Number 98 –November 2008

Horizontal issues | Child safety | Child Safety & Design for All | Design for All | Domestic Appliances & Design for All |  Domestic appliances | Domestic Appliances & Environment | Environment | Information society | Information Society & Design for All | Services | Traffic safety | News from other Organisations | New ANEC Representatives | Miscellaneous

IMCO VOTE ON PROPOSAL TO REVISE TOY SAFETY DIRECTIVE

On 6 November, the Internal Market and Consumer Protection (IMCO) Committee of the European Parliament adopted its report on the safety of toys alongside amendments to the Commission proposal. Although ANEC welcomes the IMCO decision to ban six of the most toxic heavy metals, we believe IMCO could have done more to ensure the safety of children. Find out why below under the section Child Safety.

CONSUMERS PREFER THE A-G ENERGY LABEL

A market research study has shown most consumers prefer the well-established A-G energy label to indicate the energy efficiency of white goods to a new, numerical label proposed by industry. ANEC believes this finding should be key in shaping the discussions during the present review of the EU Energy Labelling legislation. Read more below under the section Domestic Appliances and Environment.

DELETION OF THE EXCLUSION CLAUSE

ANEC has been calling for many years for the EN 60335-2 standards for household electrical equipment to be revised in order to delete an ‘exclusion clause’ which omits young and elderly people, and people with disabilities, from the safety provisions of the standards. Several revised standards have now been submitted to CENELEC members for ballot. More details under the section Domestic Appliances.

WE ARE MOVING!

On Monday 19 January 2009, the ANEC Secretariat will move to newly refurbished office accommodation on the 5th floor Avenue de Tervueren 32. The offices will include two (combinable) meeting rooms able to host all ANEC Working Group meetings. More in the next edition of the Newsletter. Please note the postal address and all other contact details for the Secretariat will be unchanged!

HAPPY CHRISTMAS & NEW YEAR!

As this is the last edition of the Newsletter before 2009, all in the ANEC Secretariat wish you a happy, prosperous and safe holiday season!

Horizontal Issues

World Standards Day: Living up to the standards of intelligent and sustainable buildings for consumers

Convergence in the fields of construction and electronics suggests that, in the not so distant future, all homes will be intelligent. This should lead in turn to higher levels of convenience, safety, comfort, security and energy efficiency in the homes of all consumers. In marking World Standards Day on October 14th, ANEC stressed the need for standards both to ensure ‘access for all’ and to provide clear information for consumers on environmental performance.

With this in mind, ANEC works in ISO (International Organisation for Standardisation) to help shape international standards for buildings, in order to guarantee that the needs of all consumers, including the young, elderly and disabled, are met. ANEC supports too the initiative of the European Commission to request the development of European standards which can ensure accessibility is reflected in public procurement of the built environment.

Moreover, remembering that the building sector in Europe consumes 40% of energy supplies, the importance of ‘green’ buildings and sustainable construction products has never been greater. ANEC has, however, expressed concerns about the development of standards in the field of Environmental Product Declarations (EPDs), especially for building products. Indeed, such declarations are based on Life Cycle Assessment data which typically omit essential human health and environmental aspects and lack benchmarks to facilitate comparison.

ANEC speaks at the International Electrical Product Safety Conference 2008

ANEC spoke about protecting consumers, and especially vulnerable consumers, at the International Electrical Product Safety Conference organized by the UK Electrical Safety Council on 8-9 September 2008 in London.

On the first day, ANEC Secretary General Stephen Russell drew the attention of the conference to the inadequacies of the present Member State-led approach to market surveillance in Europe. He noted the different approaches from country to country and the unequal demands placed upon the surveillance authorities in Member States with international borders. He ended by calling for a common European regulatory framework to be established to ensure a coherent approach and adequate funding.

On the second day of the conference, ANEC Programme Manager Chiara Giovannini presented the ANEC initiative for the revision of the Part 2 standards in the EN 60335 series on the safety of household appliances. She recalled the actions ANEC has taken with CENELEC to remove the ‘exclusion clause’ from these standards in order to ensure that their safety provisions extend to household electrical appliances used by people of all ages and abilities.

A panel discussion and audience questions followed the presentation. Great interest was expressed in the issue of children playing with appliances, as play is essential for children to learn. And yet, safety standards expressly do not address the practice of children playing with appliances. ANEC was congratulated for its efforts.

In the final session of the conference, participants agreed on the need for stronger market surveillance to increase the level of product safety for consumers. The development of best practice material for standards enforcement was also proposed.

The position of consumers and voluntary certification in Europe

ANEC presented consumer expectations from product certification at an event held to mark the 10th Anniversary of EEPCA (European Electrical Products Certification Association) in Paris in September.

ANEC Programme Manager Chiara Giovannini presented the position of consumers and stressed that consumers expect products on the market to be safe, irrespective of their origin. She noted that conformity assessment, standardisation and market surveillance contribute to the systems used to ensure product safety. Regarding use of a certification mark to attest the compliance of a product or service with a standard or other specification, she commented that such marks are a source of information for consumers on safety, quality or performance aspects. However, consumers take the safety of the products for granted and so may not look for the additional reassurance of a mark of conformity, especially a safety mark.

Bearing in mind that safety needs to be embedded in all stages of the supply chain, from design to the production process, she ended the presentation by questioning how certification could help in this regard. Participants stated that certification could aid increasing consumer safety if it were extended to products from third countries. It was acknowledged, however, that the problem of outreach presented a particular problem and that there was a first need to enhance global cooperation.

Meet the ANEC General Assembly

^{This section brings the national members from ANEC’s General Assembly into the spotlight}

Imola Ferro from the Netherlands Standardization Institute
Q: Please describe consumer participation in standardisation in the Netherlands.
Consumer participation in standardisation could be improved in the Netherlands.
Consumentenbond, the Dutch consumer association, does participate in the NEN national standardisation committee on Consumer Products and Affairs. But the Stitching Consument en Veiligheid (the Dutch foundation for safety and consumers), which participates in some ANEC activities, no longer tends to participate in NEN committees due to limited resources. We are looking for a solution to facilitate their participation.

