Digital Society

From shopping online to listening to music, products and services in the field of digital and Information & Communication Technologies (ICT) are playing an essential key role in consumers’ everyday lives. But, although they have potential to improve consumer welfare by making a greater range of products and services available, new technologies pose several challenges in terms of the protection of traditional consumer rights, with issues such as data protection, security, and accessibility to, coming to the fore. Hence it is essential that ICT standardisation processes, both formal and informal, ensure full and effective consumer participation in order to take consumer requirements into account.

The ANEC Digital Society WG strives to ensure the safety, accessibility, interoperability, security and privacy of digital products & services.

Work areas

1) E-accessibility and e-inclusion

Web Accessibility Directive

AGE Platform Europe, ANEC, EBU, EDF  joined forces to call on the Commission to make a legislative proposal that would deliver web accessibility for all by 2015.

In December 2012, ANEC welcomed the proposal by the European Commission for mandatory provisions on web-accessibility as it took into account many of our suggestions about the use of standards and monitoring of implementation.

Four years later, on 26 October 2016, ANEC welcomed the adoption of Directive (EU) 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies (‘Web Accessibility Directive’), which aims to ensure access to online public services to all consumers, regardless of their age or ability. The European Parliament, in agreement with the Council, made significant improvements to the original Commission proposal issued in 2012, in terms of the websites covered and enforcement provisions, as well as the inclusion of access from a handheld mobile device and mobile apps. These improvements were largely in line with ANEC’s position.

The adoption of the Directive brought to a close several years of intensive work by ANEC and its partners in campaigning for web accessibility legislation.

Following the adoption of the Directive, a Committee and Expert Group (‘WADEX’), comprised of Member States, was set up to advise the European Commission in the execution of its implementing powers. In addition, a WADEX sub-group of stakeholders was created. An expert, nominated by ANEC with the European Disability Forum (EDF), European Blind Union (EBU) and AGE Platform Europe, represents the organisations in the stakeholder sub-group. Through its participation in the stakeholder sub-group, ANEC contributed to drafting the implementing acts under the Web Accessibility Directive (WAD), published in October 2018.

Web accessibility is a joint priority of the ANEC Digital Society and Accessibility Working Groups. To learn more about the latest developments, please visit our ‘Accessibility’ page.

The first European Standard for accessible ICT products and services (M/376)

The Web Accessibility Directive makes use of harmonised standards to provide a presumption of conformity to its essential requirements. To this end, a draft standardisation request for harmonised standards on the accessibility of websites and mobile apps was issued by the EC, with ANEC’s support. In May 2017, it was approved by CEN-CENELEC and the EC Committee on Standards. CEN, CENELEC & ETSI were asked to deliver harmonised standard(s) based on EN 301 549 V1.1.2 (2015-04), including necessary provisions needed to support the implementation of Article 4 of Directive (EU) 2016/2102. In August 2018, the standard EN 301 549 was published and is now freely available online at ETSI website.

ANEC also participated in the work of CEN TC 224 WG 6 ‘User Interface’ on the revision of prEN 1332-3:2016 ‘Identification card system - User Interface-Part 3: Keypads’ by making sure that consumer relevant functionalities including tactile symbols and contrast requirements for blind and partially-sighted persons are taken into account. In September 2020, EN 1332-3 ‘Identification card systems - User Interface — Part 3: Key pads’ was published, as no Formal Vote was necessary. ANEC welcomes the revised standard which specifies the arrangement, the number and location of numeric, function and command keys, including placement of alphabetic characters on numeric keys. Design requirements and recommendations are also provided. It also applies to all identification card systems with a numeric keypad for use by the public for stationary or non-stationary devices. It is an important result for ANEC who initiated the revision, provided numerous comments and supported the project convenor. In December 2020, upon completion of its work CEN TC 224 WG 6 was disbanded. 

At the end of February 2024, ANEC submitted its comments on the last draft of EN 301549 'Accessibility requirements for ICT products and services' in alignment with the comments by EDF which were mostly accepted.

M/587 also requests the revision of CEN/CLC/ETSI TR 101 551:2014 “Guidelines on the use of accessibility award criteria suitable for public procurement of ICT products and services in Europe”, and of CEN/CLC/ETSI/TR 101 552:2014 “Guidance for the application of conformity assessment to accessibility requirements for public procurement of ICT products and services in Europe”. Both documents should be updated to be aligned with the current Public Procurement Directive and ongoing revision of EN 301549. In February 2024, CEN-CLC-ETSI-JWG eAcc-WG1 decided by consensus to merge TR 101551 and TR101 552 together in line with ANEC’s position. The due date for the TR revision is 15/01/26.

2) Electronic communications products, networks and services 

All consumers should be able to participate in the Digital Society and reap its benefits. Therefore, in ANEC’s opinion, digital products and services need to be safe and accessible for all consumers. However, due to their intrinsic characteristics, such as rapid technological developments and convergence, digital products and services represent a challenge for regulators. The role of standardisation, to ensure that consumers’ interests such as safety, quality of service and accessibility are adequately guaranteed, is crucial.

Radio Equipment Directive

The Radio Equipment Directive (RED) (Directive 2014/53/EU), which replaced the Radio and Telecommunications Terminal Equipment (R&TTE, Directive 1999/5/EC) in June 2016, sets safety, interoperability and accessibility requirements, to be complemented by the adoption of standards for products such as music players and mobile phones. The new RED allows the European Commission to request interoperability of mobile phones and other devices with universal chargers, a long-standing request of the consumer movement. In addition, the RED provides for additional means for market surveillance in order to track and monitor products which fail to comply with the essential requirements. The concept of “foreseeable use” must be taken into account for conformity assessment. All these points were supported and proposed by ANEC. A new standardisation request (M/536) to implement the RED was issued by the Commission, and the standardisation work, which ANEC follows, started in 2016.

Since 2017, ANEC is calling the European Commission and Member States to make privacy and security requirements mandatory for connected products in order to protect consumers from cyber risks. We support the adoption of a Commission delegated act on Internet-connected radio equipment and wearable radio under Radio Equipment Directive 2014/53/EU, to be underpinned by standards. We are working on relative standards which could become Harmonised Standards. The Impact Assessment for the delegated was done at the beginning of 2020. In 2021, ANEC continued to contribute to the discussions with the EC on the draft delegated act under the Radio Equipment Directive in order to address personal data protection and protect against fraud. This could be a valuable proposal in addressing the concerns we drew to the attention of the EC several years ago about unsecure smart toys and smart watches for children. ANEC commented on the draft standardisation request of Articles 3(3)(d/e/f) RED, implementing the draft delegated act. ANEC supported the draft request as the points address the issues we brought to the attention of the European Commission and TCAM Expert Group in December 2016 and November 2017 about unsecure smart toys and children smart watches. We suggested to change ‘where appropriate’ into ‘where applicable’ in all the draft request in order to make the assessment on whether the requirement is relevant more objective and clearer for the ESOs when drafting the standards. We also proposed a clarification of Clause 1.2, Part B of the draft standardisation request as the requirement ("The harmonised standards shall be proportionate to the risk") is too general.

