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EURAMET e.V.

The European Association of National Metrology Institutes (EURAMET) is a Regional Metrology Organisation (RMO) of Europe.

Lobbying Activity

Response to Advanced Materials Act

13 Jan 2026

Measurement science (metrology) is crucial in underpinning accuracy and standardization. To promote this, several European Metrology Networks (EMNs) have been established by EURAMET, the European Association of National Metrology Institutes. These networks are collaborative, topic-focused platforms designed to strengthen metrology research, innovation, and service provision across Europe. EMNs support the development of a coherent metrology infrastructure aligned with Europes strategic priorities and the most strongly connected EMNs to this initiative are Advanced Manufacturing (EMN-Advanced Manufacturing) and Quantum Technologies (EMN-Q). Confidence is key to accelerate innovation of advanced materials, from basic research to industrial R&D, scaling up and global trade. Metrology provides that confidence, by providing robust, validated measurement methods that yield consistent, reproducible results. The challenge is that often the pace of innovation of advanced materials is faster than the availability of robust and standard test and evaluation methods, which can create lack of trust and slow the uptake and investment in new materials. EMN-Advanced Manufacturing recently ran two large stakeholder workshops with more than 300 participants, to identify needs and priorities to support the Advanced Materials sector. A draft short report of these consultations is attached to provide further evidence to this feedback. EURAMET will publish soon a full report on the Metrology for Advanced Materials stakeholder needs. The consultations covered Critical Materials, Clean Energy Materials, Materials for Future Electronics and Electronic Materials, and Materials for a Digital World. Across all areas, the need to remove barriers to accelerate innovation was highlighted. In particular, the need to provide confidence at each stage of the innovation process, requires that stakeholders agree on metrics and are able to reproducibly measure and evaluate these metrics. These require best practice in measurement, test and evaluation that is often not available for innovative advanced materials. Therefore, we suggest that the Advanced Materials Act should foster a reliable and reproducible measurement infrastructure for advanced materials to enable faster innovation. The benefit would be higher confidence to upscale, invest in and adopt advanced materials, where measurement data is trusted and test and evaluation methods are available across the supply chain, from early-stage R&D to global trade and regulation. Accordingly, metrology aspects should be considered in the implementation of the Advanced Materials Act. Collaboration of industry and academic partners with EU National Metrology Laboratories will be critical to enable this. The added value of EMN-Q is its pan-European dimension. This would simplify the integration of the diverse expertise of European National Metrology Institutes with those existing in RTOs, academia and industry across Europe, developing the necessary measurement infrastructure for supporting the standardisation and the advancement of quantum technologies. In this perspective we suggest the European Commission to support the realisation of a measurement and testing infrastructure for advanced materials and quantum technology equipment. Indeed, quantum technologies are extraordinarily sensitive to microscopic imperfections, environmental noise, and material defects. The need for a comprehensive, standardized, and high-fidelity measurement and testing for materials and components becomes increasingly critical. Advanced materials used in quantum systemssuch as superconducting films, ultralow-defect semiconductors, colour centres in diamond, ion-trapping substrates, and cryogenic-compatible componentsexhibit quantum-level properties that cannot be fully characterized using conventional material testing methods.
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Response to EU quantum Act

15 Dec 2025

We welcome the opportunity to respond to the EU Quantum Act consultation on behalf of EURAMET, the European Association of National Metrology Institutes (NMIs), and its European Metrology Network for Quantum Technologies (EMN-Q). On Pillar 1 (fragmentation), the Quantum Europe Strategy foresees a coordinated European quantum sensing, measurement and testing roadmap as well as a Europe-wide, centralised network of open-access quantum testbeds, to support industrialisation and ecosystem setting up. To respond, the EMN-Q is proposing a European Quantum Metrology and Testing Infrastructure (EuroQMTI) to meet the objectives of the quantum strategy. On Pillar 2 (Industrial capacity and investment), the metrology facilities are critical technological infrastructures for quantum infrastructures (Area 2 of the QES) and for strengthening the EU quantum ecosystem and supply chains (Area 3 of the QES). Through projects such as FPA Qu-Test and the EuroQMTI initiative, NMIs provide access to highly sensitive, technically complex and costly systems and laboratories that would otherwise remain out of reach for most users. These facilities serve as testbeds for innovation, training grounds for talents (quantum engineers, technicians, PhD students) and would allow industry, SMEs and researchers to test, validate and benchmark quantum devices, including targeted actions under the European Metrology Partnership to mature specific quantum and enabling technologies. They de-risk quantum innovation and accelerate transfer of research results into industrial uptake, enlarging industrial capacity and helping to close the investment gap for deploying quantum technologies in Europe. The Commission will release a Quantum Chips Industrialisation Roadmap by 2026. Technical interoperability and standardisation, underpinned by metrology, are essential to respond to rapid innovation. The strong presence of European NMIs in European and international standards bodies (CEN-CENELEC, ETSI, ISO/IEC, etc.) gives the EU influence that directly supports the global competitiveness of EU companies. Metrology institutes are also key for market uptake, security certification and standardisation of quantum communication. On Pillar 3 (Supply-chain resilience and governance), the Quantum Europe Strategy notes that Europes quantum supply chain must be reinforced to reduce excessive dependency on non-European sources. Quantum metrology laboratories and facilities are integral to this supply chain: they qualify materials, components and systems, including their interoperability, and provide the traceability as well that underpin reliability and trust in critical technologies. NMIs should therefore be explicitly considered in EU-wide risk assessment, both as assets to be protected and as providers of independent evidence on performance, reliability and security.
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Response to Roadmap for artificial intelligence and digitalisation for energy (RAID-E)

