Description:
This comparative study was written in the framework of the research project "Legal Aspects of Standardisation", carried out for the European Commission and the European Free Trade Association. It is based in large part on the monographs on national legal systems, published in two separate volumes. Although in some ways it can be read as a summary of these monographs, summarising was not our main objective. In preparing this report we had two organising themes in mind: first, to point out major tendencies and striking divergencies; second, to put national arrangements and regulatory frameworks in the context of European standardisation and Community law and policy. Inevitably, much of what we have to say about national arrangements is deprived of national political and legal contexts. For a proper understanding of the legal status of standards in the single Member States, this comparative study is no substitute for the national reports. Where this study pays more intention to some Member States than others, different motives exist. Legislators, courts and scholars in some Member States pay more attention to standards than in others. Some national standards bodies carry more weight in European standardisation than others, something we could not have ignored in some chapters. Where available and intelligible to us, we have drawn from primary documentation; however, in many cases we have relied on the rendition of the authors of the national reports.