On 30 January 2020, the European Parliament, whom we were in contact with, adopted a Resolution calling on the European Commission to put forward mandatory rules on common chargers by July 2020 at the latest. The Parliament expressed “urgent need for EU regulatory action” to reduce electronic waste and empower consumers to make sustainable choices. The resolution was approved by 582 votes to 40, with 37 abstentions, in calling for mandatory introduction of common chargers for all mobile devices. The Parliament wanted the Commission to adopt a delegated act as foreseen in the Radio Equipment Directive (2014/53/EU) by July 2020 or, if necessary, table a legislative measure by the same date.

Also, we are pleased to see the European Commission has put a new proposal on common chargers for mobile phones and similar devices in its Work Programme 2020. As part of its legislative proposal, the Commission has published an Impact Assessment study. In December 2020, we welcomed the new consultation on an EC Impact Assessment Study on Unbundling of Chargers, to which we replied in January 2021. This stakeholder survey, as part of the Impact Assessment Study addresses one of the main issues we were calling for in our long-standing campaign on common chargers: the need to ensure consumers are given the choice to buy or not the charger when they buy a new phone (or another device).  

On 23 September 2021, the EC published the legislative proposal on common chargers (as a revision of the Radio Equipment Directive). ANEC welcomed the proposals about mandatory common chargers for mobile phones and other digital devices such as tablets, digital cameras, notebooks as it meets our long-standing requests. ANEC’s positions (and EC proposals) were reflected in numerous media coverages around the world. After having replied to the public consultation, ANEC also drafted some amendments on EC proposal for a Directive of the European Parliament and of the Council amending Directive 2014/53/EU on the harmonisation of the laws of the Member States relating to the making available on the market of radio equipment (COM(2021) 547 final, 2021/0291 (COD) [common chargers] and discussed them with the EP IMCO Rapporteur on 14 December. 

Throughout 2022, ANEC continued to work on the revision of the Radio Equipment Directive (RED) to introduce mandatory rules on common chargers. We discussed our amendments with several MEPs and replied to questions from the press. We are pleased that most of our suggestions were taken onboard by the Rapporteur in his report and the amendments submitted (especially on standards). The Council adopted its position on a common charger for electronic devices, again reflecting many of our views. To improve consumer information, the Council added an annex to the proposal with a pictogram indicating whether a charging device is offered together with the device, as well as a label indicating charging specifications (ANEC was informally consulted about both during the negotiations). The Council text also clarifies technical specifications for a common charger. In June 2022, we welcomed the political agreement reached by the co-legislators on the common chargers. The final approval is expected in Q3/2022. The revised Directive will enter into force 20 days after publication in the Official Journal, and its provisions will start to apply after 24 months.

This represents a significant result for ANEC and the consumer movement after many years of lobbying (since 2009) to help consumers make sustainable choices.

ANEC welcomed EC Delegated Regulation (EU) 2023/1717, amending the ‘Common Charger’ Directive (EU) 2022/2380 as regards the references to technical specifications for wired charging, has been published in the Official Journal of the European Union. ANEC supported the reference to the updated standards. Following ANEC’s long-term lobbying, common chargers for several consumer products will become mandatory at the end of 2024. Smart phones, tablets and similar products will have to comply with CEN-CENELEC standards on USB-C and speed charging capabilities (IEC 62680-1). From spring 2026, the obligation will extend to laptops. The EC will have to harmonise interoperability requirements of wireless charging by the end of 2024, to avoid having a negative impact on consumers and the environment.

ANEC submitted comments on draft standardisation request as regards charging interface and charging communication protocol for radio equipment capable of being recharged by means of wireless charging in relation with Article 3(4), sixth subparagraph, of Directive 2014/53/EU. ANEC supports the draft Sreq and suggests having physical characteristics and form factors (i.e. operating parameters) for contact and non-contact common and interoperable charging for radio equipment capable of being recharged by means of wireless charging. We also suggest that European standards shall address the problems faced by consumers. When energy losses of the wireless charger exceed the power rating of the charger used to power the wireless charger, the charging stops. The same happens when the phones temperature exceeds a certain level (eg: 40°C). In June 2024, ANEC shared with CEN-CLC its comments on the wireless charging Sreq.

Read more about our position in support for legislation on common chargers in our ANEC factsheet.

In the beginning of 2022 ANEC welcomed the delegated act of the Radio Equipment Directive (RED) on cybersecurity and privacy, published on 12 January in the OJEU. It is an initiative to which we have contributed from the outset in order to achieve improved cybersecurity and privacy for all consumers, including children (remembering Cayla “the spying doll”, and connected – but unsecure - smartwatches for children).

In June 2022, the EC Draft Standardisation Request on cybersecurity radio equipment addressed to CEN-CLC only was sent to the member States (CoS) for approval. In July 2022, ANEC expressed support for the final version. 

After the CEN-CENELEC approval, in September, we are contributing to the drafting of the standards, which were planned to be ready by 1 October 2023. However in July 2023, the Commission adopted the Delegated Regulation that amends the RED Delegated Regulation on cybersecurity, privacy and protection from fraud as regards the date of applicability. The latter is delayed until 1 August 2025. In November 2023, ANEC shared with the EC its frustration about the prENs on cybersecurity-related aspects of consumer products and the lack of progress.

Human exposure to electromagnetic fields

The development of harmonised standards in the framework of the Council Recommendation (1999/519/EC) on the exposure of the public to electromagnetic fields, the Low Voltage Directive (2014/35/EU) and the Radio and Equipment Directive (2014/53/EU), is of paramount importance for consumers to ensure that exposure levels are translated into emission requirements of products. Mobile phones and radio transmitters fall within this area. 

The ICNIRP RF EMF GUIDELINES 2020 are available on ICNRP's website.

Safety of IT audio-video equipment

Television sets, computers, mobile phones and music players are used by consumers of all ages every day. It is therefore essential that those products are safe when they are used by consumers. The term "safety" applies both in the sense of immediate physical risks of human injury, or damage to health, such as in the case of noise exposure level of music players, and through the indirect consequences that can arise from other sources of risk such as chemicals.

ANEC supported the adoption of FprEN IEC 62368-1:2019/FprAA:2019 Audio/video, information and communication technology equipment - Part 1.

In summer 2019, ANEC welcomed the CENELEC TC 61 ‘Safety of household appliances’ decision to abandon the development of prEN 50679’ Household and similar electrical appliances with a radio communication interface and/or a radio determination interface – Safety’. Following negative opinions, CLC TC 61 decided to stop the project, in line with ANEC’s position. This was the second enquiry to which ANEC had to submit a not favourable opinion and comments as the standard did not contain any safety requirement for connected appliances and thus did not provide legal certainty. The results of both enquiries were positive as the majority of National Committees approved the draft standard.

3) eRecognition

Near Field Communication (NFC) technologies such as Radio Frequency Identification (RFID), exponentially increase the possibilities of tracing and tracking consumers. The multiplication of authentication and authorisation mechanisms - such as readers and contact-less cards – is everywhere, from the workplace to public transport networks. ANEC believes there is a need for private data handling to be performed in a clear, legal and standardised framework and with absolute respect for individual privacy and accessibility (see section below on RFID). 

4) Privacy and cybersecurity

The Digital Society WG follows activities in privacy and security standardisation, one of the main priorities in the age of IoT.