Q: What maintains your motivation as a consumer champion in standardisation?
Although NEN is a national standards body and so not a consumer organisation in the usual sense, those of us who work on standards for consumer products and services do see and appreciate the benefits a well-written standard can bring to enhancing consumer welfare.

Q. And finally, what is your favourite European standard and why?
My favourite at the moment is not a standard but a guideline, namely CEN/CENELEC Guide 6 ‘Guidelines for standards developers to address the needs of older persons and persons with disabilities’. Guide 6 provides members of standards committees with a better understanding about the needs of these people in vulnerable groups. However, Guide 6 is not so well known and its use needs to be improved, especially in the development of CEN standards.
Thanks to a proposal from NEN (developed in association with ANEC), the Technical Boards of CEN and CENELEC agreed to create a Joint Working Group on ‘Accessibility for All’. This Working Group can function as a mechanism to encourage use of the Guide. Within CEN, the Guide will be used as a basis for comments on standards under revision and new work. Our task is to convince standardisation experts on the importance and use of Guide 6. The result should be an improved European framework within which the essential needs of elderly and disabled people are taken into account in the field of standardisation.



Johan Sipinen from the Finnish Consumers Association
Q: Please describe consumer participation in standardisation in Finland.
Participation in Finland is co-ordinated by the Finnish Consumer Committee on Standardisation. The members of this committee represent sixteen stakeholders in the area of consumer products and services standardisation. Among the members are all nationwide consumer organisations, SFS (the National Standards Body), NGOs including associations for the environment and for disabled people, governmental organisations like the product safety enforcement bodies, and testing and consumer research institutes.
Traditionally we have been active in the product safety standardisation and prioritised the standardisation of child articles and toys, PPE, household appliances, fire safety and the safety of leisure services. We also participate in the ISO Corporate Social Responsibility standardisation committee and finance the participation of Finnish consumer representatives in this work, both at national and international level. At the moment the main interest and the subject of our discussions is the standardisation of services.
A big challenge we face is the retirement of many consumer representatives with few younger people coming through to replace them.
Q: What maintains your motivation as a consumer champion in standardisation?
As a standards user in my daily work with comparative product testing, I can see the benefits of good standards and the role of standards in the product development. We simply need standards that take into account the safety and needs of consumers.

Q: and finally, what is your favourite European standard and why?
The first standards that come into my head are the standards for toys. However, my favourite has to be EN 14682, setting safety requirements for cords and drawstrings on children’s clothing. It is a well-defined, compact and practical tool in product safety enforcement and product development which has already saved many lives. And it was developed thanks to an initiative from ANEC!

Child Safety

Revision of the Toy Safety Directive: UPDATE
Vote in the IMCO Committee of the European Parliament

On 6 November, the Internal Market and Consumer Protection (IMCO) Committee of the Parliament adopted the report on the safety of toys, drafted by Rapporteur Marianne Thyssen (EPP-ED, BE), together with several amendments to the proposal from the Commission for a revised Toy Safety Directive.

In the months before the vote, ANEC had lobbied and met with MEPs in its campaign for the revised Directive to offer children the highest levels of safety practicable.

ANEC welcomes the decision of IMCO to ban six of the most toxic heavy metals from use in toys: lead, cadmium, arsenic, chromium VI, organic tin and mercury. Toys in food products will also have to be safer: toys firmly attached to a food product will be banned while the packaging of other toys in food products will be subject to more stringent requirements. Warnings on toys will have to be more accurate too: warnings that alert consumers to the risks posed by a toy and advise on its safe use will have to be more visible and easier to understand.

Unfortunately, there are still crucial issues for the safety of children which have not been properly addressed by IMCO:

• The use of dangerous substances is not sufficiently restricted: there is only a partial ban on CMRs (chemicals which are carcinogenic, mutagenic and toxic for reproduction). In addition, many allergenic fragrances will still be allowed in toys.
  
• It will not be possible to use the fast-track comitology procedure with scrutiny in order to adapt specific requirements of the Directive quickly to changes in the design of toys or to set limit values (e.g. for noise, speed or chemicals).
  
• There is no requirement for obligatory, independent third-party testing of specific categories of toy (such as toys for children under three years of age) or toys known to have caused serious accidents in the past (such as magnets). Hence, as today, if a manufacturer claims his toy is produced in compliance with the harmonised European standards, he will be able to affix CE marking and place the toy on the market without any further assessment or independent check whatsoever.

ANEC believes toy safety in Europe can still be further improved. In a press release with BEUC on 6 November, ANEC Secretary General Stephen Russell commented: “It is a particular disappointment that IMCO has not chosen to ban all allergenic fragrances. It makes no sense for such chemicals to be used in toys that a young child can cuddle through the night, every night”.

The European Parliament’s plenary will now vote in December, just before Christmas.

ANEC speaks at the European Parliament’s PSE Conference on Toy Safety

The Socialist Group within the Parliament organized a Toy Safety Conference on 17 September 2008. ANEC, BEUC, Konsumentverket from Sweden and OIVO-CRIOC from Belgium, were invited to make presentations at the event. ANEC Programme Manager Tania Vandenberghe re-iterated ANEC’s call to introduce the precautionary principle in the revised Toy Safety Directive, as well as the comitology procedure with scrutiny and type-examination for certain categories of toys.

ANEC/BEUC handbook: “Find (and understand) the warnings!”

Against the background of revision of the Toy Safety Directive, ANEC and BEUC issued a handbook aimed to illustrate our wishes regarding warning labels on toys. The handbook shows examples of toys which have not been marked with sufficient or correct information and provide a model example where a toy displays a comprehensive warning.

