Version 2, 23rd June 2011

Framework Contract on impact assessment

B5/ENTR/2008/006-FC-Lot 5
EU actions for the promotion of craft and SMEs in
the European standardisation area – Assessment
of the implementation of the recommendations of
the previous evaluations and assessment of
options for a future financing
Final Report

www.technopolis-group.com
Disclaimer
Technopolis Group has carried out this study on behalf of the European Commission. The views expressed are those of the
authors and do not necessarily reflect those of the Commission, or the Directorate General for Enterprise and Industry. The
European Commission does not guarantee the accuracy of the data and information included in this study, nor does it accept
responsibility for any use made thereof.
Acknowledgements
The study team would like to express its thanks to the persons consulted during the course of the study who gave freely of their
time and experience to assist in the work.
Executive Summary
Introduction
In 2008 the European Commission, DG Enterprise and Industry, asked GHK/Technopolis, to
carry out an external evaluation of the actions carried out by NORMAPME over the preceding
six-year period, and the results of that study were published in March 2009. The evaluation
identified a range of possible improvements to the work carried out by NORMAPME, which
revolved around the need for it to (i) improve its collaborations and representativeness, (ii)
strengthen its evidence base and the focus of its interventions, (iii) improve its communication
activities, and (iv) strengthen the monitoring and reporting of its activities. A final
recommendation asked the Commission to increase the level of financial support provided to
NORMAPME to allow it to implement these improvements and to strengthen its core processes.
The results of the evaluation, and especially the recommendations (which were included in the
subsequent contractual arrangements) were taken into account for the actions carried out by
NORMAPME from 2009 onwards.
This report presents the results of a follow-up evaluation that was carried out by Technopolis
Group from September 2010 – April 2011. The primary purpose of the study has been to assess
the extent to which NORMAPME had made progress in implementing the recommendations of
the previous evaluation, and to identify steps that might be necessary in order to further
strengthen NORMAPME’s operations. The study has also provided an assessment of options for
the future financing of NORMAPME by the Commission, and of NORMAPME’s financial
viability and ability to attract co-financing.
The study findings are based on a desk-based review of the activities carried out and reported on
by NORMAPME since the previous evaluation, focusing on the grants for actions covering
2009/10, and on feedback obtained from over 220 representatives of stakeholders organisations,
including NORMAPME’s staff and experts, Commission officials, the standardisation bodies,
SME representatives at European and national levels and a small number of other relevant actors.
Principal findings
The results of the study have shown that NORMAPME has made some good progress in
implementing the majority of the recommendations of the previous evaluation, and is now
considered by many stakeholders to be a reliable, helpful, effective and efficient organisation,
and that it is performing a valuable role. The majority of contributors to this study also consider
the services provided by NORMAPME to be of high relevance and utility to SMEs.
Many of the recommendations of the previous evaluation related to the need for NORMAPME to
work in a more collaborative and constructive way with all relevant stakeholders, and to increase
its representativeness. We have concluded that NORMAPME has made some progress in this
regard, and have highlighted a number of specific actions that were designed to improve its
relationships with the standardisation bodies, and with EU- and national-level associations
representing SMEs, particularly those that do not form part of NORMAPME’s membership.
The feedback suggests that these efforts have been welcomed and have helped to strengthen
NORMAPME’s position and its ability to cooperate effectively with a larger number of actors.
NORMAPME’s relationships to other actors are of central importance because, as a small
organisation that is being asked to perform a very significant role, it needs to work with others in
order to be effective. Calls for NORMAPME to strengthen and extend its relationships related in
large part to the need for NORMAPME to improve its evidence base and thereby enhance the
focus and potency of its interventions. Solutions to identified problems also have to be
developed and delivered in conjunction with or through other bodies, and without strong
partnerships NORMAPME’s ability to meet its objectives in this regard would be more limited.

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The previous evaluation therefore asked NORMAPME to work with others to better define the
types of support and information needed by SMEs, to determine which parts of the SME
community were most in need of assistance, and to use this information to improve the focus of
its interventions. The results of the study have shown that NORMAPME has made only a small
amount of progress in these respects. This is in part because CEN and CENELEC initiated a
major project in 2009 to research SMEs’ access to standardisation and to develop and implement
appropriate solutions, and this to some extent obviated the need for NORMAPME’s own
investigations. We note that NORMAPME has participated actively in the CEN-CLC project and
this is a good example of the more active and positive cooperation that now exists between
NORMAPME and the standardisation bodies. NORMAPME’s leading role in the development
and promotion of a CEN-CLC Guide to help standards writers to ensure that their outputs are
‘SME friendly’ has also been enormously helpful in this regard.
Several recommendations from the previous evaluation highlighted the need for NORMAPME to
improve its communication activities and we conclude that some positive progress has been made
in addressing several of those recommendations. NORMAPME now provides a larger body of
informative material targeted to SMEs and it has recently begun to more actively promote the
support services that are available from other organisations in addition to its own. These are
important and positive developments.
The previous evaluation also recommended that NORMAPME take steps to strengthen the
monitoring and reporting of its own activities, and again we have been able to report on some
positive progress. NORMAPME has improved the extent to which it has been collecting
feedback from the SME associations that access its services, and has improved certain aspects of
the reports that it provides to the Commission.
The final recommendation of the previous evaluation asked the Commission to increase the
financial support it provides to NORMAPME to allow it to implement the recommendations. We
can confirm that additional funding has been provided to NORMAPME and that much of this has
been used to underpin the improvements that have been made.
While our overall conclusions are positive, this study has identified a number of areas where the
recommendations of the previous evaluation have not yet been fully addressed. We have also
developed a revised understanding of the most important improvements that NORMAPME needs
to make moving forward.
Recommendations for strengthening NORMAPME’s role in the future
Transparency
We have concluded that there remains a significant level of confusion about NORMAPME’s role
and a lack of transparency surrounding many aspects of its operations, and that this limits the
extent to which NORMAPME is understood and fully accepted by the wider community. Many
stakeholders do not fully understand the role and mission of NORMAPME and what the
financing provided by the Commission is intended to achieve. In addition, there is considerable
confusion surrounding NORMAPME’s dual roles as (i) a membership-based body, which exists
to serve the needs of its members, and (ii) as an organisation tasked by the Commission to
support the needs of all SMEs in the area of European standardisation, irrespective of
NORMAPME’s formal alliances. Many stakeholders are unclear as to what this implies as
regards whose needs NORMAPME is actually serving, both in principle and in practice, and we
believe it is important for this issue to be clarified. We have therefore issued the following
recommendations:
• The Commission and NORMAPME should provide a clear public statement concerning NORMAPME’s role and
mission, setting out the specific objectives that NORMAPME is pursuing and for which it is receiving public
financing

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• The Commission together with NORMAPME should provide a clear public statement as to who it is that
NORMAPME is representing, and whether membership of NORMAPME does or does not lead to differential levels
of access to its services and influence over its activities
Confusion over NORMAPME’s role and whose needs it is serving are compounded by the fact
that its decision making processes are not transparent. It is important that NORMAPME’s
resources are deployed in a way that maximises the added-value that they can bring and that they
complement the efforts of other actors, and as such it is important that stakeholders are fully
involved in decisions concerning the nature and focus of NORMAPME’s activities. It is also
important that NORMAPME is seen to be consulting properly and that the decisions it takes are
based on inputs from relevant stakeholders, worked out through some form of consensus building
process. The feedback collected through this study and our own assessments have highlighted
the need for NORMAPME to operate in a much more transparent and ‘evidence-based’ way, and
we have therefore put forward the following general and specific recommendations:
• NORMAPME should develop and implement clear and transparent processes to demonstrate that its activities and
decisions are directly informed by the interests and wishes of the communities it represents
• NORMAPME should establish one or more ‘stakeholder’ committees to inform decisions regarding the balance of its
activities and the approaches and procedures it follows in carrying out its work
• NORMAPME should develop and implement clear, comprehensive and transparent processes for consultation,
consensus building and position formation that involve all relevant stakeholders. It should also ensure that the
positions adopted are made publicly available and include clear information on how those positions were arrived at
and which organisations contributed to their formation

Focus of NORMAPME’s activities

In addition to the general improvements recommended above, we have identified more specific
areas where the balance of NORMAPME’s activities should be adjusted or placed on a more
transparent basis. The first issue concerns the extent to which NORMAPME promotes negative
rather than positive images of European standardisation. Many stakeholders believe that
NORMAPME still does not do enough to promote the positive benefits of standardisation to
SMEs, and that most of the messages it sends out are likely to discourage rather than encourage
their use by SMEs. It is clearly important for NORMAPME to highlight issues and problems and
to develop practical solutions, but these efforts need to be balanced by a more concerted effort to
encourage SMEs to use standards and become involved in standardisation at national level. We
have therefore issued the following recommendations:
• NORMAPME should devote a greater proportion of its overall effort to (i) promoting positive messages about the
business benefits of standards, and (ii) encouraging SMEs and their representatives to participate in the
standardisation process at national level. The optimal ways and means for doing this should be agreed in conjunction
with the ESOs, NSBs and associations representing SMEs
• NORMAPME should work with the NSBs to develop a ‘map’ of SME representative bodies at national and sectoral
levels, and then work with those representatives to identify significant gaps in SME engagement. NORMAPME
should then use this information to target its awareness raising activities in the areas of greatest identified need
Another area of concern highlighted by the previous evaluation concerned the balance of
NORMAPME’s expert representation in TCs, which was thought by many to lack coherence.
This is a positively regarded activity, but it consumes the majority of NORMAPME’s operational
expenditure and so it is vital that experts are placed on the ‘highest priority’ committees for
SMEs. Unfortunately the recommendation of the previous evaluation that NORMAPME perform
a robust analysis of where representation is most needed and then use that analysis to adjust the
balance has not been adequately addressed. We have therefore issued the following
recommendation:
• NORMAPME should undertake a consultation exercise to identify the TCs that most require additional SME
representation and should use the results to actively recruit SME experts in the areas of greatest need. In addition,
NORMAPME should undertake consultations to strengthen its own assessment of the performance of existing experts

