Lead Story
ANEC comments on evaluation of Regulation (EU) 1025/2012
ANEC submitted its comments in answer to the EC public consultation on the evaluation of Regulation (EU) 1025/2012 – the Standardisation Regulation. The consultation closed on 25 July.
The answers to the online consultation are supplemented by a supporting ANEC position paper. This builds on answers to the questions in the consultation, as well as commenting on aspects not raised.
ANEC recommends a targeted amendment (rather than a full revision) of Regulation (EU) 1025/2012. Key aspects include enhancing Member States' political and financial frameworks to ensure inclusive stakeholder participation in European standardisation.
Last, but not least, ANEC highlights the need for continuous improvement in the inclusiveness and robustness of the European standardisation process, ensuring it aligns with societal needs and legal frameworks, acknowledging that harmonised standards are part of EU law.
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IPSW – 14-17 October 2024
This year’s edition of International Product Safety Week (IPSW) will take place on 14-17 October in Brussels under the theme ‘Bridges for Global Product Safety’. It will feature a series of interactive and insightful sessions on the most topical product safety issues, as well as a workshop organised together with the United Nations Conference on Trade and Development (UNCTAD).
ANEC has been invited to participate in the panel ‘Inclusiveness in product safety’.
The aim of the panel is to illustrate the lack of inclusiveness when it comes to product design, which can sometimes lead to health and safety risks for consumers. The panel will look at what has been done, or is in the pipeline, to make product safety more inclusive and what are the ways ahead.
As in the past editions, the International Symposium of the International Consumer Product Health and Safety Organisation (ICPHSO) will take place in the framework of the IPSW. This year’s Symposium will be held on 16 & 17 October under the title ‘Bridging the Gap: Linking Policy to Action’.
To register for IPSW, please visit International Product Safety Week by 8 October.
Child Safety
Approval of CEN/TS 17876
At the beginning of July, CEN approved the Technical Specification CEN/TS 17876 ‘Child care articles – Tricycles – Safety requirements and test methods’.
Although ANEC submitted a favourable opinion on the draft, we also commented that the title of the CEN/TS is misleading.
This is an image of a CTP
A Tricycle is a bicycle with three wheels, set in motion by using pedals, while the CEN/TS applies to Convertible Tricycle Pushchairs (CTPs) which are significantly different products. Throughout the entire text, the term ‘CTP’ is used to define the product to which the CEN/TS applies. Although there was agreement in CEN/TC 252 WG3 to change the wording to ‘Convertible Tricycle Pushchairs’ ahead of the vote, the current title remains ‘Tricycles’.
Although we welcome adoption of the document, we trust the change of title is still possible before publication.
Accessibility
Assistance dogs – CEN rejects two standards
prEN 17984-2 'Assistance dogs - Part 2: Dog lifetime welfare' - out for Enquiry until 18 July 2024 – and prEN 17984-4 'Assistance dogs - Part 4: Pre-training, training and tasks' – out for Enquiry until 27 June 2024 – were both disapproved by CEN members.
ANEC had supported the approval of both standards. Although we regret the outcome of the ballots, we hope that the comments submitted will be taken into account allowing the standards to proceed to the next phase (second Enquiry or Formal Vote).
Domestic Appliances & Accessibility
A step back in the inclusiveness of household appliance standards
During August, ANEC expressed disagreement and sent not-favourable opinions on draft amendments to a series of standards developed by CENELEC TC 61 ‘Safety of household and similar electrical appliances’.
The draft amendments address standards for electric irons, spin extractors, floor treatment machines, deep fat fryers, food waste disposers, electric blankets and storage water heaters. All contain the proposal to replace the term “very vulnerable people” by “people with disabilities” in the scopes of the standards.
In a note in the draft amendment to the standard for electric irons, this change is said to be a good alternative to the original sentence: “It is recognized that very vulnerable people may have needs beyond the level addressed in this standard”. The claim made is that the term “very vulnerable people” is no longer considered a defined term.
