NORMAPME - Political interventions

Political intervention

NORMAPME influences International and European standardisation via its membership in ISO, CEN, CENELEC & ETSI and thanks to the recognition of our SME representation by the European Commission.

We are consulted on regular basis by the European Commission on European standardisation and conformity policies. In this framework, we write position papers, such as the one on modular approach. Also, informed on draft mandates we can comment and influence them. In addition, we take part in sectoral committees, like the European Construction Standing Committee. This allows us to effectively provide input for European sectoral policies.

In the ESO framework, our different statutes based on each ESO structure permit various types of interventions.

At CEN, as associate member, we are observer in the General Assembly and the Board. In addition, we participate in the Bureau Technique (BT) in charge of defining the standardisation strategy of CEN.

We are a cooperating organisation of CENELEC. We take part in the General Assembly and the Board as observer. We are also invited to attend technical Board meetings.

We are an ETSI full member. This allows us to take part in all ETSI activities and gives us the right to vote. We provide input for European telecommunication standardisation policy via an active participation in the General Assembly and in the Board where one of the NORMAPME staff members has been elected in 2005 for a 3 year term.

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Current developments in the European legislation

The European law is a basis for the standardisation activities and functioning of SMEs. Therefore we submit our amendments to the drafts of the new and revised legislative acts that could affect standardisation, certification or marketing of products. This activity requires constant communication with our members as well as the European Commission, Parliament and Council. At present we are involved in the writing of legislation in the following domains:

Ecodesign

In the framework of the recently adopted Action Plan on Sustainable Consumption and Production and Sustainable Industrial Policy the Commission agreed on the content of a proposal to recast Directive 2005/32/EC on the Ecodesign of energy-using products and the Energy Labelling Directive 92/75/EEC.

An Ecodesign Directive is already into force for the moment being establishing that specific eco-design requirements are adopted through product related implementing measures.
According to this recast the list of products to be submitted to implementing measures will be additionally and consistently updated soon through the introduction of products which are "energy-related" and not only "energy-using". This may in total cover two thirds of products in the EU including SMEs' production (in particular the construction sector).

The drafting of the list of products and of the working plan is conducted through a stakeholders' consultation. Unfortunately this consultation is conducted through the Ecodesign Consultation Forum where it is very difficult for SMEs to provide valuable input.

Therefore it may be difficult for us to actively discuss the content of this list through this Forum without some experts coming from the different sectors.

This is why NORMAPME and UEAPME, after consultation of their respective constituencies, have drafted a letter asking for consistency with the current framework especially in view of possible extension to construction products. NORMAPME and UEAPME will also cooperate for finding experts to be appointed for this Forum.

The problem of overlapping legislation has been addressed in the letter. NORMAPME is concerned by this issue especially because all implementing measures will be followed by harmonised standards which are drafted by the European Standardisation Organisations on the basis of a mandate.

Now the European Parliament is analyzing the proposal (responsible Committee is ENVI) and has apparently introduced some SMEs' friendly provisions. NORMAPME will inform you on further developments.

To see the integral text of the Directive: http://ec.europa.eu/environment/eussd/pdf/com_2008_399.pdf

To see the draft reports and the proposed amendments please click: http://www.europarl.europa.eu/oeil/FindByProcnum.do?lang=2&procnum=COD/2008/0151

More information can be obtained from Ms Valentina Mauri at v.mauri@normapme.com

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Construction Products

The construction sector is strategically important for Europe providing building and infrastructure on which all sector of the economy depend.

Prior to preparing a legislative proposal to simplify the Directive, in 2006 the Commission (EC) launched a consultation of interested stakeholders (like NORMAPME and its members) on important features of the Directive, the modification / suppression of which should make this legislative tool more simple and transparent, improve its effectiveness, and reduce the costs of its implementation.

Mid 2007, a draft document was presented to the main stakeholders. NORMAPME commented this proposal.

Based on these inputs, the EC finalised the proposal that should be submitted to the European parliament and the Council early 2008.

Following the vote of Ms Neris report at the committee on Internal Market and Consumer (IMCO) in the Parliament in 2009, the document has been adopted in April 2009 plenary session (22nd of April). As at this stage no consensus was found between the European Parliament, the Council and the Commission, a second reading will be necessary. Due to the European election in June, the process may be delayed.

There are still no political consensus between the Council, The European Commission and the European Parliament. The second reading process has not yet started in April 2010.