Standards can help industry implement the provisions of data protection legislation, such as “privacy by design”, from the early stages of technical development. This principle guides the Digital Society WG when following privacy-related work, such as in CEN-CENELEC TC 8 ‘Privacy management in products and services’ which was set up in 2015, to implement the draft standardisation request on privacy management in the design, development, production and service provision of security technologies (M/530). The committee also works on two Technical Reports providing guidelines for the application of privacy-by-design principles for video-surveillance and for biometrics for access control (including facial recognition). CEN-CLC/JTC 8 ‘Privacy Management in products and services’ was disbanded in July 2019, in line with our position. The work was transferred to WG 5 of CEN-CLC JTC 13 ‘Cybersecurity and Data protection’. In September 2020, ANEC supported the enquiry of prEN 17529 ‘Data protection and privacy by design and by default’, which was approved. The standard is executing M/530 on how to address and manage privacy and personal data protection issues during the design and development and the production and service provision processes of security technologies and services, allowing manufacturers and service providers to develop, implement and execute a widely recognised Privacy by Design (PbD) approach in their processes. ANEC contributed to the work but expressed some concerns about the effect of the EN giving presumption of conformity with the GDPR and the citation in the standard in the Official Journal.

As the IoT ecosystem grows, the exposure of connected products to an eventual cybersecurity breach also increases. According to the Special Eurobarometer from the European Commission, 86% of consumers believe that the risk of becoming a victim of a cybercrime is increasing. Also, 87% of consumers avoid disclosing personal information online because of cybersecurity-related issues (EC, Special Eurobarometer 464a, Europeans’ attitudes towards cyber security, September 2017). There is a need to move the security burden from European consumers to IoT manufacturers and service providers. In this sense, in December 2020, the Council approved conclusions that underline the importance of assessing the need for horizontal legislation in the long term to address all relevant aspects of the cybersecurity of connected devices, such as availability, integrity and confidentiality. The European Commission mentioned the horizontal legislation in its Cybersecurity Strategy, published also in December. ANEC welcomes these developments as they meet our long-standing request of cybersecurity legislation on IoT devices.

Consequently, ANEC has to accelerate consumer representation in cybersecurity to ensure that consumer interests are properly represented and taken into account in developing cybersecurity standardisation solutions.

A new CEN–CENELEC TC 13 ‘Cybersecurity and data protection’ started work in the second half of 2017. The scope covers the development of standards for data protection, information protection and security techniques, with specific focus on cybersecurity, covering all concurrent aspects of the evolving information society, including organisational frameworks and methodologies; data protection and privacy guidelines; processes and product evaluation schemes; smart technology; distributed computing devices and data services.

ANEC is involved in the work on the future Harmonised Standards which already started in summer 2022 in the new CEN-CENELEC JTC 13 WG 8 ‘Special Working Group RED Standardization Request’.

In August 2023, the Enquiry for the following standards started, with closing date for the ballots on 16 November:

- prEN 18031-1 ‘Common security requirements for radio equipment - Part 1: Internet connected radio equipment’

- prEN 18031-2 ‘Common security requirements for radio equipment - Part 2: radio equipment processing data, namely Internet connected radio equipment, childcare radio equipment, toys radio equipment and wearable radio equipment’

- prEN 18031-3 ‘Common security requirements for radio equipment - Part 3: Internet connected radio equipment processing virtual money or monetary value’.

While some of our comments have been taken into account in the drafting of the standards, we are still doubtful about the applicability and wording of the requirements, which are very high-level. We also find the testing methodology unclear. Because of the many consumer products covered such as toys, child-care articles and smart meters, ANEC consulted the experts from all the WGs (as well as the General Assembly) to check the draft standards about the specific cybersecurity requirements which the specific products standards should cover in order to increase consumer protection. We decided not to support the standards (which were not accepted).

ANEC attended the multiple CEN CENELEC JTC 13 WG 8 ‘Special Working Group RED Standardization Request’ online meetings in 2023. The group went through the many comments received during the enquiry ballot. ANEC reiterated comments that the current provisions and the “unless” conditions leave too much freedom for manufacturers, and standards really need to be precise technical instructions. One of ANEC's comments was that justification was not part of the test assessment at all and agreed that the content of the documentation should be very detailed and specific.

In May 2024, the Formal Vote for the following standards started, with closing date for the ballots on 27 June:

- FprEN 18031-1 ‘Common security requirements for radio equipment - Part 1: Internet connected radio equipment’

- FprEN 18031-2 ‘Common security requirements for radio equipment - Part 2: radio equipment processing data, namely Internet connected radio equipment, childcare radio equipment, toys radio equipment and wearable radio equipment’

- FprEN 18031-3 ‘Common security requirements for radio equipment - Part 3: Internet connected radio equipment processing virtual money or monetary value’.

While some of our comments have been taken into account in the drafting of the standards, we are still doubtful about the applicability and wording of the requirements, which are very high-level. We decided not to support the standards (which were accepted).  However, the standards received a negative assessment by the HAS consultant, along the lines of the ANEC’s comments (eg: lack of risk assessment).

ANEC is also represented in ETSI TC CYBER, which is recognised as a major centre of expertise in cybersecurity. There, we aim to contribute to standards such as the ETSI TS ‘Cyber Security for Consumer Internet of Things', which was proposed by the UK Government and based on the UK Code of Practice for Consumer Internet of Things (IoT) Security for manufacturers.

On 19 February 2019, the ETSI Technical Committee on Cybersecurity (TC Cyber) published ETSI TS 103 645 'Cyber Security for Consumer Internet of Things', a technical specification for cybersecurity in the Internet of Things, which specifies high-level provisions for the security of internet-connected consumer devices and their associated services. The technical specification establishes a security baseline for internet-connected consumer products and provide a basis for future IoT certification schemes. ANEC as a member of ETSI has greatly contributed to the development of ETSI TS 103 645 and was invited to join the ETSI press release, with a quote from ANEC’ Secretary General, on the ETSI website.

In June 2020, ANEC welcomed the European Standard based on it (ETSI EN 303 645 ‘Cyber Security for Consumer Internet of Things: Baseline Requirements’). Nevertheless, we believe the standard represents only a first step in the direction of making IoT products for consumers safe and secure. In 2024, ETSI EN 303 645 V3.1.3 ‘Cyber Security for Consumer Internet of Things: Baseline Requirements’ has now been updated and published.

In May 2020, we joined the new ETSI group Industry Specification Group (ISG) on (ETSI E4P) “Europe for Privacy-Preserving Pandemic Protection”. It will work on requirements for pandemic tracing systems, proximity detection, use of smartphones (and other devices) for proximity detection, and anonymous identification (including data protection and information security). We will aim to make sure the initiative provides opportunity to develop a European privacy-oriented standard. In June 2021, ETSI ISG E4P “Europe for Privacy-Preserving Pandemic Protection” published 1 Group Report (GR) and 4 Group Specifications (GS): GR E4P 002 on Comparison of existing pandemic contact tracing systems, GS E4P 003 on High level requirements for pandemic contact tracing systems using mobile devices, GS E4P 006 on Device-Based Mechanisms for pandemic contact tracing systems, GS E4P 007 on Pandemic proximity tracing systems: Interoperability Framework, GS E4P 008 on Back-End mechanisms for pandemic contact tracing systems. ANEC submitted data protection and privacy requirements and comments for GS “Requirements for pandemic contact tracing systems using mobile devices”, GS “Device-based mechanisms” and GS “Back-end mechanisms”, which were accepted.