Members of the European Parliament’s IMCO Committee were each given a copy of the handbook ahead of the vote held on 6 November (see above).

The handbook also urges support for specific amendments to the proposed revised Directive in respect of warnings.

The handbook can be downloaded from the ANEC website
http://www.anec.eu/attachments/ANEC-CHILD-2008-G-063.pdf

At last! Baby walkers to be a little safer …

In a press release of 6 November, ANEC congratulated the European Commission and Member States for their Decision to accept that the European standard for baby walkers supports the General Product Safety Directive.

EN 1273, which dates from 2005, addresses the safety problems of excessive speed and the hazard of falling from stairs. In doing so, it offers a far higher level of protection to young children than the previous edition of the standard.

In the United States, standard ASTM F 977-96 (which forms the basis of the new European standard) has proven to be extremely successful in reducing the number of accidents with baby walkers. The introduction of baby walker models complying with the ASTM standard has led to a notable decrease in the frequency of accidents: compared with 1992, accidents with baby walkers in the US had decreased by almost 85% in 2002.

Since its publication, ANEC had urged the European Commission to publish the reference of EN 1273 in the Official Journal so confirming its harmonized status.

Despite the referencing of EN 1273, ANEC continues not to see baby walkers as a walking aid or essential nursery product. As walkers can lead to hazardous situations through encouraging overreach and falls, we do not support their use. However, as long as baby walking frames remain on sale in the European market, they should be subject to demanding technical standards. The decision of the Member States and the Commission will help avoid many accidents caused by unsafe baby walkers and ensure European children at least enjoy the same safety level as their US cousins.

ANEC recommends consumers to buy only baby walkers that comply with the European standard, EN 1273:2005.

The CEN Technical Board postpones acceptance of a mandate to revise the European Standard for child resistant lighters

On 12 June, the European Commission’s 98/34 Committee accepted a draft mandate to revise EN 13869:2000 ‘Child resistance for lighters – Safety requirements and test methods’ (see our Newsletter 96). Following this decision, the mandate was sent to CEN for approval by its Technical Board. As there was already a clear indication at the joint CEN/Commission/Stakeholder meeting on 30 May 2008 that a majority of CEN members, as well as ANEC, were against the mandate, the CEN Management Centre (CMC) proposed to the CEN Technical Board to reject the mandate.

ANEC lobbied members to reject the mandate as we are not in favour of a revision as long as there is no proven alternative test method available to the current child panel test in the standard.

Following discussion at its October 2008 meeting, the CEN Technical Board decided to postpone a decision on adoption of the mandate and to set up an Ad Hoc Group to examine the issue further and report to the next Technical Board meeting. The Ad Hoc Group will meet on 2 December in Brussels. ANEC will participate.

ANEC participates in meeting of CEN TC 136 SC1 on playground equipment

ANEC representative Helena Menezes attended the meeting of CEN TC 136 SC1 held in Bucharest on 11/12 November 2008.

Following adoption of the revised standards for playground equipment, the meeting discussed implementation of the new standards.

ANEC stressed the importance of harmonised guidelines on the interpretation of the standards, especially for inspection authorities. In support of such guidelines, further work on the advantages and disadvantages of different Impact Attenuation Surfaces (IAS) materials will be carried out in order to harmonise interpretations and help designers and operators in their choices. Also, further research on the influence of IAS on upper limb fractures is needed before deciding whether further requirements are needed in EN 1177.

ANEC proposed that SC1 issue a paper defining the current knowledge on IAS, the significance of the HIC test, and the existence of advantages and disadvantages in different types of materials. This was accepted and ANEC drafted a document which was in principle approved by SC1 members as a statement from SC1 on IAS. A small working group will finalise the document and circulate it to SC1 for definitive approval.

Autumn meeting of ANEC Child Safety Working Group

The Child Safety WG met in Brussels on 6 & 7 October. ANEC Secretary General Stephen Russell presented the new ANEC Strategy 2008-2013, adopted by the General Assembly in May 2008. The WG supported the Strategy and it was agreed to discuss at the next meeting how the WG can contribute to the realisation of the Strategy.

Members received an update on revision of the Toy Safety Directive and discussed warnings on toys, cords on toys and suction cups on toys. An exchange on the Commission’s study on child care articles followed and the formal ANEC position formulated. Concerning moveable football goals, the WG was of the opinion that an Ad Hoc Group should be set up between CEN TC 136 WG 22 (dealing with football goals) and CEN TC 52 WG 3 (dealing with mechanical aspects of toys).

On 8 October, a joint session of the Child Safety WG and the Design for All WG was held (see below).

Child Safety & Design for All

Joint meeting of the ANEC Child Safety and Design for All Working Groups

In order to address a request from ANEC representatives made at the ANEC RepNet training event in January to have more targeted training, a joint session of the Child Safety WG and Design for All WG was held in October to discuss needs of children with disabilities, child safety and accessibility requirements.

Presentations were made by representatives dealing with barrier-free playground equipments, the easy opening of packaging and child-care articles.

In the brainstorming that followed, it emerged that not only is knowledge of the needs of children with disabilities low, but so is the knowledge of issues concerning carers with disabilities dealing with disabled or able children. Members agreed a case-by-case approach was the best way to address both of these issues. Overall however, smart technical solutions should be sought to make standards as inclusive as possible.

All participants expressed satisfaction at a very useful and instructive meeting.

ANEC attends second meeting of CEN TC 136 WG12 on barrier free playground equipment

ANEC representatives Helena Menezes and Meg Galley-Taylor attended the second meeting of CEN TC 136 WG 12, held in Berlin on 27 and 28 August 2008.

WG 12 members had each reviewed a part of EN 1176 for playground equipment prior to the meeting so as to ensure the standard neither prohibits inclusive design nor contains conflicts or gaps in safety requirements in using inclusive design. ANEC assessed EN 1176 Part 7 (Guidance on installation, inspection, maintenance and operation). Following extensive discussion on the various options, it was agreed that the best way forward was to recommend CEN TC 136 SC 1 to produce a Technical Report (TR) rather than a standard on barrier-free playground equipment. After approval of the TR, some aspects could be included into a revision of the EN 1176.

