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TIC Council

TIC Council

The TIC Council represents the global independent testing, inspection and certification industry, promoting best practices in safety, quality, health, ethics and sustainability.

Lobbying Activity

TIC Council urges EU to recognize certification as taxonomy-enabling

5 Dec 2025
Topic — Review of the EU taxonomy environmental delegated act to update screening criteria.
Message — The group requests that the EU recognize accredited third-party certification as standard proof of compliance. They suggest classifying these services as horizontal enabling activities supporting all environmental objectives.12
Why — This change would eliminate regulatory uncertainty and increase demand for the sector's inspection services.34
Impact — Internal compliance teams lose relevance as companies replace self-assessment with external certification.5
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TIC Council urges EU to adopt existing international standards

31 Oct 2025
Topic — The consultation addresses a new law to enhance EU economic security and sustainability.
Message — The organization requests that the Act relies on existing international standards instead of creating new ones. They advocate for voluntary certification of management systems verified by independent third parties. This ensures confidence that products are truly circular while maintaining market harmony.123
Why — This strategy would create new business opportunities for the testing and certification industry.4
Impact — Environmental groups may lose if voluntary certification is less rigorous than mandatory laws.5
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Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

29 Oct 2025 · Introductory meeting following discussion at the Shift Forum

TIC Council urges faster accreditation for EU digital law compliance

13 Oct 2025
Topic — The Commission seeks to simplify digital legislation and reduce burdens for businesses.
Message — The group opposes delaying digital safety laws and calls for appointing national oversight bodies. They suggest that any extension to implementation timelines should be strictly limited to six months.12
Why — Faster accreditation allows these companies to begin offering paid compliance audits sooner.34
Impact — Consumers and industries face security risks if implementation of safety rules is delayed.5
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TIC Council urges exemptions for imported food testing samples

30 Sept 2025
Topic — Consultation on simplifying EU rules for food safety and marketing authorizations.
Message — The council requests a general exemption for accredited laboratories to import all food samples. They also oppose relaxing accreditation standards for reference laboratories to maintain oversight.12
Why — This would stop laboratories moving outside the EU and reduce administrative burdens.34
Impact — Consumers and health protection lose if reference laboratories are exempt from accreditation.5
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TIC Council Demands Independent Certification for New Nature Credits

29 Sept 2025
Topic — The European Commission is developing a framework for biodiversity-based nature credits.
Message — TIC Council wants a system based on independent certification and harmonized methodologies. They urge maintaining on-site audits and alignment with current EU environmental laws.123
Why — TIC firms would gain a central role as verifiers, expanding their environmental services market.4
Impact — Unregulated operators and greenwashers would be excluded from the nature credit market.5
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Response to Revision of the 'New Legislative Framework'

1 Sept 2025

As the voice of the Testing, Inspection and Certification (TIC) industry, TIC Council strongly supports the upcoming revision of the New Legislative Framework (NLF) as an opportunity to ensure a high level of consumer protection, enhance trust in products, and strengthen the EU Single Market. The TIC industry upholds an integrated, competitive, and innovative Single Market by providing services that facilitate the free cross-border movement of safer, securer, high-quality, sustainable, and compliant products. TIC services help businesses reduce costs and risks of non-compliance, boost consumer confidence, and contribute to the EUs strategic goals for innovation, sustainability, and economic growth. By ensuring product safety and regulatory compliance, the TIC sector ultimately plays a central role in enforcing EU regulations and protecting consumers. In this context, TIC Council sees the revision of the NLF as a timely opportunity to strengthen the current framework and ensure it remains fit for purpose in light of evolving products and market developments. We therefore urge policymakers to consider the following key proposals. Our detailed proposals and recommendations are outlined in the attached position paper.
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Response to Amendment to the list of the state-of-the-art documents supporting the EUCC scheme

28 Aug 2025

In the definition of "product series," it would be more appropriate to use "security characteristics" instead of "security needs." This is because "security needs" can be achieved through different design solutions, resulting in different test evidence. However, "security characteristics" ensure that the products in the series produce the same output during testing.
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TIC Council backs CBAM expansion while urging faster verifier accreditation

25 Aug 2025
Topic — The European Commission's proposal to extend carbon border costs to downstream industrial products.
Message — TIC Council supports the extension of CBAM to downstream products and anti-circumvention measures. They request that National Accreditation Bodies update schemes to ensure verifiers are accredited without constraints.12
Why — Expanding the scope creates more business for their global members who provide verification services.3
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TIC Council demands definitive deadline for battery due diligence

31 Jul 2025
Topic — The Commission is proposing to postpone implementation of battery due diligence obligations.
Message — The organization highlights insufficient implementation efforts at Member State level regarding Notifying Authorities. They demand the extended deadline of 2027 must be considered definitive.12
Why — The certification industry would finally be authorized to perform mandatory compliance work.3
Impact — Early-moving businesses lose their competitive edge after investing resources in timely compliance.4
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Response to Revision of the Standardisation Regulation

