Draft Annual Union Work Programme for Standardisation for 2017

ECOS welcomes the opportunity to comment on the preliminary draft Annual Union Work Programme for Standardisation for 2017. 

Overall, ECOS believes the AUWP adequately reflects the EU priorities in the major environmental areas. We would like to express our support for planned and on-going activities in key environmental areas, such as climate change, the circular economy, and energy and resource efficiency. We also take the opportunity to highlight gaps and make recommendations to ensure that the future standards will effectively contribute to addressing key environmental challenges.

We also believe that the AUWP should include actions that would help achieve the objectives of Regulation 1025/2012, especially regarding balanced representation and effective participation of all stakeholders. Such actions should be subject to a specific section with the same prominence as specific priority areas.

ECOS welcomes the EC’s proposed standardisation initiatives regarding:

• The development of plastic biodegradability standards (including marine biodegradability; and compostability/biodegradability field tests) in the context of Directive 94/62/EC on Packaging and Packaging Waste, with the launch of the process due Q1 2017 and deadline for delivery by standardisers by end 2020, despite the postponed deadline. We look forward to timely deliverables considering relevance of this work in supporting certain provisions under the EU Circular economy package;
• The development of European performance and descriptive standards as intermediary outputs for sustainable chemicals, including quality and type of secondary raw materials used, their processing, quality and technical performance of the sustainable chemicals produced from these secondary raw materials, as well as pre-and co-normative research in the context of the EU Circular economy action plan, with launch of the process due Q1 2017 and deadline for delivery by standardisers by end 2020;
• The development of new and updated European standards on interoperability between grids, on safe admixture of hydrogen to the natural gas grid, on gas quality and on compatibility with end-use appliances, so long as the ultimate objective is to increase the penetration of renewable energy;
• The development of standards to improve the resource efficiency of European transport, through the standardised access and use of relevant transport information.

We also look forward to the awaited developments regarding:

• The development of standard method for determining total gaseous mercury using sorbent traps for periodic and long-term measurements in the context of the Industrial Emissions Directive 2010/75/EU (IED) with the launch of the process due Q2 2016 and deadline for delivery by standardisers by end 2018; noting the relevance of this work for the proper implementation of the Minamata convention and noting that work is already ongoing under CEN Technical Committee 264 Working Group 8;
• The development of standard for formaldehyde emissions monitoring measurements in the context of the IED with the launch of the process due Q2 2016 and deadline for delivery by standardisers by end 2018; noting the relevance of this work for the new Best Available Reference Documents (BREFs) on production of wood-based panels;
• The development of validated standards on the use of modelling technique to assess air quality to ensure comparability of models used, and a harmonised methodology for source identification and quantification, to help identify factors contributing to air pollution, in the context of Directive 2008/50/EC, with the launch of the process due Q3 2016 and deadline for delivery by standardisers by end 2020;
• The issuing of a Standardisation Request in Q1 2016 for the delivery of harmonised standards by end 2020 based on the results of the scoping study carried out on behalf of EC Directorate General CLIMA in the Member States and aiming to find out where the obstacles and gaps are as regards standards to enabling a broader uptake of alternative, climate-friendly technologies;
• The continued development of standards in support of implementation of the EU Strategy on Adaptation to Climate Change, for delivery by Q4 2020;
• The start of the work and timely execution of Standardisation Request M/543 with regard to ecodesign requirements on material efficiency aspects (recyclability, recoverability and reusability indexes, durability, reversible disassembly and end of life extraction time;
• The start of the work and timely execution of Standardisation Request M/547 on algae and algae-based products or intermediates in support of the implementation of Directive 2009/28/EC on the promotion of the use of energy from renewable sources and EC Communication on “Innovating for Sustainable Growth: A Bioeconomy for Europe” (COM(2012) 60 final).

ECOS would like to underline the following gaps in the 2017 AUWP:

• Development of a Standardisation Request for the revision and development of harmonised standards to support the Proposal for a Regulation on the making available on the market of CE marked fertilising products and amending Regulations (EC) No 1069/2009 and (EC) No 1107/2009, as foreseen by the EC Fertilisers Working Group;
• Development of a Standardisation Request on water reuse to support the circular economy, including setting minimum quality standards for treated wastewater, especially in urban areas.