At the November meeting of CEN TC 136 SC1, attended by ANEC (see above under ‘Child Safety’), the proposals to draft a Technical Report and to rename the WG “Play for All” instead of “Barrier free playground” were both accepted.

ANEC informed SC1 about its joint Child Safety WG and Design for All WG meeting which could contribute to the drafting of the Technical Report. SC1 and the convenor of WG12 welcomed ANEC’s participation in this effort, stressing the importance of having different expertise in the group: special needs, child play, and playground equipment standardization. A call for experts will be made for the writing of the TR.

Design for All

ANEC Design for All Working Group Meeting

Members of the Design for All Working Group (DfA WG) held their annual meeting on 8-9 October in Brussels. The meeting was preceded by a joint session with the ANEC Child Safety WG (see above).

The ANEC Secretary General Stephen Russell reviewed the new ANEC Strategy 2008-2013. He stressed the action plan to support the Strategy focuses on options to secure the public funding of ANEC at the end of the current Consumer Programme in 2013. A general discussion followed on aspects of the Strategy, mainly its visibility and training for ANEC experts. Members expressed support for the Strategy and thanked the Secretary-General for his presentation.

DfA WG members discussed the issue of different safety requirements for consumers’ standards for lift and lifting platforms. The standard for lifting platforms allows only dimensions which lead to the exclusion of wheelchair users. In addition, EN 81-41 on lifting platforms follows the Machinery Directive which has lower safety requirements than the Lifts Directive. Members agreed ANEC should lobby to improve the standard for lifting platforms.

Accessibility for All and CEN/CENELEC Guide 6

More than 50 people attended a preliminary meeting on work of the joint CEN/CLC BT WG "CEN/CENELEC Guide 6 Implementation Mechanisms". The meeting aimed to develop the best approach for CEN and CENELEC technical bodies to use and implement the recommendations of Guide 6 "Guidelines for standards developers to address the needs of older persons and persons with disabilities".

The meeting, held on 29 October 2008 in Brussels, was opened by Cinzia Missiroli of CEN, together with Charlotte Moises and Jeannette Leenders of NEN, the organizing bodies of the event.

Inmaculada Placencia from the European Commission’s DG Employment and Social Affairs, presented the EU disability action plan 2003-10 which focuses firstly on the transition from an equal rights approach to an equal opportunities approach, and secondly on the proposed horizontal Anti-discrimination Directive (based on Art 13 of EU treaty). Standards for accessibility are considered to be useful in implementation of both policies.

Charlotte Moises outlined the national Dutch project on the use of Guide 6, presented at the CEN level with the support of ANEC. This had led to creation of the CEN/CLC BT/WG on Guide 6 Implementation Mechanisms. Mrs Moises explained the proposal about the possible structure of the BT WG to be included in the draft business plan (advisory committee and pool of experts). She finished her presentation by inviting interested participants to join the group.

In her presentation, ANEC Programme Manager Chiara Giovannini expressed strong support for the initiative, as ANEC members believe standards to be a suitable tool to make products and services accessible. Moreover, considering the demographic trends in Europe, action needs to be taken to ensure the development of European Standards that can serve societal needs.

A lively discussion followed on how to ensure the development of standards which encourage accessibility. Although NEN’s proposal was clearly endorsed, the issue of the project’s financial sustainability was nonetheless highlighted.

Domestic Appliances & Design for All

Safety of household appliances for all

For many years now, ANEC and other consumer organizations have been expressing concerns about the restrictive scope of the standards EN 60335 on the safety of household and similar electrical appliances. The standards exclude the use of appliances by both children and “infirm persons”. We believe this to be wrong as children and older and disabled people do use these electrical appliances for their intended purposes, often without supervision.

Consumer representatives have asked for the revision of these standards since 2005 and it was an ANEC proposal that led to the creation of a specific group dedicated to the issue in CENELEC, supported by a European Commission Mandate (M/392).

As a result of its work, the several revised Parts 2 of EN 60335, dealing with safety of cooking ranges, hobs, ovens and other household appliances, are now submitted to the national delegations of CENELEC for comment/approval with 21 November 2008 as deadline.

Although ANEC is pleased with the proposals for the revision of Parts 2 of EN 60335, given that the essence of the proposed Part 2 standards represents a step forward in making household appliances safer for consumers of all ages and abilities, ANEC reiterates its disappointment at the rejection of surface temperature limits for handles and knobs, and their exclusion from the revisions of the standards.

Indeed, hot handles and knobs pose a serious safety risk to children and to elderly people. As a consequence of their exclusion, we think the proposed standards only partially meet the requirements of Mandate M/392 as far as the safety of vulnerable consumers is concerned.

We now urge National Committees to request WG 4 to start working without further delay on surface temperature limits for handles and knobs in accordance with the CENELEC Guide 29 "Temperatures of hot surfaces", which provides guidance on how to perform the risk assessment related to hot surface temperatures. In addition, ANEC believes that, although Guide 29 applies only to non-functional surfaces and some plastic materials, its temperature limits can be used to indicate acceptable temperatures for children and elderly people, especially when those temperatures correspond to handles and knobs.

ANEC comments on draft revised Parts 2 of EN 60335:
http://www.anec.eu/attachments/Annex%201%20to%20ANEC-ML-2008-0173.pdf

Domestic Appliances

Meeting of the CENELEC Technical Board

ANEC attended the 133rd meeting of the CENELEC BT which was held in Brussels on 21 and 22 October 2008. The most important item for ANEC on the agenda was the update on the exclusion clause work in CENELEC TC 61.

In this regard, ANEC said it was grateful to CENELEC for undertaking this important work and thanked the European Commission for having issued the Mandate M/392 which supports it.