20 Jul 2025

The revision of the Standardisation Regulation presents an opportunity to future-proof Europes standardisation system while preserving its core strengths. As the global voice of the Testing, Inspection and Certification (TIC) industry, TIC Council advocates for the following priorities: 1. Reaffirming the primacy of the private-sector leadership in standardisation: A central pillar of the current standardisation system is the leadership of the private sector in standardisation. This approach has delivered technically sound, widely accepted standards by ensuring the active participation of industry experts, civil society, academia, and public authorities. Standardisation is fundamentally a technical discipline, and its effectiveness hinges on the expertise and consensus of those who apply and develop the standards in practice. The revision should confirm and reinforce the proven effectiveness of the European private-sector led standards system being supported by the European standardisation organisations. 2. Adapting to evolving needs and new technologies: Since the adoption of the Regulation, the landscape of standardisation has evolved considerably. The framework must now move beyond a narrow focus on products and services to encompass processes and systems, which are increasingly central to regulatory and market developments. This expansion is essential to address developments in key areas such as sustainability, AI, cybersecurity, and digital platforms. Additionally, targeted measures should be introduced to accelerate the development and timely delivery of relevant standards in fast-moving and strategically important sectors. 3. Streamlining the standards harmonisation process: Harmonised standards play a central role in the implementation of EU legislation, providing manufacturers with a transparent, reliable, and cost-effective mechanism to demonstrate conformity with regulatory requirements. However, recent experience has shown that the process for harmonising standards has become increasingly protracted and unpredictable, undermining confidence in the system. To restore trust and ensure that the system supports timely market access, it is essential to streamline the harmonisation procedure. In particular, the process for citing harmonised standards in the Official Journal of the EU must be significantly accelerated and made more predictable. Moreover, the current Regulation lacks sufficient clarity regarding the documentation required for a standard to be cited as a harmonised standard in the Official Journal of the EU. In particular, it does not explicitly state that the inclusion of an Annex ZA is necessary for a standard to support a presumption of conformity. To enhance legal certainty and procedural transparency, the Regulation should be amended to explicitly require an Annex ZA as a condition for citation in the Official Journal. 4. Reinforcing the role of international standards: The revised Regulation should explicitly reaffirm the importance of the international standardisation base as a reference point for the development of European standards. Aligning European standards with internationally recognised ones, wherever appropriate, is essential to avoid unnecessary duplication, reduce technical barriers to trade, and support the competitiveness of European industry in global markets. 5. Guaranteeing inclusive participation in the standards development process: Effective engagement in technical standardisation processes demands significant financial and human resources a requirement that often exceeds the capacity of many stakeholders, particularly SMEs and public-interest organisations. This imbalance risks undermining the diversity and inclusiveness of standard-setting activities. Beyond procedural simplification, the revised framework must recognise and support the contributions of under-resourced actors through dedicated financial mechanisms and structural assistance.
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Meeting with David Cormand (Member of the European Parliament, Rapporteur)

9 Jul 2025 · New legislative framework

TIC Council calls for staggered emissions reporting deadlines

30 Jun 2025
Topic — A review of the European Union's emissions trading system and reserve.
Message — The group suggests pushing back reporting deadlines for new carbon sectors to autumn to ensure auditor availability. They also advocate for maintaining strict European verification standards and limiting carbon removals to permanent storage projects.123
Why — Staggering deadlines reduces the seasonal workload burden on auditing firms and protects their business model.4
Impact — Non-EU auditors with less strict standards may be excluded from the European carbon market.5
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TIC Council urges EU labels and harmonised carbon accounting

27 Jun 2025
Topic — Consultation on supporting industrial decarbonisation and stimulating investments in energy-intensive sectors.
Message — The organization supports an EU label for cement and steel with harmonised accounting. They propose promoting environmental management systems to simplify compliance and build trust.12
Why — Standardising labels and certifications will increase market demand for TIC sector services.3
Impact — Firms using unverified or confusing sustainability labels would lose their market influence.4
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TIC Council demands clear auditor independence in carbon rules

27 Jun 2025
Topic — Establishing implementation rules for verifying carbon removals and storage under EU law.
Message — Certification Bodies should stay fully responsible for audits and issuing certificates. Schemes should monitor systems without interfering in individual certification decisions. Initial certifications must always include at least one mandatory on-site audit.123
Why — This protects the professional liability and independent authority of certification companies.45
Impact — Project developers will face higher costs due to mandatory on-site inspections.67
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TIC Council urges expansion of EU cybersecurity certification schemes

17 Jun 2025
Topic — The European Commission is revising the Cybersecurity Act to strengthen digital resilience.
Message — The group recommends expanding the certification landscape to include AI, consumer IoT, and space systems. They also advocate for strengthening stakeholder input and pursuing mutual recognition agreements.123
Why — Expanding the certification framework provides more business opportunities for independent assessment bodies.4
Impact — Manufacturers of high-risk products may face increased costs due to mandatory certification.56
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Response to Technical description of important and critical products with digital elements

18 Apr 2025

Dear all, Find attached TIC Council's comments. We remain at your disposal for any questions you may have. Best regards, Ángel Moreno Rubio
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Response to EU Emissions Trading System - update of Verification and Accreditation Regulation (AVR), Batch 2

18 Apr 2025

TIC Council, the global association of the Testing, Inspection and Certification (TIC) sector, represents the accredited verifiers under the EU ETS. After carefully assessing the changes proposed by this draft implementing regulation, we are confident to welcome the proposed additions. The main modification this draft act will bring is the change in the accreditation of verifiers. This accreditation will have to be modified, since its scope 12 is divided in 12a and 12b, to include the verification of non-CO2 aviation emissions. It is important that National Accreditation Bodies (NABs) swiftly work to ensure these changes to the accreditation of verifiers are brought in time, to allow companies get these emissions verified when the implemented changes are brought into force. On the contrary, the inclusion of the need to verify the Climate Neutrality Report of companies will not change the accreditation scope, being an addition to the current sector 98. Our members are confident that they can prove their internal expertise and processes to their NABs for them to also verify these reports, being it by including in the verification team dedicated experts or training the current team to also verify these reports. The main question that arises from this inclusion is whether the market demand to verify Climate Neutrality Reports under EU ETS will be large enough to scale up their capacities in this regard. We are at the disposal of the European Commission to discuss the work of the accredited verifiers of EU ETS for the upcoming revisions and amendments to the system.
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Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur) and Mouvement des Entreprises de France