5 Nov 2025

Metrology, the science of measurement, plays a crucial role in improving standardisation of AI and developing methods of quality assurance of data used for validation. To promote this, several topic-focused European Metrology Networks (EMNs) have been established by EURAMET. Article 15 of the Artificial Intelligence Act (Regulation (EU) 2024/1689) recognises metrology organisations as a stakeholder to provide appropriate levels of accuracy, transparency, robustness and security for data by which Artificial Intelligence (AI) is trained. One of the issues the European Commission (EC) highlights is access to quality data and the challenges presented by the current siloed approach to data. The EMN for Clean Energy works in investigating the use of AI in research to accelerate the discovery of new materials for next generation batteries or promoting their energy efficiency and clean energy consumption. To understand, track, and even predict performance degradation, AI tools are needed that can decipher the state of charge (SoC) and health (SoH) of each individual cell component to assess the state of safety (SoS) of a battery for second-life applications and direct or indirect recycling. This requires reliable, absolute characterisation methods that link materials performance parameters to their underlying chemical and physical properties, not just empirical correlations. For only slightly non-linear data or other data which can be appropriately transformed by an analytical function, AI applications are valuable to reveal the materials correlations. High-resolution X-ray and other spectroscopies, combined with AI-driven data analysis, can guide the rational design of next-generation energy storage materials with enhanced stability and capacity, while accelerating the directed discovery of functional materials for a wide range of electronic and energy technologies. Another issue highlighted by the EC is the intrinsic risks related to large-scale deployment of digital and AI tools. The EMN for Mathematics and Statistics helps in ensuring quality and transparency for AI input and output data, and for relevant processes, e.g. machine learning (ML) training and testing; it supports production of reference datasets as digital standards, develops metrics for the trustworthiness assessment of AI/ML tools, and helps their standardisation and regulation processes, as can be observed in the following project: The 24DIT05 GridData project aims to improve the reliability of power grid monitoring by: (1) assessing and identifying unreliable voltage and current measurements using machine-learning methods; (2) developing grid models, digital twins, and simulated datasets for testing; (3) creating a standardized framework to validate AI-based methods for detection of abnormal grid events and for forecasting grid congestion and imbalances, which includes quantifying the uncertainty and robustness of the predictions (see feedback F33085970 and attachment). AI has dual impact on energy systems: on the one hand, it requires large amount of energy for deployment of Large Language Models (LLM); on the other hand, AI has potential to optimise energy use at large scale. Long-term forecasts, with power purchase agreements, may improve deployment of renewable energy generation, and demand side response programs may help reduce demand load and facilitate more efficient use of the existing energy infrastructure. In this context, metrologically validated AI metrics and algorithms with quantified uncertainties are instrumental for digitalisation and automation of the next generation of energy infrastructure. Cooperation by European national metrology institutes (NMIs) within a joint European Metrology initiative under FP 10 is essential for providing an adequate response to the measurement challenges associated with the successful integration of AI into the energy system.
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Response to Union prevention, preparedness, and response plan for health crises

29 Oct 2025

EURAMET, the European Association of National Metrology Institutes, welcomes the opportunity to contribute to the European Commissions initiative to strengthen the EUs capacity for emergency preparedness and response to health crises. Measurement science (metrology) underpins the accuracy, reliability and comparability of data that support effective decision-making in crisis situations. Through its European Metrology Networks (EMNs), EURAMET coordinates expertise across Europe to provide harmonised and traceable measurement systems that directly strengthen resilience. Two different scientific perspectives are presented in the attached document: Part A Preparedness for radiological or nuclear events (European Metrology Network for Radiation Protection EMN RP) Part B Preparedness for health crises through reliable diagnostics (European Metrology Network for Traceability in Laboratory Medicine EMN TraceLabMed)
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Response to Targeted revision of the EU rules for medical devices and in vitro diagnostics

6 Oct 2025

Metrology, the science of measurement, plays a crucial role in developing and improving methods of quality assurance and standardization. It provides a means to achieve comparability of measurement results across different analytical systems, between laboratories, and across patient populations. Regulation of laboratory tests is important to ensure safety and effectiveness for the populations served. The inclusion of improved metrological traceability across laboratory medicine as part of the IVDR drives greater effectiveness of test results, improving the portability (across time and space) of results for laboratory measurements. Unreliable laboratory measurement causes unnecessary repetition of measurements that represents a waste of money. Thus, improving reliability of diagnostic tests contributes both to the reduction of unnecessary tests and reduces costs for both healthcare systems and patients, minimising insurance costs and co-payments inflated by services that would not have been necessary. Significantly reducing this level of wastage through improved measurements will allow nations to achieve the greatest value from the money spent on medical care. To support this effort and bring together the European metrology system, the European Metrology Network for Traceability in Laboratory Medicine (EMN-TLM) has been established by EURAMET. The EMN-TLM aims to support the IVD industry by reducing the burden of regulatory compliance for IVD manufacturers. In particular, it will provide coordination across Europe for the development of reference measurement procedures and certified reference materials and commutable CRMs for priority measurands and increase awareness and availability of measurement services for IVD manufacturers to support new device registration and post-market surveillance. This work will help enhance efficiency and reduce healthcare costs for the European IVD industry.
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Response to Revision of the Standardisation Regulation

