Comments from CEN CENELEC on COM(2010) 245 of 19 May 2010 on "A Digital Agenda for Europe" Agreed by CEN and CENELEC Members following a written consultation process
1 European standardization to support the digital agenda CEN and CENELEC welcome the establishment of the Digital Agenda in support of the European single market. To ensure effective uptake of ICT products and services within the Union, it is vital that there are no cross-border barriers. The lack of awareness of existing standardized solutions, the potential for producing additional standards in some ICT areas and the resulting scope for Member States to introduce their own arrangements, can inadvertently lead to the imposition of such barriers. In this context, we observe that the role of the European Standards Organizations can prove critical in removing them. Creation of a European Standard requires automatically its adoption as a national standard in each national member, and the withdrawal of conflicting national standards. Better recognition of this principle, completely established and accepted in the world of conventionally-traded goods, could lead to immediate real benefits for the digital economy. 2 Major issues Quite apart from these considerations, the creation of a proper framework of standards activity through the European bodies can help at the same time to resolve some the real problems identified in the recent Commission Communication, such as lack of interoperability or fragmented digital markets, and also help foster the link between standards and research. The standards environment will not be strengthened by welcoming industry consortia products that may not meet European needs partial market acceptance of these in isolation is in fact the cause of much of the weakness, not the cure for it. Clearly a lot of the barriers will have to be removed by regulatory action, but standardization for example of the technical parameters needed to support regulation - can also be of considerable help in as well. The European Standards Organizations are well able to provide the necessary standards frameworks, and have the processes to resolve the problems. Our principles of full openness and Comments from CEN CENELEC on COM(2010) 245 of 19 May 2010 on "A Digital Agenda for Europe" Page 2
transparency including access to societal stakeholders and national involvement offer far more guarantees of universal acceptance than consortia activities. In view of the international dimension of the Digital Agenda, it is also important to realize that the national standards bodies participating in CEN and CENELEC are major contributors to formal international standards (which in the case of CEN/ISO, or CENELEC/IEC, can become European Standards through the Vienna and Dresden Agreement processes by parallel development). European deliverables are envisaged where specific European requirements that cannot be accommodated in an international standard exist. We recommend that the cooperation of ESOs with fora and consortia will focus on the expression of European needs in a global context. The results of transposition processes on the international level (e.g. using the Fast-Track and PAS procedures of ISO/IEC JTC 1) should be used where appropriate. 3 Interoperability A broad acceptance is particularly important where semantic interoperability is the issue. Semantic interoperability is not a matter of the latest technology. It requires the involvement of the technology users in reaching agreement on representing the content. The latest technology may be the subject matter in consortia but semantic interoperability requires the end user involvement that the ESOs can offer. In the context of interoperability, the art is to put the different specifications (which may have been developed in consortia and preferably have been accepted as a formal standard by fast-track processes) together to allow usable applications ( profiling ). This is for instance the approach taken in the ESOs response to Mandate M/403 (ehealth) where the profiles to be developed will take into account standards from fora and consortia. To this avail, an improved cooperation of ESOs with fora and consortia for an efficient transfer of consortia outputs to formal standards is an objective. Comments from CEN CENELEC on COM(2010) 245 of 19 May 2010 on "A Digital Agenda for Europe" Page 3
4 Standards and Innovation Furthermore, we are also cultivating close links between European research programmes and standardization. The recent publication of the integrated approach to standards, innovation and research by CEN-CENELEC illustrates that standardization can be a vital part of the process to bring innovations to market acceptance. Comments from CEN CENELEC on COM(2010) 245 of 19 May 2010 on "A Digital Agenda for Europe" Page 4
