On 6 October 2026 the European Commission adopted the proposal for a regulation on European standardisation repealing Regulation (EU) No 1025/2012 (COM(2026) 780, procedure 2026/0307(COD)), whose text, at the time of writing, is available only in the English version (European Commission). The press release announces a faster and more inclusive system, with stricter participation obligations in favour of SMEs, civil society, academia and public authorities, without naming gender (European Commission); the text of the proposal does name it, in five recitals. The issue of women’s presence in technical standardisation, to which the news item “Women in Tech: gender equality in the world of technical standardisation” is devoted, thus enters the procedure for revising the European framework. We examine where it is placed in the text and with what legal force.
The starting point: the Gender Equality Strategy 2026-2030
By Communication COM(2026) 113 of 5 March 2026 the Commission adopted the Gender Equality Strategy 2026-2030. In the part devoted to equal employment opportunities it states that “Standards need to be inclusive of the whole EU population, including women” and that the Commission “will also encourage the European Standardisation System to adequately account for elements that have a direct impact on women and will continue promoting equal representation of women in the governance of European Standardisation Organisations” (EUR-Lex). The same passage announces support for a representative data sample of the EU population, building on the study on the inclusiveness of anthropometrics in European harmonised standards, and the full implementation of the General Product Safety Regulation as regards the gender perspective in the assessment of safety.
Existing law was already familiar with the issue, but outside the general rules on standardisation. Regulation (EU) 2023/988 on general product safety includes among the aspects of the safety assessment, in Article 6(1)(e), “the impact of gender differences on health and safety”; recital 29 adds that “standardisation activities should take that into account” and refers to the UNECE Declaration on Gender Responsive Standards (EUR-Lex). Regulation No 1025/2012, in the text published in 2012, refers to the integration of persons with disabilities and to the United Nations Convention on their rights, but contains no reference to gender (EUR-Lex). On 29 April 2026 CEN and CENELEC welcomed the Strategy, supporting the use of representative and gender-disaggregated data, for example in the areas of anthropometrics, product safety and usability (CEN-CENELEC).
The proposal: five recitals on women and gender equality
Recital 10 requires that the development of standards requested by the Commission involve, among civil society representatives, “women’s rights organisations, equality bodies and organisations representing persons with disabilities”; it adds that referenced standards should contribute to advancing “gender equality” and take into account, where relevant, “risks arising from products and services that can affect consumers differently on the basis of sex and gender”, with a reference to the 2026-2030 Strategy. Recital 23 lists “equality, in particular gender equality” among the areas on which standards have a broad societal impact. Recitals 27 and 36 extend the reference to those organisations to national standardisation bodies and to the other bodies that the Commission may designate (European Commission).
The most significant passage is recital 26: “The organisation representing the interests of consumers should contribute to ensure that standards reflect the lived experiences and needs of the entire population through the participation of equality stakeholders, in particular women or persons with disabilities, whose interests are underrepresented in the standardisation process.” The same recital specifies that the involvement of the European stakeholder organisations “does not necessarily entail any voting rights”. The proposal recognises the underrepresentation of women, but entrusts their voice to an organisation established for another purpose. The explanatory memorandum, which does identify among the shortcomings of the system “Insufficient and unbalanced stakeholder participation”, contains no reference to gender or to women.
The enacting terms: the principle of inclusiveness and the lists of stakeholders
In the articles the vocabulary changes. Article 3(1) places inclusiveness among the principles of European standardisation; paragraph 2 lists the interests that standards must take into account, “in particular economic competitiveness, innovation, societal needs, including climate and environmental sustainability, health and safety, security and economic security”, but gender equality, mentioned in recital 10, does not enter the list in Article 3. Articles 17 and 20 require the European standardisation organisations and the national standardisation bodies to enable the effective participation of all relevant stakeholders, “including SMEs, consumer organisations, environmental and social stakeholders, research and innovation stakeholders as well as public authorities”; Article 20 adds, at national level, participation “without obliging them to become members of a national standardisation body”, free of charge or “under reduced rates”. Women’s rights organisations and equality bodies do not appear in these lists.
