HAS assessment contract re-established The European Commission has signed a new contract with Ernst & Young for the HAS (Harmonised Standards) assessment process. Ernst & Young was the previous contractor until the beginning of 2022. This means that the HAS consultants system will be restored shortly and Technical Committees will therefore be able to request assessments of harmonised standards. CEN and CENELEC have stated they will request HAS assessments in the following order:
Documents received for Formal Vote;
Documents received for Enquiry and or which Enquiry has started;
On ad-hoc basis: all other documents (e.g first working drafts, documents not assessed previously and before publication).
Webinar on how to draft machinery harmonised standards On 6 October, from 14.00 till 16.30, CEN and CENELEC will organise a webinar with practical information on how to prepare harmonised standards under the Machinery Directive. The workshop will provide advice on how to write the informative annex (Annex Z) with information on the relation between the essential requirements of the Machinery Directive and the clauses of the standard providing presumption of conformity with those requirements (once the reference of the standard reference is published in the Official Journal). Registration is mandatory and is available here: https://cencenelec.zoom.us/webinar/register/WN_C22eFvsoRmC99VhY_xmUNA
Comments Off on CEN and CENELEC Joint Response to the European Commission Standardization Strategy Roadmap, Plus New Website
CEN, the European Committee for Standardization, an association that brings together the National Standardization Bodies of 34 European countries, and CENELEC, the European Committee for Electrotechnical Standardization, an association that brings together the National Electrotechnical Committees of 34 European countries, have issued a joint statement following the consultation on the Roadmap of the “European Strategy for Standardization”.
“CEN and CENELEC would like to thank the European Commission for organizing this consultation on the Roadmap of the “European Strategy for Standardization”. We welcome the consultation as a critical development in the joint efforts to build a robust, resilient, and competitive green economy for Europe, which encourages the alignment of strategies for and use of standardization as a key asset towards achieving these ambitions.
The feedback document details our proposals to address five specific areas in which standardization can support and for which a strong engagement with the European Commission is sought. These are supported by specific examples of what can be achieved together and that can shape our common aims going forward.”
The statement was posted on CEN and CENELEC’s brand new website, which aims to offer an enhanced user experience via a refreshed look, improved navigation and a handful of features intended to make the overall experience more impactful on either desktop, mobile or tablet.
Elena Santiago Cid, CEN and CENELEC’s Director General, commented: “The new website testifies to our ongoing commitment to making our work accessible, transparent and open to the future. We will be constantly updating the content to enhance the digital presence of CEN and CENELEC and increase our online interaction with our stakeholders and experts. I sincerely hope that you enjoy the new website and all that it has to offer!”
Comments Off on Machinery Directive Causes Standardization Issues
Since the European Commission has proposed to exclude all vehicles from the Machinery Directive, it is quite likely for the Directive to disappear as the legal framework for the standards developed in CEN TC 333 ‘Cycles’. In expectation of that legislative change, the Machinery Directive is causing headaches among the TC 333 experts.
In 2017, the EN 15194 standard for EPACs, i.e. electric bicycles with pedal assistance up to 25 km/h and 250W, was harmonized under the Machinery Directive. If an e-bike complies with the standard, it is presumed to be in conformity with the Machinery Directive. Since then however, a number of issues with that harmonization have arisen.
A while ago, the Netherlands have submitted to the European Commission a formal objection against the harmonization. The Dutch government is convinced that the EN 15194 requirements for batteries are insufficient to guarantee safe batteries and thus conformity with the Machinery Directive. It is a fact that the EN 15194 is not exactly unambiguous in this field. For instance, the test method refers in a note to two standards, i.e. EN 62133 or EN 50604-1. However, a note in a standard never has a normative character. Notes are merely meant for further clarification. The issue has been dragging on for 1.5 year. The notification of this objection was published on 22 January 2020. Now, the clock is really ticking since amendments are only allowed within 4 years after publication of the standard. Therefore, the deadline is 4th October. After that date, the change of the battery requirements will need a revision of the standard. That is a longer and more complicated procedure.
