The geopolitics of digital standards: China’s role in standard-setting organisations

Executive summary

Standards for digital technologies are all around us, enabling devices to interact with each other, allowing us to connect to mobile networks, and facilitating the exchange of information. By providing rules or guidelines for the development and functioning of technologies, products, and services, standards foster interoperability and enable safety and quality of service. This report provides an overview of the digital standardisation ecosystem and explores China’s role within this ecosystem.

Why standards matter

In addition to their technical functions, standards have economic, social, and (geo)political implications. They support innovation, economic growth, and competitiveness, and facilitate international trade by enabling companies to enter new markets and helping avoid discrepancies between trade partners. In addition, standards can help societies take advantage of the opportunities offered by digital technologies, including when it comes to advancing sustainable development and devising responses to global challenges. 

When embedded into technologies put to different uses, standards can provide a broader context for promoting – or abusing – human rights and freedoms. For instance, standards related to internet protocols can pose privacy risks if they do not embed sufficient protections to ensure the confidentiality of communications and the security of data. 

Although standards are usually looked at from a technical and economic perspective, they have always had a political dimension, particularly due to their potential to help achieve certain policy objectives, from promoting innovation and protecting consumer rights, to safeguarding critical infrastructures and protecting national security. Given the growing technological competition between nations, standards are gaining more attention in the geopolitical context. If a country’s actors can influence standards in strategic industries, that country could obtain a significant advantage on the international stage. This realisation has led to calls for strengthened cooperation between partners on standardisation-related matters, as illustrated by the adoption of a Framework for G7 Collaboration on Digital Technical Standards and the establishment of a working group on technology standards in the context of the EU-US Trade and Technology Council (TTC).

A complex and dynamic digital standardisation ecosystem

At the international level, digital standards are developed in a multitude of spaces. Formal standards development organisations (SDOs) – the International Electrotechnical Commission (IEC), the International Organization for Standardization (ISO), and the International Telecommunication Union (ITU) – are complemented by quasi-formal organisations – such as the Institute of Electrical and Electronics Engineers (IEEE), the 3rd Generation Partnership Project (3GPP), and the Internet Engineering Task Force (IETF) – and a wide range of industry forums and consortia. The large number of organisations, as well as the diversity of membership structures, working methods, and rules and procedures governing the development of standards make the standardisation ecosystem a complex one. 

State and non-state actors participate in SDOs driven by technical, economic, and/or (geo)political interests. Many tend to focus their attention on the IEC, ISO, and ITU because standards developed within these organisations are generally understood as being relevant in the context of the Agreement on Technical Barriers to Trade adopted at the World Trade Organization (WTO). The agreement calls on countries to base their regulations on international standards as a way to prevent unnecessary barriers to trade.

Beyond its complexity, the standardisation landscape is also highly dynamic, mirroring the interests of key actors and the competition environment in certain industries. While for several decades Western actors (in particular the USA and some European countries) used to take the lead in the development of international standards, the picture started changing in the 1990s and 2000s, as Asian actors (Japan, the Republic of Korea, and China) became increasingly prominent in economic and technological spheres. The growing presence of Asian actors was also coupled with shifts in industry participation, as some of the more traditional actors reduced their involvement in key SDOs, while other, newer actors started playing a more prominent role. 

Generally speaking, the SDOs function by well-established rules and are able to adapt to the changing environment in which they operate. But they are also faced with various challenges. For instance, they are called upon to encourage more diversity within their membership and bridge the standardisation gap between developed and developing countries. Other concerns relate to the speed at which standards are developed; the challenges that may appear if groups of actors – be they entities from the same country, alliances of countries, etc. – attempt to dominate the work; and the tendency of some actors to engage in forum shopping, sometimes leading to the duplication of work across several organisations. 

Mindful of such challenges, SDOs are constantly exploring modalities for more efficient and effective processes, while maintaining the quality and integrity of their work. And while questions have emerged on whether new rules are needed to enable SDOs to cope with some of these challenges, it is important to acknowledge that actors always learn to play by the rules in ways that are advantageous to them.

China’s approach towards standardisation

Standards play an important role in the context of China’s ambitions for economic and technological leadership at the global level. The government sees standards as essential in driving innovation, industrial development, and economic growth, as well as in improving the country’s competitiveness on international markets. 

Overall, China’s approach towards standardisation is characterised by several key elements:

• The standardisation strategy is aligned with the broader ‘two markets, two resources’ approach (i.e. protect the domestic market, while integrating it into the international one), and focuses on two key goals: strengthening the national standardisation system and advancing engagement in international standards development processes.
• Over the past decade, China’s standardisation system has undergone a series of changes, and is now described as ‘market-driven, government-led’. State entities usually oversee the development of national and sector standards, with most of the work being carried out by the private sector (which is actively encouraged to contribute its expertise to the process). Opportunities were also created for foreign-invested companies to contribute to standardisation processes, although it appears that some barriers continue to exist in this regard.
• China’s overall policy framework for standardisation is shaped by the new standardisation law (in effect since 2018), as well as a series of policy priorities set periodically by entities such as the State Council, the Standardization Administration of China (SAC), and the Ministry of Industry and Information Technology (MIIT). Moreover, standardisation objectives are closely connected with industrial and economic policies. For instance, Made in China 2025 (MiC 2025) sees standards as important elements in improving the quality of Chinese products (thus increasing their competitiveness on regional and global markets). The 14th Five-Year Plan for National Economic and Social Development also connects standards with broader technology-related goals. For example, it talks about ‘improving’ security standards as a way to strengthen network security protection. 
• China’s strategy of ‘opening up’ its standardisation system rests on three pillars: (1) active participation in international standardisation processes, (2) strengthened bilateral and multilateral standards cooperation, and (3) harmonisation of Chinese and international standards, through (a) the internationalisation of Chinese standards and technologies and (b) the transposition of international standards at the national level. 
• China’s growing involvement in SDOs is a result of planned and concentrated efforts, and is driven by one essential goal: The country wants to shift from being a consumer of international standards to becoming a producer and ‘exporter’ of standards. This goal is also pursued through regional and multilateral initiatives such as the Belt and Road Initiative (BRI) and BRICS (Brazil, the Russian Federation, India, China, and South Africa). 

Implications of China’s growing involvement in international standardisation 

China has emerged as a global economic power, so it is natural that it seeks to have a more prominent voice in international standard-setting. Chinese actors are now much more present in SDOs than they were before 2000; not only in terms of people attending meetings, but also in terms of active contribution, drafting of proposals, and leadership roles within technical groups. This growing involvement comes with both opportunities and challenges. 

On the one hand, it is a win for standardisation processes and an indication that China wants to be part of the global system of standards, rather than decouple itself from it. It could also have positive consequences for global interoperability and the safety of products and services, as well as strengthen the acceptance and adoption of international standards at a national level, thus reducing market barriers for foreign companies. The fact that Chinese actors become more familiar with the principles of international standardisation (e.g. transparency, consensus, and relevance) could translate into improvements in the national standardisation system. 