31 Mar 2025 · Omnibus I

Response to EU rules on medical devices and in vitro diagnostics - targeted evaluation

21 Mar 2025

The TIC Council, the international trade association representing independent testing, inspection and certification bodies, and specifically the Notified Bodies under the MDR and all bodies providing confirmity assessment services, looks forward to engaging with the European Commission and all stakeholders during the revision process. Our feedback is attached.
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TIC Council pushes for mandatory third-party water safety testing

4 Mar 2025
Topic — A consultation on a new EU strategy for water management and resilience.
Message — The council requests independent third-party certification and testing in the strategy. They advocate for 'Water Efficiency First' and specific testing requirements for PFAS.123
Why — Expanding certification requirements would increase market demand for testing and inspection services.45
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TIC Council urges EU to prioritize regulations over directives

31 Jan 2025
Topic — A consultation on the Single Market Strategy 2025 to boost industrial competitiveness.
Message — The council recommends Regulations over Directives to ensure harmonization and prevent national gold-plating. They also support digitizing Quality Infrastructure through digital certificates and the Digital Product Passport.12
Why — Harmonized rules requiring continuous monitoring would increase demand for their cost-effective outsourcing services.3
Impact — Member States lose the ability to add specific national requirements to European legislation.4
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Meeting with Pascal Canfin (Member of the European Parliament)

24 Jan 2025 · Certification policy

Meeting with Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné)

24 Jan 2025 · Simplification of sustainability reporting

Meeting with Delara Burkhardt (Member of the European Parliament, Rapporteur) and DEKRA e.V.

14 Jan 2025 · Green Claims

Response to Digital Product Passport (DPP) service providers

10 Dec 2024

TIC Council welcomes the opening of the discussions on the implementation of the DPP. An ex-ante certification scheme is the most likely to result in the success of the DPP initiative. Enforcement levels are likely to be low, especially in the first few months of legislation implementation, leading to low DPP uptake, or an abundance of DPP systems that are data venerable. Self-declaration would not provide the assurances that the value chain will require to take up the DPP concept and concerns would arise over the security of proprietary supply chain information. Ex-ante certification, however, would create a level playing field for new market competition whilst ensuring the best data security to protect international supply chains from cyberattacks. It would also foster trust from both consumers and the value chain that the data is accurate, verified, and proprietary information is securely stored. An ex-ante certification could work by examining the existing data of the provider and referring to parts of existing ISOs and international standards that are relevant to this delegated act. This will reduce the duplication of existing work and ensure a timely response and solution to meet the requirements of the delegated act. There is likely to be regulatory-driven demand for this certification in 2026, but a market-driven demand is likely to arise earlier, as battery, textile and steel producers are already purchasing services from DPP platform providers. This means that sensitive product and value chain data could already be stored on platforms that do not provide the appropriate level of data protection. Thus: 1. A DPP service provider needs to be a third party as stipulated in the ESPR (REGULATION (EU) 2024/1781). 2. TIC Council emphasizes the necessity that the DPP shall be operated by Third Parties as stipulated in ESPR (28). 3. The benefit of Third parties is in our point of view twofold: a) A Third Party can offer the DPP beyond a potential insolvency of the economic operator placing the product on the market. b) A third party can independently verify the information published via the DPP. 4. While the first aspect (3a) can be provided by any provider of a DPP platform, the second aspect (3b) can only be performed by conformity assessment bodies and have to be done by Notified Bodies in case the conformity assessment route requires involvement of a Notified Body. 5. Therefore, the DPP service provider should be a Conformity Assessment Body, respectively an organization being contracted by a Conformity Assessment Body or at least a provider of a DPP platform having contracted a Notified Body to verify all information for all Products requiring a Notified Body. 6. The Service Provider has the right to delegate the liability for the provided information to the original provider of information. This can be the manufacturer but also for example a Notified Body for the EC Certificate. 7. Assuming there are multiple Service Providers, the information to be provided via the DPP and the related fields in the underlaying database must be standardized. 8. The Service Provider must be able to classify the data provided in data accessible to all consumers and data only accessible to e.g. Market surveillance authorities / customs office and provide restricted access to the data with limited access. 9. The technical solution provided by any Service Provider should offer an API to enable certification bodies to enable a continuous disclosure of related EC Certificate and voluntary attestations or verification statements. 10. The Service Provider must ensure that the system prohibits digital not allow any mass download of data. 11. The service provider must ensure that any DPP is only published after a date specified by the related economic operator, e.g. to ensure that disclosure of product related data is delayed until the Marketing activities of the economic operator has been started.
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Meeting with Lynn Boylan (Member of the European Parliament, Shadow rapporteur)

2 Dec 2024 · Green Claims Directive

TIC Council demands expanded definitions for battery component verification

18 Oct 2024
Topic — Establishing a methodology for calculating and verifying battery recycling and material recovery rates.
Message — The TIC Council proposes including definitions for Filled Compartment, Insulation Material, Tubing, and Extinguishing Agency. These additions are essential for verification and ensure necessary legal certainty.12
Why — Precise definitions provide TIC companies legal certainty to perform their mandatory verification roles.34
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Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur)

14 Oct 2024 · discussion on Green Claims Directive

Meeting with Radan Kanev (Member of the European Parliament)

20 Sept 2024 · Sustainability Policies and Administrative Burden

Meeting with Pascal Durand (Member of the European Parliament, Rapporteur)

