1. 2004-04-15ECOS Presentation1 ECOS: NGO(s) in standardisation at European level A valuable contribution of ENGOs - An indispensable requirement for public acceptance of (envtal.) standards EC workshop, 2005-12-02

2. ECOS EC OSEuropean Environmental Citizens Organisation for Standardisation Membership: 4 European and 11 national/ regional envtal. NGOs Based in Brussels (close to CEN/ CLC) Start: 1 st November 2002 under EC service contract following a tender

3. ECOS Member organisations (1) BirdLife - European Community Office European Environmental Bureau Friends of the Earth Europe WWF - European Policy Office Bellona (NO) BUND-Bund Umwelt- und Naturschutz D. (DE) BBU-Bundesverband Bürgerinitiativen U. (DE) Bond Beter Leefmilieu (BE)

4. ECOS Member organisations (2) Deutscher Naturschutzring (DE) Danmarks Naturfredningsforening (DK) France Nature Environnement (FR) Inter-Environnement Wallonie (BE) Stichting Natuur en Milieu (NL) Svenska Naturskyddsföreningen (SE) new: Clean Air Action Group (HU) applied: Friends of the Earth Latvia (LTV)

5. ECOS Mission Integration of environmental aspects by Contributing technical expertise to the work of technical stand. bodies (CEN, CENELEC, ISO) Representing societal interests and improving procedures for balanced stakeholder participation (in CEN, CLC - political bodies, EC/EFTA stand. policy)

6. Examples for involvement Air, Water, Soil, Sludges (CEN TCs) Energy using Products (CLC TC 111X) WEEE-marking (CLC BT TF 116-3) Envtal/ energy performance of buildings, Dangerous Subst. in Constr. Products Directive (various CEN TCs, BT WGs) GMO-detection - sampling (CEN/ ISO)

7. Principles for choice of Work items EC-mandate or potential link to EC-policy? potential for envtal. impact, alternatives? expertise available in the constituency of ECOS or in institutions related to its members? can synergies be created with other stakeholders or the environmental helpdesk?

8. Role in CEN & CENELEC CEN: Associate member since 07/2003 (access to all bodies except CA part I) CENELEC: Co-operating partner since 07/2005 (potential access to all bodies except CA-Conseil d Administration) ECOS representatives have to be part of the consensus, but no vote (neither at technical, nor political level)

9. How to add value? Requirement 1: a good internal organisation/ information including backing at national level by members in the interest of CEN/CLC to avoid having comments raised at a late stage difficult to raise awareness & interest among ENGOs to dedicate their scarce staff resources to this subject

10. Current state Requirement 1: A good network of experts (many need training on standardisation procedures) Unequal coverage in the work of member organisations (Europ.>nation.) A growing involvement and presence on Europ. level, lacking national back-up A one-man secretariat through which all admin., financial and policy issues pass

11. How to add value? Requirement 2: sufficient funds to allow experts to attend meetings all over Europe (and beyond, if ISO-link), to elaborate comments pay substantial fees to CEN/CLC (lump sum or service fees, respectively) hold an adequate secretariat to follow the standardisation Work programme, EC stand. policy, admin., etc.

12. Current state Requirement 2: 3-year initial phase has just ended, intermediary funding assured, awaiting decision on funds for 2006 (EC/EFTA) discuss set-up beyond 2006 recruitment of second full-time staff? prioritise subjects for involvement

13. How to add value? Requirement 3/ current state: a process giving a fair chance of having an impact: being heard in technical bodies: sometimes difficult to get «foot in the door» (misunderstanding about ECOS role and rights among TCs resulting in withholding information), but once TCs/WGs are acquainted to experts, their input is valued - however, no vote!

14. How to add value? Requirement 3: a fair process (contd): being heard at Central level (CEN Management Center and CLC Secret.): established now, fair treatment, open ear, help with problems at technical level: POSITIVE! Conclusion: Standardisation professionals in CEN & CLC are aware of the importance of stakeholder involvement!

15. How to add value? Requirement 3: a fair process (contd): being heard at Central level (political bodies of CEN/CLC): established now, listened to however: procedures designed for NSBs, dont always take associates needs and (small) structures into account, No vote!

16. CEN-SABE (Strategic Advisory Body on Envt.) New SABE-strategy a step forward: Please implement it! Includes envtal. «avantguarde» within CEN Associates do vote in SABE! However: Representation not balanced, includes members «stepping on envtl. break» Can trigger discussions (e.g. on EHD) However: Merely advisory (to CEN BT)

17. CEN-EHD (Environ- mental Help Desk) Founded after German DIN-model, unsollicited comments to techn. bodies after scan of CEN Work programme, 1 or 2 progr. Managers, Problems: Merely advisory, insatisfactory feedback by TCs Therefore: «review of operational procedures required» on BT-agenda

18. CENELEC TC 111X (Environment) Advisory and standards-writing function (in WGs, e.g. on Energy using Products) Smaller than CEN SABE, less imbalanced Includes environmental «avantguarde» within CLC, but also members «stepping on break» Still relatively new

19. The legal framework (1) Essential requirements, EC-mandates and monitoring of compliance: Clear-cut ess. requirements & EC-mandates are the basis for focused and sucessful standards development, no political decisions (thresholds) in standards (standardisers usually agree) Weak point: Compliance monitoring, e.g. in CEN by CEN-consultants (funded by EC, but carry out task within CEN-system), EC doesnt have the staff resources to do it themselves

20. The legal framework (2) Revision of directive 98/34 Proposal to include standardisation principles by EC - ECOS/ANEC: add balanced stakeholder participation! Desirable to include s.th. like the cross- compliance clause of art. 6 EC-treaty to be applied to standardisation (such an obligation to integrate envtal. aspects in stand. work is already part of EC/EFTA guidelines for stand.)

21. Examples of ECOS- involvement (1) WEEE-marking standard (CLC): directive 2002/96/EC provides for two types of marking (consumers, producer identification for treatment facilities) potential exception for one has been extended to other by CLC-committee after not being heard, ECOS has drawn ECs attention to non-compliance, CLC has recent- ly amended standard (currently voted upon)

22. Examples of ECOS- involvement (2) Development of role of CEN-EHD: recent initiative to review operational procedures supported higher and more stable funding (2 programme managers) helped to improve terms of reference will keep on pushing for a strenghtened position of EHD within CEN

23. Conclusions 1. ECOS needs to step up a gear in order to make a contribution necessary to provide legitimacy to process, therefore needs increased resources! 2. Even much more so on national level! 3. Despite some steps in right direction, process still needs substantial further improvement to offer sufficient guarantees & well enough designed tools, e.g.: Vote, better compliance check, mandatory requirement for envtal. integration, EHD-comments, etc.,

24. Thank you for your attention! Contact: Boulevard de Waterloo 34 B-1000 Brussels Tel.: + 32 2 289 10 93 Fax: + 32 2 289 10 99 e-mail: ralf.lottes@ecostandard.org, info@ecostandard.org web: www.ecostandard.org