On the other hand, the growing involvement of Chinese actors in international standard-setting means more competition, posing a challenge to established standard powers (be they countries or companies). There is also a concern that China is trying to reshape the current international standards environment to one that is more state-driven. This is a legitimate concern, but China may only succeed in advancing such a model if there is not enough opposition from other actors. Some proposals advanced by Chinese actors in SDOs – such as the New IP proposal (intended to design a new protocol system for the internet) and a proposal related to standardising the application of facial recognition in visual surveillance systems – have generated concerns that Chinese actors may try to misuse standardisation as a vehicle to promote technologies that pose challenges to democratic values and human rights.

As these and similar issues continue to fuel discussions, the debate remains open on whether China is or could be dominating SDOs in a way that allows it to dictate how these organisations work or the standards they produce. But it is likely that Chinese actors will continue to strengthen their engagement in international standardisation, in particular when it comes to shaping standards related to advanced and emerging technologies.

Recommendations for maintaining the integrity of the standardisation ecosystem

In the debate on whether SDOs need to change their rules to cope with the challenges of the dynamic standardisation ecosystem and the emergence of new powerful actors, our report argues that a more holistic approach is needed, one focused on maintaining the overall integrity of the ecosystem. The recommendations we outline for governments, participants in international standard-setting, and SDOs themselves cover several key issues, as now summarised.

Governments

• Developing standardisation strategies with priorities and goals for the domestic standards system and the engagement in international processes. 
• Encouraging and strengthening the participation of domestic actors (governmental bodies, technical community, private sector, academia, civil society) in SDOs, through funding, awareness-raising, capacity development, and fostering cooperation and coordination, where possible. 
• Bridging the gap between the different communities, allowing them to better understand each other’s  interests and positions on standardisation matters (e.g. technical considerations, economic aspects, human rights perspectives).
• Creating frameworks for cooperation and exchange of information with other countries and their actors within SDOs. 

SDOs and participants in SDOs

• Ensuring a holistic approach to the debates and decisions on standard proposals, where technical, economic, human rights, and (geo)political considerations are given appropriate weight. 
• Fostering more diversity in standardisation processes and facilitating the participation of actors less represented. 
• Ensuring that the rules and procedures governing standardisation work are adhered to.
• Fostering strengthened cooperation within the standardisation ecosystem.
• Enabling clearer communication about standardisation processes and engagement opportunities, as a way to increase transparency and enhance information accessibility. 

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Introduction 

Standards, although invisible, shape the increasingly digital world in which we live, from the protocols that make the internet work to the 3G, 4G, and now 5G standards that enable the functioning of mobile networks and devices. Their main role is to describe how technologies, products, and services are developed and function. As such, they enable interoperability and contribute to ensuring safety and quality of service. But standards are not only about technology; they also have economic, social, and (geo)political implications. We explore these implications in the first section of this report, as we explain why standards matter for the wider society, beyond those who develop them. 

Digital standards¹The term digital standards refers to standards for digital technologies throughout this report. are set in a multitude of organisations and forums, nationally, regionally, and globally. At the international level, the digital standardisation ecosystem is highly complex, with a large number of organisations and forums with different membership structures, rules, and procedures. This complexity also comes with challenges, both for the organisations themselves and those participating in the work. We unpack some of these challenges in the second section, after we provide an overview of the standardisation landscape. Five organisations are in the focus of this report: the three key formal SDOs²Throughout this report, the term SDOs refers to international standards development organisations, unless otherwise mentioned. – the IEC, ISO, and ITU with its Telecommunication Standardization Sector (ITU-T), as well as 3GPP and the IETF. Other organisations and forums – such as IEEE and the European Telecommunications Standards Institute (ETSI) – are mentioned occasionally.

For historical and economic reasons, the West – notably the USA and some European countries – took the lead in the research and development (R&D) of digital technologies, particularly the internet and its first applications. This resulted in some decades of predominant participation of actors from these countries in SDOs, and their influence over the development of international digital standards. However, the growing relevance of Asian tech actors has brought changes to the international standardisation landscape, first with the participation of Japan and the Republic of Korea, and more recently China. 

China became more involved in international standard-setting when it joined the WTO in 2001. Reflecting the country’s rapid technological development, Chinese actors have constantly increased their participation in SDOs, in particular the IEC, ISO, and ITU. This did not receive much attention until 2020 when China proposed that ITU take up work on designing a new internet protocol (IP). The now-famous New IP proposal made the headlines and triggered heated debates on China’s participation and influence in standard-setting. As China’s involvement became ‘the elephant in the room’ in many subsequent discussions on international standardisation, it has not always been easy to separate hype from reality.

But what drives China’s engagement in international standardisation? What does this engagement mean for China, other countries, and the broader standardisation ecosystem? In trying to provide some answers to these and similar questions, we start by looking at the country’s national standardisation system and the role that digital standards play in the context of the overall economic and industrial strategies and policies. We then explore China’s approach to international engagement and cooperation on standards-related issues, look at the participation of Chinese actors in key SDOs, and discuss opportunities and challenges stemming from this participation. As we attempt to shed more light on the realities of Chinese participation in international standard-setting, we look at a few case studies of such participation.

Our report argues that the digital standardisation ecosystem is both complex and dynamic. It generally functions by well-established rules, although at times some pressure may be exercised over these rules as new dynamics emerge. Maintaining the integrity and health of this ecosystem is essential, but actions in this direction should not come in response to the participation of one actor or another. Instead, they should look at the broader picture and focus on issues such as diversity and due process. We end the report by highlighting a set of recommendations in this regard.

Methodology

This report is the result of research work carried out between June and November 2021. The methodological approach behind it is a combination of desk research and expert interviews. Desk research encompassed primary and secondary sources. Among the former are rules and procedures governing the activity of the SDOs the report focuses on, as well as membership information, activity reports, and, in some cases, documents discussed within these organisations (in as much as we were able to access such documents, considering that in many cases access to them is restricted). Primary sources also included relevant policy documents published by China, and relevant statements and declarations issued in the framework of bilateral and multilateral cooperation forums. Secondary sources include mostly academic papers, policy briefs, and opinion pieces published by academic institutions and think tanks. 

Most of the statistical data provided in the report is the result of our research; in all instances, we provide information on the sources we used to collect the data. 

The second methodological tool was expert interviews. Between July and October 2021, we conducted interviews with 27 policy and technology experts with a wide range of roles and backgrounds: staff and leadership of SDOs, personnel of country missions to the UN in Geneva, staff of international technical and intergovernmental organisations, industry experts, academics, and researchers. Most of the interviewees have participated in international standardisation processes. All interviews were run under the condition of anonymity. Some of the interviewees clarified that they were presenting their own views and not those of their organisations. One limitation has been our inability – despite attempts – to interview Chinese actors who participate in international standard-setting.

What are standards and why do they matter?

From coinage in the Roman Empire and uniform brick sizes in Ancient Egypt (Barrios Villarreal, 2018) to today’s IP, standards have been around for centuries. They are commonly accepted benchmarks that provide technical specifications or define processes. They tell us how to do something, and as such foster a coordinated approach. In addition to providing the framework for product development, standards aim to ensure the transparent and safe application of various technologies. 