Relationships

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While NORMAPME has made good progress in strengthening its relationships in a number of
important respects, certain aspects of its behaviour continue to limit its ability to cooperate as
actively and productively as it could with both the standardisation bodies and other EU-level
associations representing SMEs. In particular NORMAPME does not always give these
organisations the recognition they deserve as regards their role in supporting SMEs. In addition,
NORMAPME is sometimes seen to have unrealistic expectations and make demands that are
simply not practical or realistic. It is our view that a more moderate and constructive approach
on the part of NORMAPME will strengthen rather than limit its influence. We have therefore
issued the following recommendations:
• NORMAPME should adopt a more moderate and constructive approach in its dealings with the standardisation
bodies, and should devote a greater proportion of its resources to the co-development and co-implementation of
practical solutions that will benefit SMEs
• NORMAPME should redouble its efforts to forge closer and stronger cooperation with other EU-level industry
associations, and give greater recognition to their important role in representing SME interests within the European
standardisation system

Communications
NORMAPME has strengthened its communication activities in a number of important respects,
and these have been highlighted in our report. However, given NORMAPME’s central role in
encouraging and enabling SMEs to make better use of standards and participate more actively in
standards development, it is vital that its communication activities are as strong and well
organised as possible, and that its messages are promoted effectively. Problems with its contacts
database have meant that many of its messages are not reaching their target groups, and a number
of important improvements to NORMAPME’s website appear warranted. It is also the case that
NORMAPME is failing to share some of the outputs of its work with third parties, limiting the
extent to which they can make benefit of the information NORMAPME has at its disposal. We
have therefore issued a number of recommendations in this area as follows:
• NORMAPME should take steps to build a smaller but more complete contacts database containing only named
individuals with which it has a relationship and with which it communicates. Steps should be taken to ensure that its
database contains all of the fields needed to manage its relationships effectively and that the information contained in
each record is complete and is updated on a regular basis
• NORMAPME should (i) define the types of information that it can make available, (ii) inform all of its contacts about
these, (ii) establish which communications each contact wishes to receive and in what language, and (iv) provide this
information in line with those requests. It should also take steps to develop and distribute information that is
organised along more sector-specific lines
• NORMAPME should improve its website through the provision of a search facility and should ensure that all sections
are kept regularly up to date
• NORMAPME should build on its initial efforts to more actively promote the support services that the ESOs, NSBs
and SME representatives (including itself) can provide to SMEs. In particular, NORMAPME should create a
dedicated section on its website that provides clear information to SMEs about the support services that are available
at European and national levels
• NORMAPME should ensure that its work to track new policy developments affecting SMEs at the EU-level (policies,
legislation, standardisation) are properly documented and communicated to other parties so that they too can benefit
from and react to this information

Management, monitoring and reporting

NORMAPME has strengthened some aspects of its management, monitoring and reporting, but
we have identified a number of weaknesses that inhibit its ability to manage its activities as
effectively and efficiently as possible. We also believe it would be useful for NORMAPME to
increase the extent to which it monitors the relevance and utility of its services, building on some
good progress that it has already made. Finally, we see a very clear need for NORMAPME to
improve the clarity and completeness of its reports to the Commission, which should in turn

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expedite the payments that NORMAPME relies upon. We have therefore issued the following
recommendations:
• NORMAPME should make further efforts to strengthen its management processes in order to enable it to deploy its
resources more effectively and efficiently
• NORMAPME should in future collect routine (i.e. annual) feedback from all of its constituents to assess their
satisfaction with the support services and information that it provides
• NORMAPME should improve the clarity and completeness of its reporting to the Commission, addressing the
various issues identified in this report

Future financing
This study has reviewed the options available to the Commission as regards the future financing
of NORMAPME. Based on our analysis, we have concluded that an operating grant would be a
more appropriate arrangement than the current system of grants for actions. The latter are
intended to be used for ‘one-off actions’ while operating grants are used to provide financial
support towards the existence and functioning of a body pursuing objectives that form part of a
EU policy. Given NORMAPME’s role and the ongoing nature of its activities an operating grant
is the more suitable financing mechanism.
A switch to an operating grant does not imply any loss of management control on the part of the
Commission over the activities that it co-finances. The Commission should only co-finance
those parts of NORMAPME’s operations that contribute to community policy objectives, and it is
appropriate, given the likely level of the co-financing, that the Commission should retain a high
level of scrutiny over how the money is being used and what is being achieved as a result. We
have therefore issued the following recommendation:
• In future the community financing of NORMAPME should be made through an operating grant rather than through
grants for actions. Following this change, the Commission should ensure that it maintains a high level of supervision
over the activities receiving co-financing
The study has also looked at NORMAPME’s business model, its financial viability and its ability
to generate its own share of the financing needed to carry out its activities. Our analyses have
indicated that NORMAPME’s business model is not robust, and that it has only very limited
options for attracting revenues from other sources that can be used to co-finance the activities. It
is therefore likely that NORMAPME will continue to rely heavily on community financing for
the foreseeable future. However, under the terms of an operating grant NORMAPME must
gradually reduce its reliance on Commission financing, and so there is a need for NORMAPME
to do all it can to generate increased levels of co-financing, year-on-year. We have therefore
issued the following recommendation:
• NORMAPME should develop concrete but realistic plans to maximise its own revenues, in order to ensure it can
contribute its share of the costs of the activities. NORMAPME’s beneficiaries should be made more aware of the
financing arrangements under which it operates and the need for them to contribute towards its costs
Because NORMAPME has limited scope to generate private revenues its viability relies on
continued financial support from the Commission. Some commentators believe that this unfairly
‘protects’ NORMAPME from market forces, and while that may be true to some extent, the
Commission will only continue to fund NORMAPME’s activities if it has assurance that those
activities are necessary, useful, efficient and effective. It is therefore very important that
NORMAPME has the confidence and support of the wider community and it is why the previous
evaluation – and this one – has focused its recommendations so heavily on the need for
NORMAPME to build strong collaborative relationships, strengthen its evidence base and the
focus of its actions, communicate effectively, and ultimately provide the best possible service to
the SME communities that it possibly can. Only through these routes can it secure the full
confidence of the community and in turn secure its own future. We wish NORMAPME well in
its endeavours and hope that this report will be seen as constructive and useful in that regard.

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1. Conclusions and recommendations
1.1 Introduction
This section presents our principal conclusions and recommendations, based on the information
set out in the body of this report. While we have focused on what we consider to be the most
important issues, the reader should note that Section Error! Reference source not found.
contains a significant body of more detailed information that we believe can and should be used
by the Commission and NORMAPME to further optimise the effectiveness and efficiency of the
intervention scheme.

1.2 Implementation of the recommendations of the previous evaluation

1.2.1 Overall conclusion

The main questions addressed by this study concern the extent to which NORMAPME has
implemented the recommendations of the previous evaluation, and the extent to which the
activities carried out to address the recommendations have been effective. Ultimately we have
sought to determine whether the areas for improvement identified in the previous evaluation have
been addressed and whether additional actions are need in order to further enhance
NORMAPME’s effectiveness.
Section Error! Reference source not found. of this report presented our analysis of the
activities that NORMAPME carried out in 2009/10, and Section Error! Reference source not
found. presented our assessment of the extent to which NORMAPME has, through these actions,
implemented the recommendations of the previous evaluation which, due to their integration in
the Framework Partnership Agreement signed in March 2009, were binding. It should be
remembered that the previous evaluation reported its findings approximately two years ago, and
that this is a relatively short time frame in which to manage what is a significant body of changes.
We should therefore not expect NORMAPME to have been able to do everything, but it is
important to consider whether it has begun to make progress and is moving in the right directions.
It is on this basis that our main conclusions have been developed.
Our overall conclusion, based on the information at our disposal, is that NORMAPME has
made some good progress in addressing the majority of the recommendations of the
previous evaluation. Below we provide more detailed conclusions, highlighting the good
progress that has been made and identifying areas where further action is required. Specific
recommendations are included as and where appropriate.

