Suomen Kylmäliikkeiden Liitto ry
SKLL-FREA
SKLL - FREA is representing refrigeration, air conditioning and heat pump contractors (80 % of members), manufacturers (10 %) and wholesalers/importers (10 %) in Finland.
ID: 620585635216-73
Lobbying Activity
Response to Standardisation Strategy
7 Jul 2021
We are pleased to this opportunity to givee feedback on EU standardisation strategy.
Our experience is shortly:
- we are very dissappointed to the very slow progress on harmonising stardards, especially to the work done by the ”harmonised standards” consultants
- schedule delivering the standards is never what has been promisded causing unproportianate and significant delays in acceptance and publications of harmonised standards
- dealys hinders already acceptance of technically advanced solutions, since e.g. European EN standards needed and used for CE-marking is outdated and/or obsolete
- e.g. in refrigeration and heat pump sector this is evident since new climate friendly refrigerants can not be used to the extent they are needed which has already direct effect on combating climate change. In this context we are especially talking about harmonised standards related to low voltage directive (2014/68/EU) pressure equipment directive (2014/35/EU).
- it should be noted that delays are not always caused by consultants' work. There are also cases where TC or WG of a standard is not able to deliver standard in time
We would like to
1) whether the current European standardisation system is fit for purpose to support European strategic interests;
- based on our experience (see above) as representative of SME's system is not the best one
- basic idea that standards should be used for e.g. proving compliance to a directive, is very good
- standardisation system does not excite and accelerate development of new products and solutions
2) how the EU can leverage and promote global leadership in standards-setting;
- we should ask critically why there could be two working items on the same issue. In electrical safety there are CENELEC and IEC, and e.g. in machinery and pressure equipment CEN and ISO.
- simplyfy and speed up the whole process, especially when the delevery would be harmonised standard. Now it is quite often that when EN standards is published it is already outdated because newer version of the similar / same standard has been published as IEC/ISO standard
3) whether changes in governance and working methods are required to improve the performance of the European standardisation system.
- also in this: simplyfy and speed up the whole process, especially when the delevery would be harmonised standard
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