Standards have acquired significant importance in a broad range of areas, such as quality management, aviation, health and food safety, labour conditions, and ethical and environmental areas. So far, ISO alone has published more than 22,000 international standards. Some of the most widely used ones include the ISO management system standards, standards for international security management (ISO/IEC 27001), and occupational health and safety standards (ISO 45000 family) (ISO, no date-a).

Technical and economic implications

The modern, interconnected society we live in would not function without standards. In the mobile phone alone, for instance, there are hundreds of standards. In the past, digital standards mainly related to creating technology and devices. Today, the shift is towards standards for connecting devices (e.g. mobile phones and the internet of things (IoT)) and for connecting people to digital devices and services. 

From a technical point of view, standards provide a common language that facilitates interoperability, allowing technologies to interact with each other. They ensure that devices and applications are built using the same rules and communication protocols, and that they can exchange data in compatible formats. The lack of interoperability poses both economic and societal challenges. One example is when users of Mac OS and Windows (operating systems developed by Apple and Microsoft) could not exchange files (Stango, 2004).

In addition to interoperability, ensuring quality of service and quality of experience have also been key goals of standardisation processes. Around the mid-1990s, security became another important concern, and, more recently, issues of trust and values have also come into focus. 

Looked at from an economic perspective, standards support innovation and help develop and sustain competitiveness. The value of standards is maximised when they are developed and adopted at the international level (rather than nationally or regionally). International standards facilitate international trade by opening the door for companies to new markets and helping avoid discrepancies between trade partners. This is important not only for big players, but also for smaller economies, which have a strong interest in ensuring that there are well-functioning global standards that allow their companies to export everywhere, under as fair competition terms as possible. 

Standards can also contribute to a country’s gross domestic product (GDP) and labour productivity. For instance, standardisation is said to save the German economy €17 billion per year, while in France the average gains are estimated at €5 billion per year. In the UK, 28.4% of the annual GDP growth (€9 billion) can be attributed to standards (Wahlster and Winterhalter, 2020).

When combined with intellectual property, there are several additional benefits that standards can bring to companies. Many technologies that are essential parts of a standard are patented (the so-called standard-essential patents – SEPs). SDOs generally require companies that participate in standardisation work to make their SEPs broadly available under fair, reasonable, and non-discriminatory (FRAND) terms. This is meant to ensure that patent owners cannot prevent anyone from using the standard, but they can request royalties from SEPs, so patent users have to pay to implement the standard (Pohlmann and Blind, 2020). Such licensing fees can generate significant revenues for the patent owner. But this mechanism can also create dependencies that companies supplying much of the technology behind a standard could exploit. If a standard is broadly used at the international level, companies whose technologies are not part of the standard would typically need to invest significant resources in adapting their products to maintain market relevance (Voo and Creemers, 2021). 

Standards also have the potential to support the development of effective responses to global challenges (e.g. climate change) and the promotion of economic, social, and environmental sustainability (ISO, 2018). Governments and businesses alike are becoming increasingly aware that international standards can help societies take advantage of the opportunities offered by digitalisation, foster the spread of new and advanced technologies sustainably, and contribute to advancing the sustainable development goals (SDGs). As participants in the 2021 International Standards Summit for People, Planet and Prosperity noted, digital technologies that rely on international standards to function safely and efficiently ‘can ensure a sustainable, equitable, and prosperous future’ (ITU, 2021).

Standards and regulations

Standards are, in general, voluntary. Companies may or may not adhere to standards, depending on their goals and interests, as well as on the content of the standards themselves. But there are also instances when standards are linked to government-led regulations. Standards can serve as a basis for regulation (e.g. in the USA) or can be used as regulatory tools themselves (e.g. in China, where some standards are mandatory). In the EU, standards are sometimes embedded into regulations. Some refer to existing standards to be followed as a way to demonstrate compliance with the regulation, while others mandate European standard-setting bodies to develop certain standards. Oftentimes standards are referred to in regulations as a way to avoid the regulations themselves becoming too detailed or descriptive. 

Standards are also useful in ensuring quality for new technologies that are not yet covered by regulations. In addition, they may also help shape the evolution of the market, for instance towards more competition, thus complementing regulations. 

Standards competition

It is important to note that the mere adoption of a standard by an SDO does not represent the ultimate outcome. What matters is market uptake, i.e. the extent to which a standard is used across the industry. While some standards become highly successful, others never make it to the market. 

In addition, it is not uncommon to have multiple standards covering the same issue. As a saying within the IETF community goes, ‘The beauty of standards is that there are multiple to choose from.’ Here, too, success is driven by market forces, competition, and consumer choice. Sometimes similar standards function in parallel; other times only one standard wins. 

Standards and human rights

Standards used to be seen largely as a technical issue with economic implications. But as digital technologies have become pervasive and embedded into all aspects of society, their relevance for human rights and core values and principles have started to gain increasing attention.

Technology is only neutral until it is used. The same applies to standards. They can either directly impact human rights, or provide a broader context for promoting – or abusing – human rights. For example, standards related to facial recognition technology (FRT) can have implications for privacy, the right to non-discrimination, and other human rights. Standards related to internet protocols can also generate privacy risks, for instance by not embedding sufficient protections to ensure the confidentiality of communications or the security of data (Cooper et al., 2013). 

Adding a human rights approach to standards development processes is increasingly seen as essential in ensuring that standards, intentionally or not, do not embed structural risks to human rights. One way to achieve this is to foster convergence between human rights processes and standardisation ones, as recently outlined in a Human Rights Council (HRC) resolution (HRC, 2021).³Adopted on 13 July 2021, the resolution requests the Office of the High Commissioner to convene consultations on the relationships between human rights and technical standard-setting processes for new and emerging technologies, and to submit a report to the HRC. Encouraging and supporting the participation of civil society groups in standardisation work is another way.

Politics of standardisation

Traditionally, developing and applying international standards has largely been about companies competing over influence on the global market. But competitiveness is not the only issue at stake. For state entities and companies involved in standardisation processes, setting standards is – in most cases – a balancing act between various other interests: maintaining the health of the innovation ecosystem, protecting consumer rights and interests, and ensuring safe development of technologies (and related products and services) (Ding, 2020). 

There are also other policy objectives that standards can help achieve. They can improve a range of government services, for instance, by enabling uniform electronic medical records or allowing exchange between various government systems while ensuring adequate levels of privacy and security of data. Standards can also help protect national security and safeguard critical infrastructure from malicious cyberattacks, which ultimately is related to protecting national sovereignty (ITU, 2010). 

Although standards development processes are usually seen as largely technical, they have always had a political dimension. This is because they involve ‘choices and trade-offs which may imply economic or social consequences, or reflect the interests of the stakeholders involved’ (Voo and Creemers, 2021). The link between geopolitics and standards is not new either. It was reflected, for example, in the coordination of a European voting bloc at the 1992 World Administrative Radio Conference, to exert influence over the adoption of mobile telecommunication standards (Sung, 1992). 

