Since the end of 2014, SBS has contributed to the EC’s Vademecum documents – a set of three non-legislative documents addressing the general role, preparation and adoption process of the standardisation requests (mandates). In other words, the Vademecum provides indications to all stakeholders (EC, CEN-CENELEC, ETSI, National Standardisation Bodies, Members States, Annex III organisations and any others) on the work methodology in the drafting process of a standard (mandates and therefore all standards indirectly).

In December, SBS participated in the 3rd meeting of the Working Group 'Operational Aspects and Strategy' of the Committee on Standards where Member States and Annex III Organisations – with CEN-CENELEC, ETSI and EFTA representatives – discussed the Draft Vademecum on European Standardisation. SBS strongly called for SME focus and requested that future standardisation requests made by the EC be of market relevance. Moreover, SBS gladly welcomed its involvement in the process as an Annex III Organisation representing SMEs and very much supported such a document as a key element of a harmonised implementation of a European Standardisation Policy and related practices. It was a unique opportunity for SBS to work, in a multifaceted set-up, on the legal basis for European Standardisation. The recognition of the specific status of Annex III Organisations is a step forward and is giving SMEs better access to the drafting standards process and to information pertaining to standards.

Furthermore, in January, SBS received confirmation of an additional representative seat in the Editorial Committee of the Task Force on Vademecum. All members and observers of the Committee on Standards were previously invited to the build-up of this Editorial Committee. The aim of the Task Force was to focus on terms of reference and timeframe, and most importantly to start the work in a consensus manner on the Vademecum texts. The Task Force aimed to agree on final versions of the

Vademecum 1

SBS & EFTA 2

New Enquiry Procedure

2

Joint SBS & CEN-CENELEC webinar

3

BT WG on ‘Market Relevance’

4

SBS Reports 4

SBS Consultation

on Services

5

Roundtable on

standardisation

5

CPR Workshop 6

SBS assesses CPR 6

SBS Position on Harmonised Standards

7

Technical News 7

Inside this issue

SBS Newsletter

N.2 April 2015 English version

Mandate on Vademecum Documents

achieved

Vocabulary box

* NSO: National Standardisation Organisation * TC: Technical Committee * WG: Working Group

Page 2 N.2 — 2015

Vademecum documents and to provide regular feedback to the plenary meetings of the Committee on Standards. The Vademecum documents were finalised end of March and sent to the Committee on Standards, as requested by the Committee’s mandate.

Over the course of the six weeks of the TF activities, SBS participated in weekly meetings, in line with the mandate of the Committee on Standards. SBS regarded this contribution exercise as crucial in order to defend better inclusiveness of SMEs in the process, and to maintain a more transparent process for mandated standards. The real achievement for SBS in this process is that the role and participation of SMEs have been adequately confirmed and mentioned in all steps of mandated-standards as well as in the Annex Z.

SBS looks into synergies with EFTA Member States

On 5th March 2015, EFTA organised a meeting between its members, the European Commission, SBS and the other Annex III Organisations within the EFTA Brussels headquarters. SBS presented an overview of its role and objectives since its founding in 2013 as well as its biggest achievements in representing SME interests within the European Standardisation System. The European Commission also made use of the meeting to draw attention to the upcoming roundtable discussion on 1st July 2015 to discuss the findings of an independent review of the European Standardisation System. Additionally, during the meeting participants discussed important issues regarding the representation of SMEs and other Annex III Organisation stakeholders, potential synergies with national standardisation bodies of EFTA Member States and the objective of creating an inclusive and open standardisation system in more detail.

CEN and CENELEC implement their New Enquiry

Procedure

The new enquiry procedure at CENELEC level was introduced this April. Following the introduction of the new enquiry procedure at CEN level earlier this year and the CENELEC Technical Board (BT) in January, the new enquiry procedure will now be implemented for both CEN and CENELEC and evaluated after one year. This new procedure was also the topic of the most recent CEN-CENELEC 10-10 Webinar on 10th April 2015. The aim of the modified enquiry procedure is to speed up the development time of European standards and allow technical bodies to skip the formal vote and go directly to publication at the end of the drafting or revision of a standard.

