ECIS’ response to the public consultation on the evaluation and functioning of Regulation (EU) 1025/2012
ECIS’ response to the public consultation on the evaluation and functioning of Regulation (EU) 1025/2012
ECIS is an international non-profit association founded in 1989 that endeavours to promote a favourable environment for interoperable ICT solutions. It has actively represented its members regarding issues related to interoperability and competition before European, international and national fora, including the EU institutions and WIPO.
ECIS’ members include large and smaller information and communications technology hardware and software providers, namely IBM, Corel, Kolab Systems, McAfee, Opera, Oracle, RealNetworks, and Red Hat. The association strives to promote market conditions in the ICT sector that ensure that there is vigorous competition on the merits and a diversity of consumer choice.
Regulation 1025 as cornerstone for European standardisation
ECIS has a keen interest in European standardisation, as standardisation plays a key role in interoperability of ICT products and services. ECIS is a long-standing and proud member of the EU Multi-Stakeholder Platform (MSP) on ICT Standardisation. Regulation 1025/2012 on European standardisation is a cornerstone for European standardisation and for the achievement of the single European market. The evaluation, and the follow-up of it, will play an important role for ICT products and services and its interoperability. ECIS wants to be fully engaged in this process and hereby submits its comments.
Regulation 1025 still fit for purpose
Regulation 1025/2012 provides a good legal framework for standardisation in Europe that is still fit for purpose. Any improvements can be made within current architecture whilst also ensuring stability and consistency at a time of so much standards related activity to implement key EU regulations, such as the AI Act, Cyber Resilience Act and the Data Act. Regulation 1025/2012 has achieved its objectives as its creation has correlated with a shorter development of standards.
The general objectives of Regulation 1025/2012 are not the reason behind delays in the standardisation process when developing harmonised standards. These delays relate mainly to the implementation and operational aspects, such as citation, publication and HAS-consultants.
Moreover, there has been a marked increase in the volume of ICT standardisation with regards to software and thus an ever greater need for additional skill-set within European Standardisation Organisations (ESOs) which have typically addressed more hardware related products and/or non-ICT sectors.
The European standardisation system is organised under self-governance of the stakeholders. It is the task of these stakeholders, and of the industry as the key stakeholder, to work on a modern, up-to-date infrastructure so that ICT standardisation in and out of Europe can have a leading role. The EU Multi-Stakeholder Platform on ICT Standardisation plays an important role in facilitating ICT standardisation in Europe and keeping it up to date.
Alignment with international/ global standards
Although Regulation 1025/2012 does not explicitly promote the adoption of international standards, alignment between European and international standards is an element that remains important. Global standards and a global playing field are both for European and non-Europeans companies the best way to secure business opportunities. Economic benefits for both European and international companies are most significant if global standards are applied. The EU has already recognised this strategic importance by prioritising ‘mutual recognition’ in regulations such as the Cyber Resilience Act.
In this respect, not only international standards drafted by ISO, but also standards from more agile international consortia such as the World Wide Web Consortium (W3C), Organization for the Advancement of Structured Information Standards (OASIS), Institute of Electrical and Electronics Engineers (IEEE), and Internet Engineering Task Force (IETF) are relevant for the European standardisation system. The European standardisation system can benefit from the work of these international consortia. Alignment and involvement of international consortia in the European standardisation system will also secure that the interests of open source software is taken into account, as these international consortia often rely on open source standards and policies.
Importance of open source software in standardisation landscape
Open source software plays an important role in the standardisation landscape – in particular to ensure genuine IT choice enabled by high hygiene of interoperability and underlying open standards and specifications. EU policy should better embrace and enable this important role by optimising the possibilities of implementing European standards directly into open source.
Number of experts and awareness raising for standardisation
The number of experts that are needed to draft standards, remains a challenge, especially when multiple standardisation requests in the same industry (i.e. digital/ cybersecurity) are issued at the same time and the existing pool of experts have to deal with all of these requests at once. Last but not least, ECIS supports all initiatives undertaken by the European Commission and other stakeholders to raise the awareness for standardisation and enable education to increase the number and involvement of experts.