This (geo)political dimension of standards and standardisation processes has become more obvious in recent years, against the backdrop of intensifying technological competition between nations. There is a realisation that, if a country’s actors – through participation in standard-setting and international cooperation – can influence standards in strategic industries, that country would likely obtain a significant advantage on the international stage. Beyond the economic and geopolitical considerations, there is also growing attention to the implications that standards could have, directly or indirectly, on core values and human rights. 

Standards have started to be mentioned in bilateral and multilateral intergovernmental frameworks, such as the G7, Quad (Australia, India, Japan, and the USA), and the EU-US Trade and Technology Council (TTC) (Table 1). This reflects the growing awareness of the importance of standards and their economic and geopolitical dimensions. And it could result in strengthened cooperation between partners in the long term (e.g. national delegations participating in international SDOs would support each other more). In fact, recent agreements clearly highlight cooperation on standard-related matters as an objective. But challenges may appear also, as the partners would need to understand what standards they are aligned and could work together on, given that sometimes they may have different economic and industrial interests.

Table 1. Recent references to standards in bilateral and multilateral intergovernmental forums.

Forum	Who is involved	Key elements
Quad Leaders’ Summit, March 2021	Australia, India, Japan, USA	Quad leaders agreed to establish a Critical and Emerging Technology Working Group to facilitate cooperation on international standards and innovative technologies (Quad, 2021a). The group will facilitate coordination on standards development, including between national standards bodies and working with a broad range of partners (Quad, 2021b).
G7 Digital and Technology Ministers’ meeting, April 2021	Canada, France, Germany, Italy, Japan, UK, USA	Ministers highlighted support for ‘industry-led, inclusive, multistakeholder approaches for the development of standards’, and committed to international collaboration within the G7 and with like-minded partners to ensure that the development of digital standards supports core values. They also expressed ‘opposition to any government-imposed approaches that fundamentally seek to reshape the digital technical standards ecosystem’. The Framework for G7 Collaboration on Digital Technical Standards adopted at the meeting highlighted several areas of cooperation: *Identifying shared interests in the development of digital standards and promoting inclusive and multistakeholder engagement in standards development processes.  *Working with stakeholders to promote more inclusive development and deployment of internet protocols, and to track emerging digital standards that may have a wider societal impact. *Supporting stakeholders and SDOs to strengthen and uphold integrity in the development of standards. *Supporting the participation of civil society and other under-represented actors in standard discussions. *Supporting coordination between SDOs to avoid unnecessary duplication.  *Supporting the inclusion, where appropriate, of international principles for digital technologies in standardisation processes (G7, 2021a).
G7 Summit, June 2021	Canada, France, Germany, Italy, Japan, UK, USA	G7 leaders expressed support for industry-led inclusive multistakeholder approaches to standard-setting, in line with core values and principles. They committed to strengthening coordination with regard to engagement with, and appointments to, SDOs, as well as to sharing information and best practices and to supporting multistakeholder participation in standard-setting (G7, 2021b).
EU-US Summit, June 2021	EU, USA	A high-level EU-US TTC was established, one of its goals being to cooperate on compatible and international standards development (in the framework of a dedicated working group to focus on standards related to artificial intelligence (AI), IoT, and other emerging technologies). Also highlighted was an intention to explore the possibility of developing a new research initiative on biotechnology and genomics, with a view to setting common standards (EU-US, 2021a).
EU-US TTC inaugural meeting, September 2021	EU, USA	The creation of a Working Group 1 on technology standards was announced to foster coordination and cooperation in standards for critical and emerging technologies.  Both parties highlighted support for the development of standards in line with core values, and expressed an intention to defend their common interests in international standards activities. Sharing information regarding technical proposals and fostering participation in SDOs for civil society, startups, and small and medium-sized enterprises (SMEs) were also emphasised as goals (EU-US, 2021b).
G20 Leaders Summit, October 2021	Argentina, Australia, Brazil, Canada, China, France, Germany, India, Indonesia, Italy, Japan, the Republic of Korea, Mexico, Russia, Saudi Arabia, South Africa, Turkey, UK, USA, EU	G20 leaders committed to reinforcing their actions and international cooperation towards digital transformation, including through the use of consensus-based international standards (G20, 2021).

Implications of the growing political attention to standards

The fact that standards have gained increased attention at a political level⁴This is particularly the case for those governmental branches (e.g. ministries of foreign affairs) that used to pay little to no attention to standards. comes with both positive implications and challenges. If standards and standardisation work are more visible among policymakers, this can lead to having more resources allocated to standardisation processes, and, therefore, more participation. In some SDOs, standardisation can also become more efficient (i.e. a standard is adopted faster) if there is consensus at the political level on the matter at hand. 
But if standardisation processes become overly politicised, this could slow them down. It could also mean that discussions and decisions on adopting or not adopting some standards could be influenced more by geopolitical interests and considerations, and less by the technical merits of the proposals. In this context, maintaining the integrity of SDOs is essential. As highlighted by one interviewee, these organisations should not be seen as ‘malleable tools whose processes and rules can be bent by any one actor or groups of actors to meet their political interests’.⁵Interview with a standardisation expert, September 2021. Trying to advance one’s policy goals in the context of standardisation work should only be acceptable if this is done openly and transparently, and within the rules of the game. The results of standardisation processes should be based more on the merit of the work itself, and less on political considerations. 

There is also a risk that politicisation might attract ‘unnecessary attention’ for standards development and limit the possible innovation that standards may bring. Political interventions may block innovation if they become too intrusive.
Other challenges come from the fact that political actors do not always have a good understanding of technical issues. Bridging the gap between political actors and the technical community is key. Some SDOs have themselves embarked on a journey to raise more awareness among policymakers on standards. The IETF, for instance, which has traditionally attracted mostly technical communities, has put in place some initiatives inviting policymakers to their meetings and showcasing the connection between technology and policy. 

The digital standardisation ecosystem

Where are standards developed?

Modern standardisation is said to have emerged in the mid-nineteenth century as the globalisation trend gained momentum (OECD/ISO, 2016). The growing interdependence and expansion of global trade called for the removal of barriers to the exchange of information, goods, and capital. The first major breakthrough in this regard came in Paris in 1865 at the International Telegraph Conference. 

One outcome of the conference was the establishment of the International Telegraph Union – which later evolved into the International Telecommunication Union (ITU) – whose goal was to ‘standardise telegraphy equipment, set uniform operating instructions, and lay down common international tariff and accounting rules’ (ITU, 2015). ITU was therefore created to address the interoperability of telegraph networks, which was until then challenged by diverse national systems as well as a ‘plethora of bilateral and multilateral agreements aimed at setting common international telegraph equipment standards, regulations and agreements on tariffs’ (ITU, 2015). 

In 1906, the first international organisation dedicated solely to standardisation was created under the name of the International Electrotechnical Commission (IEC). The IEC deals specifically with international standards on electrical and electronic technologies. In 1930, a general international standardisation body –  the International Federation of the National Standardizing Associations (ISA) was founded. In 1947, the International Organization for Standardization (ISO) was established as its successor (OECD/ISO, 2016).

Today, the standardisation ecosystem for digital technologies includes a multitude of entities, ranging from formal and quasi-formal SDOs to various industry forums and consortia. 

