"Although the Regulation will be
essential in helping ANEC in its
mission, we must be pragmatic
and recognise that the financial
crisis places a long-term limitation
on the public funding we
Hence our Strategy for 2014
to 2020 must move us to focus
on those areas of consumer need
that are of high priority and
where we can achieve the most
influence, and stress that the
funding we receive is not a cost,
but an essential investment in
the increased protection and
welfare of all consumers which
could not be delivered otherwise."
Welcome to the ANEC Review of 2011, a departure from our traditional Annual Report. It aims to capture
as big an audience as possible through the use of accessible web technologies, while providing
readers with the option of a printed version. We hope you enjoy it.
Twelve months ago, we reflected on the publication of the Kozusnik Report on the Future of European
Standardisation, and adoption of the Parliament's Resolution of 21 October 2010. These anticipated
the Standardisation Regulation, proposed by the Commission on 1 June 2011.
ANEC has found much to applaud in the proposal. It acknowledges the importance of a sustained
political and financial framework at the European level to support the participation of consumers and
other societal stakeholders in European Standardisation. Moreover, it recognises such participation as
complementing national delegations to CEN & CENELEC, so helping to ensure the market relevance
of European Standards. Indeed, much of this understanding has come about through careful persuasion
by ANEC at the highest levels of the Institutions. Furthermore, the proposal sets out to strengthen
the positioning of the societal stakeholders within the European Standardisation Organisations themselves.
As I write, the draft Regulation is being considered by the Council and Parliament and I trust I
shall be able to report on its adoption in the next Annual Review.
Although the Regulation will be essential in helping ANEC in its mission, we must be pragmatic and
recognise that the financial crisis places a long-term limitation on the public funding we can expect.
Hence our Strategy for 2014 to 2020 must move us to focus on those areas of consumer need that
are of high priority and where we can achieve the most influence, and stress that the funding we receive
is not a cost, but an essential investment in the increased protection and welfare of all consumers
which could not be delivered otherwise.
But that is for the future. 2011 was the European Year of Volunteering and provided us with reason
to remind the Institutions that the success of ANEC is dependent upon its volunteer experts. I must
thank them unreservedly here. So too must I thank our members in undertaking their roles for ANEC
at the national level, and last (but not least) to the ANEC Secretariat team in providing a centre of excellence
at the hub of the association.
ANEC Annual Review 2011
Key Events of 2011
ANEC General Assembly 2011 to 2014
The first meeting of the ANEC General Assembly, appointed for the
2011 to 2014 term, was held in Brussels on 1 June. In welcoming
members, Prof Dr Lothar Maier, the retiring President, noted 11 new
individuals were present from the 26 countries attending. He believed
this to represent the dynamism of the consumer movement
and said it augured well for development of the ANEC Strategy
2014 to 2020. Members thanked Dr Maier, also retiring as the German
member of the General Assembly, not only for his four years
as President, but also his role in helping to establish ANEC in the
1990s. Mr Finn Aas, who was retiring as the Norwegian member of
the General Assembly and representative of the EFTA Consumers'
Consultative Committee, was also honoured.
In succession to Dr Maier, members elected Arnold Pindar (UK)
President. Conchy Martin Rey (Spain) was elected Vice-President,
while Benedicte Federspiel (Denmark) was elected Treasurer.
Excluding the Exclusion Clause
ANEC has worked for many years to achieve the
deletion of the 'Exclusion Clause' from the EN 60335
series of European standards for domestic electrical
appliances. This clause does not foresee the safe
use of appliances by vulnerable consumers (children,
elderly people and people with disabilities) unless
under "supervision or instruction".
ANEC Secretary-General, Stephen Russell, stressed
in a presentation to a CECED workshop in March
that warnings and information cannot be substitutes
for safe design. He also called for further cuts in surface
temperature limits, as well as the introduction of
food safety and hygiene requirements.
Reporting to the ISO/COPOLCO meeting in May, he asked for the
support of COPOLCO to encourage IEC to revise the parent IEC
60335 standards "so that consumers from around the world can
benefit from the improvements we have won at the European level".
At the ICPHSO International Symposium in November, he repeated
the ANEC view that there can be no divisions of safety, nor should
there be 'hierarchies' of safety, in international standards, such as
the IEC 60335 series.
The General Assembly meeting in 2008 agreed ANEC should
champion the importance of creating a European framework for
market surveillance & enforcement activities. Without effective
enforcement, even the best legislation and best technical
standards are worthless. Hence we welcomed the Resolution of
the European Parliament which followed an initiative report on the
revision of the General Product Safety Directive and market
Without effective enforcement, even the best legislation
and best technical standards are worthless.