Although the implementation of a shorter timeframe for the enquiry procedure certainly brings some advantages with it in terms of efficiency, it may also limit the scope of influence of standardisation stakeholders. Both CEN and CENELEC now have a new enquiry procedure in place, however some minor differences regarding the involvement of the TCs responsible for a specific standard remain. This issue was also jointly brought forward by the Annex III Organisations during the CENELEC BT in January, to which SBS took part as observer – i.e. with no voting rights.

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Indeed, in the CENELEC new procedure, if the weighted vote is positive then the formal vote is automatically skipped regardless of the possible negative comments (and votes) that have been made at enquiry stage. The condition for skipping the formal vote is that the weighted vote and simple majority associated with the enquiry procedure have to be equal to 100%. Whereas in the CEN procedure, in the case of a 71% positive weighted vote and simple majority, the Technical Committees decide whether the formal vote can be skipped or not. In this context, the TC can therefore potentially take into account the voice of all stakeholders involved as well as eventual negative comments.

However, SBS is concerned about the difference between the two procedures and fears that the opportunity to react and comment after the enquiry may be limited in the CENELEC situation. In both cases, the enquiry period was reduced from five to three months which may potentially limit stakeholders’ capacity to react.

SBS and CEN-CENELEC organise a joint webinar

Within the framework of the CEN-CENELEC 10-10 Webinar series, SBS and CEN-CENELEC jointly organised a webinar on the use of the CEN-CENELEC Guide 17 “Guidance for writing standards taking into account SMEs needs” in Technical Committees. Guide 17 was approved in 2010 by CEN and CENELEC Technical Boards and serves as a manual for TCs when drafting a new or revising an existing standard in order to take SMEs into account. The webinar enabled participants to learn about the contents of the Guide, notably its scope, normative references such as the rules for the structure and drafting of

CEN-CENELEC publications, specific terms and definitions used in the standard drafting process as well as general considerations such as the need for understandable standards for all standard users. The central focus was put on the biggest part of Guide 17 – issues to consider during the standards development process. These include checking:

market relevance of a standard,

SME needs regarding a new or revised standard,

costs of investment and training required for the implementation of a standard,

availability of elements required such as testing equipment or intellectual property rights,

content of the standard regarding examples, supportive information, testing regimes and conformity verifications,

structure and presentation of content of the standard regarding the use of a clear language,

implications of changes resulting from new and revised standards as well as investigating need for assistance in standard implementation.

SBS and CEN-CENELEC are working together within the framework of the SME Working Group in order to extend the usage and knowledge of Guide 17. This webinar was, thus, the first step of a long series of actions regarding the promotion of Guide 17.

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CEN-CENELEC BT WG Market Relevance Meeting

On 26th March, the CEN-CENELEC BT Working Group on ‘Market Relevance’ got together to discuss the assessment of market relevance in new work item forms for the development of new or the revision of existing standards within technical committees of CEN and CENELEC. As a proper assessment of market relevance represents an important measure to ensure the inclusion of SMEs and other stakeholders in the standardisation process, SBS welcomed this assessment and supported the work already done by the Working Group. A central point on the agenda of the meeting constituted the results of a survey to technical committees on the usage of the new work item form and TC secretariats’ experience in justifying the revision of a standard or assessing compliance with market relevance.

Moreover, the WG meeting offered an important opportunity to discuss measures to engage potential stakeholders affected by standards within the standards development process at a national level, through tools implemented by National Standardisation Organisations. The inclusion of market relevance assessment within the standard drafting process thus represents a meaningful tool to ensure that SMEs’ interests are thoroughly taken into account in standardisation proposals and consequently contributes to the objective of establishing an open and inclusive European Standardisation System.

SBS publishes its Activity and Annual Reports

Drawing up a summary of last year’s activities, SBS recently finalised its Activity Report. The report was prepared for the EC and serves as a reporting tool detailing SBS’ Work Programme 2014, and hence detailing the association’s activities and achievements on each Work Package.