It is very likely that, through a publication in the EU Official Journal, the harmonization of the EN 15194 will be suspended for the battery part. That will leave manufacturers with legal uncertainty until the standard has effectively been changed. WG5 of TC 333 is now working on an amendment to be adopted before 4 October, which would safeguard harmonization.
In the meantime, other issues have arisen. Germany insists that the Machinery Directive makes it necessary to introduce vibration requirements and a corresponding test. Denmark demands for chargers that claim compliance with EN 60335-2-29 to have a d.c. output of less than 42.4 Volt. This is due to a disputed note under point 4.2.4 in EN 15194, which should hold the requirements for battery chargers, but in reality consists of 2 notes. Denmark rejects the argument that notes do not have a normative character.
Finally, it has also appeared that the anti-tampering measures in the standard need to be improved. The wording is unclear and the requirements themselves go against EU policies. For instance, manufacturers should give repair and maintenance information access to independent operators, quod non in EN 15194. Also, there is a clear policy trend to safeguard repairability of products to improve their carbon footprint. The current text goes against that principle as well.
And then there are the future standards … Very recently, the FprEN 17404, the draft EPAC Mountain Bike standard was denied harmonization by the HAS-consultant. The question as to what to do with this issue is quite complicated. To turn the standard into a useful tool, it needs to be harmonized under the Machinery Directive. However, by the time it effectively gets harmonized, the Machinery Directive may well no longer be applicable anymore.
The same questions are haunting the experts in the recently established WG9 that is meant to develop standards for (e)cargocycles. The work has been distributed among 7 teams that are using and is based on a risk assessment following the Machinery Directive. Again, by the time the work is completed, the Machinery Directive may not be relevant anymore. Standards aimed at harmonization under the Directive always have a number of requirements, which are not necessarily relevant for the safety of the vehicle but are rather aimed at complying with the Directive. It may well turn out to be a difficult balancing act.
Nevertheless, there is hope for improvement. At least there is now a prospect of accurate standards to be developed purely for the safety of the vehicles. Within a few years, the sector will be freed from the imperative framework of the Machinery Directive. That will be for the benefit of all electric cycle companies.
LEVA-EU has been working tirelessly for the exclusion of all Light Electric Vehicles from the Machinery Directive. Furthermore, the trade association has several experts on WG5 and WG9 of TC333. One of them, Eddie Eccleston, has been appointed as an SBS-expert with the specific task to watch over the interests of SMEs in standardization. LEVA-EU is also particularly pleased that several members have become active in TC 333.
If you want to learn more or be kept updated about the standardization work or if you want to become actively involved, contact LEVA-EU Manager, Annick Roetynck, tel. +32 9 233 60 05, email annick@leva-eu.com.
Comments Off on Eddie Eccleston appointment as SBS-expert extended
Further to the call for experts published in June 2020, the SBS General Assembly confirmed the selection of 61 experts to represent the European SME position on standardisation Technical Committees, Sub-Committees and Working Groups in CEN, CENELEC, ETSI, ISO and IEC.
The selected experts, from 15 countries across Europe, will be active on 70 standardisation Technical Committees and more than 150 Working Groups, allowing SBS to influence the development of standards across more than 14 sectors.
LEVA-EU is very pleased with the reappointment of Eddie Eccleston to defend SME-interests in WG 5 – EPACs and WG 9 – (e)cargobikes of CEN TC 333.
Comments Off on LEVA-EU to champion better rules for manufacturers as board member is appointed as SBS-expert
Trade association LEVA-EU, the sole voice for the light electric vehicle sector, is announcing the appointment of one of its board members, cycling industry veteran Eddie Eccleston, as Small Business Standards (SBS) expert. SBS is mandated by the European Commission to watch over SME-interests in European standardisation through the appointment of dedicated experts. In his position as SBS-expert, Eddie will help drive better rules for LEV manufacturers operating in the European Union.
