
Brussels, 23 December 1998 - 190298
JR/jr/marequip/centc300/It1216hs.doc

Dear Mr.Schade,
Subject:CEN Business Planning for the drafting of European Standards.
Business Plan from CEN/TC 300 "Sea-going vessels and marine technology"
I refer to your letter CEN/TC 300 sde-gtr of 27 November 1998 on the above mentioned subject, inviting for comments on the draft CEN/TC 300 Business Plan.
I note that under the Chapter "Scope of the CEN/TC 300" reference is made to the EU as one of the market environments relevant for the work of the Technical Committee. It is stated that the European Commission sets up Directives wherein starting points for standardisation work could be found but that they are not suited for European activities, because of the international connections.
Although I appreciate that the international background of shipping is an extremely import context for the development of standards, I cannot agree with the view that Community legislation in this field is not suited for European standardisation activities.
In this respect I have to draw your attention to the provisions of article 7 of Council Directive 96/98/EC on marine equipment, as amended by Commission Directive 98/85/EC. Paragraph 1 of this article provides for the Community to submit a request to IMO or to the European Standardisation organisations, as appropriate, for the establishment of standards for the equipment listed in Annex A.2 of the Directive.
Further, its paragraph 5 stipulates that if the international organisations, including the IMO, should fail or refuse to adopt such testing standards in a reasonable time, standards based upon the work of the European Standardisation Organisations may be adopted through Committee procedure.