1.2.2 Recommendations relating to NORMAPME’s collaborative relationships

A significant number of the recommendations of the previous evaluation related to the need for
NORMAPME to improve its collaborative relationships with the other important actors in the
system, notably the ESOs, NSBs and other organisations representing SMEs at European and
national levels. NORMAPME is a small organisation charged with a very significant mandate
and we therefore considered it important for NORMAPME to be able to work cooperatively with
other organisations, both to better understand where and how to focus its activities and to access
the external resources required to implement effective solutions. The need for improved
collaboration was, however, slightly different in each case.

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In the case of the ESOs1 and the NSBs it was important for NORMAPME to understand existing
support measures being provided to SMEs by the standardisation bodies, and to better understand
the nature and extent of SME engagement in standardisation at national levels. It was also
necessary for NORMAPME to work with the standardisation bodies to agree possible additional
measures that would benefit SMEs, and to work together on the implementation of those
solutions. However, it was apparent at the time of the previous study that relationships between
NORMAPME and the standardisation bodies were under some strain, for a number of reasons.
First, the standardisation bodies felt that NORMAPME was almost exclusively devoted to the
identification and active promotion of the problems and barriers faced by SMEs, and that as a
result it conveyed a largely ‘negative’ image of the European standardisation system. This was
considered to be counter-productive, as one of NORMAPME’s primary roles is to encourage
SMEs to use standards and become involved in standardisation. At the same time it was felt that
NORMAPME was doing little to develop solutions, and that it simply demanded that the
standardisation bodies remedy the situation. Some of the changes that NORMAPME called for
were considered to be unnecessary, impractical, unaffordable, or counter to the national
delegation principle on which the CEN and CENELEC systems are based.
In the case of other associations representing SMEs, close cooperation was again considered
necessary in order for NORMAPME to properly understand the nature and extent of SME
engagement with standardisation and therefore how best to orient its own activities.
Commentators believed that NORMAPME should work more actively to understand the situation
at national levels and in different sectors, as it was widely accepted that SME needs and existing
levels of engagement vary considerably. NORMAPME was considered to have weak links at
national level, which was perhaps not surprising given its own scale, but it was nonetheless felt
that more could be done, particularly if it worked in concert with the NSBs. At the European
level, while NORMAPME had strong relationships to its own member associations, it was clear
that relationships with other EU-level representative bodies were limited and that NORMAPME
did not have the full confidence of those organisations. This left significant ‘gaps’ in
NORMAPME’s sectoral coverage and undermined its claims to understand properly and
represent fully SME needs as a whole.
Overall we conclude that NORMAPME has made good progress in strengthening its
collaborative relationships with other stakeholder organisations. It has implemented a number of
dedicated actions to strengthen its relationships with NSBs and with other SME representatives at
both European and national levels. Based on the feedback obtained it is also clear that
NORMAPME has been making steps to work in a more cooperative and constructive manner
with these other bodies. In particular the following aspects of NORMAPME’s work over the past
two years should be highlighted:
• NORMAPME’s proactive efforts to meet with National Standards Bodies in order to enhance
cooperation. These visits were well received but the NSBs that were not covered by the
action felt that NORMAPME should have reached out to them also. However, this situation
appears to have been remedied in recent months and we have discerned a more positive
‘atmosphere’ between NORMAPME and the NSBs as a result. Our questionnaire survey
found that 80% of respondents believe that NORMAPME has improved its collaboration with
NSBs to a medium-high extent
• NORMAPME’s central role in CEN/BT WG 208, which developed a guide to help standards
writers develop standards more attuned to the needs of SMEs. NORMAPME has been

1 These comments relate primarily to CEN and CENELEC.

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 widely applauded for its central role in this initiative and it serves as a good example of
NORMAPME’s increasing willingness to work constructively with the standardisation bodies
on the development of solutions
• NORMAPME’s participation in the CEN-CLC access project which has researched the
barriers facing SMEs and developed a toolkit of solutions. NORMAPME is participating in
the WG overseeing the implementation of this project and is leading on the implementation of
some of the identified solutions. Again this stands as a positive example of NORMAPME’s
improved cooperation with the ESOs and NSBs
• Continuation of NORMAPME’s generally positive collaboration with ETSI, which has been
further strengthened through the work of two NORMAPME experts each of which is making
an extremely positive contribution to understanding of SME issues and to discussions of
possible solutions
• NORMAPME’s proactive efforts to meet with other EU-level representatives and enhance the
cooperation. While a number of fairly significant barriers to full cooperation remain, the
meetings were generally well received and it has been important for NORMAPME to begin
to reach out to these organisations. Our questionnaire survey found that 79% of respondents
believed that NORMAPME has improved its collaboration with other representatives of
SMEs to a medium-high extent
While progress overall has been good, a number of issues have been identified that have limited
NORMAPME’s ability to make as much progress as we might have hoped. The issues are
summarised below, and are accompanied by specific recommendations that we believe will help
to strengthen not only relations but also the overall effectiveness of NORMAPME’s contribution.
NORMAPME’s collaborations with standardisation bodies and in particular CEN and its
members
The first major issue concerns the extent to which NORMAPME promotes negative rather than
positive messages about European standardisation. This was highlighted in the previous study,
and resulted in a specific recommendation that NORMAPME do more to help to promote the use
of standards by SMEs, a requirement that was subsequently entered into the Framework
Partnership Agreement signed in March 20092. An acknowledged barrier that SMEs face relates
to their low level of awareness of standards and the business benefits that they can bring. The
standardisation bodies all wish to see an increase in the number of SMEs making use of standards
and see it as a central part of NORMAPME’s mission to help them to actively promote the
positive benefits of European standards. From their perspective, not enough has changed in this
regard, and while NORMAPME has improved the extent to which it works with the
standardisation bodies to address identified problems, NORMAPME still devotes the vast
majority of its energies to highlighting problems, with the result that its portrayal of European
standardisation continues to be essentially negative. They feel a more positive set of messages
should be promoted by NORMAPME, and that it should devote more of its resources to ensuring
that SME communities are aware of the opportunities that can be gained by using standards. This
does not limit NORMAPME’s ability to identify and help to resolve barriers and problems, but
infers instead a more balanced approach.

2 The Framework Partnership Agreement clearly stipulates that the aim is “to promote the participation of SMEs and craft enterprises and their
interests in the European standardisation process, as well as to improve SME and craft enterprises’ information on, and use of European
standards and to show them the benefits of using standards”.

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The standardisation bodies were not the only stakeholders to raise this issue. A small but
significant number of commentators from other groups, including SME associations, would like
to see NORMAPME doing more to promote the use of standards by SMEs. We agree with this
proposition for a number of reasons. First, standards are not ‘imposed’ on SMEs – they are a
voluntary tool that can be used to help businesses meet legislative requirements or to otherwise
improve and assure the performance and compatibility of their products and services. SMEs do
not have to use standards, but the business benefits of doing so are clear, and alternative routes to
compliance with legislation are widely acknowledged to be more costly and onerous. Second,
the rationale for publicly financing an organisation such as NORMAPME is that SMEs do not
use standards as much as is socially desirable, partly due to barriers to access but also partly to
low awareness of the benefits. A focus only on the problems and barriers and an active
promotion of these in the absence of any serious promotion of the benefits is counter-productive
to the overall mission.
We believe that part of the problem here lies with a lack of clarity over NORMAPME’s mission.
At various points in this report we have highlighted problems relating to the fact that other
stakeholders are unclear as to NORMAPME’s role and responsibilities, its objectives, and its
working procedures. We agree that this is not sufficiently clear and we therefore make the
following recommendations:
1. The Commission and NORMAPME should provide a clear public statement concerning
NORMAPME’s role and mission, setting out the specific objectives that NORMAPME
is pursuing and for which it is receiving public financing
2. NORMAPME should devote a greater proportion of its overall effort to (i) promoting
positive messages about the business benefits of standards, and (ii) encouraging SMEs
and their representatives to participate in the standardisation process at national level.
The optimal ways and means for doing this should be agreed in conjunction with the
ESOs, NSBs and SME associations
The second major barrier to improved collaboration and cooperation between NORMAPME and
the standardisation bodies, or more specifically CEN and CENELEC, concerns NORMAPME’s
somewhat mixed views on the national delegation principle. On the one hand NORMAPME
seems to accept that the national delegation principle is an effective means through which SMEs
can participate in European standards development at relatively low cost, locally and in their
national language. While the standardisation bodies agree that higher participation by SMEs at
national level is desirable and necessary in some areas (and would welcome NORMAPME’s
support in helping this to happen), NORMAPME seems often to challenge the national
delegation principle (e.g. by asking for a NORMAPME vote that could be used to challenge the
consensus arrived at in TCs) and displays a lack of understanding in relation to it (e.g. by failing
to understand that CEN and CENELEC TCs are comprised of national delegations that represent
a national position rather than by representatives of specific types of organisation).
NORMAPME’s actions to place SME experts in CEN/CLC TCs to some extent already goes
against the national delegation principle, but it has been accepted by the two ESOs and has been
shown to bring some important benefits. It should, however, be viewed as a short-term palliative
measure while the real business of ensuring stronger participation by SMEs in national mirror
committees is addressed.
The third major barrier to improved collaboration and cooperation with the standardisation bodies
concerns what some see as NORMAPME’s continued tendency to overstate the nature and extent
of problems affecting SMEs and to demand that action is taken without putting forward
constructive or practicable proposals as to how this might be done. While significant progress
has been made by NORMAPME in the extent to which it is working positively with the