ANEC said it was pleased with the proposals for revision of Parts 2 of EN 60335, but expressed concern in relation to the surface temperatures of handles and knobs. ANEC added the research for which funding from the Commission is requested by TC 61 WG4, should be carried out by an independent laboratory. The Commission noted that this request for funding will need to follow the normal ‘evaluation’ procedure. Lastly, BT noted ANEC’s strong interest in the urgent need to have temperatures of handles and knobs in the proposals for revision of the Parts 2 standards.

Another important topic for ANEC was the concern expressed by several participants regarding the continued lack of financial support for round robin tests within TC 59X dealing with the performance of household electrical appliances. ANEC supported these concerns. The Commission said CENELEC had already asked for funding and that there might be a possibility of signing a contract before the end of this year.

Domestic Appliances & Environment

Research shows consumers prefer the familiar A-G Energy Label layout

In the context of the revision of the EU Energy Labelling legislation, discussions have been held on the layout of the Energy Label which currently consists of a colour-barred A-G scale. Although consumer and environmental organisations along with some Member States have defended the well-known and simple alphabetical layout, the European white goods industry association, CECED, has proposed a new open-ended numerical label where 1 would represent the least efficient appliance, and higher numbers (e.g. 7 or 9, depending on the appliance) would represent more energy efficient appliances. ANEC considers that the A-G label has achieved a very high recognition by consumers, and should be retained.

With a view to this, joint market research was carried out by ANEC, BEUC, Defra (UK), the Energy Saving Trust (UK), and Consumer Focus (UK, formerly NCC). The objective of this project, released on 6 October 2008, was to collect consumer views in Member States on the extent of consumer recognition of the current EU Energy Label, and on whether consumers prefer the current A-G layout to the numerical label proposed by industry. The market research was carried out in seven Member States (Denmark, France, Germany, Italy, Netherlands, Poland, UK) in May 2008, with the results clearly showing that an overwhelming majority of consumers across all seven Member States preferred the A-G layout.

For executive summary of study:
http://www.anec.eu/attachments/ANEC-ENV-2008-G-040a.pdf  

Environment

ANEC, ECOS and EEB call for more ambitious EMAS scheme

On 28 October, ANEC, ECOS and EEB published a joint position on the Commission’s proposal for a revised Community Eco-Management and Audit Scheme (EMAS III).

We and our partners welcomed the revision of the EMAS Regulation as part of the Commission’s Sustainable Consumption and Production (SCP) Action Plan, as we do not believe the current Regulation to be robust enough to deliver the environmental benefits intended. However, we are disappointed to note that the opportunity to transform this instrument into a true system of excellence has again been missed, making it unlikely that the proposal would help the Community to achieve its objectives on climate change or SCP.

Although the proposed Regulation includes proposals which should be welcomed as steps in the right direction, such as the announced development of sector-specific best practice documents and indicators, ANEC, ECOS and EEB believe there is much to be done to differentiate EMAS compliant organisations from those which conform only to the international equivalent, the ISO 14001 standard.

In particular, we regret that the proposal concentrates mainly on the promotion and expansion of the scheme, rather than improving the substantive requirements. In our view, at the very minimum, industrial EMAS organisations should comply with Best Available Technology and should provide evidence that they comply with the levels described in Best Available Technique Reference documents (BREF). The use of these documents should be binding rather than voluntary. Furthermore, we question the usefulness of generic core indicators, proposed by the Commission, as such indicators often lack meaning in that they do not allow for reasonable comparisons between organisations.

The organisations also call for the reference documents and indicators to be developed in a transparent and timely manner, noting that the Commission should have a clear obligation to come up with working plans based on agreed priorities and targets. Finally, ANEC, ECOS, and EEB express strong concerns about the new provision on the use of the EMAS logo as we believe this will open the door to a number of possible means of misuse and confusion with eco-labels. In our view the use of the EMAS logo on products or in connection with product information and/or advertising must be strictly prohibited.

For the joint position:
http://www.anec.eu/attachments/ANEC-ENV-2008-G-037final.pdf

ANEC comments on proposal for a revised Eco-design Directive

ANEC and BEUC issued a new position paper on consumer expectations from the revision of the EU Eco-design Directive published by the Commission in July. The organizations call for extending the scope of the revised Directive to non-energy related products, e.g. furniture and textiles, as there is a need to address unsustainable product characteristics by obligatory minimum requirements, and to remove a certain percentage of the least sustainable products from the market. The Commission proposal lacks ambition as the scope in the draft Directive only refers to energy-related products such as window frames.

We also emphasize need for the legislative framework to address all environmentally relevant factors such as resource efficiency, the use of hazardous chemicals, and waste management in the product-specific implementing measures. In addition, we argue that the provisions for market surveillance and verification procedures should be improved, and that the role of benchmarks should be clarified with a view to making it obligatory for the legislator to consider benchmarks when revising the implementing measures for specific product groups.

Finally, ANEC and BEUC stressed that self-regulatory measures should not take precedence over regulatory measures.

For the ANEC/BEUC position:
http://www.anec.eu/attachments/ANEC-PT-2008-EuP-025final.pdf

Consumer requirements for eco-design of televisions

Eco-design requirements for televisions were discussed in a Eco-design Stakeholder Consultation Forum meeting on 16 October 2008 in Brussels. ANEC and BEUC asked for a mandatory hard-off switch which puts TVs into a zero watt mode in order to prevent unwanted energy losses. We also argued for a minimum level of brightness in the home mode. A minimum level of brightness is required as otherwise manufacturers could set unreasonably low brightness levels in order to get a better rating for the Energy Label. While we welcomed that the planned Energy Label for TVs will be regularly updated until the year 2017 given that it will ensure incentives for manufacturers to continuously increase the energy efficiency of TVs, we raised concerns about the Energy Label being related to the screen size. Consequently very big televisions with high overall energy consumption could receive a class “A” label whereas smaller screens with lower total energy consumption might be rated only “B” or “C”.

