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5.5. Standards and the standardisation process

The standardisation process involves the development and establishment of technical standards that ensure products, services, and processes meet certain requirements for safety, compatibility, and quality. The process for making European standards involves the collaboration of various stakeholders, including industry representatives, consumer organisations, national standardisation bodies, and other relevant parties, such as civil society (represented by ECOS). The European standardisation system is primarily coordinated by the European Committee for Standardization (CEN) and the European Committee for Electrotechnical Standardization (CENELEC).

5.5.2. The standard-making process in short

A European standardisation process usually looks something like this:

  1. Identification of the need: The process starts with identifying the need for a new European standard. This can be initiated by industry associations, national standardization bodies, or other interested parties. They submit a proposal outlining the scope and purpose of the standard.
  2. Preparatory work: Once the need for a standard is identified, a Technical Committee (TC) or a Working Group (WG) is established within CEN or CENELEC to handle the standardization process. The TC/WG consists of relevant experts from member countries who are interested in contributing to the development of the standard.
  3. Drafting the standard: The TC/WG members collaborate to develop the draft standard. They review existing national standards, international standards, and other relevant documents to ensure consistency and avoid duplication. The drafting process involves discussions, consultations, and consensus-building among the members.
  4. Public Enquiry: Once the draft standard is ready, it is published for public enquiry. This allows interested parties, including organizations and individuals, to provide comments, suggestions, and feedback on the proposed standard. The public enquiry period typically lasts for a specified period (e.g., several months).
  5. Consensus and approval: The comments received during the public enquiry are carefully considered by the TC/WG members. They may revise the draft standard based on the feedback received. The goal is to achieve consensus among the stakeholders. Once consensus is reached, the final draft is submitted for formal approval.
  6. Formal Approval: The final draft standard is submitted to CEN or CENELEC for formal approval. The standard undergoes a final review process to ensure compliance with the organization's requirements. If approved, the standard is published and made available to the public.
  7. Implementation and adoption: After publication, the European standard can be implemented voluntarily by organizations, or it may be referenced in legislation to become mandatory in specific areas. The member countries of CEN and CENELEC are encouraged to adopt the European standards as national standards, thus promoting harmonization across Europe.

As can be gathered by this step-by-step, there are two major weaknesses with this process: First, that it is time-consuming, often taking 3-5 years, and secondly, that the stakeholders involved are limited. The time it takes to make a new standard can have detrimental effects on innovation, which can negatively impact the development and market-entry of lower-carbon products. By the time a standard is done, available technology may have already moved far beyond it. The fact that the stakeholders who are involved in the standard-making process is limited means that large, incumbent industry representatives can have an undue say over what the outcomes are, again to the detriment of smaller, newer and potentially more innovative and climate-friendly solutions.

5.5.2. Harmonised vs non-harmonised standards

There are two main types of standards in Europe: harmonised and non-harmonised standards. In short, harmonised standards are directly linked to EU legislation and provide a means for demonstrating compliance with EU requirements, while non-harmonised standards are voluntary and serve as industry-specific guidelines or best practices but do not have a direct legal relationship with EU law.

Harmonised Standards: Harmonised standards are developed under the European Standardisation System and are linked to European Union (EU) legislation. They are designed to support the implementation of EU Directives and Regulations that aim to harmonise technical requirements across member states. Harmonised standards provide a presumption of conformity with the relevant legislation when followed. Manufacturers can use harmonised standards to demonstrate that their products or services meet the essential requirements set out in EU law. Harmonised standards facilitate the free movement of goods and services within the EU's single market by ensuring a common baseline of technical requirements.

Non-Harmonised Standards: Non-harmonised standards, also known as voluntary or national standards, are developed by standardisation bodies at the national or international level, such as national standards organizations or international standards development organizations like ISO (International Organization for Standardization). These standards are not linked to specific EU legislation and do not provide a presumption of conformity with EU law. Non-harmonised standards are generally voluntary and serve as reference documents for best practices, technical specifications, and guidelines in various industries. While non-harmonised standards are not mandatory for compliance with EU law, they can still be used to demonstrate compliance with industry-specific requirements or customer expectations.

Why is this relevant for embodied carbon?

The CPR mandates the use of harmonised standards to determine the performance characteristics of construction products. These harmonised standards are developed by European standardisation organizations, such as the European Committee for Standardization (CEN) and the European Committee for Electrotechnical Standardization (CENELEC), in collaboration with industry stakeholders. In cases where no harmonised standard exists for a specific construction product, the CPR allows for the use of European Technical Assessments (ETAs) as an alternative. ETAs are issued by Technical Assessment Bodies (TABs) designated by EU member states. These assessments provide information on the performance of construction products and their fitness for intended use. The development and assessment of ETAs often involve the reference to relevant standards or other technical specifications.