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standardisation bodies in some areas, it undermines this by continuing to act in what is seen to be
an aggressive and unreasonable manner in certain fora and in relation to specific issues.
Concerns have also been expressed that NORMAPME has an altogether unrealistic set of
expectations about what can be done to resolve identified problems. The standardisation bodies
have limited resources and are already devoting significant time and energy to implementing the
58 recommendations arising from their own study to identify and address barriers to access
affecting SMEs. Several commentators asked why it was that NORMAPME itself has never
carried out or commissioned such a study, given its role, and why it is that now this project is in
train NORMAPME continues to paint a predominantly negative picture of European
standardisation’s treatment of SMEs. Ultimately the standardisation bodies feel that
NORMAPME still sheds ‘more heat than light’ on the situation, and that it would be more
influential if it adopted a more moderate and constructive approach. Relations would also be
improved if NORMAPME could do more to acknowledge the progress that the standardisation
bodies have been making.
We believe that NORMAPME can only be truly effective if it works in concert with other
stakeholders, some of the most important of which are the standardisation bodies themselves.
The previous evaluation recommended that NORMAPME “adopt a more positive and
constructive approach towards the European standardisation system and its main actors” and
while it has made some good progress to date we would like now to reaffirm the importance of
NORMAPME continuing to make further efforts in this direction. NORMAPME’s first major
role was to highlight and gain acceptance of the needs of SMEs and to persuade the
standardisation bodies to take seriously the need to improve SME access to standardisation and to
address identified barriers. Here we can say NORMAPME has been successful and that the
‘battle’ has been won. To win the war now requires the development and implementation of
practical solutions that really benefit SMEs, and NORMAPME needs to work with rather than
against the standardisation bodies to achieve this.
3. NORMAPME should adopt a more moderate and constructive approach in its dealings
with the standardisation bodies, and should devote a greater proportion of its resources
to the co-development and co-implementation of practical solutions that will benefit
SMEs
NORMAPME’s collaborations with other EU-level associations representing SMEs
The main barriers to improved collaboration with other EU-level associations representing SME
are rather more complex and may be more difficult to overcome. Nevertheless they do need to be
addressed if NORMAPME’s central role is to be assured in the future.
The main issue as we see it is that there are many representatives of SMEs at EU-level and while
NORMAPME, through its alliance with UEAPME has a very large and significant membership
base, it is by no means the chosen representative of all SMEs with an interest in standardisation.
NORMAPME relies heavily on Commission financing and is handed what is considered to be a
high level of ‘political’ influence, which can be seen to place NORMAPME and its members at
an unfair advantage over other bodies that also represent SMEs but which do not form part of
NORMAPME’s membership. NORMAPME has done little in the past to reassure other
representative bodies that its financing and influence is being used to advance the needs of their
members as well as its own and has been accused of actively ignoring or dismissing the views of
other representatives because they also represent large companies. The associations concerned
do not, however, believe that they act against the interests of their SME members and see no
reason why NORMAPME should suggest that they would. While NORMAPME has made clear
efforts to work more cooperatively with the major EU-level industry associations over the past

5
two years, relationships continue to be difficult in some cases and barriers to closer cooperation
remain.
The situation is aggravated by the fact that NORMAPME still does not have transparent
processes for forming the SME ‘positions’ that its represents. The other EU-level associations
consult their own members in relation to standardisation policy matters and tend to find that SME
needs are complex, varied and often unaligned, making it hard to reach a clear consensus.
NORMAPME on the other hand displays an unusual talent for reaching very strong and very
straightforward (i.e. simplistic) conclusions as to what SMEs want, and yet singularly fails to
explain how those positions were arrived at and which SME associations contributed to their
formation. This has led to a situation where other actors have serious doubts over the robustness
of NORMAPME’s consultative processes and the extent to which it is making efforts to arrive at
a considered and ‘sophisticated’ response. Other actors within the system have raised similar
concerns and it is widely seen to be one of NORMAPME’s major weaknesses, casting doubt over
its claims to be the principal ‘voice’ of SMEs in relation to standardisation.
Issues relating to NORMAPME’s evidence base are dealt with in the next section, and the
recommendations made there, if implemented, will certainly contribute to improved relations
between NORMAPME and other EU-level associations that represent SMEs. There remains,
however, a need for NORMAPME to give greater recognition to the other representative bodies,
acknowledging in particular that they rather than NORMAPME should take the lead role in
relation to issues specific to the sectors or parts of the sectors that they represent. NORMAPME
also needs to do more to help these other associations, and should concern itself less with the fact
that they also represent large firms. As stated above, it is not in these organisations’ interests to
do anything that would be damaging to their SME members, nor is it automatically the case that
large and small companies’ interests are misaligned. What is important is that the funding that
the Commission provides and the status that NORMAPME has been afforded is used to serve the
benefits of all representatives of SMEs (as stipulated in the FPA) and not just NORMAPME’s
own member associations. NORMAPME therefore has a duty to give these other associations
recognition, respect, and equal access to its services. It would also serve NORMAPME to be
more modest in its dealings with these other associations, and to adopt more of a service attitude.
Again, it is important for NORMAPME to realise that the best way to assure its future is to
ensure that it has the support of all relevant stakeholders and is seen to provide a good service to
all representatives of SMEs. We therefore make the following recommendation:
4. NORMAPME should redouble its efforts to forge closer and stronger cooperation with
other EU-level SME representatives, and give greater recognition to their important
role in representing SME interests within the European standardisation system
The issue of who it is that NORMAPME represents is an important issue in both practical and
political terms, and at various points in this report we have highlighted feedback that suggests the
current situation is confused and is damaging to both NORMAPME and the Commission. It is
important that NORMAPME is seen to represent all SME interests in an equitable fashion, and
some commentators have questioned whether it is helpful for NORMAPME to be a membership-
based organisation at all. There are certainly arguments to suggest that if NORMAPME
functioned more as a secretariat with no particular alliances and serving equally the needs of all
bodies that represent SMEs, many of the challenges to its position would be diminished. Such a
move would clearly have some benefits but it could also create other problems, not least in terms
of how NORMAPME would secure its share of co-financing in the absence of membership fees.
However, it is something that we believe would be a more suitable arrangement and is an option
to consider in the longer term.

6
In the meantime, we believe that the situation should be clarified as to who it is that
NORMAPME represents. At present NORMAPME states on its website that it serves the needs
of its members and that it takes its decisions only after consulting and securing the agreement of
the majority of them. Such statements can be taken to mean that NORMAPME does not serve
the needs of non-members and that it does not involve non-members in its decision-making
processes. As the principal funder of NORMAPME and its activities we consider it is for the
Commission to clarify this situation, something that should obviously be done in conjunction
with NORMAPME itself. The first question is whose interests NORMAPME represents (i.e.
who are its constituents) and the second is what processes and procedures does NORMAPME
have in place to ensure that the needs and interests of its constituents are directly informing its
activities and its positions. At present the answers to both questions are unclear and we believe
that this situation should be remedied as a matter of urgency. We therefore make the following
recommendations:
5. The Commission together with NORMAPME should provide a clear public statement
as to who it is that NORMAPME is representing, and whether membership of
NORMAPME does or does not lead to differential levels of access to its services and
influence over its activities
6. NORMAPME should develop and implement clear and transparent processes to
demonstrate that its activities and decisions are directly informed by the interests and
wishes of its constituents
NORMAPME’s collaborations with national-level associations representing SMEs
NORMAPME has made only very limited progress in strengthening its collaborative
relationships with SME representative bodies at national level since the previous evaluation,
despite the implementation of specific actions to enable it to do this. This is not an easy task to
achieve, given the distances involved, language barriers and the fact that NORMAPME is
attempting to reach organisations that may have little knowledge of European standardisation or
may feel that their European representatives should handle European matters. However, it
remains important for NORMAPME to gain an improved understanding of the situation at
national levels if it is to bring forward solutions for increasing SMEs’ use of standards and
participation in the standards development process.
NORMAPME, through its involvement in the SMEST 2 project, should be able to better
understand and improve its connections at the national level, but we believe that efforts to
increase its connections and ‘outreach’ should form part of its ongoing, core activities. We also
believe that these connections can be best achieved through active collaboration with the National
Standards Bodies, who in many respects are in the best position to determine which parts of the
relevant SME communities are or are not making use of standards and engaging actively in the
standards development process. We believe that NORMAPME should develop a ‘map’ of SME
representatives at national and sectoral level and then work with those representatives (and the
NSBs) to determine current levels of awareness and use of standards and current levels of
engagement in standardisation. NORMAPME should then use its resources to reach out to the
specific sectors in the specific countries that are adjudged to be less involved and/or less well
informed. Such an activity, if carried out effectively, would address a range of identified needs –
it would improve collaboration with the NSBs and national-level SME representatives, it would
improve NORMAPME’s understanding of where best to focus its awareness raising activities,
and it would address directly the objective of helping more SMEs to make use of standards and to
become more involved in the standardisation process. For these reasons we believe that
NORMAPME should redouble its efforts in this direction and make the following
recommendation:

7
7. NORMAPME should work with the NSBs to develop a ‘map’ of SME representative
bodies at national and sectoral levels, and then work with those representatives to
identify significant gaps in SME engagement. NORMAPME should then use this
information to target its awareness raising activities in the areas of greatest identified
need

1.2.3 Recommendations relating to NORMAPME’s evidence base and the focus of its
interventions
The previous evaluation focused heavily on the need for NORMAPME to improve its
collaborative relationships partly because these relationships would enable it to better understand
(i) the extent to which SME communities in different sectors and in different countries were or
were not making use of standards and engaging in the standardisation process, (ii) the specific
problems and issues that SMEs face in relation to standardisation within the different sectors, (iii)
the extent to which other actors, including the standardisation bodies themselves, were already
providing support services to SME communities, and (iv) the types of information most required
by SMEs. Several recommendations therefore stated that strengthened collaborative relationships
should be used to improve NORMAPME’s understanding of the situation and thereby improve
the focus of its own activities and interventions. This would ensure that the public financing was
concentrated on the areas of greatest need, and that NORMAPME’s activities complemented
rather than duplicated existing support provision and provide maximum ‘added value’. The
previous evaluation also recommended that NORMAPME do more to recognise and promote the
good work that other organisations were doing in supporting SMEs, and should use that
information to ensure that its own activities build on and complement existing support.
Based on the results of this study we can say that NORMAPME has made only limited progress
in strengthening its evidence base and in improving the focus of its interventions. Part of the
reason for this is that CEN and CENELEC have carried out their own study on ‘SME access to
European standardisation’ which researched the problems and barriers that SMEs face and
identified 58 measures that could be taken to enable SMEs to achieve greater benefit from
standards and from involvement in standardisation. These recommendations are now in the
process of being implemented. The study also notably identified a range of good practices that
were already in place or under development to improve SME access to standards and the
standardisation process. The CEN/CENELEC study therefore in large measure obviated the need
for NORMAPME to carry out its own investigations, at least to the extent recommended by the
previous evaluation, and we are pleased to be able to report that NORMAPME has been actively
collaborating with CEN/CLC on this initiative. As already mentioned, NORMAPME is
participating on the working group that is overseeing the implementation of the
recommendations, and is taking a leading role in the implementation of four of them. This is a
good example of NORMAPME’s progress in working more cooperatively and constructively
with the standardisation bodies. However, we still see a need for NORMAPME to improve its
own understanding of SME involvement and issues/ problems at the national and sectoral levels
and would therefore reaffirm the importance of Recommendation 7. above.
The previous evaluation identified two rather more specific areas where NORMAPME was
challenged in relation to the strength of its evidence base and hence on the legitimacy of its
actions. These related to:
• NORMAPME’s processes for consultation, consensus building and position formation, which
were not transparent or well understood by other actors and tended to result in what they
perceived to be rather general or over-simplistic positions. This led to suspicions that

8
 NORMAPME was either simply basing its positions on the views of a handful of its closest
member organisations or, worse still, using its own staff to decide what the ‘SME position’
should be. This was a cause of serious concern and we recommended that NORMAPME
“implement clear, comprehensive and transparent consultative processes involving all
relevant actors”, that it “ensure that any positions adopted are made publicly available and
include clear information how those positions were arrived at and which organisations
contributed to the formation of those positions”
• NORMAPME’s activities to place SME experts in TCs. Here the balance of expert
representation was called into question by many actors, with accusations that TCs of high
importance to SMEs had no expert in place while others that were of interest to only a very
narrow section of the SME community did have expert representation. The overall
distribution was seen by many to follow too closely the interests of NORMAPME’s own
member organisations and did not sufficiently reflect the areas of greatest need as viewed
from the perspective of SME communities overall. We therefore recommended that
NORMAPME “perform a systematic and comprehensive review of the relevance of all ESO
TCs to SMEs, and a more robust analysis of where within the system additional
representation is needed.” We went on to state that “the results of this exercise should be
made generally available via NORMAPME’s website”
Once again we have to say that NORMAPME has made only very limited progress in addressing
these two specific recommendations.
As regards NORMAPME’s consultative processes and its position formation, we again
encountered a range of concerns on the part of many different stakeholder organisations about a
lack of transparency and again were told that NORMAPME’s positions sometimes lack
credibility. NORMAPME has failed to address the recommendation of the previous evaluation
and provides no detailed information to explain to the wider community how it consults, who it
consults, or how it reaches a consensus. While it does publish its positions, it includes no
information concerning how many or which organisations contributed to them, and it has also
been accused of failing to provide such information when specifically asked to do so in individual
cases. To some extent questions about NORMAPME’s positions would be less likely to be
raised if they were well founded, sophisticated, and in line with the positions put forward by
other representatives of SMEs. However, this is often not the case, and there are suspicions that
NORMAPME does not really consult properly but instead uses its own staff to form a position,
which is then circulated to its members for comment, and is then adopted in the absence of any
feedback or objections.
The failure of NORMAPME to address this recommendation is regrettable and does its
credibility significant harm. It is not expected that hundreds of organisations would provide
inputs to any given position but it is expected that the positions would be based somehow in the
views of SME representatives who have an understanding of the issues concerned, and that
efforts would be made to build a consensus among the various views presented. NORMAPME’s
inability to demonstrate that this is the case continues to diminish its standing in the eyes of the
wider community and we therefore make the following recommendation:
8. NORMAPME should develop and implement clear, comprehensive and transparent
processes for consultation, consensus building and position formation that involve all
relevant stakeholders. It should also ensure that the positions adopted are made
publicly available and include clear information on how those positions were arrived at
and which organisations contributed to their formation

9
As regards the balance of NORMAPME expert representation in TCs, we have noted that the
recommendation of the previous evaluation has only been partly addressed. NORMAPME has
implemented a number of exercises over several years to assess the SME relevance of successive
‘batches’ of ESO TCs and to determine whether additional SME representation is needed.
However, as yet no comprehensive overview has been presented and little has been done to use
the analyses to optimise the balance of expert representation. NORMAPME’s efforts to conduct
the analyses have been partly confounded by a lack of available information on the extent of
existing SME representation in the national mirror committees of the TCs where NORMAPME’s
experts are already placed. However, the overall methodology that has been applied is in our
view seriously flawed and even if the results could be relied upon NORMAPME has not used its
analysis to adjust in any significant way the overall portfolio of TCs in which it has experts
placed. By way of example, despite now having experts in approximately 50 TCs, only four of
the 25 TCs that NORMAPME has stated are of the highest relevance to SMEs have so far been
covered.
It is not clear whether NORMAPME should conclude its analysis and then use the results more
actively to adjust the balance of expert representation, or whether it should abandon its analysis
and undertake a new assessment. On balance we would favour the latter course of action, and
would suggest that NORMAPME undertake a simple consultative exercise directed to all of the
major European-level sectoral associations and all of the NSBs. This should ask them to list, in
priority, the TCs that are of most significance to SMEs and that most require additional SME
representation, and then that information should be used to assemble a prioritised list of TCs, by
sector. The results should be made available for comment and the comments received should be
used to further adjust and refine the lists. By conducting its analysis in this way (rather than
behind closed doors) NORMAPME should be able to arrive at a set of priority TCs that would
have some credibility in the eyes of the community, and NORMAPME could then turn its
attention to recruiting experts for the highest priority TCs. This was, after all, the original
purpose of the exercise.
This leaves the more difficult question of how to deal with the TCs that have existing SME expert
representation but which have not been highlighted as priority areas. Overall, the results of this
study have shown that in most cases the work of the experts is well regarded and is felt to be
having some level of positive impact on the development of the standards. For this reason we do
not see an urgent need for NORMAPME to begin to remove experts from the TCs that are not
judged as high priority. However, we believe that NORMAPME is in a good position to
determine which of its experts are having a significant and positive impact and which are having
lower levels of impact, and further consultations (of SME associations and TC participants)
should be used to refine this understanding. NORMAPME can then make sensible judgements
about whether to take corrective actions, including the renewal of contracts or not, and thereby
gradually improve the balance of expert representation in the TCs. We therefore make the
following recommendation:
9. NORMAPME should undertake a consultation exercise to identify the TCs that most
require additional SME representation and should use the results to actively recruit
SME experts in the areas of greatest need. In addition, NORMAPME should undertake
consultations to strengthen its own assessment of the performance of existing experts
One final conclusion that we have drawn in relation to NORMAPME’s evidence base and the
targeting of its activities is that NORMAPME appears to operate without a ‘stakeholder’
committee that can direct the activities that NORMAPME carries out with Commission co-
financing. NORMAPME does have its own Board compromising representatives of its member
associations, but there are no structures that include non-member representatives. We believe that

10
this factor contributes to the lack of transparency surrounding whose interests NORMAPME
represents and contributes to a certain amount of dissatisfaction on the part of organisations that
represent SMEs but do not wish to become members of NORMAPME. We believe that it would
be appropriate for NORMAPME to establish one or more stakeholder committees and use these
to inform the range and focus of NORMAPME’s own activities, and sanction the approaches and
procedures it follows. This should help to improve its ‘evidence base’ as to the correctness and
legitimacy of its activities, approaches, decisions, etc. and would improve both the transparency
surrounding what it is doing and the extent to which it has the blessing and ‘buy-in’ of all of its
key constituents. It would also help to demonstrate that its work is not directed solely towards
the needs of its own members but has been worked out by committees comprising all relevant
stakeholders. We therefore make the following recommendation:
10. NORMAPME should establish one or more ‘stakeholder’ committees to inform
decisions regarding the balance of its activities and the approaches and procedures it
follows in carrying out its work