The Resolution calls for the establishment of a common European
framework for market surveillance, and calls on the Commission to
play a more active role in coordinating the activities of the national
market surveillance authorities and customs authorities. We trust
this further strengthening of market surveillance will be reflected
not only in the forthcoming revision of the GPSD, but also in the EU
Consumer Programme 2014 to 2020.
To mark International
Consumers' Day and
the European Year of
thanked volunteer experts
in a press release
issued on 15 March.
Our volunteer experts
face daily the challenge of defending consumer interests in standardisation,
and their work in shaping European standards has led
to higher levels of consumer protection and welfare. ANEC
Secretary-General, Stephen Russell, took the opportunity to thank
our volunteers for their hard work and commitment, as the battle
for improved consumer protection within Europe could not be
fought without them.
Our volunteer experts face daily the challenge of defending
consumer interests in standardisation, and their work in
shaping European standards has led to higher levels of
consumer protection and welfare.
Stephen Russell, ANEC Secretary General
Requirements for child finger entrapment in European safety standards
Static finger entrapment is covered
in most relevant European standards
along with moving (dynamic)
entrapment. The requirements for
static finger entrapment are based
on anthropometric data. An ANEC
trial showed 3D scanning is a useful
technology to produce accurate data
on the effects of dynamic entrapment
on finger size and shape.
The trial demonstrated that the depth
of the fleshy part of the fingertip
under compression will be far less
than the depth or diameter of the
joint, currently used to set requirements.
The study notes that the
current requirement for moving parts
(in EN 13387:2004) of 12mm will not
protect the fleshy part of the finger,
and recommends that the minimum
requirement for moving parts should
be less than 5 mm.
Evaluation of human toxicity impact assessment models in Life Cycle Assessments
An ANEC study is investigating the
LCA impact assessment category
of human toxicity and reviewing
the model from a more traditional
toxicological perspective. The study
complements earlier research and
is expected to reinforce our position
that LCA cannot replace other
instruments used previously in environmental
policy-making and ecolabelling
Results of 2010 R&T projects
Can consumers trust website accessibility declarations?
According to our study, only 3 out of 76
websites certified by a third-party were
found to be accessible, while none of
24 commercial websites that had selfdeclared
was accessible. ANEC will use
the results in work on the standardisation
of web accessibility in order to achieve
benefits for all consumers.
Acoustics in toy safety
The principal European Standards on
toy safety - the EN 71 series – do not
offer adequate protection from hearing
impairment as they lack requirements
for continuous noise emitted by all toys.
ANEC intends to influence the revision of
the standards, necessitated by changed
limits in the new Toy Safety Directive
(2009/48/EC), in line with the results of a
study demonstrating the scientific background
to its concerns.
Building sustainable solutions
The purpose of the ANEC study was to
develop a set of environmental indicators,
and corresponding minimum and
excellence criteria, primarily for new
residential buildings. The scope included
provision of information to consumers
on ways to achieve energy savings. As a
result of the study, we have called for a
broad debate on more stringent sustainability
measures in the construction area.
Easing the use of appliances
Although technology is improving access
to many products, it still falls short of enabling
increased independence for disabled
and older people. The ANEC study identified
data indicating the forces and grip
strengths needed by various groups of
people to operate appliances. The data
will contribute to the further development
of standards on domestic appliances.
ANEC welcomed the publication of the new toy
safety standard EN 71-1:2011 'Safety of toys -
Part 1: Mechanical and physical properties', which
replaces EN 71-1:2005. It is the first European
Standard to reflect the provisions of the new Toy
Safety Directive 2009/48/EC, which became applicable
on 20 July 2011.
ANEC was successful in influencing the mechanical
requirements of toys in the new legislation and participated
in the revision of the standard. For instance, ANEC has
ensured textile toys for children under three years must now be
able to be cleaned or washed without their safety being compromised.
Requirements to prevent children from choking or drowning have also
Despite the numerous improvements in the new standard, longer cords
on certain toys are now allowed. In our opinion, this will increase the
strangulation risk posed to children aged between 18-36 months.
Some challenges remain. Further noise requirements are under elaboration
in order to protect children's hearing. In addition, as many warnings
on toys are very small, not easy to find or easily legible, better requirements
for the presentation of warnings are also being developed. ANEC
is taking part in this standardisation work.
A Commission Decision and referencing of EN 14682:2007, on cords
and drawstrings on children's clothing was published in the OJEU
on 29 March. This standard was developed following a request from
ANEC and is one of our main achievements in the child safety area.