ANEC commented on ISO/DIS 31700 Consumer protection — Privacy by design for consumer goods and services and ISO/CD TR 31700-2 Consumer protection — Privacy by design for consumer goods and services — Part 2: Use cases. ANEC supported the approval of the standards and suggested harmonising definitions and clarifying some wording about consumers. The standard was approved and ANEC comments were accepted. The ISO 31700 series, published in the beginning of 2023, presents the first set of high-level requirements for ensuring consumer privacy is embedded into the design of a product or service, offering protection throughout the whole life cycle. The new standard will not only facilitate compliance with regulations but generate greater consumer trust at a time when it is needed most. It represents an important achievement for ANEC and ISO COPOLCO.

In 2015, ANEC released the following guidance to assist consumer representatives in standardisation committees to address personal data protection:

• ANEC Pocket Guide “Overview of Privacy Guidance for Consumer Representatives in standards technical committees. Key Principles”
• ANEC Pocket Guide “Overview of Privacy Guidance for members of standards technical committees who are Consumer Representatives: Key Principles for Digital Device Privacy Impact Assessment”
• ANEC Pocket Guide “Using Consumer Data: Consumer Representatives Guide on Privacy”
• ANEC Pocket Guide for Representatives “Using Consumer Data. Data transfer, trading and privacy”
• ANEC Consumer Representatives Guidance "Domestic privacy and the privacy of digitally connected devices"

In May 2022, ANEC responded to the EC Public Consultation on the cybersecurity of digital products and ancillary services and published a position paper on the CRA initiative. We support mandatory horizontal cybersecurity requirements for hardware, software, services and ancillary services, wired and wireless, embedded and non-embedded digital products with security by default and by design, to protect all European consumers. Standards should help in reaching generic technology-neutral security objectives approach to risk assessment, considering the functionality, the societal importance, the real use and the safety risk associated with a product.

CEN-CENELEC accepted the SReq on cybersecurity of radio equipment during September 2022. We welcomed the acceptance, having contributed to the discussion in the CEN-CENELEC SRAHG ‘RED Cyber’.

The EC published its proposal for the Cyber Resilience Act (CRA) in mid-September 2022. ANEC sees the proposal as positive, robust and wide-ranging. The proposal has a broad scope as advocated by consumer organisations. Specific mandatory horizontal cybersecurity requirements for products with digital elements and ancillary services are foreseen, with these covering any software or hardware product and its remote data processing solutions, including software or hardware components placed on the market separately.

Cybersecurity by design and default is essential for ANEC. Mandatory baseline cybersecurity requirements are to cover at least encryption, software updates and strong authentication methods. This step helps increase consumer protection, as some products will be less easily hackable, e.g. baby-phones, digital toy dolls. Harmonised Standards would give presumption of conformity to the requirements of the CRA.

ANEC wants to see the CRA require mandatory third-party assessment for more Internet of Things (IoT) consumer products, many of which are not now defined as high-risk products. The proposed CRA removes some of the burden of being tech-savvy from the shoulders of consumers. It specifies the obligations and responsibilities of economic operators who will have a duty-of-care and responsibilities throughout the lifecycle of the product. They will need to monitor and inform consumers on vulnerabilities, and to share security updates both free-of-charge and without delay.

ANEC responded to the EC public consultation in November 2022.

In 2023, ANEC expressed concerns that the EC draft SReq on cybersecurity requirements has been issued while the Cyber Resilience Act (CRA) is still under discussion by the co-legislators. Many definitions and requirements could change during this consideration, making the standards drafted potentially out-of-scope and in need of redrafting to become Harmonised Standards. In addition, the publication of the standards could put pressure on the co-legislators not to change the original EC proposal. ANEC has also suggested to strengthen some provisions as the public interest needs to take a prominent role in the execution of this SReq, given its importance to the development and the use of cybersecurity measures. The United Nations Convention on the Rights of Persons with Disabilities should also be taken into account when drafting the standards.

In September 2023, ANEC commented on the CEN-CLC Position Paper on Cyber Resilience Act developed by CEN-CLC JTC 13. ANEC disagreed with the position as it was only proving the industry point of view, ignoring our comments. Despite the position was approved by the majority of the CEN-CLC members, some disagreements and comments were expressed. The position will therefore need to be revised and we hope that the ANEC’s comments will be taken into account.

Privacy, security, accessibility and interoperability remain the issues advocated by ANEC in smart cities standardisation (CEN-CENELEC-ETSI Smart and Sustainable Cities and Communities Sector Forum).

Relevant links:

ANEC/BEUC/CI/ICRT Principles and Recommendations 'Securing consumer trust in the Internet of Things' [November 2017]

ANEC-BEUC position paper on cybersecurity of connected products (including European Cybersecurity Act) [March 2018]

ANEC comments on EC draft Delegated Act Radio Equipment Directive Cybersecurity requirements [August 2021].

Letter from ANEC and partners on the Digital Services Act [October 2021]

ANEC comments on the European Commission proposal for a Directive of the European Parliament and of the Council amending Directive 2014/53/EU on the harmonisation of the laws of the Member States relating to the making available on the market of radio equipment (COM(2021) 547 final, 2021/0291 (COD) [common chargers] [November 2021]

ANEC Response to EC Call for Evidence for an Impact Assessment on the Cyber Resilience Act (CRA) initiative [May 2022]

5) Artificial Intelligence and automatic decision-making

ANEC also keeps its focus on Artificial Intelligence. In November 2018, ANEC Deputy Secretary-General, Chiara Giovannini, was appointed to the EC High-Level Expert Group on Artificial Intelligence, which aims to support implementation of the European strategy on Artificial Intelligence. Following an open selection process, the EC appointed 52 experts to the HLEG, comprising representatives from academia, civil society, as well as industry.

On 8 April 2019, the Commission’s High-Level Expert Group on Artificial Intelligence (HLEG), of which ANEC is a member, published its “Ethics Guidelines for Trustworthy AI”. ANEC signed the Guidelines as ANEC is an opponent of most of the content of ethics guidance. However, ANEC continues to call for regulatory measures to ensure that consumers are protected when confronted and affected by AI systems (eg: robots, self-driving cars). On this occasion, ANEC together with AccessNow and BEUC - members of the HLEG - released a statement in support of these guidelines. We stressed, however, that the guidelines can be only a first step.

On 26 June 2019 the EC High Level Group on AI report on Policy and investment recommendations for trustworthy Artificial Intelligence was released and presented to EC Commissioner Gabriel. ANEC signed the report as most of our comments were taken into account. The role of standards in delivering Trustworthy AI is part of the recommendations, as well as the need to map existing regulation and consider adopting a new one.

On 19 February 2020, the European Commission ‘Shaping Europe’s Digital Future’ Strategy was released. It includes a White Paper on Artificial Intelligence proposing several policy options about how to deal with AI. The White Paper presents policy options to enable a trustworthy and secure development of AI in Europe, in full respect of the values and rights of EU citizens. In June 2020, ANEC replied to the public consultation on the White Paper on Artificial Intelligence - A European Approach where we shared our views on the policy options for a European Approach to AI. Our replies focused on use of standards and related legislation to shape the European approach for Trustworthy AI.

The Commission also released a Report on safety and liability implications of AI, the Internet of Things and Robotics. The assessment of the Union product safety legislation in this section analyses whether the current Union legislative framework contains the relevant elements to ensure that emerging technologies and AI systems in particular, integrate safety and security-by-design.

This report mainly looks at the General Product Safety Directive as well as at the harmonised product legislation that follows the horizontal rules of the “New Approach” and/or the “New Legislative Framework” (hereafter “Union product safety legislation or framework”). The horizontal rules ensure the coherence among the sectorial rules on product safety.

