These standards should at their core have transparency and flexibility, the modular nature of these standards supports these two goals.
The overarching standard to balance between too much flexibility and risking that the EPBD framework becomes a non-sense. At the same time the ERP LOT standards for products could risk sub-optimization.
The main question is how confident are we that the standards won’t be misused by mistake or on purpose?
Summary of the presentation of Jaap Hogeling, ISSO, Chair CENTC 371 Program Committee on EPBD from “EPBD: where are we now & what to improve with the review?” on October 6th in Brussels by John Woollett.