1.2.4 Recommendations relating to NORMAPME’s communication activities

The previous evaluation identified a number of ways in which NORMAPME’s communication
activities could be strengthened, and made a number of recommendations in this regard. The first
of these - that NORMAPME should do more to promote SMEs’ use of European standards - has
already been discussed above and we have issued a further recommendation in relation to that.
Other recommendations of the previous evaluation affirmed the need for NORMAPME to:
• Share good practice in the provision of relevant information to SMEs
• Do more to promote the SME support measures that are available from other actors
• Ensure that its work to track new developments affecting SMEs at the EU-level (policies,
legislation, standards) are properly documented and communicated to other parties, and
• Ensure that all interested parties receive regular information on its work, in terms of its
activities, processes, positions and achieved results
Concerning the first bullet point, based on the results of the study we can conclude that some
good progress has been made. While NORMAPME has not yet done much to promote ‘good
practice’ in information provision it has begun to take steps to better understand the relevance
and utility of the information in provides, and has taken some steps to improve these. Relating to
this, our surveys found that 57% of respondents felt that NORMAPME had improved its
provision of relevant information to their organisation to some extent since the previous
evaluation. Our surveys also revealed that recipients of NORMAPME’s direct communications
(newsletters, circulars, consultation papers, etc.) in the vast majority of cases find this
information relevant and useful. NORMAPME has also requested feedback from users of its
website in order to determine how it can provide more useful and relevant information. In
addition NORMAPME has undertaken specific activities to produce and distribute informative
leaflets and booklets in relation to standardisation and certification / CE marking, and has
updated its website so as to provide a larger body of informative material than it did at the point
of the previous evaluation.
While NORMAPME has advanced in terms of its own information provision, the study has
identified some areas where more can be done. First, we believe that NORMAPME needs to
manage much more tightly its database of contacts and ensure that it is clear as to what kinds of
information each contact should receive. Over half of the SME associations targeted by our
survey stated that they do not receive any regular information from NORMAPME, and these

11
were all named contacts supplied by NORMAPME itself. NORMAPME has clearly had
problems with its database and while it has been taking steps to improve this in recent times, we
believe that the database still contains far too many incomplete, out of date and incorrect records,
and does not contain the right kinds of fields to enable NORMAPME to manage its
communication activities properly. Its central database contains several thousand records but the
vast majority of the contacts are not sent any information and NORMAPME appears to have only
limited control over which information it should be sending to the contacts that it does interact
with. We believe that it would be preferable for NORMAPME to have 100 well founded,
complete and up to date records of named contacts with which it actually interacts than 1,000 out
of date irrelevant contacts with which it rarely if ever communicates. NORMAPME should only
list contacts that it actually has a relationship with, and its database should contain fields detailing
the nature of the relationship, the information each contact should be provided with (and supply,
where relevant), the language in which it should be supplied, etc. It should also contain fields to
indicate when the record was created ,when it was last updated, and so on. Each record should be
as complete as possible. Such improvements are vital to the ability of NORMAPME to manage
its relationships and communications effectively and efficiently, and we therefore make the
following recommendation:
11. NORMAPME should take steps to build a smaller but more complete contacts database
containing only named individuals with which it has a relationship and with which it
communicates. Steps should be taken to ensure that its database contains all of the
fields needed to manage its relationships effectively and that the information contained
in each record is complete and is updated on a regular basis
In addition to improving the quality of its database NORMAPME needs to establish much more
clearly what forms of information it should be sending to each contact. If it is to provide a high
quality service NORMAPME has to be very clear about the types of information it can provide,
and should know which types of information each contact wishes to receive and in which
language. Feedback also suggests that many stakeholders would like information that is more
sector-specific and targeted to their individual needs. We therefore make the following
recommendation:
12. NORMAPME should (i) define the types of information that it can make available, and
in which languages, (ii) inform all of its contacts about these, (ii) establish which
communications each contact wishes to receive and in what language, and (iv) provide
this information in line with those requests. It should also take steps to develop and
distribute information that is organised along more sector-specific lines
Finally, while we have noted important improvements to the range of information available on
NORMAPME’s website, we have also noted that certain types of information (e.g. on the
benefits of standards) are either not available or very difficult to find. We have also noted that
while many sections are kept regularly updated it is clear that other sections have not been
updated for many months and in some cases years. To give some examples, its most recent press
information is from 2009, its most recent annual report is from 2008, and its most recent
information on its financing relates to the 2008/9 year. And, while the website contains a wealth
of useful information there is no search function available, meaning that it can takes users a large
amount of time to ascertain whether specific information or documents are available and where to
locate them. We have also noted that certain key documents, such as the 14-page informative
booklet that NORMAPME developed are not available from the ‘Publications’ area of its
website, although it is possible to find this booklet elsewhere. We believe that NORMAPME
needs to focus more effort on these matters, and make the following recommendation:

12
13. NORMAPME should improve its website through the provision of a search facility and
should ensure that all sections are kept regularly up to date
Concerning the recommendation that NORMAPME share the ‘good practice’ shown by other
actors in providing support measures to SMEs, our analyses have led us to conclude that
NORMAPME has made a small but important amount of progress. For example, messages sent
to SME associations as part of NORMAPME’s recent activities to promote Guide 17 (which
helps standards writers to draft SME friendly standards) have included contact information on the
recipients’ NSB and have listed some of the key services that the NSB offers to SMEs, such as
reduced prices for standards or information days to help SMEs’ to become involved. The
messages sent by NORMAPME also direct recipients to the CEN-CENELEC SME Portal and
indicate that this provides additional information on NSB support for SMEs. This is an important
first step in NORMAPME communicating more positive messages to the outside world about the
services that other actors provide to SMEs. Having said this, there is little information on
NORMAPME’s own website to inform SMEs about the availability of these support services,
and in fact it is not particularly easy to determine from the website what support NORMAPME
itself can offer. We therefore feel that more can be done in this regard, and would reaffirm the
need for NORMAPME to ensure that SMEs are made aware of and are helped to access all forms
of support, irrespective of who it is that provides them. If NORMAPME can be seen to do more
to actively acknowledge and promote the services of other organisations, it will strengthen its
own position in their eyes rather than undermine it, and will provide a better service to SMEs.
We therefore make the following recommendation:
14. NORMAPME should build on its initial efforts to more actively promote the support
services that the ESOs, NSBs and SME representatives (including itself) can provide to
SMEs. In particular, NORMAPME should create a dedicated section on its website that
provides clear information to SMEs about the support services that are available at
European and national levels
Concerning the recommendation of the previous evaluation that NORMAPME share information
in relation to its work to track new developments affecting SMEs at the EU-level, our analyses
have revealed that it has made some progress, but that it still does not routinely document and
circulate information on the various policy-level meetings that it attends. The feedback we have
received indicates that this would be a welcome addition to the information that NORMAPME
already circulates, at least from the perspective of some stakeholders, and given that it receives
public financing to attend policy meetings on behalf of SMEs it seems only appropriate that
NORMAPME should document and circulate information about those meetings. NORMAPME’s
future depends on its ability to provide a useful service with as much added-value as possible and
we believe this is one way that it could ensure that other representatives of SMEs can gain more
benefit from its activities to assess new policy developments. We therefore make (again) the
following recommendation:
15. NORMAPME should ensure that its work to track new policy developments affecting
SMEs at the EU-level (policies, legislation, standardisation) are properly documented
and communicated to other parties so that they too can benefit from and react to this
information
The previous evaluation identified that many actors had a relatively low level of awareness of
NORMAPME in terms of the activities it carries out, the processes it employs, the positions it
develops and the results it has achieved. We therefore recommended that NORMAPME ensure
that all interested parties receive regular information on these subjects.
The questionnaire surveys conducted as part of this study have shown that 63% feel that
NORMAPME has improved its communication of information about its activities and

13
achievements to either a medium or large extent, and this demonstrates that good progress has
been made in addressing the recommendation. However, the surveys also revealed that 45% of
respondents consider themselves to be either ‘not very’ or ‘not at all’ well informed about the
services that NORMAPME provides to and on behalf of the SME community. This suggests that
NORMAPME still has some way to go in terms of informing others about its work, particularly
since we only sought feedback from named contacts with which NORMAPME and its experts
interact. We also found that only around half of the SME associations that provided feedback
receive consultation papers from NORMAPME, and as we have already stated many
commentators have (correctly) pointed out that NORMAPME’s processes for consultation and
position formation continue to be very unclear. In light of these factors we reaffirm the
importance of Recommendations 8 and 12 above.

