On reading the responses to EU Commission's public consultation on standardisation

The EU Commission's public consultation on the European standardisation system ended about 2.5 weeks ago. All responses which the Commission received have meanwhile been published and are available online on the Commission web site. 

Curious as I am, I scanned through several of the responses last night – not all, though, since the Commission received many – really many. So I just picked some of which I thought could be interesting. Below I record a handful of observations which I would like to share with the world (hello world!):

1. Reservations about changes prevail: The responses I looked at are far from enthusiastic about change. Almost everybody stresses that the current European standardisation system works well and its successful structures should not be jeopardized. Even more, some respondents seem to be almost frightened about possible changes and therefore give strongest “No”-statements on almost all questions. Personally, I think this might partially be due to the fact that the direction the Commission is planning to go for the revision of Directive 98/34 is not clear yet. Together with the confusion around the options listed in the context of the Impact Assessment study this might have led to a general notion that arguing against any change is the lowest risk.
   
2. Successful lobbying: There are obvious verbatim repetitions in the responses which shows that some successful lobbying with prepared responses was done ;-)
   
3. Strong support for ICT specific solution: A suprisingly high number of respondents stress the need for the reform of the EU ICT standardisation policy as proposed in the EU Commission's ICT White Paper.  This goes across all kinds of organisations and is not limited to ICT-near groups. So to conclude: there is (i) a widespread awareness of the different global structures in ICT standardisation compared to other setors; (ii) a broad consensus on the need for the changes as proposed in the ICT White Paper; and (iii) a broad consideration that the proposals of the Commission are well-defined.
   
4. Confusion about the introduction of the WTO Principles: Several respondents reject the introduction of the WTO Principles into the European standardisation system. Several others point out that the current Directive 98/34 already lists principles in whereas clause 24 on which the European standardisation system is founded. The Commission questionnaire had not mentioned that this list is already today part of the Directive. Some stress that the WTO Principles are already implemented by the ESOs and that, therefore, it is not necessary to introduce them. And others bring this proposal in context with the establishment of further ESOs – which they then reject. Whatsoever, there seems to be a lot of suspicion around this proposal. I believe the WTO Principles are the internationally recognised high-level principles for standards development and there is no reason why the current list in the Directive should not be replaced with a reference to the WTO Principles.

If I were asked to draw some conclusion from my readings, I should come up with what has a good chance of becoming my ceterum censeo and propose to focus on the ICT standardisation reform. It is well-defined in the ICT White Paper, it's pressing need is obvious and widely recognised, and the proposals brought forward by the Commission receive broad stakeholder support.

The implementation should be done in a successor-document to Council Decision 87/95 with a focus on the use and implementation of standards and on interoperability. This should be de-coupled from the horizontal standards review of Directive 98/34. And it could and should be done fast.