6 Oct 2023 · CSRD implementation

Meeting with Josianne Cutajar (Member of the European Parliament, Rapporteur)

14 Sept 2023 · Managed Security Services Regulation

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

11 Sept 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

TIC Council demands mandatory third-party verification for green claims

19 Jul 2023
Topic — The EU is proposing rules to verify environmental claims and combat greenwashing.
Message — The group calls for mandatory third-party verification of all green claims by accredited bodies. They want the responsibility for proving claims shifted from consumers to businesses. They also urge clearer definitions for new labels to ensure fair competition.123
Why — Mandatory certification would create significant new business opportunities for independent testing and inspection firms.45
Impact — Dishonest companies using misleading green labels would face higher costs and stricter market exclusion.67
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TIC Council urges mandatory climate and social reporting standards

7 Jul 2023
Topic — A consultation on new European sustainability reporting standards for companies under the CSRD.
Message — The group demands that climate and social reporting remain mandatory for all companies. They want high-impact sectors required to disclose transition plans to ensure a level playing field.123
Why — Mandatory reporting ensures steady demand for the sector's verification and assurance services.4
Impact — Firms in high-impact sectors would lose the flexibility to avoid disclosing transition plans.5
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Meeting with Andrus Ansip (Member of the European Parliament, Rapporteur) and SMEunited aisbl

4 Jul 2023 · Meeting on Green Claims

Meeting with Pascal Durand (Member of the European Parliament)

14 Apr 2023 · CSRD implementation

Meeting with Morten Løkkegaard (Member of the European Parliament, Rapporteur for opinion) and Apple Inc.

21 Mar 2023 · CRA Stakeholder Consultation

Meeting with Henna Virkkunen (Member of the European Parliament, Shadow rapporteur) and Siemens AG

1 Mar 2023 · EU Cyber Resilience Act

Meeting with Pascal Durand (Member of the European Parliament)

3 Feb 2023 · Audit schemes

Meeting with Nicola Danti (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

25 Jan 2023 · Stakeholder consultation on the CRA

Meeting with Kim Van Sparrentak (Member of the European Parliament)

18 Nov 2021 · Product Safety

Response to Smartwatches and connected toys

27 Aug 2021

The TIC Council, representing independent Testing, Inspection and Certification (TIC) companies, welcomes the European Commission’s proposal for a Regulation laying down essential requirements for radio equipment. The text moves towards greater protection against risks linked to connected devices and the Internet of Things and greater safety and security for users, an objective fully supported by the TIC sector. TIC Council agrees with the general objective of the text, which aims to respond to the increasing applications and uses of inter-connected radio equipment. We therefore welcome the introduction of mandatory cybersecurity requirements for certain consumer products such as smart wearables and toys. However, the use of internet-connected radio equipment can cause damages to networks or their operation and ultimately lead to safety and security risks for many players in the radio equipment value chain. Thus, TIC Council expresses its concerns that the current proposal only limits the potential hazards arising from the subjects of clauses (d), (e) and (f) of the article 3 of the RED, but does not address the problems mentioned above. - We advocate for a risk-based approach, in which the essential requirements are tailored according to the risk analyses carried out on each product category. This approach will make it easier for regulators to develop and adapt the text to a fast moving digital environment. This will also facilitate the efficiency of compliance processes and avoid legal uncertainty. - We believe that the proposal does not provide sufficient protection for certain categories of users, in particular children. Since the existence of harmonized standards does not guarantee their effective application, connected toys should be checked by independent notified bodies for compliance with the requirements of Art. 3 (3) (d), (e) and (f). - We believe that RED legislation is not the most appropriate framework to deal with complex security issues such as personal data protection, privacy, and anti-fraud requirements. Ensuring the protection of these features is likely to be lengthy for some products, potentially raising the cost of testing and implementation. This could hamper European innovation or refrain actors from performing the necessary conformity assessment processes. The security aspects of radio devices should be dealt with under the EU Cybersecurity Act. - We believe that third-party certification should be an option for manufacturers and used as means to demonstrate to customers that the device and associated cloud-based services associated with the device are secure. TIC Council also would like to draw attention to the following unclear points in the text : - the definition of radio equipment, especially the characteristic by which they “communicate itself over the internet”. The wording is too abstract, may lead to different interpretations and would deserve to be clarified. - the relationship between 5G and the level of security applicable under the essential requirements set out in Article 3(3)(d), (e), (f): are these security levels conditional or excluded when 5G is involved? Furthermore, as it appears that the proposal is building a framework legislation, the European Commission should pay attention not to put it in competition with the Cybersecurity Act. In addition, we doubt that the 30-month transition period will be sufficient to allow for the drafting of harmonized standards. If this situation occurs, economic operators will face a significant obstacle to placing devices on the market. As a result, TIC Council believes that this part of the proposal does not address properly the above-mentioned objective of the text. TIC companies are actors that can effectively participate in the development of a secure radio equipment environment, especially for European consumers, thanks to their expertise and resources to properly assess these products and the associated hazards.
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Response to Sustainable Products Initiative

