Main Page     I. The Administrative Framework     II. European Environmental Policy
III. Directives Implementing the EU Environmental Policy
IV. Chart of the Directives and Enforcement Dates

Background (Developing the Environmental Standards)/Green Standards Initiative

A. Background

For the most part, these directives do not set forth any specific performance requirements. The directives and proposals for directives governing product safety and environmental performance are primarily concerned with definitional and procedural issues. The directives usually include careful definitions of the product that are included and excluded from coverage. The definition define the level of conformity assessment that will be applicable to a product are also included. The procedures that the manufacturers and/or notified bodies must complete to prove conformity are also spelled out in some detail.

CEN, CENELEC and ETSI, the EU standards development organizations, create the harmonized standards that are used to implement the essential requirements of the directives. These standards, in effect, provide specific product requirements on the basis of the very general essential requirements.

The technical committees (TC) organized by CEN, CENELEC and ETSI develop the harmonized standards that provide concrete criteria for implementing the essential requirements in the New Approach directives. Most TC members are safety experts recruited from the industry. Although the members of these TCs act under instructions from their mirrors committees, participation in the work of a TC is voluntary and unpaid. The national standards development organizations that sponsor the mirror committees and the TC members are dependent on industry to support the work of these volunteers.

B. The Green Standards Initiative

In the 1999 critique of the process for developing the harmonized standards, DG Enterprise argued that environmental implications should be considered closely in the process of standards development. Since then, DG Environment has sponsored the development of ECOS, a green NGO, to participate in standardization activities. The three EU standards development organizations, CEN, CENELEC, and ETSI, are also developing a series of measures to ensure a fuller consideration of environmental issues in standards development.

The successful development of the green standards initiative can provide the program managers with a way around the article 175 problem. All of the European national standards development organizations are members of CEN, CENELEC and/or ETSI. Under the bylaws of these organizations, standards that have been developed and issued at the EU level must be transcribed as national standards and any conflicting standards must be removed. This process forces all EU member states to adopt the same CEN, etc standards as national standards. The potential problem for governments imposing environmental requirements which are more stringent than the EU legislation would be eliminated if the environmental performance requirements were incorporated into the harmonized standards. However, this could mean that the TC’s would be, in effect, developing the critical environmental policies, something that the CEN management would like to avoid.