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 SBS-Survey to identify key areas of standardisation for SMEs
SBS launched a study at the end of 2020 to identify key areas of standardisation for SMEs spanning the next five years. Both European and international standards cover an extremely broad range of goods and services, and the number of standards being developed or revised is growing every year. The study will assist SBS in focussing its activities on standardisation areas that have been identified as especially relevant and strategic from the SME perspective.
As a part of this effort, SBS has developed a questionnaire to be completed by SMEs to assist in prioritising sectors and topics of particular SME relevance. The deadline for submission of the questionnaire is 15 July 2021. The questionnaire is available in Dutch, English, French, German, Italian, Spanish and Swedish here
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 ISO/TS4210-10:2020 is NOT a standard
ISO has published ISO/TS 4210-10:2020. This document is not a standard but a technical specification with safety requirements for electrically power assisted cycles (EPACs).
WG15 of ISO TC149/SC1 had been working on a draft standard for EPACs for a number of years. The idea was to come to an international standard that could potentially replace EN 15194, which is only valid in the EU.
The draft text for the future ISO standard was to a very large extent based on EN 15194. However, it becomes increasingly apparent that the quality of the electrical part of the EN 15194 is poor. CEN TC333 is currently dealing with a number of national objections against the standard for that reason.
Another issue of the draft ISO-standard for EPACs was the fact that it had too many requirements, which did not result from safety considerations and which created regulatory bottlenecks for innovation and technological development.
LEVA-EU is working in the ISO WG15. For all the above reasons, together with a significant number of other experts, we have rejected the draft text for the standard twice. ISO procedures did not allow for a third vote on the standard. That is why ISO has now published the text as a Technical Specification (TS). According to ISO: “A Technical Specification addresses work still under technical development, or where it is believed that there will be a future, but not immediate, possibility of agreement on an International Standard.”
All this changes nothing to the status of EN 15194:2017, this is still the European standard for EPACs, harmonised under the Machinery Directive.
For further details, please contact Annick Roetynck, tel. +32 9 233 60 05, email annick@leva-eu.com.
In April, ISO received a proposal for the creation of a new Technical Committee on social responsibility. If created, the committee would aim to revise the ISO 26000 standard and develop further guidance and/or standards on social responsibility.
SBS considers that the proposal neither provides a proper justification for the creation of a new ISO Technical Committee nor considers SMEs as an important stakeholder in this area. The principles of social responsibility have not changed since the adoption of the standard. The current ISO 26000 already covers the main principles of social responsibility including sustainability aspects. Therefore, there is no need to revise it. Moreover, SBS doubts whether the development of multiple guidelines and standards under the umbrella of ISO 26000 would help to advance social responsibility and fears that this may just add unhelpful burdens on companies, especially SMEs, instead.
Small Business Standards (SBS) is a European non-profit association established in 2013 with the support of the European Commission devoted to representing and defending Small and Medium-sized Enterprises’ (SMEs) interests in the standardisation system at European and international levels