Formal SDOs are generally recognised by national or international authorities. They have well-established rules and procedures for developing and approving standards, most often through consensus-based approaches (ITU, 2014). 

At the national level, these organisations usually bring together experts from various stakeholder groups to develop standards. Examples include the British Standards Institution (BSI), the German Institute for Standardisation (DIN), and the French Standardisation Association (AFNOR). Notably different from these is the American National Standards Institute (ANSI), which does not develop standards itself, but oversees their development by accredited standards bodies. 

At the EU level, there are three recognised SDOs: the European Committee for Standardization (CEN), the European Committee for Electrotechnical Standardization (CENELEC), and ETSI (European Parliament and Council, 2012). Similar regional standards bodies include the Pacific Area Standards Congress (PASC) and the African Organisation for Standardisation (ARSO). At the international level, the IEC, ISO, and ITU are the key SDOs developing standards for digital technologies. Within ITU, the Telecommunication Standardization Sector (ITU-T) focuses on the development of international technical standards for information and communication technologies (ICTs) (known as ITU-T recommendations), although some standardisation work – related to radiocommunication systems – is carried out by the Radiocommunication Sector (ITU-R) as well.⁶ITU has three specialised Sectors: ITU-R contributes to the global management of the radio frequency spectrum and satellite orbit resources and develops standards for radiocommunicationsystems; ITU-T develops standards for information and communication technologies; the Development Sector (ITU-D) focuses on promoting access to telecommunications.

Quasi-formal SDOs are largely similar to formal SDOs in how they are organised and how they work, except that they are not formally recognised by national or supra-national authorities. IEEE, the IETF, and the World Wide Web Consortium (W3C) are typically included in this category (Teubner et al., 2021), as is 3GPP, which develops mobile telecom standards. 

Industry forums and consortia are usually formed with a narrow focus. Private sector entities driven by similar interests get together to develop specific standards catering to those interests. Some are even established to develop standards for a single specific technology. Industry consortia are often seen as ‘less bureaucratic and more efficient in reacting to market needs’ (Pohlmann, 2014). Examples include the Broadband Forum (develops broadband network specifications); the DECT Forum (developed the Digital Enhanced Cordless Telecommunications – DECT standard); the LoRa Alliance (worked on the LoRaWan specification – a low power, wide area networking protocol); the MEF Forum ( develops standards for overlay digital services); and the Organization for the Advancement of Structured Information Standards (OASIS).⁷The portal consortiuminfo.org offers a comprehensive overview of the multitude of industry consortia involved in standardisation work.

The large number of organisations and forums involved in the development of standards for digital technologies makes the international standardisation system a complex one. This complexity is also reflected by the diversity of membership structures and working methods of SDOs. For some organisations, their membership is composed of national SDOs (e.g. the IEC and ISO), but they also facilitate the indirect participation of private entities, through the national SDOs. Others have a more diverse membership. One example is ITU. Although it is an intergovernmental organisation at its core, direct participation in standards development work is open to both state and non-state entities. The IETF does not have a formal membership structure, with everyone interested welcome to participate in the work. Each SDO has its procedures and rules governing standard-developing processes; one element they have in common is that they strive to work based on consensus (although voting is sometimes also involved, in particular in the last stages of approving a standard). See Annex 1 for details on membership structures and standards development processes within six SDOs. 

Standards in the WTO framework: The TBT Agreement

Standards play an important role in international trade, probably best illustrated by the fact that they are included in one key World Trade Organization (WTO) agreement – the Agreement on Technical Barriers to Trade (TBT Agreement). 

With the goal to ensure that standards do not create unnecessary barriers to trade, the agreement outlines a series of obligations for member states, as well as a series of principles for the development of standards. 

Member states are required to do the following:

• Ensure that technical regulations
• Use relevant international standards, or relevant parts of them, as a basis for technical regulations, except when such standards would be an ineffective or inappropriate way to fulfil the legitimate objectives pursued.
• Participate, within the limits of their resources, in the development of international standards by appropriate international standardising bodies.
• Notify other members of proposed technical regulations that are not in accordance with relevant international standards and that may significantly affect trade.

The Agreement also contains a Code of Good Practice for the Preparation, Adoption and Application of Standards. The Code is open to acceptance by any standards body within the territory of member states, as well as to regional bodies that include participants from WTO members (WTO, 1994). Among other provisions, the Code encourages standards bodies to operate transparently, ensure nondiscrimination towards imported products, and align national standards with international standards whenever possible (DeVaux, 2000).

In 2000, to complement the TBT Agreement, the TBT Committee adopted a set of Principles for the Development of International Standards, Guides and Recommendations. The document highlights six principles that international standards bodies are invited to follow:

• Transparency. All essential information regarding work programmes, proposals for standards, guides and recommendations under consideration and on the final results should be made easily accessible to all interested parties. Procedures should be established so that adequate time and opportunities are provided for written comments.
• Openness. Membership should be open on a non-discriminatory basis to relevant bodies. Any interested member should be provided with meaningful opportunities to participate at all stages of standards development.
• Impartiality and consensus. Members should have meaningful opportunities to contribute to the elaboration of an international standard so that the standards development process will not give privilege to, or favour the interests of, a particular supplier/s, country/ies, or region/s. Consensus procedures should be established that seek to take into account the views of all parties concerned and to reconcile any conflicting arguments.
• Effectiveness and relevance. To prevent unnecessary trade barriers, international standards need to be relevant and to effectively respond to regulatory and market needs, as well as scientific and technological developments in various countries. They should not distort the global market, have adverse effects on fair competition, or stifle innovation and technological development. In addition, they should not give preference to the characteristics or requirements of specific countries or regions when different needs or interests exist in other countries or regions.
• Coherence. To avoid the development of conflicting international standards, SDOs are encouraged to avoid duplication of, or overlap with, the work of each other. 
• Development dimension. Constraints on developing countries to effectively participate in standards development should be taken into consideration in the standards development process. Tangible ways of facilitating developing countries’ participation in international standards development should be sought. (WTO, no date-b) 
  

Although it highlights obligations for member states regarding the integration of international standards into regulations, the TBT Agreement does not clarify what is actually meant by international standards. And although it refers to ‘international standardising bodies’, it only notes that an international body is one ‘whose membership is open to the relevant bodies of at least all member states’. This creates challenges for regulators when deciding what international standards to use as a basis for their technical regulations, and which international bodies to take part in. It can also generate regulatory divergence: ‘What might be considered an international standardising body or an international standard by a WTO member might not be considered as such by another, creating more barriers to trade’ (Barrios Villarreal, 2018). 

Despite this lack of clarity, standards developed by the IEC, ISO, and ITU are generally understood as relevant in the context of the TBT Agreement, because (a) the three organisations meet the agreement’s definition of an international body, and (b) the standards they develop are consistent with the principles for the development of international standards adopted by the TBT Committee. 

As these SDOs themselves note, ‘policy makers can have confidence when using IEC, ISO or ITU international standards that they are fulfilling their WTO obligations, and not creating unnecessary obstacles to international trade’ (IEC/ISO/ITU, no date). This helps explain the interest of multiple actors in participating in these three organisations, since technologies that comply with standards developed there are practically prevented from being barred in international trade.