For consumer position:
http://www.anec.eu/attachments/ANEC-PT-2008-EuP-029final.pdf

ANEC supports conference on user needs in sustainable construction labelling

The Consumer Council of the Austrian Standards Institute hosted a well-attended conference on user needs in sustainable construction labelling on 21 October 2008 in Brussels. The event was supported by ANEC, ECOS, and the EEB.

The main objective of the conference was to discuss and review current developments concerning environmental information in the construction sector, and identify the labeling needs of potential users. Representatives from DG Enterprise & Industry, DG Transport and Energy, and DG Environment gave an update on their current activities. User expectations were then presented by representatives of consumers, professionals, environmental NGOs, and public procurers. An important point made was the need to balance information asymmetry, and to ensure that sustainability is tackled as a broad issue including also e.g. indoor air quality and social aspects rather than mere energy efficiency. Dr Franz Fiala, organizer of the event and Chair of the ANEC Environment Working Group, stressed the need to have requirements for setting benchmarks and scales in order for users to be able to assess good and bad environmental performance – such requirements are in particular missing from the current draft European standard 15804 ‘Sustainability of construction works - Environmental product declarations - Product category rules’. As an alternative, Dr Fiala proposed Environmental Data Sheets which would combine information from different instruments depending on the product and provide clear scales for comparison. Several speakers noted that the Life Cycle Assessment (LCA) approach does not allow for a comprehensive assessment of all environmental burdens in the cycle, making it a potential tool to be used for ‘greenwashing’.

The afternoon session was dedicated to discussing possible (alternative) methods for environmental product declarations (EPDs, also known as Type III Environmental Declarations) and other labelling systems, as well as limitations of the LCA approach.

EEB 2008 Annual Conference on Sustainable Consumption and Production

ANEC attended the annual EEB conference ‘Turning the Tide’ on 26 September 2008, which focused on sustainable consumption and production issues in light of the recent Commission Action Plan on SCP. The event saw speeches by Commissioners Dimas and Kovàcs, as well as statements from the Sustainable Europe Research Institute, various government representatives, and societal stakeholders.

During the first part of the event, Commissioner Dimas underlined that the EU needs to become an exemplar economy with regard to SCP, but due to the economic crisis institutions face strong opposition to any measures that would limit the current lifestyle. He added that the Action Plan is only the first step for change and in the future all products with environmental impacts would be included in the Eco-design of (Energy-using) Products Directive which is now being revised. The afternoon session focused on EU trends in the use of market-based instruments for environmental purposes, and actions to take. Commissioner Kovàcs, in charge of taxation issues, explained the aims of the revision of the energy taxation framework and noted that the plan is to make it fully compatible with the Commission’s energy package.

NGO representatives noted the importance of steering the market towards better products, ensuring a good implementation mechanism for the Action Plan, with the hope - shared by ANEC - that in the future many additional relevant products are included under the Eco-design Directive.

Information Society

ANEC attends the European R&D Policy RFID-Results and Recommendations in Brussels

ANEC representative Kristina Unverricht attended the ‘European R&D Policy RFID-Results and Recommendations’ Conference on Radio Frequency Identification, held in Brussels on 9 September 2008.

As regards standards and radio regulation, it was noted during the Conference that there appears to be a mismatch between public perception and reality. Indeed, the general public seems to feel as though there are not enough standards when in fact over 200 RFID standards have already been developed.

Although standardisation of RFID is already well established, it was argued that the area of security and privacy was still being addressed poorly and inadequately. Indeed, the existing legal framework was at the heart of the discussion. Some participants believed that the current regulatory situation was sufficient, while others claimed that this issue needed to be further addressed.

ANEC attends IEC TC 108 meeting on safety of audio video equipment

An IEC TC 108 meeting was held in Matsue, Japan from 08 to 14 October 2008, attended by ANEC representative Helmut Hintz.

The subjects under discussion included the IEC 62368 standards on Audio/Video, Information and Communication Technology Equipment.

During the previous meeting in May 2008, it was proposed to add temperature limits for single fault condition. Indeed, there was some concern about the amendment of the standard for temperature limits for single fault condition and about the ambient temperature (25ºC) for measurement. The ANEC representative argued that consumers should be protected against injury during normal operating conditions as well as during and after single fault conditions. Hence, temperature limits should be specified for normal use and for abnormal use including single fault condition. Nonetheless, even though the majority of the National Committees and the experts were in favour of implementing limits for single fault condition, the proposal was not accepted, because not sufficient and therefore premature for vote. A new draft will be prepared as proposal for the 2nd edition of the standard.

Information Society & Design for All

ANEC supports copyrights regimes compatible with assistive technologies

ANEC expressed its support for a letter sent by the Transatlantic Consumer Dialogue (TACD), where ANEC is an observer, to the World Intellectual Property Organisation (WIPO). The letter conveyed its support to the World Blind Union proposal (WBU) for a Treaty for Improved Access for Blind, Visually Impaired and other Reading Disabled Persons.

Since 2003, the WBU has petitioned to allow accessible formats of copyrighted works to be exported and imported, so as to facilitate the global distribution of accessible works over the Internet. Some national laws do not address the new publishing platforms, important to the disability community, and the current legal environment does not allow for the export and import of works across borders.

The TACD letter was to be sent out during the WIPO meeting on copyright limitations and exceptions, on November 3-7, 2008 in Geneva, where the topic was discussed. After an interactive demonstration of assistive technologies devices made by WBU representatives, it was agreed the WBU proposal be discussed at the next meeting.