7 Jul 2025

EURAMET, the European Association of National Metrology Institutes, welcomes the opportunity to contribute to the European Commissions initiative to revise the EU Standardisation Regulation. We strongly support the European standardisation system and, in particular, the role of harmonised European standards (hENs) in ensuring the smooth functioning of the Single Market, supporting regulatory compliance, and fostering innovation. Harmonised standards are essential instruments for the implementation of Union legislation, enabling manufacturers to demonstrate conformity with legal requirements in a transparent and reliable way. Their development through a consensual, inclusive, and technically rigorous process by the European Standardisation Organisations (ESOs) and involving stakeholders from industry, regulators, and scientific actors, should remain the cornerstone of their legitimacy and quality. As the regional metrology organisation for Europe, EURAMET emphasises the importance of ensuring that harmonised standards are based on scientifically validated, traceable, and reliable measurement methods. For this reason, we highlight the critical role of pre-normative research in metrology - research activities aimed at developing and validating the measurements needed to support the drafting and implementation of standards. Pre-normative research provides the scientific underpinnings for test methods, performance criteria, calibration protocols, and reference data essential for many hENs. EURAMET and its members have a long-standing track record in contributing to European and international standardisation efforts. This happens primarily in projects under the European Partnership on Metrology, either through dedicated pre-normative projects or through metrology research projects where, in most cases, standardisation is included in the impact work package. These projects provide practical tools, guidance, and data that feed into standardisation processes and provide support to EU SMEs, startups, civil society and academia to participate in the process. We encourage the Commission to recognise and strengthen the interplay between standardisation policy and research policy. Ensuring continued support for pre-normative and co-normative research in metrology will be essential for the quality and future relevance of harmonised standards. EURAMET remains fully committed to supporting the European standardisation system and is ready to engage in dialogue to ensure that the revision of the Regulation reflects the evolving needs of the European economy and society.
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Response to EU Fusion Strategy

1 Jul 2025

The European association of national metrology institutes (EURAMET) welcomes the development of EU Fusion Strategy. Due to recent developments, the time horizon for commercial use of fusion energy has come closer. However, unlike well-developed nuclear fission, major technological challenges still need to be addressed on the path to a fusion power plant which require European coordination through European research programmes. The challenges arise from the extreme conditions of a fusion power plant, e.g. in terms of energy flows, temperature gradients and especially neutron flows. Significant progress has been made in existing experimental facilities, e.g. on plasma insertion, but there is still a particularly high need for research and development with regard to the expected extremely high neutron flows leading to extreme material contamination. Metrology facilitates trust in measurements. In a large and complex research programme such as that for fusion, it is essential that results once established, are consistent over time and location. Since validation and performance assessments, including digital twins, simulations and training of AI with reliable data are dependent on experiments and therefore on measurements, these measurements have to be performed against an unwavering baseline. The SI system of units has been that universal reference to great success for many years, and it is traceability to the SI which is the specialty of the metrology community. Some of the topics where metrology can potentially support fusion through dedicated research activities are: Traceability for material characterisation of novel materials under fusion-relevant conditions, such as high temperatures and high-energy particle flux; traceability for temperature and pressure measurements in high magnetic fields and harsh radiation environments; plasma diagnostics, such as density, energy content and presence of impurities; characterisation of magnet performance in terms of field shape, strength, stability; measurement capabilities for very high neutron fluxes and accurate neutron cross sections for new materials over a large neutron energy range; sensor networks and digital metrology twins; The research agenda for fusion in the EU should include the necessary research on metrology to support development and deployment of fusion power. An assessment of measurement needs must be performed, and a roadmap for metrology research must be developed with all relevant stakeholders from the fusion community. The demanding measurement challenges, unique environmental conditions and physical restraints imposed by the fusion reactor can only be overcome with the two communities working together closely for an extended period of time. Metrology supports also quality assurance. Procurement of parts, components and subsystems and its alignment and assembly will require strict specifications that need to be verified as part of quality control. The European metrology network (EMN) on Advanced Manufacturing has been working on solutions for this across a range of sectors, and has mentioned ITER explicitly in its Strategic Research Agenda. For the successful deployment of nuclear fusion power, quality assurance and standardisation are needed on safety-critical structures, systems and components (SSC) and how they relate to each other. Establishing traceable, validated measurement standards for e.g. degradation thresholds, in-situ and ex-situ inspection techniques for non-destructive evaluation of material performances will be relevant. Interlaboratory comparisons and certification processes are needed e.g. to define calibrated measurement protocols to verify SSC behavior under stress, thermal loads, neutron irradiation, and magnetic interference. Standards supported by metrology will maintain international alignment and trust. To ensure the safety of employees, immediate surroundings and the wider environment an appropriate regulatory framework is needed.
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Response to Biotech Act

