British Standards Institution                                                                                                                              CBM0020

Written evidence from the British Standards Institution (BSI)


Introduction to BSI

  1. This consultation response is provided by BSI in its capacity as the UK’s National Standards Body (NSB). BSI is appointed to this role by government to oversee the development and management of national standards by UK stakeholders, to represent the UK at the leading international and European regional standards organisations and to provide the infrastructure for UK experts to participate in international standards setting activity.
  2. BSI operates in accordance with a Memorandum of Understanding with the UK Government and has a public function in support of the UK economy and society.  We bring together over 13,500 stakeholders (including government, businesses and consumers) to facilitate the development of “what good looks like”.  BSI is sponsored by the Department for Business, Energy & Industrial Strategy.
  3. BSI is the UK member of ISO (the International Organization for Standardization) and the IEC (International Electrotechnical Commission).  We facilitate access for UK experts to international standards making, ensuring the maximum influence for UK stakeholders.  BSI also provides support to DCMS in government’s membership of the ITU (International Telecommunication Union).  Where standards are required on a regional basis, BSI is a member of the European Standards Organizations (CEN and CENELEC) and the European Telecommunications Standards Institute (ETSI).
  4. Standards offer an agile, collaborative and cost-effective complement or alternative to regulation. They are a versatile, proportionate and low-burden way of addressing a wide-range of policy agendas, either directly or in support of regulation and legislation
  5. In this response, we refer specifically to stakeholder-led, consensus based, technology agnostic, patent free standards such as the national standards (BS), PAS and Flex standards maintained by BSI for use by government, industry and consumers. Bringing together businesses, consumers, regulators and other interested stakeholders to develop new standards through a consensus approach can lead to better policy outcomes than regulation. 
  6. BSI has a track record both in leading global consensus and in helping form early-stage international consensus.  Our existing standards tools, particularly the fast-track PAS and Flex standards, help the UK to influence global outcomes.

Standards to support net zero / CBAMs

  1. BSI already has a range of standards that can be used to help organisations transition to net zero, including in areas such as greenhouse gas management, energy transition, biodiversity and sustainable finance.  Standards are already supporting the deployment of renewable energy technology and the reduction of emissions. The UK Government’s Faraday Battery Challenge includes a standards programme led by BSI that will support the rapid scale up of new manufacturing capability.
  2. BSI’s response to the inquiry is not to comment on the merits or scope of CBAMs, but to stress the role of standards in any effective CBAM and to offer BSI’s support, as the UK’s National Standards Body, in the development of the necessary standards. As the UK’s representative in the international standards system, BSI can do this on a global scale.
  3. BSI is committed to using standards to achieve climate objectives.  Standards will play a critical role in accelerating the transition to net zero.  This is why we facilitated the London Declaration, a commitment by ISO signed in September 2021, for all members to actively consider climate change in the development and revision of all international standards and to facilitate the involvement of civil society and those most vulnerable to climate change.  The London Declaration was referenced in the government’s Net Zero strategy published on 19th October.
  4. In the absence of global regulation, international consensus building will be essential in achieving net zero.  The international standards system provides an existing mechanism to do this, bringing together nearly 170 countries to agree best practice on a wide range of challenging international issues. 
  5. ISO also offers a valuable link to the real economy, with over 24,000 standards covering almost all aspects of technology, manufacturing and management practice.  The UK participates in more international (ISO) standards committees than any other country so is well placed to lead the development of the new standards that will be required to achieve net zero. 
  6. Any CBAM will require assessment of the carbon footprint of products.  International standards will be needed to provide common terminologies and methodologies.  Standards will also provide best practice to help manufacturers to reduce their carbon footprint and assess their carbon performance.  
  7. There is a risk that a multitude of methodologies will make it impossible to compare the emissions of product.  A single standard, developed through the established international standards development process, would avoid this.
  8. BSI is working with the Taskforce for Scaling Voluntary Carbon Markets (TSVCM) and Race to Zero.  There are many more initiatives.  It will be essential to create consistency in terminologies and methodologies.  BSI can facilitate this across the various programmes, including any future carbon border adjustment mechanisms.
  9. BSI would be pleased to discuss how standards can support CBAMs, and climate issues more generally, with the Committee.

Further Information

BSI would be pleased to provide further information or to discuss the content of this submission.

Please contact:



Steve Brunige

Head of Industry & Government Engagement
British Standards Institution

October 2021