13 Nov 2020

The testing, inspection and certification (TIC) sector welcomes the sustainable products’ initiative. TIC Council members provide services that help manufacturers assess the compliance of their products with all legislation, including on energy, resource efficiency, traceability, social compliance and safety. They also conduct conformity assessment against internationally recognised standards and labels on sustainability, recyclability and supply-chain transparency. Enforcing EU’s sustainability rules Experience illustrates that certification is an indispensable tool for enforcing product sustainability principles and rules. In the US, third-party certification for Energy Star labeled products was introduced after the U.S. Government Accountability Office (GAO) investigations in 2010 found massive fraud and misuse (https://www.gao.gov/products/GAO-10-470). Equally, 10-25% of products on the market in the EU do not fully comply with energy efficiency labelling regulations and around 10% of potential energy savings are lost due to non-compliance. (https://www.eca.europa.eu/Lists/ECADocuments/SR20_01/SR_Ecodesign_and_energy_labels_EN.pdf) This is caused by the EU’s over-reliance on self-declaration of conformity, whilst market surveillance for these aspects remains weak. It leads to unfair competition to compliant products and undermines the EU’s sustainability goals. Moreover, the broad circulation of under-performing products significantly restricts the energy saving potential of the exiting rules. It also damages consumers’ trust to energy-saving and overall sustainability labelling. Therefore, we consider that any new rules on sustainability should require mandatory third-party conformity assessment and certification. Thereby, instances of unintentional non-compliance will not enter the market. More importantly, market surveillance authorities will focus their resources on products not bearing certification marks or bearing fake ones. Our sector will also act against fake certification marks with legal means and awareness campaigns. Establishing EU rules for sustainability labelling We support the establishment of EU requirements on mandatory sustainability labelling and disclosure of information to market actors along the value chain. We consider that minimum labelling requirements will remove from the market any vague or misleading labels. To this end, it is necessary to establish the following credibility criteria: 1. Develop a regulatory framework for the mandatory labelling of all products regarding their environmental impact. 2. Ensure that the EU-wide labelling will be attached to products only after third-party assessment. Otherwise, products may continue bearing misleading claims. 3. Ensure that the labeling and information-disclosure rules are based on international standards developed in open and transparent standardization fora. Under these conditions the sustainability labels in the EU will reinforce consumers’ trust to products’ claims. Moreover, they will raise consumers’ awareness for products’ sustainability qualities, creating financial incentives for placing sustainable products on the market. In this context, it is important to continue allowing products to be labelled by existing private or national labels that fulfil the above-mentioned transparency criteria. Removing such labels from the products may lead to consumers’ confusion. Even more, it is important to establish a level playing field for all credible labels, including the EU ones, such as Ecolabel, national ones, such as Blue Angel and private ones, which comply with the credibility criteria mentioned above. Finally, we consider that the products’ information disclosure should follow the same rules as the products’ technical file to facilitate manufacturers to handle the information in the most convenient form, as not all information is destined for consumers.
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Response to Review of the general product safety directive

1 Sept 2020

The TIC Council is an international trade association representing the third party testing, inspection and certification companies. The GPSD is a historic cornerstone of the Single Market. Nevertheless, it falls short of addressing the challenges raised by digital transformation, the proliferation of online sales channels and the shortcomings of market surveillance in the EU. In this context, we recommend that the Directive’s revision – be it targeted or full – increase the scope of products that are subject to third-party conformity assessment. We consider that this would enable market surveillance authorities to focus their limited resources on targeted controls and products not subject to third-party conformity assessment. This would allow for a better enforcement of the EU’s product safety rules. In general, the TIC Council supports a strengthened role for market surveillance authorities and recommends that any revision of the Directive create the means for increased joint market surveillance activities that would come to complement activities by third party conformity assessment bodies. Indeed, third party conformity assessment and certification has already demonstrated its added value in comparison with self-declaration of conformity, as the latter system is not able to block a large part of unsafe products from being sold in the Single Market. More precisely, there is a proportion of 17% of the products which are deemed faulty or dangerous despite bearing self-declaration of conformity by the manufacturer. On the contrary, only 1% of certified products are non-compliant . This tendency is expected to grow as products become increasingly digitised and sales channels proliferate. Additionally, according to the data released by the European Commission, 32% of toys, 58% of electronics, 47% of construction products or 40% of personal protective equipment inspected do not meet the requirements for safety or consumer information foreseen in EU legislation . In this context, the legislative framework cannot reasonably rely solely on self-declaration of conformity given the meagre resources of market surveillance authorities across Europe and the complexity of a globally fragmented supply chain that makes traceability practically impossible for manufacturers. Moreover, market surveillance authorities can only test the product after it has been placed on the market, with these operations often taking several months. The intervention from market surveillance authorities often comes too late, since during this time of investigation, dangerous products are still available on the market to the consumers. Any late intervention may also complicate any product recalls, as the product might already have reached several consumers. In contrast, third party certification provides the benefit of acting at an earlier stage, precisely before placing the product on the market. Finally, we fully support the European Commission’s intention to add requirements for online marketplaces. In particular, we recommend that products sold online should clearly demonstrate their markings and labels, including CE marking and any certification marks.
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Response to Empowering the consumer for the green transition