In September 2020, ANEC replied to the European Commission Consultation on Inception Impact Assessment: Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence. ANEC said there are gaps in present legislation and new AI related aspects such as explicability require new legal provisions, especially for enforcement purposes. We therefore support Option 3.c: EU legislative instrument establishing mandatory requirements for all applications (underpinned by standards and conformity assessment modules.  

ANEC is a member of the new Sub-Group on Artificial Intelligence (AI), connected products and other new challenges in product safety” to the Consumer Safety Network (CSN). The sub-group’s tasks will be to assess whether and to what extent existing product safety frameworks are adapted to emerging market realities (connected products, AI, software, etc.). In particular, it will assist the Commission in developing an assessment on the need for the possible adaptations of the General Product Safety Directive (GPSD 2001/95/EC). At the beginning of 2021, the work has come to an end with adoption of an Opinion of the sub-group on Artificial Intelligence, connected products and other new challenges in product safety. We are pleased its recommendations reflect several proposals from ANEC and BEUC.

The CEN-CENELEC Focus Group on Artificial Intelligence (AI) was established in December 2018 by the CEN and CENELEC BTs with the aim to develop a vision and roadmap for AI standardisation in Europe. ANEC is the liaison person between the Focus Group and the EC HLG AI. In August 2020, ANEC supported the CEN-CENELEC Focus Group Roadmap on Artificial Intelligence (AI) adoption as it sets the right course for AI Standardisation in Europe. ANEC strongly believes that European Standards can be developed reflecting EU values and strategic interests. 

In June 2021, ANEC commented on the European Commission proposal for an Artificial Intelligence Act, published in April 2021 and which makes use of Harmonised Standards: we expressed support for a legislative instrument establishing mandatory requirements for all applications for trustworthy AI, as we had suggested last year. The new rules should cover risks posed by AI systems in a proportionate manner, with more stringent rules for high-risk applications. However, from the point of view of consumers, the concept of “intended use” does not correspond with real-life situations and neglects the expectations of consumers in modern society. In order to cover the consumer behaviours and what influences them, we suggest introducing the concept of foreseeable use (and not only misuse). 

In October 2021, we co-authored the section on standards of the BEUC position paper on the AI Act “Regulating AI to protect the consumer”. We expressed doubts about how technical standards could deal with fundamental rights.

In November 2021, ANEC joined 114 civil society organisations in a joint statement to ask for changes to the AI Act to ensure that it is an effective instrument for protecting fundamental rights. We have supported the drafting of the section on standards, as part of our work financed by the European AI Fund.

In December 2021, ANEC released its position on the role of standards in the AI Act. Parts of the AIA propose using standardisation based on the New Legislative Framework. This framework is designed for product access in the single market but raises questions when applied to the domain of AI. We think that there are difficulties in transposing fundamental rights and EU values and principles into technical standards from both a substantive and process perspective. ANEC presented its position about the appropriate use of hEN in AIA to CEN-CLC JTC 21 'Artificial Intelligence', which was welcomed by the JTC officers.

In April 2022, ANEC submitted amendments for the European Commission proposal for an Artificial Intelligence Act: While we agree that technical standards are a useful part of a wider regulatory/governance context for AI, we have some concerns (primacy of international over regional standardisation). We are pleased to see that they seem to be shared by the policy makers in the EP JURI Committee draft opinion on the AI Act and the Council Presidency compromise text on the AI Act. Both documents contain the same text about standards which shall respect EU values and strengthen the Union's digital sovereignty.

In June 2022, the European Commission launched a pre-consultation on the draft standardisation request on AI in accordance with Article 12 of Regulation (EU) 1025/2012 on European standardisation, in support of safe and trustworthy artificial intelligence. As the AI Act is still under approval by the European Parliament and Council, the request refers to European Standards (and not Harmonised Standards yet). The request is expected to be amended by the Commission when the AI Act is finally adopted in order to request CEN, CENELEC and ETSI to develop Harmonised Standards to support that Act. Future harmonised standards should build on the work done on the basis of this request.

While the draft request is reflecting some of the concerns we expressed in the past about the role of international standards and the involvement of consumers (and civil society) in the standardisation process, we continue to be worried about this request being already issued while the AI Act is still under discussion by the co-legislators. Many definitions and requirements could change during the legislative process making the drafted standards potentially out of scope and in need of complete redrafting to become Harmonised Standards. In addition, the publication of the standards could put pressure on the co-legislators not to change the AI Act, in contravention of the EU democratic principles of decision making. In addition, ANEC already expressed concerns about the use of standards to implement fundamental rights. 

We think that the text of the draft request needs to be strengthened to describe more accurately what is required with regards to EU values and interests, and in view of the high numbers of vote of non-EU bodies and companies in the ESOs. We also stress that dedicated resources are needed to support the participation of underrepresented stakeholders in standardisation to make it effective. Finally, we believe that the AI standards need to be fit for purpose within the product context and fit in the product context of reasonably foreseeable use.

Those are the messages we also shared with CEN-CENELEC and which were partially taken into account in their position.

Following this consultation that ended on 30 June 2022, the Commission proceeded with the launch of the formal adoption procedure.

In February-March 2024, the EU co-legislators finalised their approval of the AI Act, which was published in the EUOJ in August and will enter into force after 24 months. The EC shall issue a standardisation request covering all the high-risk requirements of the AI Act two months after the entry into force. ANEC did not want the requirements to cover the requirements on data bias. Actors involved in the standardisation process shall ensure a balanced representation of interests and effective participation of all relevant stakeholders in accordance with Regulation 1025/2012. This is in line with ANEC’s position. Those actors shall also consider existing international standards that are consistent with EU values, fundamental rights and interests. This is in line with ANEC’s position.

In February 2021, the CEN-CLC BTs agreed the creation of new CEN-CLC Joint Technical Committee on AI, which ANEC supported. One of the recommendations of the CEN-CENELEC Roadmap for AI, to which ANEC contributed last year, is the setting up of a such a JTC to produce standardization deliverables in the field of Artificial Intelligence (AI) and related data, as well as provide guidance to other technical committees concerned with Artificial Intelligence. ANEC stressed the need for the JTC to focus on European needs and values and not only adopt ISO-IEC standards on AI.

In April 2021, we started the recruitment of an expert to represent consumers in the standardisation of Artificial Intelligence (AI)/automated decision-making technologies (ADM) to help strengthen our advocacy on technology. The expert is participating in CEN-CLC JTC 21 on AI, including CEN-CLC/JTC21 Strategic Advisory Group (SAG), CEN-CLC/JTC 21 AHG 7 ‘Overarching unified approach on trustworthiness’, Standardization Request ad hoc Group (SRAHG) on AI, CEN/CLC/JTC 21 WG 4 ‘Foundational and societal aspects’, CEN-CLC JTC 21 WG 1 TG on Inclusiveness and CEN-CLC JTC 21 WG 1 ‘Technical Coherence Forum’ Task Group (TG). This project has been supported by the European AI Fund, a collaborative initiative of the Network of European Foundations (NEF). The sole responsibility for the project lies with the organisers and the content may not necessarily reflect the positions of European AI Fund, NEF or European AI Fund’s Partner Foundations.

