In principle, the choice is made to let the system work with self-declarations. Ensuring a level playing field will imply great supervisory pressure for supervising authorities. The question is whether this is feasible (in practical sense) for all member states.
NMC
NEN (member of CEN)
Other · Netherlands
2
positions filed
in the 583 files tracked
1
legislative file
of 583 tracked
0
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
NEN (member of CEN) filed 2 positions on 22 Jul 2022, across 1 of the 583 legislative files tracked here.
What they argued
In a previous (not officially published) version of the EHDS, references to ‘harmonized European standards’ were included. Surprisingly, in the current version the ‘harmonized European standards’ are deleted from the text and only ‘national and international standards’ are mentioned. This is not in line with the Standardization Strategy of the European Commission (see https://ec.europa.eu/docsroom/documents/48598).
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