11 Jun 2025

Metrology, the science of measurement, plays a crucial role in developing and improving methods of quality assurance and standardization. To promote this, several European Metrology Networks (EMNs) have been established by EURAMET. These networks are collaborative, topic-focused platforms designed to strengthen and streamline the coordination of metrology research, innovation, and service provision across Europe. European Metrology Networks support the development of a coherent and responsive metrology infrastructure aligned with Europes strategic priorities. Three EMNs are strongly connected to biotechnology and biomanufacturing: Advanced Manufacturing, Traceability in Laboratory Medicine and Radiation Protection. The work of the EMN on Advanced Manufacturing helps to develop traceable measurements providing quantitative information on product reproducibility, consistency, performance and safety in fields including therapeutics, medical devices and packaging. It ensures compliance with long-term sustainability principles by developing the analytical framework underpinning manufacturing at reduced energy consumption, waste and use of materials and processes with large carbon footprint. This is in part realized through disruptive approaches to manufacturing, including continuous and digital manufacturing. The biotechnology and biomanufacturing topic addresses the metrology requirements to enable the following methods. Methods for quality control and quality assessment of pharmaceuticals and biologics; Methods to assess properties and safety of advanced materials in biological environments, including nanomaterials, biosensors and bioelectronics; Methods to evaluate performance of biologicals (manufactured biological materials); Methods for agile scale-up and scale-down manufacturing, the latter supporting manufacturing of personalised therapeutic solution; Development of reference standards for bio-manufacturing and engineering biology, including reference materials and methods to benchmark bio-, bio-based and bio-derived materials; Methods to ensure safe use of ionizing radiation in accordance with European regulation and ensuring that these methods are technically advanced. This encompasses metrology to characterize novel sustainable materials, develop safe and resource efficient manufacturing processes to assure the safety and quality of materials, components and products in support of the European Green Deal. Within Traceability in Laboratory Medicine, the network aims to provide support for the development of fit for purpose reference measurement procedures and (commutable) reference materials which will support quality control of novel biological diagnostic tools for biomarkers (e.g. genomics, companion diagnostics, personalised medicine), ultimately reducing the burden of regulatory compliance for manufacturers and improving confidence for investors. The early adoption of metrological concepts in the research, development and design of novel biological diagnostic tools can support faster transfer from research only use to routine clinical use.
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Response to EU Strategy on medical countermeasures

9 May 2025

Our statements reflect preparedness for radiological or nuclear events in the view of the European Metrology Network for Radiation Protection (EMN RP), a network under EURAMET, the Association of National Metrology Institutes. Statement 1: A mechanism is needed that consistently requires and promotes the modernisation and transformation of national radiological monitoring to ensure the availability of high-quality measurement data (through traceability to the SI system) to facilitate a fast decision making based on trustworthy information. The aim must be to harmonise radiation monitoring approaches internationally. This also includes clear quality criteria, defined in norms and standards that protect the population and enable new technologies. The transformation process of digitalisation through the provision of digital conformity assessments, digital calibration certificates and the digital product passport, for example, can be a decisive building block here. European countries have different monitoring strategies and techniques in preparing and responding to radiological and nuclear emergencies, and harmonization would allow for more efficient and consistent protective actions, also across national boundaries. Radiation measurements made by citizens have a huge potential in establishing radiation situation in Europe with very good coverage. However, more research is needed to understand uncertainties and useability of these data and how it could support decision making in emergencies. In the field of technical standards, European involvement is declining. There is increasingly less involvement from the member states within the framework of CEN-CENELEC and ISO and IEC. As a result, Europe is increasingly playing a minor role in standardisation. This is a serious disadvantage for European interests because those who do not standardise will be standardised. The consequences to European industry can be overwhelming. Measures are needed to make participation from Europe in international standardisation attractive (again) for those concerned. The standardization should not be driven by economics and industry only safety, reliability and applicability should be driving forces, too. Bureaucratic obstacles should be avoided and established tools that ensure trust in the quality and safety of new technologies should be supported and digitalised in a targeted manner. Statement 2: Establish a mechanism that fosters participation in standardisation when addressing issues of CBRN. Metrology and EMN RP supports this ongoing transformation by providing a sound basis for measurements and modelling. Availability of appropriate standards and metrology services, such as measurements and radiation protection instrument calibrations, create a basis on which reliable radiation exposure estimates can be based on. At the same time the European Partnership on Metrology brings together metrology community and its stakeholders to tackle global challenges in fundamental science and applications of ionizing radiation, including health, environment, and industrial applications. For this reason, public consultations have been established to shape the Calls within the Partnership of Metrology which provides us with the opportunity to speak for the needs of our Stakeholder. EMN RP works on an urgently needed knowledge-sharing programme for stakeholders, regularly hosted activities for a wide range of stakeholders such as the exchange of scientific personnel between organisations, metrology workshops, training courses and interlaboratory comparisons. These activities are funded by the metrology institutes directly or by small capacity building initiatives within EURAMET. To maintain technological updates or to adjust to new threat scenarios appropriate funding mechanisms are needed to ensure safety and competitiveness of Europe regarding measurements, services, and standardisation that are based on the stakeholder needs.
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Response to EU Life sciences strategy

17 Apr 2025

Metrology, the science of measurement, is key for the quality infrastructure in health and is instrumental to accelerate the innovation process for new European medical products for high-quality and efficient healthcare. While metrology and metrological traceability of results is a required foundation for the accuracy, precision, comparability, and exchangeability of medical test results, there are capability and competence gaps that need to be covered. A strategic and collaborative approach is needed for successful establishment and implementation of the metrological traceability concept in life sciences. Accordingly, in designing the strategy for European life sciences, metrology and European Metrology Institutes constitute a key research area and research infrastructures, to support accurate, precise and comparable measurements, including vital signs, in-vitro diagnostics, quantitative medical imaging, analytics, (nano- and cell-based) pharmaceuticals, radiotherapy, medical devices and care solutions. develop improved measurement solutions and certified reference materials for medical applications. support evidence-based decisions for more proactive, accurate, and patient-centered healthcare by providing reliable data. support to the health care regulatory frameworks such as for in-vitro diagnostics and medical device regulation. support to faster market entry of new technologies and devices within the regulatory frameworks. assess data quality in eHealth and in Health Data Spaces, including algorithms and the use of artificial intelligence in healthcare (EU AI Act article 10 and 15).
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Response to EU Start-up and Scale-up Strategy