Annex 1 - Specific comments on the proposals, including suggestions for specific actions Topic 2.1.1 Opening up access to content In 2003-2005 CEN organized at Commission request a Focus Group on Digital Rights Management the result was an interesting state of the art report but no consensus between different interest groups. However, in 2009, the Commission and CEN co-organised a meeting on Electronic Publishing standards issues, which we are ready to follow up. The Commission proposes additional measures beyond collective rights management allowing EU citizens, online content services providers and right-holders to benefit from the full potential of the digital internal market These measures should include European standardization action to complement the legislation. As a first step we propose the Commission ask the ESOs to prepare a report on the standards aspects of these questions. Topic 2.1.2 Making online and cross border transactions straightforward CEN has long had a large and very well-supported consensus-building activity concerning electronic invoicing. This provides guidance and is linked to the outcome of a Commission Expert Group in 2008-2009. However, banks will not so far collaborate with European standardization in the SEPA context. This is a pity as it gives an impression of a closed club. Standards work on eid has been widespread as regards individuals (eg the European standards actions on electronic signatures). As regards entities (companies etc), one CEN Workshop Agreement has been published. Since financial institutions are often global entities rather than European, international standards (such as those of ISO/TC68) are particularly important. We propose that the specifications for supporting SEPA are developed in the European Standards Organizations, to ensure full stakeholder participation. Comments from CEN CENELEC on COM(2010) 245 of 19 May 2010 on "A Digital Agenda for Europe" Page 5
Revision of the esignature Directive should include European standardization action to complement the legislation. We recommend further work on authentification of entities Topic 2.1.3 Building digital confidence CEN has had previous consensus standards work helping business to implement the data protection and privacy Directives and the results were published as CEN Workshop Agreements. Most recent publications are CWA 16111:2010; Voluntary Technology Dialogue Framework (VTDF) CWA 16112:2010; Self-assessment framework for managers CWA 16113:2010; Personal Data Protection Good Practices CEN has further published in 2009 a CEN Workshop Agreement (CWA 16026:2009) on Standardization of On-line dispute Resolution Tools see ftp://cenftp1.cenorm.be/public/cwas/standodr/cwa16026_standodr.pdf We propose ESOs prepare guidance material for service providers to help build consumer confidence. We propose ESOs provide stakeholder consensus to support regulatory measures in relation to dispute resolution and in relation to trustmark criteria. Topic 2.2 Interoperability We recognize the barriers caused by lack of technical interoperability. However in the application environment the barriers are often related to semantic interoperability problems, or to lack of a consistent cross-border framework (noting the items in 2.1) Comments from CEN CENELEC on COM(2010) 245 of 19 May 2010 on "A Digital Agenda for Europe" Page 6
The distinction should be made between infrastructure standardization which must necessarily concern global technologies and applications, which frequently require a European approach. Topic 2.2.1 Improving ICT standards-setting Public procurement or legislative requirements for applications (ehealth, ebusiness, etc) seldom imply the use of one specification. Allowing the use of consortia specifications in legislation will not solve this problem the art is to put the different specifications together to allow usable applications ( profiling ). Furthermore, the requirements for European Standards (ENs) in public procurement Directives specify that the ENs be transposed as national standards (therefore in most cases in local languages), with the withdrawal of conflicting national standards. How this transposition can be achieved with consortia specifications is completely unclear. The Commission should encourage the standards consortia to bring their specifications to be used in Europe to the ESOs for adoption as European deliverables. The ESOs can prepare profiles for specific application scenarios (as we propose eg in our response to Mandate M/403 for ehealth) For application standards, IPRs are seldom a problem. We currently see no advantage in the expense incurred in organising ex ante disclosure and we think current policies should be retained Topic 2.2.2 Promoting better use of standards We strongly support this Topic 2.2.3 Enhancing interoperability through coordination We have many complaints from national standards bodies about uncoordinated approaches from their national governments towards the standards aspects of egovernment and there are concerns that this is leading to cross-border trade barriers. This should be much better coordinated. Comments from CEN CENELEC on COM(2010) 245 of 19 May 2010 on "A Digital Agenda for Europe" Page 7