In order to prevent children falling from windows, CEN adopted EN
13126-5 for integrated window locking devices in 2011, and submitted
draft standard prEN 16281 for consumer fitted window locking
devices to public comment. Both standardisation activities were
initiated following research conducted by ANEC on child protective
In 2011, ANEC welcomed the approval of two new ISO standards on access to the built
environment. ISO 21542 "Accessibility & usability of the built environment" aims at creating
a sustainable built environment that is accessible. Its purpose is to define how the
built environment should be designed, constructed and managed in order for people to
approach, enter, use, leave and evacuate a building independently, irrespective of their
ages or abilities. ANEC was pleased to contribute to the standard.
ANEC also worked on ISO 23599 'Assistive products for blind & vision impaired persons
— Tactile walking surface indicators' (TWSIs). The standardisation of TWSIs is needed to
ensure one indicator indicates the same obstacle or impediment around the world.
Both ISO standards can benefit countries, particularly developing countries, where few
accessibility standards exist and where there is little guidance or regulation on TWSIs.
Within Europe, we believe ISO 21542 could be the basis for a European Technical Specification
that would also take into account some established standards in European countries.
Indeed, we made such a proposal in our response to Phase 1 of Mandate M/420
on the creation of an inventory of standards and other technical documents that facilitate
access to the built environment, a task led by ANEC. Phase 2 will use the inventory in the
identification of the European standards that need to be developed.
On 20 December, the European Commission published a proposal for the revision of the
Public Procurement directives. Compared with the present directives, the proposal aims
at certain technical specifications taking into account accessibility criteria for people with
disabilities. We welcome this response from the Commission, as it builds on the intent of
the work under Mandate M/420, and is in accord with our vision to see all products and
services accessible to consumers of all ages and abilities.
ANEC Annual Review 2011
Introducing food & hygiene requirements
Although European standards do define food safety & hygiene requirements
for commercial catering appliances, no such requirements are set for household
electrical appliances. An ANEC proposal to introduce food safety &
hygiene aspects in standards for electrical household appliances was discussed
by CENELEC in June 2011. A revision of EN 60335-2-24 "Household
and similar electrical appliances - Safety - Part 2-24: Particular requirements
for refrigerating appliances, ice-cream appliances and ice
makers" will serve as the model for the inclusion of food & hygiene aspects
in the European standards for other appliances. The work was initiated by
ANEC as a result of a research project.
The ANEC concerns have been supported by Member States, especially
following the deaths of several babies in Cyprus due to hygiene problems
with humidifiers, as well as problems with surface-cleaning appliances.
In 2011, ANEC ensured the safety of fairground equipment
returned to the political agenda.
Fairground equipment is not covered by the revised Machinery Directive and
the General Product Safety Directive provides insufficient provisions. Articles
in the Parliament Magazine led to a meeting between ANEC and IAAPA
(the International Association of Amusement Parks and Attractions) to
establish channels of communication and to discuss common aims. ISO
also established a new Technical Committee, TC 254 "Safety of attractions".
ANEC Annual Review 2011
CEN sustainable building standards prevent sustainable solutions
In October 2011, ANEC called on the European Commission to develop a Green Paper on
sustainable construction. Although CEN is developing a series of standards for sustainable
buildings, through TC 350, we have been long-time critics of the approach and disagree
profoundly with the methodologies used. We believe the solutions will be expensive
to implement and hold little value for consumers.
ANEC proposes an alternative approach, based on a study
commissioned from the Austrian Institute of Healthy and Ecological
Building (IBO). It uses a mix of different instruments, both
quantitative and qualitative in nature. It includes energy
consumption during the use stage of the building, as
well as taking into account the embedded energy in
construction products, together with requirements for
chemicals and releases to indoor air, construction site and endof-
In support of our proposal, we issued a position paper detailing a
critique of the CEN approach, with a particular focus on the
environmental and health aspects, and the limitations of Life Cycle
Assessment (LCA) and Environmental Product Declaration (EPD).
The current European regulatory framework for consumer products does not ensure a sufficient level of protection against exposure
to dangerous chemicals. Relevant provisions in EU legislation are patchy or missing.
A horizontal approach including a new legislative framework may be needed. The conference 'How to eliminate hazardous
chemicals from consumer articles', organised by ANEC with the ASI Consumer Council & BEUC on 5 October, succeeded in
initiating a well-attended and high-level debate.
At the moment, there is little regulation of these chemicals at European level, be it in childcare articles, electrical and electronic
equipment or construction products. The regulations that do exist are vague or have so many exemptions that the result
is the same: consumers continue to be exposed to hazardous chemicals in everyday articles.