A dynamic standardisation landscape

State and non-state actors participate in international standard-setting largely driven by economic and political interests. As such, the standardisation landscape – in particular within the IEC, ISO, and ITU – is dynamic, always in flux, mirroring the interests of the key actors and the competition landscape in certain industries. 

The broader picture

Let’s take ITU-T as an example. In the 1980s, the USA, the UK, and Germany were among the most active contributors. In the 1990s, Japan and the Republic of Korea started becoming more involved. And in the early 2000s, China emerged on the scene and has since gradually increased its participation to the point that today it has the second-largest number of members (after the USA). 

The growing involvement of Asian actors – also valid for the IEC and ISO – reflects the region’s increasing technological and economic power. 

Some Middle East countries have reportedly also started to become more engaged in standardisation work, in particular in areas related to the IoT and smart cities. But some countries have never been very active in SDOs. This is particularly the case for countries in Latin America and Africa to some extent. Although some of them participate in the work, they tend to do so mostly from an observer’s perspective, and be standard-takers more than standard-developers. 

Shifts in industry participation

As new technologies evolve, the interest in creating related standards drives the participation of certain actors in key SDOs. Once these standards are developed, the industry may become less interested in standardisation work. But the cycle continues with new technologies and new players getting involved in standardisation. To illustrate, in the mid-1990s, large companies like Cisco and Nortel and vendors like Microsoft and Sun were very active. In the mid-2000s, mobile companies – such as Ericsson, Nokia, and Motorola – started becoming more involved. Some of these companies are now still active contributors (e.g. Ericsson and Nokia), others less so. And new actors continually find their way into standardisation work. Huawei, for instance, is a relatively new player on the mobile network standardisation scene, compared to Ericsson and Nokia. When it comes to the application layer, companies like Apple, Amazon, Facebook, and Google are also stepping up their participation in certain standardisation areas.

As many of our interviewees noted, a portion of the Western industry that used to be highly involved in some SDOs (in particular ITU-T) has toned down its participation over the past two decades. For instance, telecom operators like BT and AT&T or vendors like Siemens now participate less than in the past. This has happened for several reasons, such as the deregulation and privatisation of the telecom industry, the shifting of focus on new technologies, and the emergence of a plethora of industry consortia working on specific digital standards.⁸Interviews with SDO participants, July–October 2021. Previously, if industry players wanted a new standard, they would typically try to get it approved at a major SDO. Now, many prefer to turn to industry consortia (or create new ones altogether) focused on specific technologies, where processes are faster, there is no need to ‘negotiate’ with governments, and the results are more predictable (as these consortia are usually formed by like-minded companies driven by similar interests).

Filling in voids

The fact that the standardisation landscape is in continuous flux means that voids can be created when some actors reduce their involvement. These voids offer an opportunity for other actors to demonstrate strength: ‘Voids would always be desirable and pursued. Whoever has the interests, motivation, time, and competency to take up more activities, they are going to do it.’⁹Interview with an SDO staff member, September 2021. 

One concern about such scenarios is that they enable more compact groups to fill in the space left by others, thus leading to less diversity. Less diversity means fewer opportunities for discussions and more chances for proposals aligned with the interests of certain actors to gain traction and go forward. 

Challenges that SDOs face

There are ongoing debates on whether and how SDOs should adjust their standards development processes to make them more effective and efficient. But what are the challenges SDOs face that need to be addressed?

Speed of developing standards

There are arguments that the speed at which international standards are developed needs to improve. A typical cycle for a standard to be developed and approved is somewhere between nine months (which rarely happens) and three/four years. The challenge, it is argued, is that the longer it takes to develop a standard, the more chances there are for the standard to be outpaced by technological progress. Speed is one of the reasons why some of the industry prefers to turn to private consortia to develop certain standards. 

But the SDOs say that being more agile and more responsive to current realities is a permanent objective for them. They are constantly looking at how to offer more efficient and effective processes, while maintaining the quality and integrity of the work. Achieving this balance is key. Speed cannot come at the expense of the quality of work and the need to achieve consensus in the process.¹⁰Interviews with staff members of SDOs, July–October 2021. 

One thing that could help improve the overall efficiency within SDOs is the behaviour of participants. If standards’ proponents were more willing to put their proposals to rest once it becomes obvious that there is little chance of generating consensus, this would save time and allow more attention to be paid to other proposals. Similarly, abandoning work on proposals that generate little interest or have lost relevance because of technological progress¹¹Some SDOs have procedures that cover such cases. At 3GPP, for instance, a work item is automatically considered by a technical specification group for stopping if no progress is achieved in a given period of time (usually six months). could be encouraged more. Instead of spending time on approving something that would likely end up not being used by the industry, that same time could be allocated to more relevant proposals, with overall efficiency gains.¹²Interviews with SDO participants, July–October 2021. 

Dominating players

Some SDO participants note that challenges may appear when groups of actors – be they entities from the same country, alliances of countries, etc. – attempt to dominate the work in a way that makes other participants feel like they cannot make their voice heard, or that there is little room to have balanced and open discussions leading to a consensus. While it is natural for some delegations to be larger than others, or for some actors to be more vocal than others, what matters is to maintain the integrity of the standards development processes, and to ensure that participants can interact freely and contribute to the work on an equal basis.¹³Interviews with SDO participants, July–October 2021.

Forum shopping and duplication of work

One of the most frequently mentioned challenges within the standardisation ecosystem is the tendency of some actors to engage in forum shopping. This is not something new. Different actors have always tried to identify the places where their standard proposals stand a better chance of being approved. This becomes more complex when the scenario involves different entities putting forward similar proposals in different SDOs. ‘Entities go into one SDO and they start some work there. Then their competitor goes to another SDO and starts doing similar work. Then they both complain that there is duplication of work and they try to block the work of one another. Those who have sufficient resources to be active in different places would sometimes play this game.’¹⁴Interview with an SDO staff member, August 2021.

SDOs have tried to develop mechanisms to limit forum shopping tendencies, for instance by strengthening consensus rules within the organisations or fostering more cooperation between them.

What makes forum shopping easier is that there is no such thing as a general agreement on which SDO should deal with which types of standards. There seems to be a form of a tacit understanding between key SDOs that one organisation retains change control for something they originate. If a certain standard is developed within one organisation, any changes to that standard should ideally be discussed with the same organisation. And if another organisation wishes to take up related work (e.g. extend the scope of the standard), it would be expected to liaise with the organisation where the standard was originally developed. So while there is an expectation, for instance, that IP-related issues are dealt with at the IETF, nothing is stopping any one actor from proposing related work somewhere else. 

Diversity

When it comes to participation in international standard-setting, diversity is another often-cited challenge. This issue takes multiple forms. On the one hand, it is about the need to attract more participation from developing countries, and to have more stakeholder and gender diversity among participants. For instance, the limited (if at all) participation of civil society stakeholders in standardisation is increasingly being noticed, and some efforts are being made to address this. The European Commission, for example, is offering funds to support the participation of experts representing consumer interests. SMEs also often find it challenging to contribute to standardisation work, given the resources (time, money, expertise) that need to be allocated in this regard.