ANEC stressed in its comments on the drafts that the proposed use of “disabilities” in place of “very vulnerable people” is based on a misunderstanding of the history of the standards initiated by Mandate M/392 and led by CENELEC TC 61 and its WG4 “Use of appliances by vulnerable people, including children”, since adopted by IEC.
This work led to the transformation of the series of EN 60335 standards – more than 100 in total - to cover use by persons with a range of common disabilities or vulnerabilities.
At that time, it was recognised that the revised standards could not cover all possible forms of disability: hence the adoption of the carefully-drafted descriptor, “It is recognized that very vulnerable people may have needs beyond the level addressed in this standard”. The descriptor has remained understood by new generations of standards developers who have maintained the provisions covering use by less able persons.
The proposed descriptor, being less well-defined, could result in these provisions being eroded over time.
ANEC will defend its position during the next meeting(s) of CENELEC TC 61, as this change would result in a serious step back in what we have campaigned for during many years. The proposal also goes against the EC’s efforts on inclusiveness in product safety that aim to make products safe for the European population in all its diversity.
Domestic Appliances
Circular saws: instructions are crucial
The EU joint market surveillance action JAHARP2021-07 on circular saws came to an end in July 2024. ANEC attended the final conference on 11 June 2024.
With funding from the EU and under the coordination of PROSAFE, the participating market surveillance authorities observed a low level of non-conformities in the 55 tested products.
Unfortunately, the number of injuries caused by circular saws was available from only a few countries. ANEC reminded participants of its call for a pan-European accident and injury data system, financed and coordinated by the European Commission.
ANEC noted instructions were incomplete for several products which is of concern. Correct warnings and instructions are crucial for consumers to use a circular saw in a safe way. We found it of even greater concern that “Non-conformities of instructions are considered to present a low risk”. During the kick-off meeting in 2023, ANEC stressed that warnings and instructions for use were one of the most important aspects to be checked during the action from the consumer view. As most consumers do not use a circular saw often and have little experience in working with the product compared with professionals, non-conformities of instructions and warnings can lead to serious accidents. We therefore asked to amend this risk assessment to medium risk. Our request was accepted.
More information on the findings and results of the ‘JAHARP2021-07 circular saws’ project can be found in the PROSAFE Newsletter and the Final Press Release.
Accessibility & Services
ANEC on accessibility of cultural heritage
ANEC expert, Monika Klenovec, spoke on how to achieve improved accessibility to cultural heritage, and how the conservation of cultural objects can benefit from accessibility at the “Bruges: Building Bridges between Heritage and Inclusion” event on 24 June 2024.
Monika, who represents ANEC in the drafting of ISO/FDIS- 5727 “Accessibility of immovable cultural heritage”, showed examples of sites that follow a methodology based on the draft standard.
See the presentations from the event.
Digital Society
Civil society engagement in AI standardisation
On 19 June, ANEC and BEUC hosted a workshop on “Civil society engagement in AI standardisation: How to maximise participation?”. This virtual event gathered over 40 participants from civil society organisations.
Participants heard the state of play of AI standardisation from Antoine-Alexandre André (EC AI Office), as well as standardisation tips from Emilia Tantar (Chair of JTC 21 WG2 and SBS representative). The workshop concluded with break-outs where participants could discuss the barriers to joining AI standardisation, and how to engage or better engage. Our thanks to the Mercator Foundation for supporting the workshop.
ANEC AI Expert Presents at CEN-CENELEC JTC 21 ‘Artificial Intelligence’ Plenary
In early June, 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’;
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- 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.
Ecodesign
ESPR enters into force
The Ecodesign for Sustainable Products Regulation (ESPR) was cited on 28 June 2024 in the Official Journal. ANEC applauds the ESPR will be a game-changer for consumers and the environment. Here is why it matters:
- Scope: Environmental criteria will be integrated during the design phase of far more products.
- Durability & Repairability: ESPR will make products more durable and repairable, reducing the total cost of ownership for consumers.
- Energy Efficiency: Products will use less energy, benefiting both consumers and the planet.
- Circular Economy: By ensuring products are designed with their entire lifecycle in mind, ESPR supports the EU’s goals of reducing emissions and minimizing waste.
| List of meetings 2024 |
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