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On 16 April 2024, the episode entitled “Viele Normen - Teure Wohnungen? - Vom Bürokratiewahnsinn im Wohnungsbau” [Numerous standards - expensive apartments? - The bureaucratic madness in housing construction] of the feature programme “SWR Story” examined the topic of standardization in the housing construction sector. Unfortunately, due to its in part very biased, one-sided and misleading statements, the programme does not make a substantial contribution to the important debate about rising costs in housing construction. In numerous instances, the feature shows a lack of thorough examination of the underlying subject.

Nevertheless, we at DIN take criticism seriously and always endeavour to examine our structures and processes critically. However, in order to achieve a more nuanced discussion of this highly relevant social topic, we would like to supplement or correct some information on the content presented below:

Balanced representation within the committees

As outlined in the programme, standards are developed jointly by experts from industry, science, the public sector and civil society. In the programme, DIN is accused of a lack of balanced representation within the committees and of allowing industry to exert too much influence; these findings are supported by alleged evidence. Here it should be understood that balanced representation within the standards committees with regard to widely recognized standardization principles is not synonymous with an equal proportion of experts from the fields of business, science, the public sector and civil society.

It is true that all relevant parties affected by the application of a standard can contribute their expertise to standardization and thus ensure the relevance and applicability of a standard. Another factor as regards to committee representation is the technical expertise required for the complexity of the issues encountered in standardization.

Moreover, decisions in standardization are usually adopted by consensus. The actual number of experts in the standardization committees who represent stakeholders from various areas of interest is not significant in itself, as this number is not decisive for the decision-making process.

The standardization principles outlined in DIN 820 are available to the public; they are the result of a standardization process involving all interested parties.

Here it is important to understand that the criticism of the perceived lack of balanced representation within the committees expressed in the programme is that the “industry” does not exist as a single entity capable of exerting influence on standardization. For the purpose of clarification: In the construction sector, stakeholders from “industry” include the entire construction industry value chain and neighbouring economic sectors. These include planners, architects, engineers, craftsmen, manufacturers of various construction products and materials, associations, service providers, trade, banks, insurance companies, suppliers, raw material suppliers, processing companies, property insurers, training organizations, operators and real estate companies.

Due to the wide range of players, who also have extremely heterogeneous interests, one can hardly refer to “industry” as a single entity with aligned interests. Rather, it is only logical and plausible that “industry” also provides the majority of experts. In contrast, individual representatives from “industry” do not dominate in the DIN committees.

In the construction industry value chain, there is a particular need for standardization where interfaces between individual parties are regulated, i.e. between property developers and planners, planners and construction companies, construction companies and product manufacturers and between product manufacturers and suppliers. The diverse range of interests of the individual parties are accompanied by the interests of science, the public sector and civil society.

When it comes to standardization topics, balanced representation within committees means, in particular, that the different perspectives within industry are represented. Conversely, the assertion that industry exerts too much influence on standardization is therefore untenable. In this regard, the supposed contradiction between DIN’s commitment to balanced representation and the actual situation does not exist.

The standardization process relies on active participation in order to ensure all interests are adequately taken into account. The critical views expressed in the programme originate at least in part from interest groups that do not want to participate in the standardization process itself, as they say they do not want to give up their neutral and independent position. This indicates an incorrect understanding of standardization work. Voicing criticism without having been actively involved is probably easier, but it is certainly not a constructive, solution-oriented approach.

The standardization process requires that the experts in the working committees prepare a draft standard. This draft standard is then published and can be commented on by the general public. This ensures that all interests are also heard in the follow-up to the actual committee work and that all those who were not directly involved in the drafting of a committee standard can also contribute.

We have already taken the criticism from representatives of the housing sector, who believe that the committees in the DIN Standards Committee Building and Civil Engineering (NABau) are not properly composed, as an opportunity to review the composition. We were unable to identify any significant deficiencies. We discussed the results in the Special Presidial Committee “Construction and buildings” which is again made up of all key stakeholders. Measures for further improvement were derived from the results of the analysis.

Transparency as regards to representation within the committees

We take the issue of transparency very seriously at DIN. Together with our stakeholders, we are constantly discussing how we can meet the demands for greater transparency. The declared goal is to avoid additional bureaucracy, to uphold the voluntary nature of standards and to ensure compliance with all applicable regulations at national, European and international level.