ANEC also participated in IEC SEG 10 ‘Ethics in Autonomous and Artificial Intelligence Applications’. The scope of the group is to Identify ethical issues and societal concerns relevant to IEC technical activities and develop broadly applicable guidelines for IEC committees on ethical aspects related to autonomous and/or AI applications as well as consider any change needed in the IEC Use Case Template to address ethical issues and societal concerns. In October 2021, unfortunately IEC SMB decided to disband SEG 10 and it is unclear at this stage what will happen to the final report on 'Ethics in Autonomous and Artificial Intelligence Applications'. 

In 2022 we secured additional funding from the Mercator foundation to work jointly with BEUC on AI policy and standardisation. We recruited a new staff member jointly with BEUC to work on a project that aims at ensuring a high level of consumer protection in EU legislation on AI as well as in related technical standardization. Thanks to the funding ANEC has also become a member of CEN/CLC/JTC 21/WG 2 ‘Operational aspects’ and CEN/CLC/JTC 21 WG 3 ‘Engineering aspects’. The Mercator Project ended in June 2024. ANEC continued its work in WG 2 and WG 3 upon completion of the project.

ANEC has also been active in supporting civil society actors to engage in standardisation processes. We have organised trainings to brief interested consumer representatives and civil society about the AI Act and the role of standards which have shown the added value of our specific expertise in standardisation.

In August 2023, ANEC submitted negative comments on CEN/CLC/JTC 21 CIB Draft Work programme in response to SReq AI (Doc. N 442). It is still unclear to us how the assessment about how the ISO/IEC standards meet the AI Sreq requirements was made so we suggest providing a justification/rationale. ANEC also asked for measures which will be described to ensure that European standards and European standardisation deliverables are in conformity with Union law on fundamental rights and Union data protection law. In September 2023, the CEN/CLC/JTC 21 Work programme in response to SR AI was sent to the EC, partially reflecting the ANEC’s comments (and others’ comments). This led to complaints about the functioning of WG 1 and JTC 21 in general.

In June 2023, ANEC joined CEN-CLC JTC 21 WG 1 TG on Inclusiveness, thanks to the European AI and Society Fund funding. In July 2023, ANEC and BEUC published a legal study on “The Role of Standards in Future EU Digital Policy Legislation”. Our two organisations commissioned this research to Professor Hans Micklitz (European University Institute). The legal study provides a pathway to reform the process by which harmonised technical standards are drawn up so that they are better able to address today’s challenges, including artificial intelligence.

The decision to transfer the topic and assets of WG2 task group on AI inclusiveness to WG 1, as suggested by ANEC, was taken at CEN-CLC JTC 21 plenary in May 2023. From July to December 2023, ANEC supported the activities of the WG 1/ TG Inclusiveness.

ANEC supported the preliminary New Work Item Proposal (NWIP) for a ‘AI Trustworthiness framework” to which it contributed by participating in CEN–CENELEC JTC 21/WG4, which was approved in line with ANEC’s position. Trustworthiness embraces all the key aspects of AI that are needed by European society. It includes addressing AI ethical issues in a practical way, as well as security, privacy, safety and inclusivity with a risk removal/mitigation-based approach throughout a product’s lifecycle. ANEC – also active in the CEN–CENELEC JTC 21/WG1/ TG ‘Inclusiveness’ - urged CSOs to support it at the level as soon as possible by making contact with their national standardisation bodies.

In December 2023, ANEC organised a lobbying campaign to support CEN-CLC JTC 21 AI New Work Item Proposal for a European Standard (EN) “AI Risk Management”. ANEC was able to include the consideration for "vulnerable people", to have the risk management "covering the whole lifecycle" of AI systems and "long-term risks" as well as the "use of water" and "use of energy”. ANEC asked its members and partners to support it at the national level. The NWIP was approved, in lined with ANEC’s position.

In 2024, ANEC also joined CEN-CLC JTC 21 WG 5 'Joint standardization on Cybersecurity for AI systems'; and WG 1 ‘Technical Coherence Forum’ Task Group (TG).

6) On-line disinformation and ‘fake news’

At the beginning of 2018, ANEC was invited to join the CEN Workshop ‘Journalism Trust Initiative’ (JTI) aimed at developing a verifiable set of rules and benchmarks for trustworthy news and journalism. The Workshop proposers are Reporters Without Borders (RSF) who is supported by the Global Editors Network (GEN), European Broadcasting Union (EBU), and Agence France Press (AFP). Reporters Without Borders and BEUC were members of the High-Level Group on fake news set up by the European Commission (DG CNECT) to address these problems.

In December 2019, the published CWA 17493 was made available for free download and was communicated via social media (#JournalismTrustInitiative). ANEC is pleased to have contributed to this initiative and we hope it will bring clarity to the media landscape and increase consumer trust in the media.

In 2020, the standard was made available in a form so that any publisher can take a self-assessment and self-publish their results if they choose to do so. A framework for getting those assessments independently certified will be offered too.

In March 2021, ANEC was invited to join the JTI Accreditation Council, set up to develop an accreditation and certification scheme based on CWA 17493. Prior to the first meeting on 6 April 2021, ANEC contacted European Accreditation to present the project.  While developing the specific content of JTI Programme, the Council confirmed RSF as the programme owner according to ISO/IEC 17065; The governance and decision-making mechanisms, The business and funding model and the process for monitoring and reviewing of JTI Programme.

7) Smart & Sustainable Cities and Communities

In 2014, ANEC joined the CEN-CENELEC-ETSI Coordination Group on Smart and Sustainable Cities and Communities (SSCC-CG). For consumers, it is important to participate in the use of information and communication technologies ICTs, social and environmental capital in supporting city development and competitiveness, and especially in terms of protection of their rights as citizens in an increasingly interconnected environment. You can read more about the citizens’ requirements for smart cities and what standards can do in our infographic.

In 2017, the SSCC-CG was transformed into a CEN-CENELEC-ETSI Sector Forum with a new plan of activities. It acts as an advisory and coordinating body for the European standardisation activities related to SSCC, analysing and recommending standards for development, adoption, adaptation, or revision by CEN, CENELEC and ETSI, and organising events on standardisation activities for smart and sustainable cities.

In April 2024, the CEN-CLC-ETSI/SF on Smart and Sustainable Cities and Communities was disbanded, following the review of the CEN-CENELEC governance.

In 2017, ANEC made a new proposal to ETSI Human Factors Technical Committee (TC HF) for a work item on Smart Cities standardisation for consumers and citizens, which was approved by ETSI TC HF and ETSI Board. Accessibility is one aspect of the work of this TC which finished in 2020. In September 2020, the ETSI Human Factors Technical Committee published ETSI TR 103 455 ‘Smart cities and communities: Standardization for citizens and consumers’ following ANEC’s proposal and leadership. Prepared with the support of the EC and EFTA Secretariat, the Report aims to demystify standards to local communities, since the needs of citizens are often overlooked in the standardisation processes. A broad set of recommendations is included in the report- for the preparation of guidance material to help cities, codes of conduct to help service to the citizen, and standard measures needed to design citizen services, and improve security, privacy and accessibility. We are very proud of this achievement in times when our collective conditions of living are changed by sanitary measures.

In October 2019, ANEC supported the CEN BT decision on creation of a new CEN/TC 465  ‘Sustainable and Smart Cities and Communities’ (2019/c145). ANEC supported the creation of the new TC, which was agreed. The TC now changed its name to "Sustainable Cities and Communities" and will support the development and implementation of a holistic and integrated approach to the achievement of sustainable development and sustainability in response to the needs of European cities and communities. In March 2020 ANEC attended the kick off meeting.  