31 Aug 2020

The testing, inspection and certification (TIC) sector welcomes the European Commission’s intention to strengthen the regulatory framework that will help consumers choose products with a full understanding of their environmental characteristics. In this respect, it is critical that the citizens can easily assess the validity of the environmental claims described on a product. Our members provide services that help manufacturers to assess the compliance of their products with all EU legislation, including on energy, resource efficiency and safety. They also conduct conformity assessment against internationally recognised standards and labels on recyclability and supply-chain transparency. Our experience illustrates that certification supports consumers’ empowerment, trust and confidence, as it provides them with reliable information on the tests and audits that manufacturers undertake to substantiate sustainability claims. Thanks to certification, consumers can make informed purchasing choices and have an independent voice of reason to rely on so as to make sense of the ever increasing environmental claims. Additionally the TIC sector, helps prevent the entry on the market of any product that does not prove it is safe and environmentally-friendly throughout its life cycle As a result, mandatory certification provides financial incentives for manufacturers who place on the market compliant products and who take extra steps for their products’ sustainability as it ensure a level playing field against rogue economic operators. Moreover, certification is a powerful and effective resource to take timely action if used in a pre-market surveillance approach as it can save valuable resources used by members states in post-market surveillance. For instance, the compostability of plastic bags takes several months to be tested. As a result, even if a bag is taken from the market to be tested by authorities, such bags will continue to be sold while the tests are ongoing. On the contrary, certification acts before a product is placed on the market and prevents non-compliant products to reach consumers and professional users. Therefore, we support developing a new standalone consumer protection instrument that would include information requirements regarding environmental claims. We consider that the following recommendations will contribute to its success. 1. this instrument should establish mandatory third-party conformity assessment for the labelling of products regarding environmental claims. Thereby, it will prevent non-compliant products from entering the market and will provide financial incentives for compliance with the legislation. Mandatory third-party testing will also enable the notification of conformity assessment bodies according to the new legislative framework, improving the transparency and reliability of the market. 2. this instrument should be based on the existing international standards for environmental claims to ensure that certification and labelling are conducted against transparent and measurable criteria. 3. Thirdly, the new instrument should not restrict the use of existing international labels that are well-recognised by consumers. Removing such labels from the products may lead to consumer confusion. The purpose is rather to inform consumers and help them be an actor of the transition through the purchases. Product labelling according to international standards and product characteristic reporting through labels or web platforms inform consumers and help them to select products with the highest green characteristics, thereby significantly strengthening their role in supporting the green transition.
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Response to A new Circular Economy Action Plan

18 Jan 2020

The testing, inspection and certification (TIC) sector welcomes the EU Green Deal and the measures announced in this roadmap. TIC Council members provide services that help businesses identify carbon and environmental hotspots throughout processes and supply chains. These include products’ lifecycle impact, Ecodesign and carbon footprinting assessment, auditing for energy and environmental management throughout the supply chain, as well as reduction at source, reuse, recycling and recovery of residual materials, within a global waste management framework. The TIC sector also enables the proper introduction of new technologies, by testing, verifying and certifying renewable energy technologies, reverse cycle related technologies (e.g. recycling, disassembling and remanufacturing), technologies for industrial symbiosis (e.g. energy generators from waste steam), for smart manufacturing (e.g. additive manufacturing and its repairability fostering) and technologies for e-mobility, fuel efficiency and autonomous driving. As such, certification contributes to the continuous improvement of products, as well as manufacturing and service delivery processes’ environmental footprint, and helps mitigate risk of impacting environment across organizations and value creation processes. Our experience illustrates that mandatory third-party conformity assessment and certification are necessary tools for preventing environmentally harmful products and technological solutions from being placed on the EU market. Firstly, it prevents manufacturers from accidentally placing on the market products not compliant with EU legislation, including circular economy provisions, by applying our members’ broad experience to product testing and thorough understanding of potential rules applying on the product. Secondly, it enables market surveillance to focus their controls on products that bear no certification and identify those bearing counterfeited markings. To this end, our members often team up with authorities to help them identify fake certificates and take corrective action against suppliers who illegally use fake or false TIC markings, without having their products tested and certified, and take preventive action to deter re-occurrence of fake and counterfeit certification. In this context, certification, relieves the work of publicly-financed market surveillance authorities, as it enables them to use their resources more selectively by focusing on products that are not third-party tested. Thirdly, certification can provide more timely action than post-market surveillance. For instance, the compostability of plastic bags takes several months to be tested. As a result, even if a bag is taken from the market to be tested by authorities, such bags will continue to be sold while the tests are ongoing. On the contrary, certification acts before a product is placed on the market and prevents non-compliant products to reach consumers and professional users. Fourthly, certification can help manufacturers and authorities gain confidence about products’ compliance with regulation in cases where there are no standards in place. This is often the case for new technologies and innovative solutions that enter the market before standards have been developed. Finally, certification supports users’ empowerment, as it provides reliable information on tests and audits that manufacturers undertake to substantiate sustainability claims. It also provides information about the impact of materials used in products. In this context, it leads to informed purchasing choices and contributes against fake environmental claims. Therefore, it provides financial incentives for manufacturers who place on the market compliant products and who take extra steps for their products’ sustainability. Overall, we strongly believe that mandatory third-party certification is a key element to the successful implementation of the circular economy action plan.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

16 Sept 2019 · Presentation of the Council representing independent testing, inspection and certification companies

Meeting with Carl-Christian Buhr (Cabinet of Commissioner Mariya Gabriel) and International Confederation of Inspection and Certification Organizations

11 Sept 2018 · Cybersecurity

Meeting with Vivian Loonela (Cabinet of Vice-President Andrus Ansip)

