EU Commission study on "Access to Standardisation"

Recently the European Commission published the study on “Access to Standardisation” commissioned by the European Commission, DG Enterprise and Industry, and carried out by EIM. The study is available for downloading at http://ec.europa.eu/enterprise/standards_policy/index_en.htm. Follow-on discussions and comments on the study are taking place these days.

The study is very interesting with a remarkable and convincing amount of data which has been collected as a base for the analyses. I can definitely recommend reading it. It asks the right questions, gives some helpful insights and draws some interesting conclusions given in 13 concrete recommendations. It is in particular worth noting that the study correctly looked at the aspect of access both from the perspective of participation in the development of standards and from the perspective of using and implementing standards.

Below I give some more detailed comments on specific aspects addressed in the study:

Better processes for public enquiry:

I strongly support recommendation 10 that “public enquiries are indeed published widely and that stakeholders not (yet) participating in standardisation are indeed reached”. The process of public enquiry as practiced today is rather outdated. Most notably it does not sufficiently leverage modern ICT technologies. Their use can improve transparency and the ability of real “public” outreach to a large extend. In addition, the process for public enquiry and for reaching consensus should be harmonised across the national standards bodies to ensure that the same rules apply in all member states.

Use of modern collaboration technologies:

Similarly strong I support recommendation 12 to increase the use of modern collaboration technologies for standards development in order to further facilitate broad stakeholder participation and involvement and to minimise the requirements for travelling. This would be an important step towards smarter ways of collaboration. Several global standards organisations already have implementations of such technologies, see for instance W3C, OASIS or the recent activities around the ETSI Green Agenda.

Three identified major barriers for using standards:

Very interesting are the three top barriers which have been identified for using standards: (i) price of standards; (ii) cost of implementing the standards; (iii) the number of cross-references in the standards (p. 9 of the study). Needless to say that I wholeheartedly agree that these are important topics to be addressed. It is very positive that barriers for the use of standards have been identified with such clarity. It is up to standards organisations and to the members and stakeholders in standardisation to draw their conclusions and develop measures for overcoming such barriers and thus facilitating the use and uptake of standards.

Consolidation of institutions:

Recommendation 7 makes another interesting point. It proposes to “monitor continuously the possibilities to merge different institutions”. Consolidations of standards developing groups and bodies is certainly a key issue. In fact, industry does continuously look at such possibilities. A prominent example for consolidation of standards bodies is the establishment of the Open Grid Forum merging several organisations. A second recent example is the consolidation of the CIDX organisation in OAGi. In the end it is very much a market decision when to found new organisations and when to terminate or merge them; but certainly consolidation is a key element in industry considerations around standardisation.

For sure I also have some points where I think further discussion is required:

The full standards ecosystem ought to be considered:

Above all, the study focusses entirely on the formally recognised standards organisations CEN, CENELEC and ETSI and the national standards organisations. However, the European Standardisation System is more than just the formal standards bodies. Especially in Information and Communication Technologies (ICT) the majority of relevant standards is developed in global private standards organisations. Examples include organisations like W3C, OASIS or the IETF. Some of these global standards organisations can make significant contributions to best practices in standards development processes, openness, transparency and the way consensus is achieved. For global market access through standards and for the use and implementation of standards these organisations, or in other words: the full standards ecosystem, need to be considered regarding access to standardisation.

Similarly, the study takes strong emphasis on the principle of national delegation. Even though ETSI with its different model is taken into account, many passages read as if ETSI was exceptionally recognised despite it's different membership model. I would argue for a more balanced approach in this respect – acknowledging that there are different but equally eligible models implemented around the globe for achieving best results in standardisation. This also includes the global fora and consortia.

For a comprehensive approach instead of an exclusive one:

In Recommendations 2 and 4 the report suggests to move towards “one system” and proposes a route of “gradually dismantling the system of national delegation and moving towards a truly European system, in which a consensus between the various interests is actually developed and obtained at the European level”. From my experience and many talks I had on standardisation in Europe I am cautious about this concept that presupposes that one size fits all. While the ICT industry largely uses global organisations for standards development other industrial sectors have a strong preference for working in a system of national delegation. Therefore, I'd propose looking at a comprehensive approach integrating different structures and models of standardisation rather than trying to reduce everything into one system. I believe that this is also more promising to be able and provide the necessary flexibility and adaptability for a future system being able to leverage standards and standardisation for smart solutions to pressing problems around the globe.

Caution against more administrative requirements:

And finally I am sceptical about recommendation 9 on implementing a “uniform registration of the participation of the various types of stakeholders in technical bodies”. There is a risk of increasing the level of administration (and of associated cost) to an extend that is not justified by the expected improvements and insights from such a move.