The ANEC proposal for CEN TC465 – Sustainable Cities and Communities Draft New Work Item Proposal form on Smart City Citizen Services was accepted by CEN TC 465, with more detailed comments made on indicators and with 8 members expressing a positive view (AT, CY, DE, FR, IT, NO, RO, UK). The services to the citizen work item proposal will now go forward to CEN NWIP ballot in 2022, which is a very important achievement for ANEC.

ANEC is convening WG 2 on Services to Citizens with the scope to consider the standardisation of the basic elements of citizen-oriented service design, and related aspects, and prepare draft deliverables for the TC. ANEC chaired the monthly meetings and edited the document, incorporating the comments received from the WG experts.

In February 2024, ANEC prepared the third draft of EN TR Services to Citizens Working Draft for discussion at the CEN TC 465 WG 2 meeting on 20 February 2024. The document, proposed by ANEC, aims at providing a framework for a standardization project to establish and document best practice in the design and execution of smart and sustainable services made available by local government to citizens, both for residents and for visitors to a community.

In June 2024, the draft CEN Technical Report ‘Sustainable Cities and Communities ― A framework for standardization of services to the citizen’ was out for comments until end August. All the comments received will be discussed by WG 2 during 2024.

Activities in the European & international standards bodies

ANEC is represented in:

• CEN TC 224 ‘Personal identification and related personal devices with secure element, systems, operations and privacy in a multi sectorial environment’
• CEN/TC 224/WG 18 ‘Biometrics’
• CEN/TC 224/WG 19 ‘Breeder Documents’
• CEN TC 465 ‘Sustainable Cities and Communities’
• CENELEC TC 106x 'Electromagnetic fields in the human environment’
• CENELEC TC 108x ‘Safety of electronic equipment within the field of audio/video, information technology and communication technology’
• CENELEC TC 108X WG 3 ‘Sound pressure related to portable music players’
• IEC TC 108 'Safety of electronic equipment within the field of audio/video, information technology and communication technology'
• ETSI TC CYBER
• CEN-CENELEC-ETSI Joint Technical Body on eAccessibility
• CEN-CENELEC JTC 13 ‘Cybersecurity and Data Protection’
• CEN-CENELEC JTC 13 WG 1 ‘Chairman Advisory Group’ (CAG)
• CEN/CLC/TC 13 WG 5 ‘Privacy management in products and services’
• CEN-CENLEC/JTC 13/WG 8 ‘Special Working Group RED Standardization Request’
• CEN-CENELEC/JTC 13/WG 9 ‘Special Working Group on Cyber Resilience Act‘
• CEN-CENELEC JTC 13 WG 6 ‘Product security”
• CEN-CENELEC JTC 19 ‘Blockchain and Distributed Ledger Technologies’
• CEN-CENELEC JTC 21 ‘Artificial Intelligence’
• CEN/CLC/JTC 21/WG 1 Strategic Advisory Group SAG
• CEN-CLC JTC 21 WG 1 TG on Inclusiveness
• CEN-CLC JTC 21 WG 1 ‘Technical Coherence Forum’ Task Group (TG)
• CEN/CLC/JTC 21/WG 2 ‘Operational aspects’
• CEN/CLC/JTC 21/WG 3 ‘Engineering aspects’
• CEN/CLC/JTC 21 WG 4 ‘Foundational and societal aspects’
• CEN-CLC JTC 21 WG 5 'Joint standardization on Cybersecurity for AI systems'
• Standardization Request ad hoc Group (SRAHG) on AI
• CEN-CENELEC-ETSI Sector Forum 'Smart and Sustainable Cities and Communities' (SSCC-SF)
• ISO PC 317 ‘‘Consumer protection: privacy by design for consumer goods and services’

News and recent success stories

EP approves CRA and AIA

At its plenary sitting in March 2024, the EP adopted the Cyber Resilience Act (CRA) and Artificial Intelligence Act (AI Act).

ANEC welcomes the adopted texts, even though they do not fully reflect our positions. Work has started on drafting the SReq to support the CRA and we look forward to its adoption and the development of the harmonised standards.

We are also contributing to the standards development under the current SReq on AI. However, we retain our concerns about the use of standards to support fundamental rights defined in the Act. We therefore see the possibility for the EC to develop “common technical specifications” as a fallback if the standards cannot be developed or are inadequate in their safeguards.

ANEC AI Expert Presents at CEN-CENELEC JTC 21 ‘Artificial Intelligence’ Plenary

In early June 2024, ANEC AI expert, Pete Eisenegger, presented to the CEN/CENELEC JTC 21 Plenary which was attended by 80+ experts and held at the University of Bath, UK.

 ANEC puts forward the need for standards that ensure ‘on the market’ lifecycle care and diligence. However, with respect to AI Trustworthiness, ANEC sees a slow progress on care and diligence throughout the product lifecycle for consumer goods and services.

The AI Act is intended for goods and services on the market and the number of JTC 21 contributions with direct experience of products on the market is very limited. This is significant as being ‘on the market’ brings with it many requirements for product (AI system) governance, many requirements for initial design and subsequent lifecycle activities including customer and user support services. Therefore, ANEC requested JTC 21 to seek and engage with more expertise about what having a product on the market means for good practice requirements.

Moreover, ANEC expressed concerns about the intense frequency high number of meetings which are organized by the different WGs and TGs, which could result in challenges to achieving the goal of increasing inclusiveness of EU civil society in AI Standardisation.

Approval of cybersecurity standards

At the end of June 2024, CEN approved the following cybersecurity standards:

• prEN 18031-1 ‘Common security requirements for radio equipment - Part 1: Internet connected radio equipment’;
• prEN 18031-2 ‘Common security requirements for radio equipment - Part 2: radio equipment processing data, namely Internet connected radio equipment, childcare radio equipment, toys radio equipment and wearable radio equipment’; and
• prEN 18031-3 ‘Common security requirements for radio equipment - Part 3: Internet connected radio equipment processing virtual money or monetary value’.

Although some of our comments were taken into account in the drafting of the standards, we are still doubtful about the applicability and wording of the requirements which we find to be too high-level. Additionally, the testing methodology remains unclear.

Due to the many consumer products to be covered by these standards - such as toys, child-care articles and smart meters – ANEC did not to support the standards.

Final agreement on common charger

As the European Commissioner, Thierry Breton, said on 7 June during a press event, “It is a great day for consumers and the environment”. ANEC could not put it better. We applaud the final agreement on the common charger for mobile phones and other devices (revised Radio Equipment Directive) reached among the European Parliament, the Council and EC. Moreover, the agreement reflects ANEC’s position on common chargers, one we have urged since 2009. The USB Type-C port will be mandatory for portable devices, and harmonisation of wireless charging will be achieved in the future.

The EU institutions enlarged the scope of the EC proposal to include handheld videogame consoles, keyboards, portable speakers, portable navigations, digital cameras, tablets and earbuds. Laptops will also have to be adapted to the requirements by 40 months after the entry into force of the revised Directive. The agreement also includes the provision of clear information and labelling on new devices about charging options, as well as whether a product includes a charger, following requirements on “unbundling”. In the future, after an assessment by the Commission, unbundling could become the default.

A further goal of the agreement is to avoid new fragmentation in the market by asking the European Standardisation Organisations to draft Harmonised Standards on wireless charging.