17 Mar 2025

The Role of Metrology Metrology is key to supporting start-ups based on breakthrough technologies by improving infrastructure access and facilitating regulatory knowledge transfer. To strengthen the EUs start-up and scale-up strategy, the following measures should be considered: 1. Enhanced Access to Testing and Validation Infrastructures. Start-ups often face challenges in accessing essential technology infrastructures. European Metrology Networks (EMNs), along with national metrology institutes, provide improved access to testing and measurement services available from the European NMIs. This support facilitates feasibility studies, product validation, and accelerates certification of processes, thereby reducing bureaucratic hurdles and fostering innovation 2. Support for Standardization Initiatives. Pre-normative research conducted by national metrology institutes is crucial for the standardization of new technologies. By involving small and medium-sized enterprises (SMEs) and start-ups in these research projects, EURAMET and its members, National Metrology Institutes, can accelerate the standardization of European technologies, promoting innovation and ensuring products meet regulatory requirements. 3. Facilitating Knowledge Transfer in Regulated Sectors. Start-ups operating in heavily regulated sectors, such as medical devices and radiation protection, require guidance to ensure compliance with complex regulations. EMNs can facilitate the transfer of knowledge from previous research projects to these start-ups, aiding in regulatory alignment and reducing time-to-market
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Response to Interim evaluation of the Euratom Research and Training Programme 2021-2025

24 May 2024

Statement 1: Establish a mechanism that implements quality assurance and traceability to the SI system by ensuring metrology participation as a matter of course. The aim must be to harmonise approaches internationally. This also includes clear quality criteria, defined in norms and standards that protect the population and enable new technologies. The transformation process of digitalisation through the provision of digital conformity assessments, digital calibration certificates and the digital product passport, for example, can be a decisive building block here. In the field of technical standards, European involvement is declining. There is increasingly less involvement from the member states within the framework of CEN-CENELEC and ISO and IEC. The reasons for this are: It is a time-consuming commitment that ties up personnel, many years of expertise are required of the person involved and it is a cost-intensive activity for the engaging organisation. As a result, Europe is increasingly playing a minor role in standardisation. This is a serious disadvantage for European interests because those who do not standardise will be standardised. The consequences to European industry can be overwhelming. Measures are needed to make participation from Europe in international standardisation attractive (again) for those concerned. The rules of technology, as laid down in the standards, should be the basis for legislation. Thus, the standardization should not be driven by economics and industry only safety, reliability and applicability should be driving forces, too. Bureaucratic obstacles should be avoided and established tools that ensure trust in the quality and safety of new technologies should be supported and digitalised in a targeted manner. Statement 2: Establish a mechanism that implements participation in standardisation as a prerequisite for funding within Euratom Calls. The EMN RP holds relations to the ICRP and supports the statements of the ICRP calls for action to strengthen expertise in radiological protection worldwide through: 1. National governments and funding agencies strengthening resources for radiological protection research allocated by governments and international organisations. 2. National research laboratories and other institutions launching and sustaining long-term research programmes. 3. Universities developing undergraduate and graduate university programmes and making students aware of job opportunities in radiation-related fields. 4. Using plain language when interacting with the public and decision makers about radiological protection. 5. Fostering general awareness of proper uses of radiation and radiological protection through education and training of information multipliers. Our contribution: Metrology and EMN RP supports this ongoing transformation by providing a sound basis for measurements and modelling. Availability of appropriate standards and metrology services, such as measurements and radiation protection instrument calibrations, create a basis on which reliable radiation exposure estimates can be based on. At the same time the European Partnership on Metrology brings together metrology community and its stakeholders to tackle global challenges in fundamental science and applications of ionizing radiation, including health, environment, and industrial applications. For this reason, public consultations have been established to shape the Calls within the Partnership of Metrology which provides us with the opportunity to speak for the needs of our Stakeholder. EMN RP works on an urgently needed knowledge-sharing programme for stakeholders, regularly hosted activities for a wide range of stakeholders such as the exchange of scientific personnel between organisations, metrology workshops, training courses and interlaboratory comparisons. These activities are funded by the metrology institutes directly or by small capacity building initiatives within EURAMET.
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Response to Persistent organic pollutants - pentachlorophenol