ANEC defends M/376 on eAccessibility and public procurement final report

ANEC Representatives Nikolaos Floratos (in ETSI) and Mark Magennis (in CEN/CENELEC) attended the final joint meeting of CEN/CENELEC BT 185 WG and ETSI HF TC 47, on eAccessibility. The purpose of the meeting held on 6-9 October in Sophia-Antipolis, France, was to submit both the CEN/CENELEC PT and the ETSI STF final reports for approval. The first referred to the analysis of testing and conformity schemes of products and services meeting accessibility requirements, and the second dealt with the issue of accessibility standards and guidelines for use in ICT public procurement.

Discussions focused mainly on procurement scenarios, and the recommendations for phase 2 of Mandate M/376. Regarding the first, in response to comments from ANEC and industry, it was decided to insert additional text to specify that the scenarios were purely illustrative and that the ‘recommendations’ they contained were hypothetical. Concerning the recommendations, the ANEC representatives argued that phase 2 should explicitly include recommendations for required upcoming work. Indeed, there will need to be sufficient testing methods within the standard, as well as sufficient market surveillance resources to police supplier’s declarations of conformity, and sufficient third party testers.

When the time to vote on whether or not to accept the two reports came, the industry representatives requested that the decision be delayed in order to allow for more time for consultation. The ANEC representatives stressed that, even though the review period was short, the release date had been communicated well in advance. They added it was difficult enough for consumer and disability groups to find the resources to participate in this process and that an extra round of submissions would put an undue burden on them.

Finally, acceptance of the two reports was voted on and they were approved. They will now be sent out for final approval to the Technical Boards of the bodies.

Services

ANEC questions draft European standard on real estate services

ANEC attended the meeting of CEN TC 373 Project Committee ‘Services of Real Estate Agents’ on 8-9 September in Vienna. The aim of the meeting was to resolve the remaining comments received during the enquiry phase, and finalise the document for the formal vote.

ANEC succeeded in deleting a separate annex on e-commerce (in ANEC’s view the requirements should apply to all services, whether provided by traditional or electronic means), and in setting a recommended minimum educational level of 120 ECTS and minimum training period for real estate agents. Regrettably, due to the number of requests for national A-deviations, the group decided not to discuss these requests but to, instead, develop an informative annex listing of all the countries which have national legislation on real estate agents. ANEC objected on grounds that such an annex would have no added value in terms of informing the reader of the standard. Also, ANEC supported the Dutch proposal to make the document into a CEN Technical Report instead of a European standard (EN), thus giving the group more time to find proper consensus on the requirements and thus avoid A-deviations. Although some members agreed that more discussion would be useful on the issue of national deviations, and despite objections that having a mere informative annex was not in line with CEN procedures, a majority decision was taken to draft such an annex, and to proceed to formal vote.

Following the meeting, ANEC sent a letter to CEN and the European Commission to express our concerns regarding decisions taken at the meeting, and the overall low level of consensus in the group, evident from the requests for national deviations made during the enquiry phase.

ANEC attends first meeting of CEN TC 331 WG 5 on letterboxes

After calling for revision of EN 13724 ‘Apertures of private letterboxes and letterplates – requirements and test methods’ for some time, ANEC took part in a meeting of the new CEN TC 331 WG 5 on 17 October in Wenden, Germany. ANEC has called for a revision of the standard due to problems of accessibility and integrity of mail related to the opening of the letter box/plate.

It was made clear that the scope of the standard related only to the aperture and not to the size of the box and that the standard covered letter boxes only with regard to letter post and not parcels. Several members noted that it would be impossible to get agreement on including the size of the box due to cultural and logistical problems, but that it would not be contravening the European standard if national standards bodies made their own individual requirements for the box size provided this did not conflict with the standard. They felt this would address many of the concerns raised which they believed were related to the size of the box rather than the size of the aperture.

The issue of height restrictions for boxes was also brought forward, with agreement to look into this in a subsequent meeting to see if more account could be taken of people with disabilities without being too prescriptive. It was agreed that the revision would be carried out taking into account CEN/CENELEC Guide 6 on the needs of older persons and persons with disabilities.

The next meeting will be held on 30 January 2009.

ANEC participates in CEN BT WG 163 meeting on service standardisation

ANEC attended a meeting of CEN BT WG 163 ‘Service standardisation’ on 6 November in Dublin. As the CEN services feasibility studies, carried out by several National Standards Bodies under Programming Mandate M/371, were finalised earlier this year, the main aim of this meeting was to discuss the follow-up of the projects. The group was informed that the final report on the projects was to be submitted to the Commission for approval in mid-November, and that subsequently the reports would be published in January 2009.

ANEC stressed the need to have a transparent and inclusive action plan for the implementation of any initiatives resulting from the feasibility studies. ANEC also supported the idea for a possible stakeholder workshop once the final report is published, to discuss the results with relevant stakeholders.

The group also exchanged views on the certification of services based on standards, with several members noting a need to have a common approach to service certification. It was proposed that some guidance would be useful in this field.

Finally, the group noted a new study commissioned by the European Parliament on professional and business-related services which also includes a chapter on service standardisation. ANEC’s position and study on service standardisation, from 2007, are both referred to in the study, which considers the possibility of a ‘new approach’ for service standardisation and notes the need for democratic participation of all stakeholders in the standards development process.

CEN BT WG 192 discusses qualifications of professions and personnel

ANEC participated in a meeting of CEN BT WG 192 ‘Qualifications of personnel & professions’ in Milan on 26 September. The WG was set up to identify existing EU Directives, national legislation and standards on the qualification of professions & personnel (QPP), to collect basic terms and definitions, and to define the way QPP should be introduced in process and service standards. Considering that QPP issues are integral to ensure service quality and safety, ANEC is following this work.

It was proposed at the meeting that one of the outcomes of the group should be a CEN guidance document on QPP – this would help ensure a more harmonized approach to QPP issues in European standards. ANEC reminded members of the difficulties experienced in implementing CEN/CENELEC Guide 6, and stressed that if a CEN Guide were to be proposed, a clear implementation mechanism and follow-up, endorsed by the CEN Technical Board, woud be needed to ensure the document is used in technical committees. Members of the WG supported ANEC’s views.