The revised Directive will enter into force 20 days after publication in the Official Journal, and its provisions will start to apply after 24 months.

Regulation on machinery products

On 21 April 2021, the EC published its proposal for a Regulation on machinery products (https://bit.ly/3i1VKyc). ANEC believes the Machinery Directive (2006/42/EC) has generally worked well in providing a sufficient level of safety for consumers in the EU, as well as aiding the free movement of machinery products. Nevertheless, the Directive needs updating to improve safety levels further, taking account of the latest IT innovations. As the Machinery Directive covers many consumer products, such as gardening equipment, it is vital for the proposed Regulation to ensure the same level of protection for consumers as for workers.

In a position paper published in July 2021 (https://bit.ly/2U3Ss5q), we welcome that several of our suggestions from last year have been taken into account in the proposal. We also give recommendations on provisions that need to be modified in the proposal in order to ensure the highest practicable level of safety for consumers.

We ask for fairground and amusement park equipment to be included in the Regulation, and for means of transport (such as e-bikes and e-scooters) to be included in this or dedicated legislation. The concept of foreseeable use should be used in determining whether a machine poses a high risk, and not only the intended use, especially for AI systems. In line with our first comments on the GPSR proposal, we believe a pan-EU accidents & injuries database, or a revitalisation of the European Injury Database (EU-IDB), is needed to assess whether a machine poses a high-risk to consumers. We believe escalators should be considered high-risks machines. The provision of instructions for use in electronic form (instead of hard copy) should be subject to a specific risk assessment by the manufacturer.

In July 2021 we submitted our position to the EC public consultation: https://bit.ly/3kcCNvb.

European Cybersecurity Act

In June 2019, the European Cybersecurity Act was published in the Official Journal of the European Union and entered into force 20 days after its publication (27 June 2019). According to the Regulation (EU) 2019/881, a European cybersecurity certification scheme ‘shall include at least the following elements: (...) references to the international, European or national standards applied in the evaluation (...).

Furthermore, the act establishes a European cybersecurity certification framework for the development of schemes. The EC will adopt schemes concerning specific groups of ICT products, ICT services and ICT processes. These should be implemented and supervised by national cybersecurity certification authorities, with certificates issued under these schemes valid throughout the EU.

Standards will therefore be the basis for several schemes, with the purpose of ensuring that ICT products, ICT services and ICT processes that are certified as complying with specified requirements which aim to protect the availability, authenticity, integrity and confidentiality of stored, transmitted or processed data throughout their life cycle.

ANEC is already participating in relevant cybersecurity standardisation activities in CEN CENELEC and ETSI.

Opting-in into consumer protection

On 12 May 2009, the EC adopted a Recommendation on privacy and security aspects of RFID which implements the “opt-in” principle. Hence the Commission backed ANEC’s long-standing request for consumers not to be obliged to ask for Radio Frequency Identification (RFID) tags on a product to be deactivated in order to avoid tracking or profiling. Deactivation must be done by default if consumers are to trust commercial use of RFID. ANEC was pleased with the provision calling for a unified RFID sign to be developed by the European Standards Organisations, as we believe consumers should be told of the presence of an RFID tag by a sign, that is easy to understand and accessible to all consumers.

The EC also issued a standardisation mandate to request the European Standards Organisations to develop standards on data protection, privacy and information security aspects of RFID applications. ANEC was able to influence the content of the mandate as far as “privacy by design” is concerned with the results of our research study on RFID standards(visit our Technical Studies page).

In 2014, ANEC welcomed the adoption of European standards on the procedures and logo for the protection of consumers personal data when Radio Frequency Identification (RFID) chips are used.

In July 2009, ANEC welcomed the European Commission Communication on the ‘Internet of things - An action plan for Europe’ as it fully takes on board consumer demands that the “Internet of Things (IoT)” is an “Internet for people”. Internet of Things is a paradigm where novel applications combine mainly wireless, physical objects that can be located and can communicate with each other. ANEC, which works with BEUC and Consumers International (CI), on this issue, believes that the Internet of Things needs to be built in such a way as to ensure easy and safe user control. Consumers need confidence to fully embrace the Internet of Things in order to enjoy its potential benefits and avoid risks to their security and privacy.

In June 2010, the European Parliament adopted a Resolution on Internet of Things in response to the European Commission Communication of 18 June 2009 on the "Internet of Things – An action plan for Europe" (COM(2009) 278final). ANEC welcomed the Resolution as MEPs call for the European Commission to further assess many of ANEC’s requests, such as the impact on health of radio waves and other means of enabling identification technologies; the right to "chip silence", which provides empowerment and user control and the environmental impact of the chips and of their recycling, among others. In addition, the Parliament stressed that “(…) the consumer has the right to privacy by opt-in and/or privacy by design, notably through the use of automatic tag disablement at the point of sale, unless the consumer expressly agrees otherwise” (section 16). And that it “(…) believes that the IoT encompasses many benefits for people with disabilities and may be a way to meet the needs of an ageing population and provide assertive care services”.

"Pump down the volume!"

Young consumers often listen to music using personal music players and radio communication devices including such a facility. It is essential to ensure these devices do not cause certain health risks, in particular unforeseen hearing loss or hearing impairment.

In April 2008, ANEC commented on a draft international safety standard for IT and Audio/Video equipment (IEC 108/276/CDV), noting the sound level of 118dBA – to 125dBA for “long-term” exposure (>0,5s) to be extremely high but below the barrier of pain. A sound pressure at such high level can result in hearing damage and even loss. The requirements of a safety standard should avoid such injuries.

The draft standard also proposed that equipment instructions should require a general warning along with a warning label on the product. However, ANEC believes that the users of portable sound systems are often children or young adults who often do not understand or respond well to cautionary advice. Hence, in order to protect the users of portable sound systems from hearing damage, a technical limitation of sound pressure is necessary. ANEC’s position was confirmed by scientists who conclude that 5-10% of personal music players listeners risk permanent hearing loss within 5 years due to the excessive use of personal music player. ANEC called for sound levels to be limited by default settings in personal music players at a European Commission conference held on 27 January 2009 in Brussels. ANEC also proposed that the role of headphones and in-ear earphones in protecting consumers should be better assessed. For example, the anti-noise function of noise-cancelling headphones can allow consumers to enjoy listening to music at lower sound levels without losing the “groove” (ANEC position paper on the Safety of Music Players).

In June 2009, the European Commission issued a standardisation mandate to develop and revise standards for the safety of personal music players (PMPs). ANEC participated.

In 2011, we welcomed approval of the new standards for Personal Music Players (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: General requirements’). The approach adopted is based on an average sound pressure limit of 85dBA. This is a level that is considered to be safe under all conditions of use. Nevertheless, there is the possibility for consumers to choose to override the limit so that the level can be increased up to a maximum average of 100dBA. 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. Lower limits are prescribed for PMPs for children. The 85dBA and 100dBA limits became applicable in 2013.

Since then, we have been working on a sound level dosage system now detailed in prEN 62368-1:2014/prAD:2018. Among other improvements, it provides the user with much-needed information on safe periods for listening. The aim is to avoid young consumers potentially reaching the safe maximum weekly dosage in a matter of minutes, and then continuing to listen at a high volume simply by acknowledging a warning.

To read more about ANEC’s achievements in different sectors please visit our ‘Success stories’ web page.

Publications

To access position papers related to Digital Society please click the link, Position papers.