23 Sept 2020

Euramet welcome this initiative: Pentachlorophenol and its salts and esters are of prime concern and have been included in Annex I to Regulation (EU) 2019/ Convention of Stockolm. The initiative to set a limit for those chemicals as unintentional trace contaminants in substances, mixtures and articles is by consequence relevant as this limit will help to enforce the ban. In order to support this regulation, reliable and comparable measurements within Europe but also outside are needed. Euramet Technical Committees (TCs), such as the one for metrology in chemistry and biology (MC), are involved in the development and dissemination of measurement methods traceable to the International System of Units. In particular, TC MC plays a role in providing reliable measurements of key pollutants in in the sector of goods, food and feed and also environment. The European National Metrology Community, under the umbrella of Euramet, is available to help the EC in implementing this new regulation by providing metrology tools as reference methods, Certified Reference Materials and Interlaboratory comparisons for pentachlorophenol and its salts and esters at the level where decision has to be made through the European Metrology Programmes and establishing strong collaboration/coordination with the National Metrology Community outside from Europe under the umbrella of the CCQM-OAWG (Comité consultative pour la quantité de matière: Organic analysis Working group). About EURAMET EURAMET e. V. is the European Association of National Metrology Institutes. The science of measurement, metrology, is vital for scientific research, trade and industry, and our daily lives. Modern society could not function without it. EURAMET coordinates research in measurement across Europe to provide the high accuracy, low uncertainty measurements needed both now and in the future. Two research programmes (both jointly funded by member states and the EU) bring together world-class measurement expertise in a series of targeted projects: European Metrology Programme for Innovation and Research (EMPIR) and European Metrology Research Programme (EMRP).
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Response to Persistent organic pollutants - annex I amendment

23 Sept 2020

Euramet welcome this initiative: PFOA, its salts and PFOA-related compounds are of prime concern and have been included in Annex I to Regulation (EU) 2019/ Convention of Stockolm. The initiative to set a limit for those chemicals in medical devices is by consequence relevant as this limit will help to enforce the ban. In order to support this regulation, reliable and comparable measurements within Europe but also outside are needed. Euramet Technical Committees (TCs), such as the one for metrology in chemistry and biology (MC), are involved in the development and dissemination of measurement methods traceable to the International System of Units. In particular, TC MC plays a role in providing reliable measurements of key pollutants in in the sector of goods, food and feed and also environment. The European National Metrology Community, under the umbrella of Euramet, is available to help the EC in implementing this new regulation by providing metrology tools as reference methods, Certified Reference Materials and Interlaboratory comparisons for PFOA, its salts and PFOA-related compounds at the level where decision has to be made through the European Metrology Programmes and establishing strong collaboration/coordination with the National Metrology Community outside from Europe under the umbrella of the CCQM-OAWG (Comité consultative pour la quantité de matière: Organic analysis Working group). About EURAMET EURAMET e. V. is the European Association of National Metrology Institutes. The science of measurement, metrology, is vital for scientific research, trade and industry, and our daily lives. Modern society could not function without it. EURAMET coordinates research in measurement across Europe to provide the high accuracy, low uncertainty measurements needed both now and in the future. Two research programmes (both jointly funded by member states and the EU) bring together world-class measurement expertise in a series of targeted projects: European Metrology Programme for Innovation and Research (EMPIR) and European Metrology Research Programme (EMRP).
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Response to Amending administrative & scientific requirements for applications for novel foods in view of “Transparency Regulation

19 Aug 2020

The metrology community supports activities at the European level to strengthen the transparency and the sustainability of the EU risk assessment in all areas of the food chain where EFSA delivers a scientific risk assessment, including in the area of novel foods. Nevertheless, in the administrative and scientific requirements concerning novel foods, there aren’t references to measurement results obtained by experimental tests and their comparability. Consequently, metrological aspects cannot be applied. In order to ensure food safety, also validated experimental procedures, scientific methods and analytical measurements which verify the quality of food products are necessary. Metrological measurements will help to maintain the highest standards of food safety. Metrological aspects indeed could be applied considering the Regulation (EU) 2015/2283. In fact, in Articles 9 and 10 of this latter Regulation, detailed composition of the novel food is required. If in these cases measurement results obtained by experimental tests are required, then also an evaluation of the measurement uncertainty has to be required. About EURAMET EURAMET e. V. is the European Association of National Metrology Institutes. The science of measurement, metrology, is vital for scientific research, trade and industry, and our daily lives. Modern society could not function without it. EURAMET coordinates research in measurement across Europe to provide the high accuracy, low uncertainty measurements needed both now and in the future. Two research programmes (both jointly funded by member states and the EU) bring together world-class measurement expertise in a series of targeted projects: European Metrology Programme for Innovation and Research (EMPIR) and European Metrology Research Programme (EMRP).
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Response to Amending the administrative and scientific requirements for traditional foods in view of the “Transparency Regulation”

19 Aug 2020

The metrology community supports activities at the European level to strengthen the transparency and the sustainability of the EU risk assessment in all areas of the food chain where the EFSA delivers a scientific risk assessment, including in the area of traditional foods from third countries. Nevertheless, in the administrative and scientific requirements concerning traditional foods from third countries, there aren’t references to measurement results obtained by experimental tests and their comparability. Consequently, metrological aspects cannot be applied. If the risk assessments and scientific requirements mentioned in the Draft implementing regulation and ANNEX - Ares(2020)3882700 include the determination of the composition of traditional foods then also an evaluation of the measurement uncertainty has to be required, taking into account metrological traceability to SI units. About EURAMET EURAMET e. V. is the European Association of National Metrology Institutes. The science of measurement, metrology, is vital for scientific research, trade and industry, and our daily lives. Modern society could not function without it. EURAMET coordinates research in measurement across Europe to provide the high accuracy, low uncertainty measurements needed both now and in the future. Two research programmes (both jointly funded by member states and the EU) bring together world-class measurement expertise in a series of targeted projects: European Metrology Programme for Innovation and Research (EMPIR) and European Metrology Research Programme (EMRP).
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Response to Evaluation of the Sewage Sludge Directive 86/278/EEC

