European standardization in connection with the time-consuming "HAS assessment" of harmonized standards is often perceived as too slow. This is not the only reason why the EU Standardization Regulation 1025/2012 is to be revised. The "fall back" option of the so-called "Common Specifications" also raises more questions than providing any discernible benefit. To this end, the EU Commission can adopt implementing acts to define common specifications that cover the technical requirements. This option can come into play, for example, if CEN or CENELEC do not accept a standardization mandate or are unable to develop it within a specified period or if the standardization results do not correspond to the mandate.
KAN and the German Social Insurance European Representation (DSV) also expressed criticism here in an open letter on March 27, 2026, whose assessment the author shares:
"...advocate an efficient but measured and targeted reform and call on the European Commission to uphold the tried and tested basic principles, in particular the consensus principle. Both organizations also underline the role of the existing standardization organizations. Awarding standardization mandates to other organizations or adopting results from external standardization sources could jeopardize the uniformity of the body of standards and place an additional burden on social stakeholders. In the opinion of KAN and DSV, acceleration measures must not be at the expense of consensus, safety and quality. As the participation of social stakeholders is already challenging and resource-intensive, reforms must not make it more difficult for them to participate. Structures and processes must remain transparent, understandable and clear.
KAN and DSV are also critical of the instrument of common specifications. As there is still a lack of clearly defined use cases, transparent procedures and effective opportunities for stakeholders to participate at an early stage, common specifications must remain a strictly limited exceptional instrument. The priority of harmonized standards must remain unrestricted."
The two European standardization organizations CEN and CENELEC have now brought a new approach into play: the so-called "European Agile Specifications". The proposal envisages that this new format could be used to provide technical specifications within short development periods. EAS should potentially be given the opportunity to trigger the presumption of conformity. The aim is to be able to react more quickly to new market-related, technological and regulatory requirements. At first glance, this does not seem well thought out - especially as it does not solve the problem of "HAS assessments".
KAN also takes a clear stance:
"From KAN's point of view, the European Agile Specification (EAS) must not trigger a presumption of conformity. This is because standardization documents should only be able to trigger a presumption of conformity if
- accelerated processes do not jeopardize their quality and legitimacy
- they continue to enjoy a high level of acceptance by being based on the broad expertise of all relevant stakeholders, for which sufficient time must be allowed in the creation and coordination process,
- genuine consensus building takes place during their development, as this is the only way to ensure that important social interests, such as occupational health and safety, are adequately taken into account,
efforts to make the drafting process more flexible do not lead to additional restrictions on the participation of interested parties, as limited participation and a lack of public consultation reduce their legitimacy and prevent early feedback on technical and practical problems."
What the new standardization regulation will ultimately look like remains an exciting question. However, both "common specifications" and "European Agile Specifications" are probably not the right instruments.
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Author's note
This article has been machine translated into English.
TERMS AND ABBREVIATIONS
CEN: The European Committee for Standardization
CENELEC: The European Electrotechnical Committee for Standardization
