The Regulation 1025/2012 provides a solid foundation for the European Standardisation System (ESS) that has stood the test of time and continues to provide the right basis for the EU to address current and future challenges and opportunities. It allows the EU to leverage standardisation and standards to enable a green, digital, and resilient industry transition and to maintain a leading role in the global standardisation ecosystem.
While we, therefore, fundamentally see neither need nor merit in revising Regulation 1025/2012, we see potential benefit in considering a punctual targeted amendment to clarify the role and function of European Standards in the context of EU law in light of recent interpretations by the European Court of Justice.
We encourage the European Commission to, instead of considering further revisions to the Regulation, focus efforts on solving a number of implementationissues that have been plaguing the operation of the ESS in the context of Standardisation Requests and procedures towards making Harmonised Standards available. These issues are causing severe burden and cost on EU industry. Solutions can and should be found within the legal framework set by the current Regulation, therefore we would like to offer a number of recommendations on how this could be done.