2014 - Ed. 7
ISO Strategy 2016-2020
The draft ISO Strategy 2016-2020 was out for consultation until 22 August. ANEC prepared a position paper expressing its views on the proposed ISO Strategy, which was sent to the ISO Secretariat and ISO’s Committee on Consumer Policy (COPOLCO). As a general comment, we reiterated the concerns expressed by COPOLCO about the lack of reference to consumers in the proposed strategy: it refers to industry as a key player and mentions academia as an important stakeholder, but there is no mention of consumers. Perhaps as a consequence, the document does not refer to societal and public-interest focused standards. In our opinion, the strategy needs to make a distinction between "customer" (the ones buying standards and other ISO services) and "consumer" (the final non-professional users of products and services complying with ISO standards). One useful basis for stakeholder definition could be the pre-defined seven categories of stakeholders used in the ISO Global Directory, and reference to the ISO 26000 stakeholder categories.
Our answers to some of the specific questions asked in the consultation document stress the need to improve the participation of consumers and public interest representatives in the ISO standard development process. We also expressed concerns about the impact of shortening the timeframes for the development of standards on the inclusiveness of the process.
EC Work Programme 2015
The College of Commissioners adopted the second Annual Union Work Programme (AUWP) for Standardisation on 30 July. In March, ANEC expressed its first views in a position paper on the draft Work Programme, sent to DG Enterprise.
The EC also issued a "Guidance Note" on its priorities for European Standardisation for 2015. The Annex III Organisations (ANEC, ECOS, ETUI & SBS) and three European Standardisation Organisations were first consulted on a draft of the Guidance Note during a meeting hosted by DG ENTR on 8 July. Subsequently, the Annex III Organisations were asked to provide a common written position on their political expectations from the ESOs in 2015, ahead of an EC deadline for comments of 28 July. ANEC, ECOS, ETUI and SBS prepared comments most of which have been reflected in the adopted Guidance Note.
European vote on ISO/IEC Guide 71
ANEC supports adoption of the revised Guide 71 ‘Guide for addressing accessibility in standards’ as a CEN-CENELEC Guide, in order to ensure consistency of approaches at the European and international levels.
The document outlines the developments in thinking (around design, and accessibility itself) since the previous version was published in 2001. It lays out various approaches to accessibility in more detail, acknowledging that there is no single definition in current use worldwide. It then presents two ways to tackle creating accessibility requirements and recommendations for specific standards - the first focusing on the intended "system"; the second on the human characteristics. Thus the guide allows the standards developer to look at the issue of accessibility from either or both perspectives - the guide providing, in its final chapter, a set of strategies that can be used from either or both perspectives.
ANEC has been involved in the revision of Guide 71 since the outset and played a key role in its drafting. The European decision should be taken by mid-September. The final version of ISO/IEC Guide 71 is also out for vote in ISO/IEC with the same deadline.
ANEC/BEUC position on Imaging Equipment
ANEC & BEUC have repeatedly expressed reservations about the efficiency and efficacy of voluntary agreements as a policy option under Ecodesign. In a paper on the revision of the voluntary agreement on “Imaging Equipment” we highlight numerous weaknesses of the proposed revised voluntary agreement and suggest ways to strengthen it. We also refer to the latest version of the draft Guidelines on voluntary agreements and urge the Commission not to endorse any product-specific voluntary agreement before these are adopted. The Commission would then need to ensure the adopted voluntary agreement satisfies the criteria laid down in the Guidelines.
Ideally, however, we would favour abolition of this voluntary agreement, and to see it replaced by a regulatory measure, as we are convinced regulation is the only way to deliver the full potential of this product group.
Protecting consumer privacy
ANEC welcomes the adoption of European standards on a logo and procedures for the protection of consumers personal data when Radio Frequency IDentification (RFID) chips are used. “ANEC believes consumers should be informed of the presence of the RFID tag by a clearly understandable sign” said ANEC Secretary-General, Stephen Russell, in a press release welcoming the new EU logo and standards.