We also draw attention to the example of M/403 (ehealth) where the ESOs will develop standards that are profiles of specifications which were produced by relevant fora and consortia. While we consider that it is not very clear what is meant by licensing interoperability information, we believe that such measures should not be necessary with correctly interoperable standards We propose the ESOs draw up a harmonised reference framework for egovernment, and publish this as a European Standard, in support of the proposed EIF, taking due advantage of the obligatory uptake of ENs in the EEA. Topic 2.3 Trust and security Standards play a subsidiary role, but it should be noted that we are currently discussing with the Commission services a new standards mandate on security applications, to prepare an updated overview of standards requirements. CEN currently is preparing a Technical Specification for internet filtering software We propose ESOs provide stakeholder consensus to support regulatory or administrative measures Topic 2.5 Research and innovation The link between standards and innovation is now well-recognised as an important meant to disseminate the fruits of European innovation and the ESOs have fast and dedicated deliverables and processes Topic 2.5.3 Industry-led initiatives for open innovation We strongly support this (except open platforms are not a clear concept; the creation of consensus platforms in competition with the standards organizations should be avoided). The Comments from CEN CENELEC on COM(2010) 245 of 19 May 2010 on "A Digital Agenda for Europe" Page 8
CEN-CENELEC STAIR (Standards, Innovation and Research) Group has prepared proposals for an integrated approach for research projects We propose to build consensus standards processes into research programmes and projects Topic 2.6.1 Digital literacy and skills CEN has a long-running and well-supported Workshop on ICT Skills (http://www.cen.eu/cen/sectors/sectors/isss/activity/pages/wsictskills.aspx); We propose ESOs prepare additional frameworks for ICT practitioner and ebusiness skills; where these frameworks are mature, the ESOs may consider the potential of European standards. Topic 2.6.2 Inclusive digital services The ESOs are in discussion with the Commission services concerning the preparation of a European Standard for Accessibility in ICT goods and services (to be used in public procurement). The work on the production of a European Standard that contains the functional requirements that ICT goods and services have to comply with, together with standard guidance material for use by the public procurer, will start by the end of 2010, under a joint activity between CEN, CENELEC and ETSI as part of Mandate M/376 Phase 2. Topic 2.7.1 ICT for the Environment The ESOs have considered possibilities and indeed have certain relevant standards mandates. There is also a lot of work on these issues in ISO The three ESOs have a common Working Group on smart grid standards issues, which is working closely with the Commission Smart Grid Task Force as well as with international standardization. We will complete the smart grid standards overview and then discuss with the Commission and stakeholders what additional standardization may be needed as a result. Comments from CEN CENELEC on COM(2010) 245 of 19 May 2010 on "A Digital Agenda for Europe" Page 9
The ESOs are also preparing a framework for smart meter standardization including common additional functionalities. We propose the ESOs prepare the proposed common measurement framework for greenhouse gas targets Topic 2.7.2 Sustainable healthcare and ICT-based support for dignified and independent living The ESOs are at an advanced stage in project discussions with the Commission concerning standardisation, interoperability testing and certification of electronic health records. We should start this work as soon as possible project negotiations have taken 18 months Topic 2.7.3 Promoting cultural diversity and creative content CEN has just produced European Standard EN 15907:2010: Film identification - Enhancing interoperability of metadata - Element sets and structures, which is a good example of European ICT standardization helping in this field The ESOs with their unsurpassed network of European and neighbouring states - can provide additional strong technical and guidance support to cultural diversity. The national members in particular, represent local stakeholder communities, their concerns and culture. Topic 2.7.4 egovernment CEN has currently work on eprocurement (WS/BII), einvoicing (WS/eINV) supporting egovernment applications. Internationally, standardization activities take place among others in ISO/TC68 (Financial services). We are also working in specific areas of public administration such as use of GNSS for transport of dangerous goods. See also 2.2.3 above Comments from CEN CENELEC on COM(2010) 245 of 19 May 2010 on "A Digital Agenda for Europe" Page 10
We propose consensus standardization to prepare pan-european technical solutions for egovernment (see also 2.2.3) Topic 2.7.5 Intelligent Transport Systems for efficient transport and better mobility The ESOs are currently working under mandates in support of the ITS Directive (CEN/TC 278 and ETSI/TC ITS), ATM in support of the Single Sky (CEN/TC 377) and rail standardization (CEN/TC 256) Continue consensus standardization to provide stakeholder consensus to support regulatory measures and extend to support the measures on passenger rail transport and e-maritime services Topic 3 Implementation and Governance We propose the Commission invite ESO participation as appropriate in the actionoriented platforms per topic, to ensure the standards dimension is addressed Comments from CEN CENELEC on COM(2010) 245 of 19 May 2010 on "A Digital Agenda for Europe" Page 11