These include SBS’ work related to the monitoring of standardisation work and appointment of experts to TCs of the three European Standardisation Organisations (CEN, CENELEC and ETSI), contribution to policy and regulatory work in sectors related to standardisation or participation in the managing bodies of the ESOs.

Furthermore, SBS recently published its Annual Report 2014 outlining its accomplishments to the broader public. The Annual Report 2014 covers the work of SBS throughout the year as well as a view into the association’s role and

functioning aimed at a public not necessarily familiar with the European Standardisation System.

Page 5 N.2 — 2015

SBS launches a consultation on services

SBS launched a consultation among its member on obstacles regarding cross-border operations and provisions of services. The EC is currently working on the programming for a mandate on horizontal service standards which will deal, among other things, with matters related to information provision to customers, performance measurement and customer satisfaction measurement. Within this framework, the EC intends to identify reasons for technical barriers to trade related to standards. The survey is addressed to service providers, manufacturers and service recipients.

Standardisation stakeholders’ roundtable on

standardisation and competitiveness

“Standardisation is a key for competitiveness and innovation.”

This statement summarises the bottom line of the Standardisation Stakeholders’ Roundtable jointly organised by CEN-CENELEC and the Parliament Magazine on 4th March 2015, and hosted by Vicky Ford (MEP, IMCO Chair). SBS participated in this meeting alongside representatives from CEN and CENELEC, the European Institutions, and industry stakeholders. This roundtable offered different standardisation stakeholders the opportunity to put their views forward on how standardisation serves as an

important tool to boost competitiveness and enable innovation.

SBS Board Member and expert, Barbara Sorgato, gave her personal business perspective from the viewpoint of SMEs. Proving the example of SMEs in the structural fixing markets and their importance within the construction sector, she pointed out how SMEs have decided to jointly cooperate in standardisation in the best and most efficient way in order to have their common interests represented within the European Standardisation System in the interest of an overall favourable economic framework for businesses. The presentation also included a description of the work SME experts cover in TCs, the importance of the CEN-CENELEC Guide 17 “Guidance for writing standards taking into account SME needs” and the work carried out by SBS. The key message consisted of the need for cooperation among business sectors – notably multinationals and SMEs – in order to genuinely boost Europe’s competitiveness by enabling active participation of the whole business sector. A necessary requirement in order to keep the “biodiversity in the EU construction market”.

The roundtable ended with concluding remarks provided by Ms Ford, stressing once more the importance of standards in boosting Europe’s competitiveness.

Page 6 N.2 . — 2015

In the framework of the participation to the Workshop organised by RPA on the implementation of the CPR, SBS contributed to the main topics of interest to SMEs in the construction sector – e.g. the derogation from drawing up a DoP (Declaration of Performance) and the application of simplified procedures.

While SMEs in the construction sector are benefitting from the possibility to refer to sharing and cascading practices foreseen by Article 36 of the CPR, the same positive story cannot be shared for simplifications described in Articles 37 and 38. In this case, the issues are strictly related to the concept of “equivalence” of the procedures which can deviate from defined procedures, as set out in a harmonised standard. When a manufacturer uses a simplified procedure, the manufacturer has to demonstrate compliance of the construction product with the applicable requirements by means of a Specific Technical Documentation and also has to demonstrate the equivalence of the procedures used with the

SBS assesses the implementation of the Construction

Product Regulation

SBS participates in the CPR Implementation Workshop

On 23rd March, Risk & Policy Analysts (RPA) and EC DG GROW held a one-day workshop to discuss the state of play of the implementation of the Construction Products Regulation (EU) No 305/2011. The workshop followed a consultation exercise carried out from November 2014 to January 2015 to obtain the views of all stakeholders across the construction sector on the topic.

The consultation involved companies, notified bodies, technical assessment bodies, standardisation bodies, public authorities and associations/organisations. The contributions of the interviewed topics – e.g. CE marking, free movement of construction products, Simplification of the Legal Framework, Market Surveillance – and an overall view of the CPR have been summarised in a presentation and four Topical Reports (available here).