During the programme, an assertion is made explicitly several times that the composition of the committees as regards the interested parties is a secret and that there is no transparency in this respect. What is not mentioned, however, is that the composition at standards committee level is published on the DIN website and can be viewed there by anyone. Contrary to what is claimed in the programme, the proportion represented by industry at committee level is therefore neither secret nor is it a surprise. This is because standardization is a form of self-regulation by industry, which means that this group also has the largest part in the development of standards.

The programme also attempts to convey the impression that DIN is hindering transparency by means of non-disclosure agreements. It is true that every expert is free to report on their involvement in standardization committees and the structures, processes and procedures there. Standardization relies on this kind of publicity, as it is the only way to get people who are not involved in standardization interested in standardization work.

It is also true that agreements with the experts ensure that they are not influenced externally during the course of an active standardization process. It is therefore not a “witness protection programme”, as claimed in the programme, but rather serves to ensure complete focus on the content of standardization work.

Experts have the right not to be named publicly and personally. Any interests, provided they are technically suitable, can be put forward either through direct involvement in the standardization process or subsequently as part of the public participation process. Any desire for secrecy on the part of DIN is therefore untenable. Experts are free to report on their work once standardization procedures have been completed.

Financing

The accusation that large companies can buy their way in to DIN is false. It is true that the efficient, privately organized standardization system is financed primarily through the sale of standards, i.e. the application of standards ensures that their development is financed.

In addition, there are low-threshold participation fees for experts who can use the infrastructure provided by DIN (e.g. meeting and conference rooms) for committee meetings. Particularly for small and medium size enterprises, financial support is available towards these fees from DIN or via funding programmes such as WIPANO.

Furthermore, specific provision has been made for consumer interests, which would otherwise not be heard, such that they are represented at an institutional level in the standardization process by the independent Consumer Council, which has been established specifically for this purpose.

Small enterprises are usually represented in standardization by their respective associations. Special financing structures created for this purpose at DIN provide direct incentives for associations and their members to get involved, to bundle interests, and contribute to standardization. 

Increasing requirements in standards: The requirements placed on construction in terms of safety, accessibility and climate protection by legislators in the form of new laws and regulations are increasing. In addition, construction projects are becoming increasingly complex and often reflect society's expectations of attractive living space. This change is also reflected in standards and specifications.

Although DIN recognizes the challenges for affordable living space and actively supports corresponding activities such as “Building Type E” [an initiative of the Federal Chamber of German Architects that allows greater freedom/ease/experimentation in the construction sector] or the distinction between minimum requirements and more stringent requirements; contrary to what is presented in the programme, the objective is not to develop construction standards that make construction particularly cost-effective. Rather, standards represent the state of the art, which allows further development and innovation and thus makes a sustainable contribution to our prosperity.

Standards are recommendations on how legal or social requirements for living space can be implemented but are not mandatory. The application of standards is voluntary. Initiatives such as those of the construction company Eitel interviewed in the programme are therefore to be welcomed – at best, the knowledge gained can be incorporated into the ongoing standardization process.

A broad social and political discourse is needed in order to rebalance the different requirements, e.g. in terms of climate protection, safety, consumer protection and economic efficiency, and thus reduce construction costs. This can enable effective cost reductions in some areas but must be actively promoted by those involved in standardization.

DIN’s role

DIN coordinates the standardization process as a project manager. The initiative for the development and revision of standards always originates from the interested parties. DIN does not influence the content of the standards. This means construction standards can of course be adapted or withdrawn by the interested parties if there is a definite need. Standardization relies on participation - all interested parties are cordially invited to get involved in standardization and to shape the content of standards together - interested parties make an important contribution to society through their involvement.  

Standards as cost-cutters

Standardization is presented exclusively as a cost driver in the SWR programme. The opposite is true; the targeted application of standards and specifications saves costs. Standards serve to rationalize and facilitate planning and construction processes by establishing common rules.

While many of the legal requirements in the German construction industry are federally regulated and sometimes differ considerably between the sixteen German federal states, national and often also European standards reduce the complexity in the construction industry.

Legislators have always had the power to refer to standards in legislation or not; in the past, they have failed to fulfil this task adequately. Unfortunately, the various German federal state-specific regulations that make building complicated and expensive are not addressed at any point in the SWR programme. Politicians should focus on this point in particular in order to simplify and standardize regulations. Standards provide the best basis for this.

In addition, an assessment of the Special Presidial Committee “Construction and buildings” (SPB) on the subject of construction costs can be found here. The SPB is made up of high-ranking representatives of the relevant players in the construction industry, such as the German federal government, German states, municipalities, Chambers of Commerce, science, industry and consumers.

Further information on this topic can be found in the FAQ of the DIN Standards Committee Building and Civil Engineering.