RFID is a technology for the transmission of data stored on a microchip of a credit card, travel card or price tag, etc. As the technology is ‘contactless’, data can be read remotely from within the local geographical environment of the microchip. The data collected can be used to profile the behaviour of consumers for both commercial and law enforcement purposes.
“A precondition for the successful take-up of RFID is that it be introduced by industry in full respect of privacy, and that consumers remain in full control of their personal data” added Mr Russell “. ANEC contributed for many years to the elaboration of standards which will encourage industry to respect EU data protection rule. Consumers are ready for the use of new technologies such as RFID if the respect of their fundamental right to private data protection and privacy is guaranteed. We have a sound legal framework which is now implemented by robust technical standards.
ANEC must pay special thanks to its expert, Peter Eisenegger, who fought ceaselessly for the consumer positions to be taken into account in this activity.
Green Paper on Safety of Tourism Accommodation Services
DG SANCO published the awaited Green Paper on the Safety of Tourism Accommodation Services, COM (2014) 464. As the title states, the Green Paper focuses only on Tourism Accommodation services, rather than on the wider number of tourism services categories initially suggested by the European Commission. The related consultation nevertheless covers safety aspects beyond fire safety (carbon monoxide; safety of balconies, rooms, & glass doors). Horizontal aspects include ‘accessibility and vulnerable consumers’ and ‘data on injury and accidents’.
Moreover, DG SANCO made available the report with the overview they compiled in 2013 on existing regulatory frameworks at national level across the EU on the safety of certain services to consumers. The report Service Safety – 2013- National regulatory and no-regulatory framework across the EU outlines the main policies and legislative structures in place in countries that responded to the questionnaire. ANEC will prepare a response to the consultation – open until end of November – in collaboration with its partners in the TASC campaign.
"Should we split?"
The ANEC position paper: "Should we split?", published in August, defines criteria that ANEC believes relevant for standardisers to consider when making a decision on whether to split a project into different parts.
The ANEC paper is developed on the basis of our experts experience in standardisation committees dealing with services where they have observed, both at European and international levels, a trend for single projects to be split into parts then published as discrete standards. We are concerned that, under certain circumstances, the publication of these standards as standalone parts may lead to consumer detriment.
The paper proposes a solution to ensure that the usefulness of service standards in providing a fair and safe service is not jeopardised by such partitions. We suggest the use of a checklist in the guidelines for standardisers that would indicate the conditions under which a project should not be split.
Commission warns car rental companies
The European Commission has published a letter sent to several car rental companies known to engage in unjustified discrimination against consumers.
The letter notes the practice of automatic rerouting after identification of the consumer's IP address when booking online. This means that some consumers, depending on their Member State of residency, may be charged more for a booking than a resident of another Member State. The Commission has not ruled out the possibility of further action to ensure consumers are able to benefit from opportunities offered by the single market.
Car rental services were the most problematic area in the ANEC Services Research study European cross-border travel and tourism - Learning from consumer experiences with almost one-quarter of users reporting a negative experience. ANEC has shared its study results with the Commission officials and relevant standardisation committees. ISO TC 228 ‘Tourism and related services’ has consequently started an internal consultation on possible interest for new international standards in this area.
Corporate Social Responsibility
The European Commission has launched a public consultation on the implementation of its most recent policy on Corporate Social Responsibility (CSR), outlined in the Communication “A renewed EU strategy 2011-14 for Corporate Social Responsibility” (COM(2011) 681).
In its response to the consultation, ANEC emphasises the need to establish clear-cut and substantive rules for the conduct of business, as well as meaningful indicators. We welcome the developments related to the proposal of a Directive on the disclosure of non-financial and diversity information by certain large companies and groups as the most important contribution of the CSR Communication (COM (2011) 681).
Register for nanomaterials
ANEC & BEUC replied to the public consultation, “Impact Assessment on Possible Measures to Increase Transparency on Nanomaterials on the Market”. The consultation is part of the Commission impact assessment study on policy objectives and preliminary policy options under consideration. The outcome will be the basis for a decision on whether additional reporting obligations for manufacturers are put in place about the use of nanomaterials in consumer products. Mandatory reporting about nanomaterials is a longstanding demand of consumer organisations and we will therefore watch the next steps.
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