During the workshop, specific discussions took a deeper dive into stakeholders’ positions on the legal certainty and transparency of the rules for CE marking as well as on the application of simplified procedures foreseen by the Regulation. In this framework, precise references were made to the necessity of reconsidering the type of information reported on the CE mark while, as far as simplification is concerned, the contributions to the discussion of representatives of different Member States served to better outline potentialities and overcome the limited possibilities for SMEs to benefit from simplified procedures. RPA will further analyse the data based on the outcome of the workshop in order to publish a final report in August this year. SBS is going to follow these activities so as to guarantee that all the relevant issues related to the implementation of the CPR are correctly reported on and to voice the proposed solutions for the interests of SMEs.

Page 7 N.2 — 2015

Through its participation in meetings related to the Construction Product Regulation, SBS developed and shared positions regarding the future of harmonised standards under the CPR. SBS then considered it worthwhile to contribute in writing to the discussion by publishing a position paper on relevant topics for SMEs in the construction sector such as the quality of harmonised standards, the definition of less onerous methods for assessing the performance of construction products and SBS’ proposal of adjustments to Annex ZA in accordance with the prescriptions of the CPR on simplified procedures for micro-enterprises.

Indeed, SBS has recently worked on the proposal of introduction of a direct reference, in Annex ZA, to those provisions of Article 37 that allow micro-enterprises to proceed with the assessment and verification of constancy of performance (AVCP) of their products in accordance with System 4 instead of System 3. The relevance of this measure is strictly related to the possibility for micro-enterprises to get clearer information about how to treat their products and benefit from simplified procedures foreseen by the CPR. SBS will be monitoring the status of the proposal to make sure that all the relevant concepts will be properly reported in the final version of the template of Annex ZA.

SBS publishes a position on the future of harmonised

standards

procedures laid down in the harmonised standards. The problem, however, stems from the fact that the CPR does not sufficiently define the concept of “equivalence of procedures” which causes difficulties to prove that and how equivalent procedures comply with procedures stipulated in harmonised standards. Moreover, the difficulties SMEs are currently encountering in applying Articles 37 and 38 can also be seen through the lack of a template of reference for the drafting of the Specific Technical Documentation (STD).

In addition to the outlined considerations on simplified procedures, SBS also highlighted how the specificity of Article 5 on derogations from drawing up a DoP does not satisfy the needs for SMEs. Indeed, it appears evident that the strict prescriptions given in this article negatively affect the activities of those manufacturers who could more largely benefit from the possibility of being exempted from drawing up a DoP and currently see this option limited to very limited cases.

Tourism - ISO TC 228 - Tourism and related services

The SBS expert working on tourism was appointed at ISO level to evaluate if the standard proposed is in the interest of SMEs. Although the theme is acceptable, the content has to be shaped to be SME compatible. In tourism, variety is the asset of SMEs. The strength of SMEs is the personal and/or familiar approach to the guest, which is a fact far beyond what can be mirrored by a standard.

The initiative for standards in ISO TC 228 is rarely driven by the industry or SMEs but by standards institutes or certifiers, architects or government related bodies. The proposals thus tend to serve interests others than those of SMEs. Indeed, SMEs suffer from standards establishing burdensome evaluation, time-consuming documentation, costly investments and lots of obligations which – if not fulfilled – could entail liability.

Technical News

Page 8 N.2 — 2015

Cosmetics - CEN TC 392, CEN TC 369 and ISO TC 217

European standards for cosmetics are automatically endorsed in the national standards repository. It is therefore crucial to closely follow the work conducted by CEN because of the mandatory application and the direct impact on SMEs. In 2014, CEN TC 392 initiated an interesting relationship with DG SANCO with coordination meetings regarding the priorities of the work between CEN, the European Commission and experts. However since the responsibility of cosmetics is now under DG GROW, it is important that continuation of the work in favour of SMEs is properly taken on board.

Within CEN TC 392 on Cosmetics, the three Working Groups are of essence because of their direct relation with the Regulation 1223 of cosmetic products. These standards developed within

those WGs are widely used by industry and by authorities to comply with the regulation and/or verify the compliance.

At ISO level, the SBS expert still has no access to the TC. Problems related to recognition of SBS and its insertion within ISO categorisation requires many administrative steps before a TC secretariat provides access. SBS is working with ISO relevant contacts to solve the problem.