1.2.5 Recommendations relating to the monitoring and reporting of NORMAPME’s activities

The previous evaluation made two specific recommendations in relation to NORMAPME’s
monitoring and reporting activities. The first asked NORMAPME to strengthen the regular
monitoring of its activities by increasing the extent to which it routinely collects and analyses
feedback from users, in order to build an improved understanding of the relevance and utility of
its services. The second recommendation asked the Commission and NORMAPME to ensure
that in future the contract documents and activity reports provided a more coherent and complete
account of the tasks carried out, the resources allocated to each, the outputs that have been
produced and the outcomes that have been achieved.
Based on the available evidence we can conclude that NORMAPME has made good progress in
addressing these two recommendations. As regards the regular monitoring of its activities we can
point to the following developments:
• The collection and analysis of feedback from participants in seminars that it co-organised, in
order to determine the relevance and utility of the sessions from the perspective of the SME
associations that attended
• Specific enquiries directed to EU-level SME representatives to determine their level of
satisfaction with the cooperation and with the information they obtain from NORMAPME
• A survey of recipients of its communication activities and users of its website to determine
the relevance and utility of the information and to identify areas for improvement
These examples demonstrate that NORMAPME is now doing more to understand the relevance
and utility of some aspects of its activities. We believe that this good progress can be built on by
extending the range of points at which it seeks feedback from stakeholder organisations. One
obvious example would be to issue annual requests to the contacts in its database in order to (i)
update their records and (ii) assess their level of satisfaction with the nature and extent of
interaction with NORMAPME and with the services and information it provides. We therefore
make the following recommendation:
16. NORMAPME should in future collect routine (i.e. annual) feedback from all of its
constituents to assess their satisfaction with the support services and information that it
provides
Concerning the previous recommendation that NORMAPME, together with the Commission,
strengthen the reporting of the activities, some good progress has also been made. In particular
the contracts and associated activity reports are much more coherently structured around a
defined set of actions and sub-actions and its is now much clearer as to how much resource has
been allocated and expended on each activity. Weaknesses in reporting meant that the previous
evaluation struggled to understand exactly what NORMAPME had been doing and how much

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time and money each activity had consumed, and our perspective on these matters has been much
improved this time around.
While the activities and related expenditure have been more coherently structured and more
clearly described over the past couple of years, we have still identified a large number of small
but important ways in which NORMAPME can improve its reports to the Commission.
NORMAPME provides a lot of information about its work but much of this confuses rather than
clarifies the situation, and there is ample opportunity for NORMAPME to provide clearer
accounts of what its objective were, what has been done to achieve these (i.e. activities), and how
much progress has been made (i.e. achievements), in each of the areas where it operates. In each
case NORMAPME should provide clearer assessments of the situation at the start of each action
and the situation at the end, which should further enhance the Commission’s ability to understand
and appraise performance. We also believe it would be helpful if in areas where progress has
been below expectations, NORMAPME provides a clear statement as to why it believes this has
happened and what it plans to do to address the situation. NORMAPME should also ensure that it
provides the Commission with all of the agreed outputs and deliverables. We therefore make the
following recommendation:
17. NORMAPME should improve the clarity and completeness of its reporting to the
Commission, addressing the various issues identified in this report

1.2.6 Recommendations relating to the financing of NORMAPME’s activities

The previous evaluation noted that it had identified a large number of areas for improvement, and
that NORMAPME would need time and resources to strengthen its operations. We therefore
recommended that the Commission increase the volume of financing it provided to
NORMAPME (as it already had plans to do) and that NORMAPME should ensure that some of
the additional resources were used to open its activities to a broader range of actors and to
develop the necessary systems to allow it to operate on a more professional and transparent basis
in future.
The results of this study have indicated that the Commission has indeed increased its financing
and that NORMAPME has used some of this additional resource to begin to collaborate more
actively with a broader range of actors. Several of the sub-actions undertaken by NORMAPME
in the past two years have explicitly sought to extend its reach and allow it to serve the needs of a
larger pool of SME representatives, and it has clearly made efforts to work in a more cooperative
way with other representative associations and with the standardisation bodies. We can therefore
conclude that some good progress has been made in relation to this recommendation. However,
the study has also identified that there is room for further improvement, and in particular we have
seen little evidence to suggest that NORMAPME has done much to develop its ‘systems’ to allow
it to act on a more professional and transparent basis. In many respects it has improved its
professionalism but it is not clear that this has happened in a systematic way and is in any way
ensured through its management systems. It is also the case that much of what it does and how it
goes about it is not fully transparent to other stakeholders, and that further improvements are
needed. In particular we believe that its processes for consultation, consensus building and
position formation are not transparent, and we have already restated in recommendation 8 above
the need for NORMAPME to address this issue as a matter of urgency.
In addition, we can say that while we believe that there is evidence to suggest that NORMAPME
has opened its activities to a wider range of actors, it is not very clear how many actors were
accessing its services at the point of the previous evaluation and how many are doing so today.
Therefore, while some good progress has been made it is very difficult to judge the extent of
progress because NORMAPME still lacks the necessary internal management systems to

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maintain a clear picture of the nature and extent of its interaction with other representatives of
SMEs and the impacts that its activities are generating. This was part of the reason for
recommendations 11 and 16 above, the importance of which we reaffirm.
Our overall judgement is that NORMAPME needs now to dedicate more resources to
strengthening its core management processes and putting in place systems that will permit it to
manage its activities more effectively and efficiently. We have noted that NORMAPME’s
individual staff members work across most or in some cases all of its activities, and we believe
that this is creating difficulties with time and information management, and in some cases means
that its staff are spread too thinly to perform all of their roles effectively. Ultimately we believe
that NORMAPME’s work would be strengthened if it took on fewer actions but performed each
action more effectively and with a small, dedicated team. As such, we do not believe that it is
necessary to give more funding to NORMAPME at the present time. Instead it should seek to
work in a more efficient and effective way, focusing its time and energy on those activities that
add most value to its constituents, and abandoning or curtailing activities that are less
effective/efficient in this regard. We therefore make the following recommendation:
18. NORMAPME should make further efforts to strengthen its management processes in
order to enable it to deploy its resources more effectively and efficiently

1.3 Stakeholders’ perceptions of NORMAPME

Given NORMAPME’s role and the fact that it relies so heavily on public financing, it is
important that it has the confidence and support of its stakeholders, which are principally SMEs
and their representatives, but also the Commission and the standardisation bodies. This study has
therefore sought to understand how the wider community perceives NORMAPME, and we can
state that the results are broadly positive and that the majority of stakeholder organisations
expressing an opinion consider that NORMAPME is:
• Performing a valuable role - 76% of stakeholders agreed, while only 4% disagreed
• A reliable organisation – 73% of stakeholders agreed, while only 4% disagreed
• A helpful organisation – 73% of stakeholders agreed, while only 8% disagreed
• An effective organisation – 65% of stakeholders agreed, while only 9% disagreed
• An efficient organisation – 56% of stakeholders agreed, while only 7% disagreed
Overall then, it is clear that the majority of the stakeholders consulted during this study have a
positive opinion of NORMAPME. We have noted, however, that a significant proportion of
respondents felt unable to express an opinion or gave a neutral response, signifying that many
stakeholders are not sufficiently well informed to express an opinion or believe that
NORMAPME’s performance is ‘mixed’. Not surprisingly the most positive feedback was
obtained from NORMAPME’s own experts and member organisations, which were in almost all
cases able to express an opinion that was largely positive. The standardisation bodies were most
‘neutral’ in their feedback, with the majority either not able to answer or indicating that
NORMAPME was sometimes reliable, helpful, effective, efficient and sometimes not. Other
stakeholders were also characterised by a high inability to answer and also gave a large number
of neutral or mixed responses.
Based on the evidence presented above we can conclude that NORMAPME is at present a
generally well-regarded organisation. It is notable, however, that respondents were least well
informed as to whether NORMAPME is effective and efficient. Taking all respondents into
account less than half were able to positively affirm that they consider NORMAPME to be
effective (46%) or efficient (39%), and it is clear therefore that more can be done to raise the

16
extent to which organisations outside of its own circle of experts and member associations are
able to offer an affirmative opinion. We believe that the recommendations we have made will
help it to do this.