7 Sept 2018 · DSM/CYBERSECURITY

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

7 Sept 2018 · presentation of their regulation & testing activities

Response to Evaluation of the Toy Safety Directive

2 Aug 2018

The independent Testing, Inspection and Certification (TIC) sector welcomes the initiative by the European Commission to evaluate the Toy Safety Directive 2009/48/EC. Data shows that there are still too many (potentially) unsafe and non-compliant toys in the EU market: With the publication of the Goods package (December 2017), the European Commission published alarming data: “as many as 32% of toys, 58% of electronics, 47% of construction products or 40% of personal protective equipment inspected do not meet the requirements for safety or consumer information foreseen in EU legislation.” The RAPEX figures of the last 5 years show a significant and increasing trend regarding non-compliant toys (and related): - the highest category of non-compliant product category notified in 2017 was toys (29%) - In 2016 the two most common product categories notified were childcare articles and children’s equipment (31%) and toys (26%) with injuries related to toys as the most common risk notified - In 2015 the most notified product category were toys (27%) - In 2014 and 2013 the most notified product categories were toys (25%) and clothing, textiles and fashion items (25%) These figures have not improved despite significant efforts of the European Commission as well as at Member State level through cooperation programs with China in order to raise awareness, training on European toys regulation, conformity assessment etc. The TIC sector recommendations: The TIC sector strongly recommends that the evaluation of the Toy Safety Directive focuses on achieving the following key objectives: - Protecting European consumers health and safety - Securing a level-playing field for industry by deterring rogue, non-compliant economic operators To such end, the evaluation of the Toys Safety Directive: 1. Should not be limited to the requirements set forth in the directive but also look at the conformity assessment procedure (self-declaration with the EU harmonized standard EN71 – Module A vs. EC-type examination and certification – Module B for the design phase plus Module C for the production phase) since the high noncompliance levels are directly linked to the conformity assessment procedure provisions in the regulation. 2. Digitalization is a substantial part of our lives today. The European Commission should consider looking at risks associated with connected toys since inadequately protected connected devices on the market might lead to serious cybersecurity threats impairing safety and data privacy. Connected toys and devices are being hacked more and more frequently and children are being increasingly exposed to imminent danger. IFIA and CEOC International strongly advocate for robust measures to be implemented to prevent non-compliant toys from entering the European market. (for more information read the document enclosed)
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Response to More and better mutual recognition for the single market for goods (revision Regulation (EC)764/2008) (Goods package)

19 Mar 2018

THE TIC INDUSTRY PROPOSAL TO BOOST CONFIDENCE IN THE INTERNAL MARKET Globalization has drastically transformed the international trade landscape with the opening of the international markets and while European consumers are benefiting from a growing range of products, at the same time they must be able to trust that the products they are buying are safe and compliant. Likewise, whilst European industry is benefitting from a wider market, it must also be protected from unfair competition from rogue operators who cut corners and do not pay the price of compliance. To give EU consumers the peace of mind they deserve and to protect the level playing field of the EU industry, Europe needs to implement a robust regulatory framework for the European single market. The independent Testing, Inspection and Certification (TIC) sector welcomes the Goods Package as a small step in this direction. However, given the alarming data published by the European Commission: “as many as 32% of toys, 58% of electronics, 47% of construction products or 40% of personal protective equipment inspected do not meet the requirements for safety or consumer information foreseen in EU legislation.”, we believe that the draft regulations on compliance and enforcement and mutual recognition, as well as the soft-law options identified in the European Commission’s Communication fall short of achieving the following key objectives: • Protecting European consumers health and safety • Securing a level-playing field for industry by deterring rogue, non-compliant economic operators Market surveillance in Europe continues to show serious weaknesses in practice, especially as it is performed with varying resources and intensity by the authorities in the individual member states. Since 2008 various reports by the EC have identified inadequate Market Surveillance as the cause of a high level of non-compliance. With an increasingly complex global supply chain, insufficient resources and lack of cooperation between the national authorities makes it virtually impossible to adequately control the range and number of products imported and traded in the EU. Therefore, it is urgent that market surveillance and other mechanisms be urgently improved and raised to a consistently high level in Europe. In addition, the scope of market surveillance activities and the frequency of checks should no longer be left solely to the discretion of the respective European Member States. To such end, the independent TIC industry should be considered as a partner that can contribute to providing an effective and viable solution. The TIC industry has the expertise and resources to play an essential role in raising the compliance rate to provide protection to consumers’ health and safety while levelling the playing field for the manufacturers who are willing to follow the rules and invest in compliance. THE TIC INDUSTRY RECOMMENDATIONS ON THE MUTUAL RECOGNITION REGULATION 1. The mutual recognition declaration, as established under Article 4, does not create additional trust. 2. Conformity according to national law should be presumed when products have been assessed by an accredited third party. Conclusion We share the view that the Single Market is built on trust, and that robust measures should be implemented to prevent non-compliant products from entering the European market. Conformity with the requirements on products and services is the key for a smooth functioning of the European Single Market as well as for the protection of the health and safety of European citizens. In addition, only conforming products are able to compete in international trade. Therefore, the benefits of the Single Market can only fully unfold for all economic operators if the conformity of the products traded in the Single Market increases significantly and sustainably. For more details read the document enclosed.
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Response to Proposal for a Regulation on Enforcement and Compliance in the Single Market for Goods (Goods package)