Space - Mandate M496: A closer look at satellite navigation industries

With the appointment of two new experts in the field of intelligent transport and satellite navigation systems, SBS extended its scope of appointed experts to the new field of space industry. Standardisation within this field is based on the European Commission Mandate 496, issued in 2011 and addressed to CEN, CENELEC and ETSI to develop standards regarding space industry. The scope of the mandate particularly aims at fostering European space industry projects such as the Galileo satellite navigation system, the Global Monitoring for Environment and Security (GMES) and projects in the satellite telecommunications and earth observation fields. By doing so clarity for potential future investment as well as interoperability between national and European space and ground-based systems shall be established.

Consequently, the mandate encompasses a broad scope of sectoral dossiers such as information exchange systems, navigation and positioning receivers for road applications and airport services, navigations and position applications with telecommunications, interoperability and integration of mobile satellite systems (MMS) and Fixed Satellite Systems (FSS) with terrestrial systems such as Next Generation Network (NGN) and with Global Navigation Satellite Systems (GNSS) such as Galileo.

In particular GNSS standardisation activnpities require a common approach between the ESOs’ TCs, especially regarding those working on navigation and positioning receivers for road applications, intelligent transport systems and satellite earth stations and systems. CEN/CLC TC 5 WG 1 deals with navigation and positioning receivers for road applications which is of relevance for any SME developing, integrating or dealing with positioning, navigation and timing (PNT) issues in their applications or service offerings. This may include GNSS or any other sensors such as Wi-Fi, Bluetooth, cell-ID, gyro, accelerometer or others. As different aspects of these topics are being discussed in various TCs, SBS aims to follow a holistic approach towards standardisation in space industries. Indeed, this is in view of hybrid solutions in which the use of GNSS technologies and Galileo is complemented with other sensors. SBS can therefore better respond to standardisation needs and SME interests in the field of navigation satellite systems.

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N.2 — 2015

Upcoming events

27.05.15 SBS Board Meeting & General Assembly

04.06.15 European Standards Day (Riga)

Small Business Standards (SBS) is a European non-profit association established in 2013 with the support of the European Commission. SBS is exclusively devoted to representing and defending SME interests in the standardisation system at European and international levels.

Its 22 members are national and European sectoral and inter-professional associations representing SMEs all over Europe. The membership is thus open to all associations matching these criteria.

SBS was created to meet the European Union’s aspiration to make the standardisation system as inclusive, transparent and open as possible, by strengthening the participation of “weak” stakeholders such as SMEs.

4, Rue Jacques de Lalaing B-1040 Brussels Phone: +32.2.285.07.27 Email: info@sbs-sme.eu

www.sbs-sme.eu

The work conducted

under SBS is mandated

and financed by the

European Commission

Intelligent Transport Systems - New Business Opportunities

Nowadays the majority of our society is constantly connected via their mobile phones, smartphones or laptops and evolution is proceeding towards a more ambitious target. There are about 7 billion people to be multiplied by 3-10 devices connected, in other words there are around 50 billion connected devices, this is called Internet of Things. An example is an intelligent house equipped with sensors allowing to turn the heating on remotely, depending on the temperature. There are also more and more popular wearables monitoring the levels of human physical activity and they therefore enable people to monitor their physical activity achievements and share with friends.

All these new situations and demands are opening many new business opportunities when it comes to SMEs. In the area of the transport system, data could be collected to be used to create a specific application. Here is a list of examples:

A driver wants to park his car and selects the destination in his car navigation system. The system will suggest appropriate parking basing on current availability.

Advise drivers (over car navigation system) on whether it is more efficient to drive directly to the destination or to use public transport along the way.

Reporting to the car service garage about ongoing problems with the car which would enable the garage to set up the repairs via contacting the owner.

Naturally in order to do so, for data to be efficiently collected, standards are needed. CEN TC278 is dealing with Intelligent Transport Systems. These systems consist in applying Information and Communication Technologies (ICT) to the transport sector. This contributed to increasing transport efficiency, sustainability, safety and security, and leverage new businesses.