18 Aug 2020

Euramet welcomes this initiative: the Sewage Sludge Directive 86/278/EEC adopted to encourage the correct use of sewage sludge in agriculture and to regulate its use in order to prevent harmful effects on soil, vegetation, animals and humans, complements EU existing legislations. The use of sludge in agriculture is an effective alternative for chemical fertilisers, especially phosphorus fertilisers but it is important that, when used as a resource, it is not contaminated, otherwise recycling will result in increasing pollution of soil, water and/or air and therefore could lead to severe sanitary consequences to living beings (One health concept). In order to manage these wastes, reliable measurements are needed to verify their harmlessness, to measure the environmental pollution and to assess associated risks: Euramet Technical Committees, such as the one for metrology in chemistry and biology, are involved in the development and dissemination of SI traceable measurement methods. In particular, they play a role in providing reliable measurements of pollutants in different environmental compartments. The EU National Metrology Community is available to provide support to the EC for the implementation of the new directive by developing and providing metrological tools for pollutants in sludge such as metrological traceability of the measurements, Certified Reference Materials and Interlaboratory comparisons through the European Metrology Programmes and the European Metrology Networks. About EURAMET EURAMET e. V. is the European Association of National Metrology Institutes. The science of measurement, metrology, is vital for scientific research, trade and industry, and our daily lives. Modern society could not function without it. EURAMET coordinates research in measurement across Europe to provide the high accuracy, low uncertainty measurements needed both now and in the future. Two research programmes (both jointly funded by member states and the EU) bring together world-class measurement expertise in a series of targeted projects: European Metrology Programme for Innovation and Research (EMPIR) and European Metrology Research Programme (EMRP).
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Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

24 Jul 2020

The European Association of National Metrology Institutes, (EURAMET) supports the proposed updates to the monitoring and reporting rules. We agree strongly with the summary that “for it to be effective, greenhouse gas emissions must be monitored, reported and verified in a transparent, consistent and accurate manner” and we wish to draw the Commission’s attention to ongoing research by the metrology community to increase the role that metrology, the science of measurement, can play in support of a transparent, consistent and accurate monitoring, reporting and verification process. The Regulation allows for either a “calculation-based methodology” or a “measurement-based methodology” for the monitoring of emissions from an installation. Metrologists at EURAMET’s member institutes have supported the development of measurement standards which provide the reference methods for measuring CO2 and flow in emission ducts and provide the quality assurance framework for automated measuring systems and data handling systems. EURAMET research projects have also supported the development of models of uncertainties in mass emission reporting from approaches used in the EU-ETS. While EURAMET recognises the pragmatic benefit of a calculation-based approach, we strongly advise that such approaches be validated and supported by measurement-based methodologies, both at the local scale (measurements within an industrial process, or transport fuel system) and for top-down verification of aggregated calculation-based analyses, using, for example, high resolution satellite-based observations. To enable the direct comparison of local and aggregate analyses, the methodologies for strong metrological rigour, such as those described in Article 34 for fuel volume calculations, should also be applied to emissions measurements. Metrological rigour would include harmonising measurements to a common reference, quality assurance of observational data and modelling processes, the inclusion of uncertainty statements and formal calibration of measurement instruments. Such processes can more straightforwardly be applied to measurement-based methods. For example, reference measurements for determining flow and concentration in ducts can provide an uncertainty on the reported mass emission, while the calculation-based methodologies only provide uncertainty information for the activity data. The amendments under consideration deal, for the most part, in the validation of the biomass fuel component in a mixed fuel system. That validation is based, solely, on a calculation-based methodology. EURAMET members, through the IMPRESS2 project, are developing measurement-based methodologies which have the potential for directly verifying the biomass proportion of CO2 in emissions from biomass combustion, using the ratio of the carbon and oxygen isotopes. Such a measurement-based approach to establishing the biofuel component of emissions from a mixed fuel system would also reduce the risk of “double-counting” that is clearly emphasised in the proposed text. The EURAMET project BIOFMET is researching online metrological methods for analysis of solid and liquid biofuels, to provide a metrological framework, including determination of the calorific value and quantification of impurities for validation of the developed methods, ensuring traceability of online instrumentation. The introduction of the new online methods and traceability schemes for moisture and ash content in biofuel power plants will allow continuous accurate measurements of the biofuels’ properties and will result in a high degree of digitalisation. This will lead to better control, more efficient use of the fuel, lower consumption, and thereby minimalised emissions. The development of the new methods, technology and knowledge will therefore have impact on climate and environmental protection.
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Response to Climate Law