1.4 How should NORMAPME be financed in future?

This study has investigated the options available to the Commission for the future financing of
NORMAPME, and has identified that its options are essentially limited to two types of grant:
• The first, grants for actions, are designed to support ‘on-off’ actions that support community
policy objectives. They are the most widely used mechanism through which Commission
departments allocate financing to other organisations to help support the implementation of
their policies. It is also the method that DG ENTR uses at present to co-finance the activities
carried out by NORMAPME
• The second, operating grants, are designed to finance the operating expenditure of a body
pursuing an aim of general European interest or an objective that forms part of European
Union policy. This is the form of grant currently used by DG ENTR to co-finance CEN,
CENELEC and ETSI and by other DGs to support the activities of ANEC (representing
consumer interests in standardisation) and ECOS (representing environmental interests in
standardisation)
Our assessments of the activities being carried out by NORMAPME and of the differences
between the two types of grant lead us to conclude that an operating grant would be a more
suitable financing mechanism than grants for actions. This is because the activities that the
Commission co-finances constitute NORMAPME’s core or ‘day-to-day’ business rather than a
set of ‘one-off’ actions that, once completed, will no longer receive community financing. The
steady flow of new standards and the gradual expansion of areas in which standards are
developed and used implies a need to maintain an ongoing watch on the extent to which these
might impact on SMEs, to continue to ensure that SMEs are well informed and can actively
engage with the standardisation process, and to ensure that SMEs are able to apply the standards
at a reasonable cost. An operating grant is the most suitable financing mechanism in these
circumstances because the activities are likely to be needed far into the future and represent the
‘core’ business of the entity receiving the financing.
One crucial difference between grants for actions and operating grants concerns the rule of
degressivity, which applies to the latter but not the former. Put simply, this requirement states
that if an operating grant is to be renewed annually then it should be gradually reduced, not
necessarily in terms of the financial value of the grant but in terms of the proportion of the
recipient’s operating budget that is financed by the Commission. Grants for actions are ‘one-
offs’ and so there is no expectation that they will be continued and therefore no expectation that
the Commission’s level of co-financing will reduce over time. However, an operating grant is
not a ‘one-off’ but a more enduring financial arrangement, and the degressivity rule requires that
recipient organisations gradually reduce their level of financial dependence on the Commission.
This is intended to ensure that the operating grant does not increase the beneficiary’s financial
dependence on the Commission or serve to maintain ‘artificially’ organisations that would
otherwise reduce their activities or disappear entirely without substantial and repeated
Community intervention. However, it is possible for the degressivity rule to be waived in certain
specific circumstances and there are no strict rules concerning the speed at which the financial
dependence should decrease or the extent to which it should happen. From NORMAPME’s
perspective this implies that there would be a need for it to increase its income from sources other

17
than the Commission, but the extent to which this will need to happen and over what timescale
remains open.
Our discussions with the Commission have indicated that operating grants are slightly different
than grants for actions in terms of the formal rules as to how they are managed and on the
requirements for audits, etc. However, there is no reason why the Commission would not be able
to exercise the same degree of management control and monitoring of the work under an
operating grant as it can exercise in relation to grants for actions. ANEC and ECOS, both of
which receive their financing through operating grants, are required to comply with fairly
stringent contractual and reporting procedures, and neither the amount of funding they receive
nor the activities that they are able to carry out are in any way guaranteed. If any organisation
receiving an operating grant chooses to adjust its activities in directions that the Commission
judges not to be in line with its policy then the Commission is free to no longer co-finance those
elements. As such, there are no obvious or significant negative impacts associated with a switch
to an operating grant, as viewed from the perspective of the degree of control that the
Commission can exercise.
Taking all of the issues and factors into account we would make the following recommendation:
19. In future the community financing of NORMAPME should be made through an
operating grant rather than through grants for actions. Following this change, the
Commission should ensure that it maintains a high level of supervision over the
activities receiving co-financing

1.5 How robust is NORMAPME’s business model

The final element of this study has addressed questions surrounding NORMAPME’s business
model and in particular its ability to ensure its share of co-financing and, ultimately, its financial
viability. The results have shown that NORMAPME is very highly dependent on the financial
support provided by the Commission, and that without it there is little prospect of NORMAPME
surviving based on the very limited income it is able to secure through membership fees. In this
respect it has a rather precarious business model. However, NORMAPME was created as an
organisation dedicated exclusively to the support of SMEs’ interests in the area of European
standardisation, across all sectors, and it was expected that its primary source of income would be
financing from the Commission, at least in the short term. There are limited numbers of SME
representative bodies at European level and while some of these provide a small amount of co-
financing to support NORMAPME’s activities, this amounts to less than 5% of its current
operating costs. As such, the financial support provided by the Commission continues to be vital
for NORMAPME to meet its own objectives.
NORMAPME’s limited ability to generate its own resources is in some respects inevitable.
NORMAPME was set up to address a widely accepted ‘market failure’ wherein SMEs do not
make full use of standards due to low levels of awareness and a lack of human and financial
resources, and are not sufficiently represented in all areas of the standardisation process. This
leads to a situation where the developed standards may not reflect the needs of SME users, which
in turn leads to lower use by SMEs. Ultimately, this situation is believed to adversely affect both
the competitiveness of European SMEs and their ability to comply with legislative requirements
to an extent that is socially desirable. However, because SMEs lack the human and financial
resources to engage in standardisation, and may not even be aware of standards and the benefits
that they bring, public financing has to be used to address the problem. In other words,
Commission funding is used to address an identified market failure.
Once the public financing is in place, NORMAPME’s ability to then attract private financing is
in some respects weakened. In cases where SME communities recognise the value of standards,

18
use standards and are actively engaged in the standardisation process, either individually or
through their representative associations, there is little need for NORMAPME to intervene and
little reason for SMEs to pay for its services. However, in areas where SME communities do not
recognise the value of standards, do not make full use of them, and are not engaged in the
standardisation process, there is a need for NORMAPME but no realistic way in which the SME
communities involved could be expected to pay towards its costs. As such, NORMAPME
continues to be dependent on Commission financing and it is hard to imagine how it could easily
escape from this situation.
The situation is confounded by another factor. The Commission financing requires that
NORMAPME deliver its services on an equitable basis to all European SMEs and their
representatives, rather than just to its own members. Because of this NORMAPME cannot offer
its members any kind of ‘additional’ services or support in exchange for the membership fees
because if it did those revenues would be connected to the additional services rather than to the
services provided through the Commission’s financing. Under this scenario the fees would
become ‘ineligible’ for the purposes of co-financing. So at present NORMAPME’s current
members are in effect paying a contribution to support a set of services that they would
individually be able to access for free if they were not members. And any organisation wishing
to become a member of NORMAPME has to be told that there are no clear benefits to joining,
the fee is simply a ‘gift’ to ensure that NORMAPME can continue to access financial support
from the Commission.
This is clearly not a strong ‘business model’ and it is not clear that NORMAPME can do much to
change the situation. It could and should make efforts to more openly state that this is the
situation, and make appeals to all of the beneficiaries of its services to make some form of
contribution, whether that be through membership fees or through other forms of donations.
However, SME representative bodies in general have limited resources and there are a limited
number of EU-level associations that could actually be expected to contribute. National-level
associations are unlikely to contribute as they already pay fees to other associations to represent
their interests at the EU-level. NORMAPME could of course seek to charge for some of its
services, such as training or information provision, but these are currently available for free and
as we have explained, the sections of the community most in need of support are probably least
willing or able to pay for them. Other contracted services, including projects not connected to the
co-financed activities, could also be undertaken by NORMAPME and it is possible that these
could generate some small level of ‘profit’ that NORMAPME could use to help to co-finance its
core activities, but again it is in our view unlikely that substantial levels of income could be
secured through this route.
One further option that we believe merits consideration, however, relates to the concept of
‘contributions in kind’ and the possibility that these could be used within the co-financing
arrangements should the Framework Partnership Agreement allow it. In 2009/10 NORMAPME
had four SME experts who undertook their activities without charging the €9,000 fee that
NORMAPME provides to its other experts. To our mind this means that these experts can be
considered to have made a contribution in kind of approximately €36,000 to the overall costs of
the action. This is more than double the scale of the membership fees generated by
NORMAPME in 2009, and yet it is not counted as part of the overall costs of the action. We are
aware that in the case of grants for R&D projects it is commonplace for the Commission to
accept that part of the co-financing required will come in the form of researchers’ time rather
than in cash, and we see no reason why the same logic cannot be applied to the work of these
experts. If an expert works on the action unpaid then he or she makes a contribution in kind to
the overall costs of the action, and it does not seem unreasonable for this to be considered and

19
counted as part of the co-financing generated by NORMAPME. This option would not be
applicable in the case of operating grants, but we believe that both NORMAPME and the
Commission should explore it further.
Overall, then, while further efforts can and must be made by NORMAPME to increase its
revenue streams we do not believe that it is feasible for NORMAPME to attract significant
volumes of additional funding, at least not in the short-medium term. However, NORMAPME
does need to increase its efforts in this regard, and we make the following recommendation:
20. NORMAPME should develop concrete but realistic plans to maximise its own revenues,
in order to ensure it can contribute its share of the costs of the activities.
NORMAPME’s beneficiaries should be made more aware of the financing
arrangements under which it operates and the need for them to contribute towards its
costs
As a final point, we have noted that some commentators believe that NORMAPME is ‘protected’
from market forces because it is funded almost exclusively by the Commission. While that may
be true to some extent, the Commission will only continue to fund NORMAPME’s activities if
the wider community (i) confirms that they are necessary and useful, and (ii) contributes towards
the costs of the activities. If the majority of each of the stakeholder groups in the European
standardisation area argued strongly that there is no need for NORMAPME’s services and no
value to them, and if none of the beneficiaries are prepared to contribute towards the costs, it is
not possible for the Commission to continue to finance NORMAPME. It is therefore very
important that NORMAPME has the confidence and support of the wider community and it is
why the previous evaluation – and this one – has focused its recommendations so heavily on the
need for NORMAPME to build strong collaborative relationships, strengthen its evidence base
and the focus of its actions, communicate effectively, and ultimately provide the best possible
service to the SME communities that it exists to serve. Only through these routes can it secure
their full confidence and in turn secure its own future. We wish the organisation well in its
endeavours and hope that this report will be seen as constructive and useful in that regard.

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