Common specifications – a BusinessEurope position paper

Key messages

• The European Commission’s Standardisation Strategy must not undermine the New Legislative Framework for products by creating a parallel system via the Commission’s reliance on common specifications instead of standards.
• Common specifications should be seen as a time-limited ‘fallback option’ until harmonised standards are available. Their use should be permitted only under strict, finite, and clear criteria; reinforcing that they are not to be used as a complete replacement for harmonised standards.
• If common specifications must be issued, it is critical they follow standards and the appropriate scrutiny process is applied, as outlined in Regulation (EU) 1025/2012, in order to maintain consistency.
• The horizontal approach of the European Standardisation Strategy requires more clarification and precision to create legal certainty both with EU legislation and international criteria.