On the other hand, diversity is sometimes challenged by the complexity of the system. At ITU-T, for instance – where there are 11 SGs, 33 working parties (WPs), and many more areas of work (called ‘questions’) – even the delegations of developed countries have difficulty in following all the work. 

Addressing diversity challenges is not only a matter of making standardisation processes more inclusive. It is also a way to limit the likelihood that some actors or groups of actors could advance their proposals faster and with fewer debates. The more actors at the table, the more debates there are.

Do SDOs need to change their rules? 

This question appears more and more often when discussions are held about the challenges encountered within the standardisation ecosystem. Several ideas are brought up for potential new rules that some SDOs could introduce. One such idea is to introduce a due diligence process to be performed by SDO staff. Standard proposals would be checked against a set of key criteria (e.g. compliance with human rights) and only allowed to go through the standardisation process if they meet these criteria. Other suggestions include the introduction of rules to limit the number of proposals a single actor can put forward within a technical group,¹⁵SDOs use different names for the technical groups where standard proposals are developed and discussed. For instance, ITU-T has study groups (SGs) and working parties (WPs). At the IEC and ISO, there are technical committees (TCs), subcommittees (SCs), and working groups (WGs). 3GPP has technical specification groups (TSGs), while the IETF and IEEE have WGs. See Annex 1 for details. or to limit the number of participants that any one actor or national delegation can have at meetings of technical groups. These would be in response to concerns that some actors submit significantly more proposals than others (in some cases of questionable quality), or that sometimes meetings are dominated by certain actors.¹⁶Interviews with SDO participants and standardisation experts, July–October 2021. 

Looking at the broader picture, however, it becomes rather clear that, even if the rules are changed, actors would learn to play by those rules in a way that is advantageous to them. As one interviewee pointed out, ‘It is a misconceived idea that you have to change the rules to make the system better. No matter what rules you have, actors will always learn how to play within those rules. It is a power game where people come and use the rules to advance their proposals or to try to stop proposals they don’t support. The bottom line is “be ready to play the game”.’¹⁷Interview with an SDO staff member, August 2021.

Other aspects also need to be considered. Introducing new rules would require changes in SDOs’ procedures. And this could come with challenges participants may not be ready to address. As one interviewee asked: ‘Do we really want to open this up? Once we start discussing new procedures, many more ideas may come up, and we might not like the end results.’¹⁸Interview with a staff member of a technical organisation, July 2021. Moreover, for any new rules to bring improvements to the standardisation ecosystem, they would have to be introduced across the spectrum of organisations. For instance, if the goal is to ensure that standardisation processes embed certain values and principles, then all SDOs would have to live up to those values. Otherwise, practices like forum shopping and duplication of work would only be exacerbated.

China’s role in shaping digital standards

Over the past few decades, China has focused on becoming a global technological power, with multiple policies, strategies, and plans having been issued towards this goal. The results are already noticeable, as the country is moving away from being a manufacturing hub to becoming an innovation-driven economy capable of developing and exporting high-end technology. 

With this growing technological power also came growing attention to technical standardisation. China sees standards as a key element in driving innovation, industrial development, and economic growth, as well as in facilitating economic and trade exchanges (SAC, 2020b). Standards are also considered essential for improving China’s competitiveness on the global market (State Council, 2021), as they contribute to enhancing the quality of Chinese products (State Council, 2015). The government understood that the previous growth model (based on cheap products) is no longer suitable, so a different approach was needed, one focussed on high-end, value-added manufacturing. 

China’s approach towards standardisation is generally aligned with the country’s broader ‘go out’ strategy dedicated to advancing integration into the international economic system. At the core of this strategy is the ‘two markets, two resources’ principle, highlighting two connected goals: (1) protection of the domestic market, and (2) integration into the international market (De la Bruyere and Picarsic, 2020).

If standards tended to be used largely as a tool to protect national industries from external competition, the opening-up of the Chinese economy has brought a shift in the country’s approach to standardisation. The government is now paying more attention to aligning Chinese and international standards, both by integrating such standards domestically and by increasing the country’s involvement in international standard-setting. Standards are also becoming the subject of a growing number of bilateral and multilateral agreements concluded and pursued by the government (Seaman, 2020).

National standardisation system

Given the importance that China attaches to standardisation, standards feature prominently across a wide range of national policies. Not only does the country have dedicated standardisation strategies and plans, but standards also reverberate in industrial, economic, and technological strategies. 

China’s standardisation system has undergone a series of changes over the past two decades. From a clearly state-driven process (where the government developed standards and the industry had to follow them), standard-setting can now be described as hybrid (Seaman, 2020). While the state maintains overall oversight, the system is not entirely state-controlled, allowing market-driven action (Rühlig, 2020). Companies are encouraged to be key players in standard-setting and contribute their expertise to these processes, within the existing framework. And many do so, trying to make sure that their contributions are aligned both with their interests and with the goals and objectives set by the government.

The Chinese approach to standardisation – with a relatively large number of mandatory standards and the state having an oversight/steering role over the system – is different from EU and US approaches. In the USA, standards have – most of the time – a voluntary nature and are developed by a multitude of private-sector-led bodies. ANSI functions as a private organisation, whose role is limited to coordinating the overall standards system, for instance through accrediting standard-setting bodies. Government agencies are encouraged to participate in standards development processes (ANSI, no date). At the EU level, the development of European standards happens at CEN, CENELEC, and ETSI, in the framework of what could be described as a public-private partnership.¹⁹At ETSI, the industry can participate directly in standardisation work, together with governmental organisations, research entities, and other actors. CEN/CENELEC membership includes national standardisation bodies; the industry and other actors can contribute through the national bodies. While largely voluntary, European standards can also be referenced in regulations (as a preferred way or as a mandatory requirement to comply with specific rules), and there are instances when the European Commission can request standardisation bodies to develop certain standards to support EU legislation and policies (Your Europe, no date).

The 2018 standardisation reform

The Chinese standardisation system used to be highly complex, with multiple standards – most of them mandatory – developed at the level of ministries and other bodies under the State Council, research institutes, local authorities, industry groups, and individual companies. The standardisation reform – initiated by the State Council and implemented through a new standardisation law in force since 2018 (National People’s Congress, 2017) – has sought to simplify the landscape (Table 2), rethink the role of state entities in standardisation processes, and reduce the number of mandatory standards. 

There are now five types of standards, grouped into two broad categories:

• State-led standards (developed under the coordination of state bodies)
• Market-issued standards (developed by the industry)

Table 2. China’s standardisation system before and after the reform.

The standardisation system is coordinated by SAC, which functions within the State Administration for Market Regulation. SAC sets general standardisation policies/strategies, issues national standards, and maintains some level of overall supervision on the development of association standards (which, however, do not need to receive SAC approval). 