LEVA-EU represents a wide range of LEV manufacturers in the EU, Norway, Switzerland, China and Korea, a large number of which are small businesses active in the European e-bike sector. Eddie Eccleston comments; “It is brilliant for LEVA-EU to gain a stronger voice through SBS as this is a key organisation which can help drive better rules and regulations for the LEV sector, which is not well understood always at EU level.” He continued: “The coronavirus crisis is accelerating the use of LEVs as a safe, alternative, green and healthy form of travel. However, legislation must keep up with the sector and there are serious issues where the rules are not fit for purpose for LEVs and they need resolving urgently.”
Eddie’s appointment comes as LEVA-EU campaigns among other things for the exclusion of e-cargo bikes from legislation that it says is stifling industries that rely on them. LEVA-EU has already written to the European Commission calling for urgent legislative change for LEVs centering on the technical legislation for L-category vehicles – mopeds and motorcycles.
The European Council and Parliament decided in 2013 to only exclude electric bicycles with pedal assistance up to 25 km/h and 250 W from this L-category in Regulation 168/2013. All other electric bicycles are included in technical legislation that was originally written for internal combustion engine mopeds and motorcycles, leaving manufacturers forced to navigate complicated and costly procedures. E-cargo bike manufacturers currently limit their vehicles to 250W to avoid the regulation and the ensuing type approval.
Eddie said: “This is a big issue I have already raised with SBS and we want as much input from LEV manufacturers as possible,” he said. “The 250W power limit, which e-cargo bike manufacturers must adhere to to stay out of type approval, is clearly insufficient in view of the increasing weight of the loads and for hilly areas. At the same time, European cities are banning cars, vans and trucks, and e-cargo bikes are being seen as a brilliant alternative. For this reason, and for e-cargo bike manufacturers to really thrive, it is essential that these types of vehicles are more widely excluded from the legislation so that the industry can reach its full potential.”
In his position of SBS-expert Eddie will be watching over the specific interests of small and medium sized enterprises (SMEs) in CEN TC 333 – cycles. There he is looking to ensure that standards do not hold any requirements, which are too difficult or too complicated for SMEs to comply with.
“Every day, LEVA-EU receives information requests from small businesses that are totally unable to grasp the EU rules and regulations that apply to their products,” he said. “It is our hope that having a voice through SBS will considerably contribute to both simplifying the standards and making them more effective, through a better harmonisation under the different relevant directives. In particular we want to ensure that the future standard for e-cargo bikes is tailored to small businesses.”
Eddie said he is now in the process of setting up a mirror group for businesses in the E-Bike and E-Cargobike sector to input into his work within CEN TC 33. Eddie is working in WG5 – EPACs and in WG9 – (E)Cargobikes.
“This mirror group is not only meant to share information on what is going on in CEN TC 333 it is also meant to consult and discuss the ongoing standardization work,” he said. “As a result, mirror group members will have direct access to and participation in the standardization work.”
For further information on standardization work for light, electric vehicles please contact LEVA-EU, email leva-eu@telenet.be, tel. +32 9 233 60 05
In CEN TC 333 Eddie Eccleston follows up on:
– CEN TC 333 – Cycles – General Assembly where general progress of the standardization work is discussed as well as potential new work items and miscellaneous issues.
– CEN TC 333 – Cycles – WG5 EPACs: this is the working group in which EN 15194:2017 has been developed. This working group discusses potential corrections, amendments and revisions of EN 15194:2017.
– CEN TC 333 – cycles – WG 9 (E)Cargobikes: this is a new working group that is preparing a European draft standard for (E)Cargobikes.
SBS background
Small Business Standards is a European non-profit association, co-financed by the European Commission and EFTA Member States. The SBS reported goal is to represent and defend small and medium-sized enterprises’ (SMEs) interests in the standardisation process at European and international levels. Moreover, it aims to raise awareness to SMEs about the benefits of standards and at encourage them to get involved in the standardisation process. For more information click here
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