1. The European umbrella organisation representing environmental interests in standardisation activities IMCO-hearing « European standardisation » 23.11.2011, Ralf Lottes, ECOS Secretary General

2. 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/http://www.ecostandard.org/

3. 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!

4. 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.

5. 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.

6. Appropriate representation - 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.

7. 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)

8. 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!

9. THANK YOU FOR YOUR ATTENTION! Ralf Lottes, Secretary General of ECOS Mundo-B, The Brussels Sustainable House Rue dEdimbourg 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