2004-04-15 ECOS Presentation 1

ECOS:ECOS:NGO(s) in standardisationNGO(s) in standardisation

at European levelat European level

A valuable contribution of ENGOs - An indispensable requirement for public acceptance of (envtal.) standards

EC workshop, 2005-12-02

ECOSECOS

• European EEnvironmental CCitizens OOrganisation for SStandardisation

• Membership: 4 European and 11 national/ regional envtal. NGOs

• Based in Brussels (close to CEN/ CLC)• Start: 1st November 2002 under EC service

contract following a tender

ECOS’ Member ECOS’ Member organisations (1)organisations (1)

• BirdLife - European Community Office• European Environmental Bureau• Friends of the Earth Europe• WWF - European Policy Office• Bellona (NO)• BUND-Bund Umwelt- und Naturschutz D. (DE)• BBU-Bundesverband Bürgerinitiativen U. (DE)• Bond Beter Leefmilieu (BE)

ECOS’ Member ECOS’ Member organisations (2)organisations (2)

• Deutscher Naturschutzring (DE)• Danmarks Naturfredningsforening (DK)• France Nature Environnement (FR)• Inter-Environnement Wallonie (BE)• Stichting Natuur en Milieu (NL)• Svenska Naturskyddsföreningen (SE)• new: Clean Air Action Group (HU)• applied: Friends of the Earth Latvia (LTV)

ECOS’ MissionECOS’ Mission Integration of environmental aspects by• Contributing technical expertise to the work of

technical stand. bodies (CEN, CENELEC, ISO)• Representing societal interests and improving

procedures for balanced stakeholder participation (in CEN, CLC -political bodies, EC/EFTA stand. policy)

Examples for Examples for involvementinvolvement

• Air, Water, Soil, Sludges (CEN TCs)• Energy using Products (CLC TC 111X)• WEEE-marking (CLC BT TF 116-3)• Envtal/ energy performance of buildings,

Dangerous Subst. in Constr. Products Directive (various CEN TCs, BT WGs)

• GMO-detection - sampling (CEN/ ISO)

Principles for choice of Principles for choice of Work itemsWork items

• EC-mandate or potential link to EC-policy?• potential for envtal. impact, alternatives?• expertise available in the constituency of

ECOS or in institutions related to its members?• can synergies be created with other

stakeholders or the environmental helpdesk?

Role in CEN & CENELECRole in CEN & CENELEC

• CEN: Associate member since 07/2003 (access to all bodies except CA part I)

• CENELEC: Co-operating partner since 07/2005 (potential access to all bodies except CA-Conseil d ’Administration)

• ECOS representatives have to be part of the consensus, but no vote (neither at technical, nor political level)

How to add value?How to add value? Requirement 1: a good internal

organisation/ information including backing at national level by members

• in the interest of CEN/CLC to avoid having comments raised at a late stage

• difficult to raise awareness & interest among ENGOs to dedicate their scarce staff resources to this subject

Current state Current state Requirement 1:Requirement 1:

• A good network of experts (many need training on standardisation procedures)

• Unequal coverage in the work of member organisations (Europ.>nation.)

• A growing involvement and presence on Europ. level, lacking national back-up

• A one-man secretariat through which all admin., financial and policy issues pass

How to add value?How to add value? Requirement 2: sufficient funds to• allow experts to attend meetings all over

Europe (and beyond, if ISO-link), to elaborate comments

• pay substantial fees to CEN/CLC (lump sum or service fees, respectively)

• hold an adequate secretariat to follow the standardisation Work programme, EC stand. policy, admin., etc.

Current state Current state Requirement 2:Requirement 2:

• 3-year initial phase has just ended, intermediary funding assured, awaiting decision on funds for 2006 (EC/EFTA)

• discuss set-up beyond 2006

• recruitment of second full-time staff?

• prioritise subjects for involvement

How to add value?How to add value? Requirement 3/ current state: a process giving a

fair chance of having an impact:• being heard in technical bodies: sometimes

difficult to get «foot in the door» (misunderstanding about ECOS’ role and rights among TCs resulting in withholding information), but once TCs/WGs are acquainted to experts, their input is valued - however, no vote!