4 Feb 2020

The European Association of National Metrology Institutes, (EURAMET) supports the European Green Deal and the future Climate Law. Metrology, the science of measurement, plays a crucial role in all measurement infrastructure and the International System of Units (the SI) maintained by the world’s national metrology institutes provides a firm foundation for all measurement-based policy (cf. Directive 80/181/EEC). In responding to the considerable challenges created by anthropogenic climate change, metrology has a significant influence in four areas: 1) Metrology provides a stable basis for long term, global monitoring of the state of the climate to ensure climate observations can be compared over decadal timescales and that data from a wide variety of ground, airborne and satellite observations taken worldwide can be seamlessly combined. Data quality and reliability are at the base of this data fusion process. They rely on the development of adequate metrological standards, the establishment of suitable calibration infrastructures for devices measuring the Essential Climate Variables (ECVs), as well as on the formulation of procedures and guidelines to determine the measurement uncertainty associated with climate observations. 2) Metrology provides an independent reference for observations of climate sources (greenhouse gas emissions) and sinks (forests, oceans), linking observations from satellites and local observing stations and underpinning the carbon stock-take. 3) Metrology provides the stable basis for measurements made during manufacturing and testing of technology to test and support efficiency claims ; this is achieved by spreading and improving awareness of metrological traceability, calibration procedures, and evaluation of measurement uncertainty and interlaboratory comparison data. 4) Metrology supports research into new materials, technologies and manufacturing methods needed to decarbonise the economy. Implementation of the Green Deal will require high-quality, robust observations of the state of the climate and of sources and sinks, as recognised in Article 7 of the Paris Agreement, which requires parties to strengthen research and the systematic observation of the climate system in a manner that informs climate services and supports decision making. Europe has made a significant and valuable investment in the Copernicus Environmental Information Services, which bring together ground-based, airborne and satellite-based observations of our environmental system as a service for governmental, commercial and non-governmental organisations to make decisions. European metrology projects through EURAMET, including those funded by national programmes and through the EMPIR programme (https://www.euramet.org/research-innovation/research-empir/) have demonstrated the feasibility of bringing metrological principles and SI-traceability into observations of a wide range of essential climate variables and show the need for ongoing collaborative research in developing new metrological methods for those making and using climate observations. Metrology is also needed for the development and testing of low carbon technologies. It is important that efficiency claims are verified against irrefutable, independent references and SI-traceability provides that basis. In both observations and technological development, metrology and, specifically, traceability to SI units, provide confidence, clarity and independence. These qualities are essential for the implementation of the Green Deal and we encourage the Climate Law to require SI-traceability for all relevant measurements (similarly to requirements introduced for air quality monitoring, https://ec.europa.eu/environment/air/quality/legislation/pdf/aquila.pdf) and to support ongoing research in climate metrology.
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Response to Sustainability requirements for batteries

2 Feb 2019

EURAMET welcomes this initiative. A part of it aims to extend “… the useful lifetime of the batteries with second life applications”. We support activities on the European level to reuse batteries salvaged from electric vehicles, since they can still be used for many years afterwards. Significantly more energy storage capacities will be needed in future to store energy from renewable energy sources, especially in residential and rural areas. From an environmental point of view, it would be reasonable to reuse those batteries rather than to produce new ones for the same purpose, which would additionally impair the ecological life cycle assessment of electric vehicles. A few start-ups have already launched to run a business with second life batteries. Besides the legal issues (e.g. ownership, liability), which must be considered, the technical assessment of second life batteries will most probably require EU regulation. Second life batteries must be characterised with respect to their quality, residual capacity, expected life time and other technical properties to assess their residual value, their safety and technical compatibility with other batteries on common legal grounds. To support this, EURAMET has initiated the European Metrology Research Project “LiBforSecUse” (https://www.euramet.org/project-17ind10) to investigate reproducible measurement techniques for adequate and cost effective characterisation of second life batteries. To encourage a lively market for second life batteries, the EU should regulate the quality assessment of second life batteries in terms of standardised measurement methods and harmonised quality parameters. EURAMET members are ready to support the development of European Standards and national testing infrastructures that such regulation would require. About EURAMET EURAMET e. V. is the European Association of National Metrology Institutes. The science of measurement, metrology, is vital for scientific research, trade and industry, and our daily lives. Modern society could not function without it. EURAMET coordinates research in measurement across Europe to provide the high accuracy, low uncertainty measurements needed both now and in the future. Two research programmes (both jointly funded by member states and the EU) are currently bringing together world-class measurement expertise in a series of targeted projects: European Metrology Programme for Innovation and Research (EMPIR) and European Metrology Research Programme (EMRP).
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Response to Revision of the Drinking Water Directive

28 Mar 2017

EURAMET is the European association of National Metrology Institutes. We develop and disseminate an integrated, cost effective and internationally competitive measurement infrastructure for Europe. Always taking into account the needs of industry, business and governments. We respond to EU consultations with the intention of improving subsequent regulations, we want to ensure that any measurements required by those regulations can be done reliably and cost effectively. Our views on this consultation are: On pesticides: - A definition of relevant pesticide metabolites and “non relevant” pesticide metabolites should be included. - The Quality Standards for individual pesticides should be revised with respect to toxicological concern taking into account long term exposure and not analytical ones (as it has been done in the past that’s to say the famous 0.1 µg/L). - To date the sum of pesticides relies on an indefinite and highly variable list of pesticides. Some discussions on the possibility to build a “European sum” for a set of common pesticides to all member states (MS) should be proposed. - Rules to aggregate individual pesticides to express the “Sum of pesticides” (eg how to deal with measurements below LQ with good accuracy) and to estimate uncertainty on the sum shall be included in the DWD to harmonize between MS When revising, it would be relevant to put the DWD in perspective with the WFD. Water is a cycle, for management and communication issue (to EU citizens) it could be relevant - Some discussions to widen DWD to more holistic monitoring approach (eg bioessays, online measurements etc..) should be included in the revision as it has been done for WFD. It could be positive to sustain the need of metrological infrastructure to address incoming challenges. - On the same way, the principle of a “WATCH LIST” principle (has been done in WFD) to sustain the inclusion of additional substances in the DWD should be addressed - Basic metrological concepts and requirements to ensure comparability and accuracy of measurements namely Use of CRM (pure standards or matrix CRM) or PT with assigned reference value when they exist, shall be enforced in the body of the text. Stability studies to demonstrate that incoming new substances, specially by-products are not artefacts, are urgently needed.
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