19 Mar 2018

THE TIC INDUSTRY PROPOSAL TO BOOST CONFIDENCE IN THE INTERNAL MARKET The independent Testing, Inspection and Certification (TIC) sector welcomes the Goods Package as a small step in the right direction. However, given the alarming data published by the European Commission: “as many as 32% of toys, 58% of electronics, 47% of construction products or 40% of personal protective equipment inspected do not meet the requirements for safety or consumer information foreseen in EU legislation.”, we believe that the draft regulations on compliance and enforcement and mutual recognition, as well as the soft-law options identified in the European Commission’s Communication fall short of achieving the following key objectives: - Protecting European consumers health and safety - Securing a level-playing field for industry by deterring rogue, non-compliant economic operators Market surveillance in Europe continues to show serious weaknesses in practice, especially as it is performed with varying resources and intensity by the authorities in the individual member states. It is urgent that market surveillance and other mechanisms be urgently improved and raised to a consistently high level in Europe. To such end, the independent TIC industry should be considered as a partner that can contribute to providing an effective and viable solution. The TIC industry has the expertise and resources to play an essential role in raising the compliance rate to provide protection to consumers’ health and safety while leveling the playing field for the manufacturers who are willing to follow the rules and invest in compliance. THE TIC INDUSTRY RECOMMENDATIONS ON THE COMPLIANCE AND ENFORCEMENT REGULATION: 1. Enlarge the scope in order to align all existing provisions for market surveillance: - The proposal should cover all harmonized products, not only those listed in the ANNEX 1; - The proposal should include the provisions for consumer products still regulated in the General Product Safety Directive (2001/95/EC); - The provisions for market surveillance in regulation 765/2008 shall be maintained. 2. Adopt stricter and more precise requirements for national market surveillance authorities: - Precise and concrete requirements for sampling (Art. 15.1) with the aim to harmonize the intensity of market surveillance controls; - “Adequacy” of resources (Art. 11.4) (e.g. personnel and financial means) of the market surveillance authorities is too vague; - “Adequacy” of sanctions (Art. 61) has to be translated into concrete figures and minimum requirements for sanctions. 3. Due to limited resources, market surveillance authorities should presume conformity of products that have been assessed by an accredited third party. 4. (Art. 20) It should be possible for accredited third-party conformity assessment bodies to be designated as Union Testing Facilities. Maintaining cutting-edge laboratories requires extensive resources in terms of funding and skills. The private sector conformity assessment industry currently provides these accredited independent and impartial services. The proposal to create, design, build, and staff Union Testing Facilities would spend public funds (taxpayer money) to duplicate what already exists in the private sector. There is no funding for such facilities within the current proposals. Further, the previous system of Member State owned Notified Body laboratories was recognized to be unnecessary many years ago, which resulted in privatization of those Bodies. This proposal is a step backward that will not contribute to the improvement in either compliance or market surveillance activities. If the EC is finally serious about making changes to the current inadequate system they should focus on leveraging the private sector resources that currently exist. 5. Increase market surveillance authorities’ reliance on accredited third parties to perform their tasks. For more details please read the document enclosed.
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Response to Evaluation of the Low Voltage Directive 2014/35/EU

27 Nov 2017

CEOC-ETICS-IFIA-VdTÜV: THE TESTING, INSPECTION, CERTIFICATION (TIC) FEDERATIONS CALL FOR A RE-VISION OF THE LOW VOLTAGE DIRECTIVE 2014/35/EU CONFORMITY ASSESSMENT OF LVD PRODUCTS SHOULD BE REVIEWED TO RAISE COMPLIANCE The level of conformity of LVD products in the internal market does not provide assurance that products comply with the requirements for protection of safety and health. In the context of market surveillance, it can be traced over a longer period of time that electrical products are often not compliant. RESPOND TO INCREASED RISK POTENTIAL OF ELECTRICAL PRODUCTS Through innovation, products in the course of their development, must satisfy new functional expectations. In short, products need new requirements and the European legislator has to adapt the regulatory framework for that. Increasing risks with significant hazards can be observed in the area of mobile products such as battery operated products with increasing energy densities and dangerous electro chemicals used on or nearby the human body (for example: smart phones, tablets, power banks, Power tools, electronic cigarettes) and for laser operated products with high emitted energies (for example, Laser and LED bicycle (ultra) bright light, Lane laser, Laser distance laser pointer, LED (laser) flash light, Laser-LED head lamp). As a consequence of accidents with batteries (esp. Li-Ion) and LED/Laser in mobile devices a review of the directive should consider: 1. To decrease the low voltage limit to 1 V DC / AC or less 2. To assess and to adapt the applicable conformity assessment procedures in accordance with the risk potential of these products (based on the relevant conformity assessment modules). 3. To stipulate that an independent body (Notified Body) will be mandatorily involved New function can particularly be observed in the context digitization and Internet of Things (cyber-security). In the context of the LVD products become increasingly smart and requirements need to be adapted. In reviewing the LVD the European Commission is urged: 1. To include the aspect of information security in safety requirements for products, including smart products, in the respective annexes to swiftly close regulatory gaps. 2. To put the risk potential presented by products through a fundamental reassessment, while taking information security into account. 3. To assess and to adapt the applicable conformity assessment procedures in accordance with the newly determined risk potential of the product (based on the relevant conformity assessment modules). 4. To stipulate that an independent body (Notified Body) will be mandatorily involved where the risk potential of the product is significantly increased by the ICT components. 5. To grant this body suitable access to the product’s source codes/software when the product is to be assessed by a Notified Body. - please see complete position paper attached -
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Response to Review of ENISA Regulation and laying down a EU ICT security certification and labelling

25 Jul 2017

IFIA, representing the global independent testing, inspection and certification sector, support the preliminary policy option 3 for certification as this option would support a coherent regulatory framework across the Single Market. Harmonizing the diverging certification schemes currently in existence would ease the burden on industry and ensure trust for users. A coherent regulatory framework with clear requirements will help guide businesses in the design and creation of their products while demonstrating evidence that these products are at the level of compliance expected by users. The conformity assessment methods used to demonstrate compliance should be based on a risk assessment and on confidence needs, i.e. policy makers need to determine the confidence needed based on the risk of non-compliance and on what market-driven mechanisms exists as mitigation tools for non-compliance. Third part conformity assessment is a cost-effective policy solution as it provides the highest level of confidence and helps governments leverage scarce resources. At the same time it allows users to have confidence in their choice of products and enables a fair competition between manufacturers and distributers. IFIA and our members are available to cooperate with the European Commission, ENISA and the standardization bodies in developing the necessary standards and requirements as well as the required conformity assessment methods to ensure the ICT security of specific products and services.
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Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and FTI Consulting Belgium

13 Oct 2015 · Regulatory cooperation, mutual recognition and conformity assessment