From December 18, 2024 to February 16, 2025, SAC/TC286 (standardization principles and methods) solicited public input on the draft revision of Rules of Standardization Activities—Part 3: Guidelines for Referencing Standards in Regulations (national standard number: GB/T 20000.3). This update aims to refine the integration of standards into legal and regulatory frameworks, aligning with the goals outlined in the National Standardization Development Outline.
Key Objectives of the Revision
The revised standard seeks to enhance regulatory clarity and usability by establishing clear methodologies for referencing standards in laws and regulations. It supports two critical systems emphasized in China’s standardization strategy: the Regulation Referencing Standards System and the Standards Supporting Policy Implementation System. By providing structured guidance, the update intends to streamline compliance and enforcement processes while addressing emerging challenges in standardization practices.
Current Challenges Driving the Update
China’s existing framework, governed by GB/T 20000.3—2014, aligns with ISO/IEC guidelines by categorizing standard references as direct (specific) or indirect (general). However, evolving regulatory needs and theoretical advancements have exposed gaps:
- Scope of referenced standards: The 2017 Standardization Law redefined the roles of mandatory and recommended standards while recognizing association standards. This raises questions about which regulatory tiers (e.g., national laws vs. local regulations) may reference mandatory or voluntary standards and whether association standards can be legally cited.
- Ambiguity in enforcement: Current regulations often broadly reference entire categories of standards without specifying exact documents. While this approach suits high-level legislation, the lack of precise lists in supplementary guidelines creates confusion for enforcement agencies, hindering consistent implementation.
- Procedural gaps: China lacks a formalized process for incorporating standards into regulations. Uncertainties persist around when and how drafters should reference standards, leading to inefficiencies and inconsistencies in legislative practices.
Global Benchmarks Informing the Revision
The revised standard draws on international best practices, including:
- ISO/IEC: Use and Citation of Standards in Public Policy and Standards and Public Policy Toolkit.
- EU: New Approach for Technical Harmonization and Standards and methodologies for legislative citation.
- The United States: National Technology Transfer and Advancement Act and guidelines for integrating voluntary consensus standards into federal regulations.
These references inform principles for selecting, citing, and expressing standards within regulatory texts, ensuring alignment with global norms.
Next Steps and Stakeholder Engagement
Once finalized, the updated GB/T 20000.3 will harmonize with other standards in the GB/T 20000 series, offering comprehensive guidance for China’s standardization ecosystem. SAC/TC286 encourages stakeholders—particularly international partners such as EU regulators and industry groups—to submit feedback during the public consultation period. Their input will help shape a robust framework that balances domestic priorities with global interoperability.
Foreign stakeholders are advised to notice that this revision marks a critical step in modernizing China’s regulatory infrastructure, fostering clearer compliance pathways and reinforcing the role of standards in policy implementation.
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