EFESME Position Paper on Standard Accessibility for SMEs in the Elevator Industry

Background

Small and medium-sized enterprises (SMEs) are the backbone of Europe’s economy. They represent the principal share of all businesses in the EU. In the past five years, they have created around 85% of new jobs and provided two thirds of the total private sector employment in the EU. The European Commission considers SMEs and entrepreneurship as fundamental to ensuring economic growth, innovation, job creation, and social integration in the EU.

Promoting competitiveness and innovation are key aspects of EU policy in relation to industry and enterprise, in particular for SMEs. In this respect, standardisation is an important tool: European standardisation helps to boost the competitiveness of enterprises by facilitating in particular the free movement of goods and services, network interoperability, means of communication, technological development and innovation. European standardisation reinforces the global competitiveness of European industry, especially when established in coordination with the international standardisation bodies.

Regulation n° 1025/2012 on European standardisation calls the National Standardisation Bodies (NSO) to facilitate access of SMEs to standards and standard development process. This Regulation came into force in January 2013 and, taking into consideration what has been achieved so far, EFESME believes that more steps need to be done, in order to fully apply Article 6 “Access of SMEs to standards” of the regulation.

Accessibility of harmonised standards for SMEs in the elevator industry 

European harmonised standards for Directive 2014/33/EU and Directive 2006/42/CE are produced by the European Committee for Standardization (CEN) and their references are published in the Official Journal of the European Union (OJEU). Currently, the references of almost thirty harmonized standards for the two directives, approved by Technical Committee 10 of CEN, have been published in the OJEU. All economic operators in the elevator industry should be granted access to these standards.

Through a quick survey in some member states, EFESME noticed some barriers to the accessibility of standards.

The first barrier is language. European standards are published in English, French and German. Basically, they are drafted in English, but they are translated by CEN in the other two languages prior to any circulation for comments or approvals. It is clear that SMEs expect that a similar approach is taken by CEN at least for all those countries where lift SMEs are important players, if they have to be involved in all the decision making steps (without affecting the process timing!). In countries where none of these languages is the official one, today standards shall be translated by the NSO. If and when this happens, a translation in the national language requires not less than one year: in the meantime, SMEs that do not understand foreign languages will not have access to the standards. Nevertheless, the worst is yet to come: very often, harmonized standards are not translated at all. EFESME monitored the availability of the eight main lifts harmonized standards (EN 81-20, 21, 28, 50, 70, 72, 73, 77) in the national language of Estonia, Greece, Italy, Portugal, The Netherlands and Spain. The outcome is quite frustrating: as far as EN 81-20 is concerned, i.e. the most important harmonized standard for lifts, in three countries (Estonia, Greece and Portugal) the national version is not available! According to the data accessible online, Spain is the only country where the eight standards are all available in the national language; in Italy, there are six standards translated in Italian, in The Netherlands only three standards available in Dutch, in Portugal two standards in Portuguese, while Estonia and Greece have just one standard in their national languages. With the involvement of the new generations, most probably, this need of translations in the national languages might be less and less important, but nowadays this is still one of the major obstacles to the access of lift SMEs to the standards of their interest.

The second barrier consists of costs. The prices of standards are fairly high and do not take into consideration the limited financial capacity of the SMEs. In the already mentioned research on standard costs, EFESME noticed that the cost of standards translated in the national language is generally higher than the English versions – among the monitored countries, only Spain and Germany propose translated standards at a lower price. Another remark concerns the discounts offered by some NSOs to their members. A worth-mentioned example comes from the UK: the British NSO, that sells standards with 50% discounts to its members, calculates its membership fee on a ratio between the size of the enterprise (no. of employees) and the turnover. Anyway, in the cases we investigated, it is not foreseen a difference of price between SMEs and big companies. This uniformity in prices hampers the integration of the SMEs in the market and a regime of fair competition. A solution could be conceiving standard packages, containing all TC10 standards, at a special, reduced price for lift SMEs: a system already existing in some NSOs but, apparently, not particularly efficient.

The third barrier continues to be the representativeness of lift SMEs in the CEN / TC10. Despite the commitment of EFESME to this issue, CEN still lacks in equally representing all stakeholders. SMEs continue being largely underrepresented in terms of number of delegates in the TC, with an unavoidable advantage for the big companies, the real decision makers in CEN. Being the SMEs not able to influence the development of standards, the disparity of conditions in the market described in the previous points is thus reflected also on a political level. The under representativeness of SMEs in the CEN / TC10 proves the lack of elevator SME representatives within the NSOs: apart from the Italian case, there are very few – if any – representatives from SME attending the national lifts technical committees in the European  NSOs. SMEs expect the EU Commission Policy to include a further support granting a much lower participation fee for joining the relevant NSOs and, in addition, a comprehensive subsidy by such NSOs for the expenses incurred in participating to the CEN TC10 and relevant WGs activities. This would greatly help enhance the SMEs attitude and capabilities to contribute positively to the development of standards, with a deeper involvement of a much larger SME base in such activities.

Conclusion

EFESME believes that access to standards and standard development processes for micro-sized businesses must be as easy as it is for large enterprises.

Article 6 of Regulation (EU) No. 1025/2012 identified the NSOs as the main tool for facilitating a better access to technical standards and the standardisation process by SMEs and, in addition, indicated some operational measures. However, more than four years after the entry into force of the regulation, the outcomes are disappointing, at least in the lift sector. EFESME is observing to this day serious and widespread difficulties regarding the availability of standards in the national languages, the price of standards and the participation of SMEs in the standardisation process, at both national and European levels.

EFESME believes that it is necessary a much bigger effort from the European standardisation system, in order to guarantee a better access to standards for SMEs. For this purpose, it could be appropriated that:

  • CEN ensures the simultaneous publication of standards in all EU national languages or, alternatively, at least in the languages of the countries in which the number of enterprises active in the specific reference market is higher;
  • the NSOs adopt affordable and preferential price policies for SMEs by creating ad hoc offers for them, with a sensible price difference compared to big companies;
  • the EC support given to European organisation representing SMEs in the European standardisation activities is maintained and strengthened; similar supporting schemes shall be promoted at national level, including through the NSOs, in order to finance the participation of SME representatives in the national standardisation activities, as propaedeutic to the European one.

 

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