Article 18 provides for four European stakeholder organisations, designated by the Commission by means of implementing acts “at least every four years”: one representing SMEs, one representing consumers, one representing environmental interests and one representing social interests. The criteria in Annex II contain no reference to gender (European Commission). The scheme follows the current one, in which Annex III to Regulation No 1025/2012 sets the requirements for European stakeholder organisations eligible for Union financing, currently ANEC, ECOS, ETUC and SBS (CEN-CENELEC). The representation of women remains mediated, and entrusted to a recital rather than to a rule. Article 13(1)(c) introduces a key performance indicator on “the inclusiveness of the standardisation process of European standardisation organisations for requested standards and standardisation deliverables”, but leaves to implementing acts the setting of “the target value, the frequency and the methodology” for its calculation; Article 4 requires the publication, for each requested standard, of “the list of organisations and stakeholders participating in their technical bodies” and of “the interests that those organisations and stakeholders represent”.
Standardisation bodies: action plans and voluntary commitments
On the side of the bodies, the picture is made up of voluntary commitments. CEN and CENELEC recall that in 2019, together with more than twenty national bodies, they signed the UNECE Declaration on gender-responsive standards, and that their second gender action plan was approved in January 2023 for the period 2023-2026; in October 2025 they approved the creation of an advisory committee on diversity and inclusion, to be launched in 2026 with a work programme for 2026-2028 (CEN-CENELEC). The UNECE page indicates more than eighty signatories of the Declaration (UNECE).
The same page observes that standards development is generally dominated by men and that the lack of balanced participation has exposed women and girls to health and safety risks that could have been avoided. The observation should be read together with what emerged from the OECD data on artificial intelligence and gender gaps, where the low presence of women in design teams is identified as a risk factor. At technical level, gender equality is also the subject of an international standard, ISO 53800:2024, “Guidelines for the promotion and implementation of gender equality and women’s empowerment”. Commitments on equality in the standardisation process remain self-regulation by the bodies, not legal obligations.
Critical aspects: mediated representation and undefined indicators
In our view the first limitation is one of legislative technique. Recitals guide interpretation but do not by themselves create obligations: if the reference to women’s rights organisations remains in the recitals, the bodies will have to ensure inclusiveness in general terms, not the participation of specific actors. What is missing between the 2026-2030 Strategy and the proposal is precisely the commitment to equal representation in governance: no article concerns the gender composition of the bodies of the European standardisation organisations.
The second limitation concerns data. The Strategy, and CEN and CENELEC, insist on gender-disaggregated data; Article 4 requires the publication of the organisations and interests represented, information that does not describe who sits at the technical tables. The third limitation is that the inclusiveness indicator in Article 13 is defined only as to its subject matter: whether and how it will measure women’s participation will depend on implementing acts yet to be written. Finally, the reaction of CEN and CENELEC of 6 October 2026 focuses on the independence of the system, delays, fragmentation and the sustainability of wider access to standards, and does not mention gender (CEN-CENELEC): we consider that, in a negotiation centred on speed and financial sustainability, equality aspects risk remaining on the margins.
Conclusions
The proposal now passes to the European Parliament and the Council for examination. The move from the recitals to the articles is the condition for gender equality to become a verifiable requirement. In our view the most straightforward interventions would be three: including gender equality among the interests in Article 3(2), as recital 10 already does; naming women’s rights organisations and equality bodies in the lists in Articles 17 and 20; providing that the indicator in Article 13 include data on participation by gender. The Commission will remain responsible for defining the indicators; CEN and CENELEC, whose action plan ends in 2026, for the choice of giving the new committee on diversity and inclusion measurable objectives. Equality organisations would do well to follow the negotiation and to take part from now on through the national bodies.
Author: Valentina Grazia Sapuppo
