Common Specifications – fallback or challenge for harmonised standards within the EU?

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About trade

Published: 29 Sep 2025

Harmonised standards have long been the primary tool for businesses to demonstrate compliance with EU product legislation. They play a crucial role in fostering innovation, strengthening legal certainty and enhancing competitiveness, while ensuring a well-functioning single market.

– Harmonised European standards should remain the main tool for demonstrating compliance with EU legislation, as they also promote innovation, legal certainty and competitiveness. The Commission’s use of common specifications should be limited to well-defined exceptional cases and should rely on clear processes that ensure transparency, inclusiveness and international cooperation, says Iness Hadji, legal adviser at the National Board of Trade Sweden.

Accessibility challenges and new solutions

Recently, delays and limited availability of harmonised standards have created challenges for businesses, leading to uncertainty, higher compliance costs and delays in bringing products to market.

To address this situation, the EU has introduced so-called common specifications in several legislative acts. The aim is to provide an alternative solution when harmonised standards are unavailable. Unlike harmonised standards, which are developed through open, consensus-based processes, it remains unclear how the process for developing common specifications will work in practice.

Broader application of common specifications

As part of the Omnibus IV package, presented in May together with the EU’s Single Market Strategy, the Commission now aims to broaden the use of common specifications. It refers, among other things, to the Court of Justice ruling on public access to harmonised standards and to the absence of ISO/IEC-based harmonised standards for reference in the Official Journal of the European Union.

According to the Commission, there is a risk that the single market could be weakened and that business costs will increase if these issues are not addressed.

Read and download the full analysis in English.