During the conference, different perspectives on the use of hazardous chemicals were presented. The debate further addressed
gaps present in the current regulatory framework related to chemicals in consumer products. It finally discussed possible ways
forward to ensure a high level of consumer and environmental protection against exposure to dangerous chemicals.
As a result, ANEC confirms its call to the EU to wake up to the ticking bomb of hazardous chemicals in consumer
products. It is now urgent to address the gaps in existing product legislation, and adopt a coherent
horizontal approach to chemicals in products, in order to ensure the high level protection that consumers
In answer to ANEC's campaign, "Pump down the volume!", safety requirements for
Personal Music Players are now included in European Standards (EN 60065:2002/
A12:2011 "Audio, video and similar electronic apparatus - Safety requirements" and
EN 60950-1:2006/A12:2011 "Information technology equipment - Safety -- Part 1:
Since 2009, we have worked to achieve the maximum sound levels permitted
to be limited to safe thresholds by default. The standardised
approach is based on an
average sound pressure limit of 85 dBA.This is a level that is considered to be safe
under all conditions of use.Nevertheless, there is the possibility for a consumer
to override the limit so that the level can be increased to a maximum
average of 100 dBA. In this case, users are informed by warnings,
repeated after every 20 hours of listening time, about the risks of listening
music at such a high volume. The 85 dBA and 100 dBA limits
enter into force no later than 2012.
Listening to PMPs at high volume settings over sustained
periods can encourage permanent hearing loss. The EU
Scientific Committee on Emerging and Newly Identified
Health Risks (SCENIHR), in an opinion of October 2008,
warned that 5-10% of users - or up to 10 million people in
the EU - could be at risk of permanent hearing loss,
with young people a special concern.
On 18 October 2011, nearly one year after its initial proposal, the European
Commission agreed to a Recommendation defining "nanomaterial" for use in
future EU legislation, with the elaboration of risk assessment and measurement
methods. ANEC welcomed the definition only in part. Although several
aspects of the definition meet the ANEC position - such as the adoption of
size distribution and special provisions for fullerenes, graphene flakes and
single-wall carbon nanotubes - we believe the definition contains an important
The 1% threshold of particle number size distribution, as recommended by
many scientific opinions, was abandoned in favour of a 50% threshold, despite
lack of scientific justification. We understand the change was made to
reflect opposition expressed during the public consultation phase to the lower
threshold, especially from industry. The consequence could be that some
materials, in their nano size and form, escape proper safety risk-assessment
before being placed on the market.
Hence ANEC calls on legislators to make use of the options foreseen
in the Recommendation in order to ensure that the legislation offers
the highest levels of consumer protection practicable.
ANEC welcomed approval of the CEN Guide, "Guidance for the development of service standards",
particularly as it reflects most of the ANEC comments made during its drafting.
The CEN Guide is broader in scope than the pre-existing ISO/IEC Guide 76 "Development of service
standards - Recommendations for addressing consumer issues" as it addresses business and legal
aspects, as well as consumer issues. The two guides will thus co-exist and we trust both will be used by
ANEC is pleased that the CEN Guide is addressed to all those who are interested by, or involved in, the
development of service standards. We are also pleased with the fact that the Guide covers both the
pre-normative phase and the normative phase; that it makes clear reference to the need to consider
national legislation that may exist, and that reference is made to existing guides and standards.
However, we regret that it does not clarify how standardisation should be approached in its interaction
with existing national laws on service provision. It should be noted that European legislation on services
is not set to follow the maximum harmonisation used for European legislation on products.
Hence differing laws among Member States will continue
to exist, leading to variations in the quality of services
offered to European consumers.
Safer child seats on the horizon
Younger children will be better protected when travelling by car following
the adoption of a new regulation on child restraint systems (CRS) by the
UNECE (United Nations Economic Commission for Europe) Working Party
on Passive Safety (GRSP) in December 2011.
ANEC contributed over three years to the development of the new regulation
under the umbrella of Consumers International (CI). We influenced the
regulation - called i-size - by ensuring that greater safety is offered to the
youngest consumers through the mandatory rear-facing transport of
children up to 15 months of age, and by reducing the risk of misuse
through easier installation. Furthermore, i-size provides better side impact
protection than the existing regulation.
ANEC urged the World Forum for Harmonization of Vehicle Regulations to
ensure implementation of the new regulation as early as January 2013.
ANEC welcomed the adoption of the European Parliament's own initiative
report on European Road Safety 2011-2020, which besides numerous
other measures to improve road safety, also recommends that children
are kept in rearward facing restraint systems in vehicles until they are
three years old.