports for the operating grant  are 
the most time-consuming tasks, with a slight increase in the required person-days since 2015. 
However, while the reported data from the ESOs show an increase in the average time needed 
to draft proposals for action grants, they show a decreased average time for the reporting on 
action grants. 

4  Conclusions 

This  second  report  to  the  European  Parliament  and  Council  on  the  implementation  of 
Regulation (EU) No 1025/2012 shows that the European standardisation system improved in 
some aspects – e.g. with regard to new IT tools – but that there is room for improvement in 
different areas. This applies in particular to aspects of inclusiveness, the role of NSBs in the 
ESS and the delivery time of HENs to the Commission, as illustrated above. 

As regards the time for processing standards and standardisation deliverables, both the ESOs 
and the Commission must continue improving their efforts to increase the efficacy despite the 
Commission’s recent efforts to substantially reduce its adoption time for the publication of the 
HENs. 

10