For more information please contact Ms Karine Iffour

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Finished campaigns

Toys

The total toy market is estimated in 17.3 billion euro at retail prices in 2002, which total imports amounting to over 9 billion euro. The European toy industry employs over 100,000 people directly and there are over 2000 companies operating in the toy and games sector. Most of them are small and medium sized enterprises. Some of the European regions in which toy companies are concentrated are the Jura in France, the province of Alicante in Spain and the Black Forest in Germany. There are toy industries also in some regions in the enlargement candidate countries.

Although the revision of the Toy Directive was in the pipeline, the process has speeded up following the Mattel cases of summer 2007 and the European Parliament communication urging the European Commission to revise this directive.

The final proposal of the directive was published on 25th January 2008. It addressed a wide range of issues to improve the existing rules for the marketing of toys that are produced in and imported into the EU. The directivel intends in particular to:

Manufacturing issues:

Prohibit the use of chemical substances that are susceptible to provoke cancer, so-called CMR (Carcinogenic, Mutagenic or toxic for Reproduction) substances;
Reduce the allowed limits of certain dangerous chemical substances like lead or mercury;
Prohibit allergenic fragrances;
Strengthen the rules to prevent accidents due to small parts in toys;

Marketing of products issues :

Oblige toy manufacturers to issue appropriate warnings to improve the prevention of accidents. The Commission will also carry out further work on more detailed guidelines on warnings;
Ban toys which are firmly attached to a food product at the moment of consumption and which require food to be consumed before getting access to the toy;
Reinforce the importer's responsibility for ensuring that toys imported into the EU are safe;
Foresee testing of toys through independent laboratories where no standards for toys yet exist (e.g. for toys with magnets)
Require toy manufacturers to establish comprehensive technical information for all their toys to allow Market Surveillance authorities to check the design and manufacture of the toy;
Enhance the visibility of the CE mark on the toy;

Market surveillance issues :

Oblige Member States to strengthen market surveillance and controls on the spot and at the EU-borders,
Oblige Member States to lay down and impose penalties if toy manufacturers/importers do not produce toys in line with the safety requirements of the Directive.

NORMAPME prepared its own postion paper with amendments to the proposal.

The EP and the Council reached a first-reading agreement before the plenary vote and on 18th December 2008 MEPs adopted the toy safety proposal with 481 votes in favour, 73 against, 40 abstentions. The amended text aims at making toys safer and will beef up safety regulations, ban carcinogenic, mutagenic or toxic for reproductions substances and restrict the use of heavy metals and of fragrances.

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eCommunication

At the end of 2007, the European Commission has presented the Electronic Communication Package amending five directives and a decision to the European Parliament and the Council. Considering the crucial and increasing importance of electronic communication for SMEs in their daily business, NORMAPME together with PIN-SME produced a draft position and a draft amendment proposal on the package.

On 24th September 2008 the European Parliament adopted the telecommunication package.

We are glad to inform you that most of our amendments were adopted in the text that was approved. It gives better protection to small business users vis a vis network operators and manufacturers and ensures a reasonable good quality of services as well as interoperability regardless of the technology used.

For more information please contact Ms Karine Iffour.

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Marketing of products (New Approach)

After stakeholder consultation, in which NORMAPME took part, in February 2007 the European commission presented the three following proposals to the European Parliament (EP) and the Council regarding the marketing principles of products (including CE marking) in Europe:

These proposals were handled first by the IMCO committee in the EP. During the process that ended by the vote of the reports of Mr Brie and Ms Shaldemose, NORMAPME met different Members of the EP in order to raise SME concerns (see Key elements of NORMAPME position). Meanwhile, the proposals were also dealt with by the Council. Hence, NORMAPME contacted National representations backed by our members' actions at National level.

The voting on the proposal at the Parliament's plenary session in Strasbourg took place on 21st February 2008. NORMAPME warmly welcomed the vote as the adopted "goods package" brings the legislation closer to the needs and expectations of European small companies, by enforcing the proportionality principle and facilitating conformity assessments for small series and made-to-measure products.

First of all, small series and custom-made goods will not be submitted to the same rules applied to large-scale production. Conformity assessments will be considerably facilitated, which is in line with the requests put forward by NORMAPME in the past months. Secondly, conformity assessment bodies will have to ensure proportionality and consider the so-called "4S", i.e. the operator's size, structure, economic sector and serial production when testing SMEs' products. Thirdly, the vote opens the possibility for trade associations to use and set up notified testing laboratories and certification bodies, thereby cutting costs and increasing the number and the SME-friendliness of facilities available.

NORMAPME praised the EU Institutions for reaching consensus on this crucial dossier, and encouraged all EU policymakers to take these principles into account in the upcoming revision of sector regulations and directives.

Full texts of the adopted documents can be found here:

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