The letter sent by the Commission, addressed to CEN/TC 151 “Construction equipment and building material machines – Safety”, aims to clarify the “long-standing issues regarding the production of harmonised standards”.
It touches upon three main topics. On one hand, the standards that reproduce legal provisions. Since the purpose of the harmonised standards is to support the application of relevant legislation, they mustn’t overlap with the EU legal provisions. Doing so risks an “unnecessary redundancy, or even incoherence with legal text”, as the European Commission explains.
The entity also recommends the application of the common checklist for harmonized standards.
On the other hand, concerns arise regarding the standards covering large categories of products. Due to its scope, it can lead to the “lack of detailed and appropriate test methods and/or lack of information for the intended use”. Those specifications are important to reduce the level of interpretation and ensure legal certainty.
Lastly, the letter talks about the possible problems with the testing methods. Ideally, to avoid any mistakes and discrepancies in the test results, only one testing method should be included in a harmonized standard. Although there are exceptions to that rule, the methods must be “equivalent in terms of accuracy and reproducibility and reflect the state of the art”.
Additionally, AFNOR, the French member of the CEN/TC 151, has prepared a video about those discrepancies, which you can watch below:
Despite the concerns, the European Commission remains optimistic about the future actions of both entities. As the letter expresses:
“We are encouraged overall by the improved cooperation and look forward to our future work together.”