EGMF position paper shares recommendations to enhance European Standardisation System
In response to the European Commission’s Call for Evidence on the revision of the Standardisation Regulation (EU) No 1025/2012, EGMF has submitted a detailed position paper outlining practical and forward-looking recommendations to enhance the European Standardisation System (ESS).
This revision is a key opportunity to address inefficiencies, improve legal clarity, and ensure the standardisation process remains a driver of innovation, competitiveness, and safety. With its deep industry expertise and representation of both large manufacturers and SMEs, EGMF is advocating for reforms that will help harmonised standards remain relevant, timely, and globally aligned.
EGMF’s response highlights six priority areas for improvement
1. Preserve voluntary standards and self-declaration
Maintaining the voluntary nature of harmonised standards is essential for flexibility and innovation. EGMF strongly supports this principle, which allows manufacturers – particularly SMEs – to meet legal requirements through standards without being locked into prescriptive rules. Voluntary standards also underpin the ability of companies to self-declare conformity, providing legal certainty and reducing administrative burden.
2. Reform the HAS Consultant System
The current HAS consultant framework suffers from inconsistency, lack of transparency, and procedural delays. Conflicting assessments cause confusion and slow down the standardisation process. EGMF calls for a comprehensive revision of the system.
3. Improve Alignment Between Standardisation and Legislation
The development of Standardisation Requests must be closely aligned with legislative timelines to avoid delays in implementation. The Annex Z correspondence table is a helpful tool, but the process for addressing consultant feedback is currently too complex.
4. Maintain Alignment with International Standards
European standards often build upon ISO and IEC standards. Preserving this alignment is critical for reducing trade barriers, ensuring global interoperability, and supporting European competitiveness. EGMF warns that current EU procedures make it increasingly difficult to adopt international standards, even when it would be logical and beneficial.
5. Improve the Formal Objection Process
The process for formal objections to harmonised standards is often unclear and disruptive. EGMF proposes amending Article 11 of the Standardisation Regulation 1025/2012 to enable early dialogue between the objecting Member State and the responsible standardisation body before a formal objection proceeds. This would prevent unnecessary delays or uncertainty for manufacturers, offer a quicker route to resolving concerns and improve mutual understanding and technical clarity. EGMF also supports enhancing Article 7 to encourage greater involvement of public authorities in standardisation work, reducing the likelihood of misalignment or last-minute objections.
6. Establish Proportionate Transition Periods
The current default of 18-month transition periods, regardless of complexity, is often unworkable. When new standards require significant redesign, sourcing of new components, or revalidation, manufacturers – especially SMEs – need more time to adapt.
Conclusion
EGMF encourages the European Commission to take these six recommendations into serious consideration as it revises the Standardisation Regulation 1025/2012. A better-functioning, transparent, and innovation-oriented Standardisation System is essential to support Europe’s competitiveness, sustainability, and consumer protection goals.
Download the position paper HERE.