Considering the strong link between service standards and QPP, it was agreed that CEN BT WG 163 ‘Service standardization’ should be consulted during the work.

ANEC will attend the next meeting of this group on 30 January 2009.

Traffic Safety

Joint ANEC/CI Representative attends 6th meeting of the Informal Group on Child Restraint Systems (CRS)

The joint ANEC/CI representative Ronald Vroman attended the 6th meeting of the Informal Group on CRS held in Brussels on 7 October 2008.

The discussions started with one of the most important consumer concerns: a more consumer friendly system of classification. As in the previous meetings, the ANEC/CI representative defended the classification system based on size rather than mass groups. The Netherlands proposed a first draft text for the classification part of the new regulation. The proposal defined new size groups, but seemed to be based on existing dummies. The ANEC/CI representative expressed concern at this proposal.

Further discussion included the test bench specifications. The Transport Research Laboratory (TRL) presented an update on the test bench development and it was agreed to develop the NPACS test bench for frontal impact for use in the Regulation.

Other topics discussed were the load level in Isofix anchorage points, side impact testing and dummies. There was less progress in the choice of dummies to be used, side impact test procedure and choice of frontal crash pulse.

The CI/ANEC representative intervened several times in the discussions, usually advocating rearward facing transport for older children, and more generally to argue for new concepts in the new Regulation.

Annual meeting of the Traffic Safety Working Group

The ANEC Traffic Safety Working Group held its annual meeting on 22 and 23 October 2008 at the premises of Consumentenbond in The Hague. The key issue on the agenda was the use of the results of the ANEC 2007 study, which revealed children up to four years of age would be better protected in cars if they travelled in rearward facing restraints. Members provided feedback on the actions taken at national level and discussions took place on a future strategy aiming at a higher level of safety for children.

Not only was the means of transportation of children in cars of concern but also the child restraint systems in buses. The ANEC Traffic Safety WG, in collaboration with the European Child Safety Alliance (ECSA), had conducted a survey regarding the compulsory use of safety belts in vehicles of less than 3,5 tonnes (Directive 2003/20/EC). The meeting discussed the data which showed different interpretations of the Directive in different countries. It was decided to follow-up on this issue.

The ANEC Secretary-General presented the ANEC Strategy for 2008-2013 and gave an overview on the challenges faced by the organisation. The session then continued with questions and answers on the Strategy. The group also discussed the proposal to rename the Traffic Working Group, leaving out the term “safety”, since the scope of the WG covers a wider range of issues relevant to consumers than just safety, such as emissions and vehicle repair information. This proposal will be submitted to the ANEC Steering Committee for approval.

News from other Organisations

CEN and CENELEC agree to appoint a common Director-General

CEN and CENELEC have agreed in principle to appoint a common Director-General as head of a new CEN/CENELEC Management Centre. The decision follows long and detailed discussions in a common initiative known as the ‘Future Landscape of European Standardisation’ (FLES).

Although the two European Standards Organisations will continue to remain separate entities (with their own General Assemblies, Administrative and Technical Boards), new common structures will be established to address ‘non-specific sectoral issues’ (such as innovation, the convergence of techologies and external policy). Potential savings from the expoitation of synergies between the two associations (estimated by CENELEC President Dieter Harting at 1M€ annually) will be invested in new products and services.

A road map for the creation of the new structures and their supporting processes will now be developed by CEN and CENELEC with its adoption foreseen by July 2009. Implementation of the new structures – and appointment of the new Director-General – is expected during 2010.

CEN and CENELEC relocate office accommodation and Meeting Centre

From 1 January 2009, CEN Management Centre, CENELEC Central Secretariat and the CEN/CENELEC Meeting Centre will be based on the upper floors of Marnix 17, 1000 Brussels (www.marnix17.com), 450m from the present rue de Stassart location.
The nearest metro station will remain Porte de Namur.

The Belgian Disability Forum

ANEC was pleased to attend the ‘Standardisation’ conference organised by the Belgian Disability Forum on October 28th in Brussels, aimed at raising awareness of standardisation and Accessibility. We had the opportunity to learn more about the current situation of standardisation on Accessible Design in Japan. Indeed, Representatives from the Japanese Industrial Standards Committee, the National Institute of Advanced Industrial Science and Technology and the Accessible Design Foundation, came to share with us their different approaches on Accessible Design and Products. As CEN, NBN, Sirris-Agoria and EDF were also there to outline the Belgian and the European situation on Standardisation in Accessibility, the exchange of ideas on the matter was notably fruitful.

New ANEC Representatives

ISO TC 228 ‘Tourism and related Services’ and ISO TC 228 WG 2 ‘Health Tourism Services’

Conchy Martín Rey (CECU - Confederación de Consumidores y Usuarios, Spain) has been approved as the new ANEC Representative in ISO TC 228 ‘Tourism and related services’ and its WG 2 ‘Health tourism services’. Conchy is a long-standing member of ANEC and currently Vice-President of the association as well as Spanish member of the General Assembly. In addition to having long-established experience in both consumer representation and standardisation, Conchy has already been actively involved in ISO as an ANEC/CI Representative on tourism issues. We look forward to working with her in her new role.

CEN/CENELEC BT WG "Accessibility for All"

Mr Carsten Graversen, an architect from the Danish Disabled People Organisation, has been nominated as the ANEC Representative in CEN/CENELEC BT Working Group "Accessibility for All". Mr Graversen has been working on accessibility issues in general since 2001 and more specifically on the issue of accessibility to the built environment. We welcome Mr Graversen and look forward to working with him.

Miscellaneous

Meetings with ANEC representation

Standards Out for Public Enquiry

Published Standards

Latest ANEC Comments

Further Information

For comments, or to write an article for the ANEC Newsletter, please contact: Natalia Giorgi (Natalia.Giorgi@anec.eu)