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ECOS is a European umbrella organisation representing the interests of environmental NGOs in standardisation activities. With 25 member organisations and counting, ECOS fulfills the requirements of Annex III of the EC-proposal and actively participates in standards development. Learn more at www.ecostandard.org.
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The European umbrella organisation representingenvironmentalinterests in standardisation activitiesIMCO-hearing « European standardisation » 23.11.2011, Ralf Lottes, ECOS Secretary General
25 Member organisations at European and national level (and counting) • Founded 2001 to represent environmental NGOs (ENGOs) in standardisation • Fulfills requirements of annex III of EC-proposal • More details: http://www.ecostandard.org/
ECOS’ role & experience • CEN associate member and CENELEC cooperating partner, ISO/IEC active liaison • Active with technical experts in standards development (about 40 technical bodies) • Contribution to policy debates within CEN & CLC and with the European Commission • Ralf Lottes was a member of EXPRESS-panel • Represents a part of civil society and the public interest in European standardisation Only environmental NGO worldwide so deeply involved in standardisation work!
Transparency and stakeholder participation (chapter II) - 1 • Central article for ECOS: Art. 5 I, since it enshrines “appropriate representation” in the procedures for EU-driven standardisation activities. • Whether “appropriate”, “balanced” or any other is secondary compared to the principle as such. • Whatever the adjective, however, a definition is necessary. Otherwise no consequences.
Transparency and stakeholder participation (chapter II) - 2 • Why need annex III organisations be “appropriately represented”? – Because the national delegation principle (currently) does not work for those stakeholder groups. • ENGOs have been systematically represented in only 1 MS (DE). Henceforth also in the UK. • Various reasons for that, but certainly far from appropriate Need for EU level corrective.
Appropriaterepresentation - content • Absence of obstacles to participation, e.g. fees for participation or commenting (EU and national) • Effective membership (see ANEC-proposal) – from representation to influence: Equal weight & impartial appeals procedure • For environmental interests: Tools to integrate environmental aspects into standardisation, since environment still not mainstream(ed). Existing CEN tools are best practice examples.
Stages of representation • Art. 5 outlines the stages very well – except: • The voting stages are missing! – to progress a standard from one stage to the other, incl. final vote (before publication). • EC impact assessment does not spot any inconvenience, just questions feasibility (NSBs). • Two limits for (annex III-) beneficiaries of votes: - Content: Actual participation in elaboration of standard - Time: As long as stakeholder group not systematically represented in tech. work at national level (2/3 of NSBs)
Miscellaneous • ECOS applauds art. 12 (fin. for annex III –org.), as recommended by EXPRESS and EP before. • Need for speed: ESOs have done a lot already, look at EC internal procedures for reserves! • EC-Communication COM(2011)311 final: - Extension to other policy fields («societal challenges») shall remain a case-by-case decision for best regulatory tool. - « Mainstreaming environmental issues » (action points 8,9) most welcome, since crucial! • Scientific support by Joint Research Center welcome!
THANK YOU FOR YOUR ATTENTION! Ralf Lottes, Secretary General of ECOS Mundo-B, The Brussels Sustainable House Rue d’Edimbourg 26, B-1050 Brussels, Belgium Switchboard: + 32 2 894 46 68 Direct line: + 32 2 894 46 55 Fax: + 32 2 894 46 10 Ralf.Lottes at ecostandard.org http://www.ecostandard.org