How to add value?How to add value? Requirement 3: a fair process (cont’d):

• being heard at Central level (CEN Management Center and CLC Secret.):

established now, fair treatment, open ear, help with problems at technical level: POSITIVE! Conclusion: Standardisation professionals in CEN & CLC are aware of the importance of stakeholder involvement!

How to add value?How to add value? Requirement 3: a fair process (cont’d):• being heard at Central level (political

bodies of CEN/CLC): established now, listened to however: procedures designed for NSBs,

don’t always take associates’ needs and (small) structures into account, No vote!

CEN-SABE (Strategic CEN-SABE (Strategic Advisory Body on Envt.)Advisory Body on Envt.)

• New SABE-strategy a step forward: Please implement it!

• Includes envtal. «avantguarde» within CEN• Associates do vote in SABE!• However: Representation not balanced, includes

members «stepping on envtl. break»• Can trigger discussions (e.g. on EHD)• However: Merely advisory (to CEN BT)

CEN-EHD (Environ-CEN-EHD (Environ-mental Help Desk)mental Help Desk)

• Founded after German DIN-model, unsollicited comments to techn. bodies after scan of CEN Work programme,

• 1 or 2 progr. Managers, • Problems: Merely advisory, insatisfactory

feedback by TCs• Therefore: «review of operational procedures

required» on BT-agenda

CENELEC TC 111X CENELEC TC 111X (Environment)(Environment)

• Advisory and standards-writing function (in WGs, e.g. on Energy using Products)

• Smaller than CEN SABE, less imbalanced• Includes environmental «avantguarde» within

CLC, but also members «stepping on break»• Still relatively new

The legal framework (1)The legal framework (1) Essential requirements, EC-mandates and

monitoring of compliance:• Clear-cut ess. requirements & EC-mandates are

the basis for focused and sucessful standards development, no political decisions (thresholds) in standards (standardisers usually agree)

• Weak point: Compliance monitoring, e.g. in CEN by CEN-consultants (funded by EC, but carry out task within CEN-system), EC doesn’t have the staff resources to do it themselves

The legal framework (2)The legal framework (2)

Revision of directive 98/34• Proposal to include standardisation principles

by EC - ECOS/ANEC: add balanced stakeholder participation!

• Desirable to include s.th. like the cross-compliance clause of art. 6 EC-treaty to be applied to standardisation (such an obligation to integrate envtal. aspects in stand. work is already part of EC/EFTA guidelines for stand.)

Examples of ECOS-Examples of ECOS-involvement (1)involvement (1)

WEEE-marking standard (CLC):• directive 2002/96/EC provides for two types of

marking (consumers, producer identification for treatment facilities)

• potential exception for one has been extended to other by CLC-committee

• after not being heard, ECOS has drawn EC’s attention to non-compliance, CLC has recent-ly amended standard (currently voted upon)

Examples of ECOS-Examples of ECOS-involvement (2)involvement (2)

Development of role of CEN-EHD:• recent initiative to review operational

procedures• supported higher and more stable funding (2

programme managers)• helped to improve terms of reference• will keep on pushing for a strenghtened

position of EHD within CEN

ConclusionsConclusions 1. ECOS needs to step up a gear in order to make a

contribution necessary to provide legitimacy to process, therefore needs increased resources!

2. Even much more so on national level! 3. Despite some steps in right direction, process still

needs substantial further improvement to offer sufficient guarantees & well enough designed tools, e.g.: Vote, better compliance check, mandatory requirement for envtal. integration, EHD-comments, etc.,

Thank you for your Thank you for your attention!attention!

Contact: Boulevard de Waterloo 34

B-1000 Brussels

Tel.: + 32 2 289 10 93

Fax: + 32 2 289 10 99

e-mail: ralf.lottes@ecostandard.org,

info@ecostandard.org

web: www.ecostandard.org