Recently the European Commission published the study on “Access to Standardisation” commissioned by the European Commission, DG Enterprise and Industry, and carried out by EIM. The study is available for downloading at http://ec.europa.eu/enterprise/standards_policy/index_en.htm. Follow-on discussions and comments on the study are taking place these days.
The study is very interesting with a remarkable and convincing amount of data which has been collected as a base for the analyses. I can definitely recommend reading it. It asks the right questions, gives some helpful insights and draws some interesting conclusions given in 13 concrete recommendations. It is in particular worth noting that the study correctly looked at the aspect of access both from the perspective of participation in the development of standards and from the perspective of using and implementing standards.
Below I give some more detailed comments on specific aspects addressed in the study:
Better processes for public enquiry:
The full standards ecosystem ought to be considered:
Above all, the study focusses entirely on the formally recognised standards organisations CEN, CENELEC and ETSI and the national standards organisations. However, the European Standardisation System is more than just the formal standards bodies. Especially in Information and Communication Technologies (ICT) the majority of relevant standards is developed in global private standards organisations. Examples include organisations like W3C, OASIS or the IETF. Some of these global standards organisations can make significant contributions to best practices in standards development processes, openness, transparency and the way consensus is achieved. For global market access through standards and for the use and implementation of standards these organisations, or in other words: the full standards ecosystem, need to be considered regarding access to standardisation.
And finally I am sceptical about recommendation 9 on implementing a “uniform registration of the participation of the various types of stakeholders in technical bodies”. There is a risk of increasing the level of administration (and of associated cost) to an extend that is not justified by the expected improvements and insights from such a move.