National standards and sector standards are usually developed within TCs (and related SCs and WGs).²⁰There are over 1,300 technical committees and subcommittees working on standards. Some of them mirror similar committees within international SDOs such as ISO and IEC. Details can be found at https://std.samr.gov.cn/org/orgTcQuery (available in Chinese only). These include experts from both the public and the private sectors (e.g. government agencies, research institutes, companies, industry associations, academia), and are usually overseen either directly by SAC or by relevant ministries or other state bodies (there are also cases of TCs overseen by industry bodies). For instance, TC485 on communications falls under the guidance of MIIT, while its secretariat is ensured by the China Communications Standards Association. TC260 on information security is directly subordinated to SAC, but it is chaired by the Cyberspace Administration of China. See Annex 2 for a detailed overview of the standardisation system (types of standards and how they are developed).

Standards are subject to review within five years of adoption. The review processes aim to determine whether standards still meet the needs of economic and social development and technological progress; if this is no longer the case, standards are revised or withdrawn. 

The implementation of the new standardisation framework has led to what could be described as a partial liberalisation of the standards system. On the one hand, the overall number of mandatory standards has decreased. In September 2019, the National Center of Standards Evaluation (NCSE) reported that many of the sector/industry and local standards that were mandatory before 2018 had been abolished or converted into voluntary standards, and the number of mandatory national standards was also reduced (NCSE, 2019). On the other hand, the role of the private sector has increased. The introduction of association standards has created more space for the industry to develop standards that respond to market needs and support innovation.²¹There is, however, criticism that the large number of both association standards and associations that develop such standards generates confusion, duplications, and sometimes contradictions in standards, and, overall, a fragmented standards environment (Kamensky, 2020a). Also, when national and sector standards are developed within TCs, most of the work is reportedly driven by experts from the private sector, while state institutions maintain the formal, overall leadership.²²Interviews with researchers and standardisation experts, July–October 2021. 

The government, however, still has a steering role when it comes to the standardisation framework. As one interviewee noted, ‘The system cannot be changed directly from a state-driven one to a purely market-driven one; the government is not in the habit of completely giving up control.’ ²³Interview with a standardisation expert, October 2021. For instance, beyond the role of state bodies in the development of national and sector standards, the government can also influence the degree to which some association or enterprise standards are used or not (e.g. it can encourage certain standards over others in the framework of public procurement processes). Moreover, standards can sometimes become part of the regulatory framework after adoption. Even if not originally adopted as mandatory, some standards can be referenced in certain regulations that require compliance. 

The participation of foreign companies in standardisation processes has also been somewhat simplified, and most of the TCs are open to participation from such companies. A set of guidelines issued by SAC, the National Development and Reform Commission (NDRC), and the Ministry of Commerce (2017) state that foreign-invested enterprises are entitled to the same treatment as domestic ones when it comes to participating in standardisation work. This principle was later codified in the Foreign Investment Law (adopted in 2019, and in force from 2020), which introduced an obligation for the state to guarantee that foreign-funded enterprises could equally participate in standard-setting (the law also clarified that the mandatory national standards apply to foreign-funded companies) (National People’s Congress, 2019). 

In practice, however, there seem to be certain TCs and related WGs where the participation of foreign companies remains challenging. For instance, members of the US-China Business Council reported that two WGs within TC260 on information security do not allow foreign companies to participate. While there are no formal policies against such participation, their applications to participate ‘remain in perpetual limbo’ (Kamensky, 2020a). As one interviewee noted, ‘Whether and to what extent foreign companies can contribute to standards-setting very much depends on whether China considers that the respective companies can bring something to the table.’²⁴Interview with a researcher, August 2021.

Advancing the standardisation reform 

Since the entry into force of the new standardisation law in 2018, advancing the standardisation reform has been a key goal highlighted across several policy documents. After reviewing some of the most recent such documents – SAC’s standardisation priorities for 2020 and 2021 (SAC, 2020a; 2021a), and the Outline for National Standardisation Development issued by the State Council (2021) – we have identified several core elements of this continuous reform process: 

• Promoting a more open national standards development process, and optimising the ‘market-driven, government-led’ standardisation system. This relates not only to advancing the involvement of Chinese companies in the standardisation work, but also ensuring the participation of foreign-funded enterprises. 
• Continuing to simplify the system of mandatory national standards (e.g. ensure it is of appropriate size and implement a coordinated approach for the development of such standards). 
• Ensuring that national standards are effectively implemented (through strengthening the supervision of standards implementation), and improving the evaluation and revision of national standards (e.g. through the introduction of external expert evaluation mechanisms).
• Improving the system of sector standards and reducing the number of such standards (e.g. by expanding the coverage of individual standards).
• Increasing the number of association standards and encouraging the private sector to develop high-quality, original standards. Facilitating the integration of standards developed by the industry into national and sector standards.
• Encouraging enterprises to develop higher-quality standards and continuing to implement the ‘forerunner’ system (a system designed to identify the best enterprise standards).
• Preventing the use of standards for protectionist goals (e.g. in the case of local standards) and trade monopolies.
• Improving the cooperation between different technical standardisation organisations and promoting cross-industry standardisation. Better cooperation mechanisms would help address problems related to overlaps and redundancy in standards, and misuse of resources.
• Strengthening capacities for standards development, including through establishing new standards laboratories, research institutes, and innovation bases; integrating standardisation into the curricula of higher education institutions; building training programmes for standardisation professionals; and providing incentives for engagement in standardisation work.

Standardisation priorities for digital technologies

China has made it a clear goal to increase the global competitiveness of its technological sector. This is highlighted in several policies and plans adopted in recent years. Improving the quality of products, advancing research in core technologies, and strengthening innovation capabilities in key areas are among the objectives set within plans such as MiC 2025 and the 14th Five-Year Plan for National Economic and Social Development. Standardisation plays an important role within these documents, with standards being seen as key in meeting the demands of market competitiveness and innovation. 

Besides being referred to in industry and technology plans and strategies, China’s priorities related to setting standards for digital technologies are also highlighted in various standardisation documents, such as the annual standardisation priorities set by SAC and MIIT, and the State Council’s Outline for National Standardisation Development from 2021. As the following overview shows, the goal is to develop or strengthen standards covering a vast array of technologies, from communication networks and the IoT, to AI, quantum computing, and biotechnology. 

Made in China 2025

MiC 2025 is the country’s manufacturing strategy. One of the plan’s strategic tasks is to transform China’s manufacturing sector and increase its competitiveness, so that by 2049 the country becomes ‘the leader among the world’s manufacturing powers’ and has competitive advantages in major manufacturing areas, including advanced technologies.

In addition to advancing intelligent manufacturing, one of the underlying elements of MiC 2025 is the development of strategic industries. Such industries include integrated circuits, communication equipment (including 5G, quantum computing, and neural networks), industrial software (including industrial IoT), robotics, biotechnology, and new materials. 

The plan sees standards as important elements in improving the quality of products and in ‘meeting the demands of markets and innovation’. It highlights objectives to promote technology standards and to carry out standardisation activities in the area of intelligent manufacturing. 

Environmental issues are also covered in the plan, which commits support for enterprises that implement green standards and overall green strategies for their production and management processes. The plan also talks about ‘making national security equipment adopt advanced civilian standards and promoting the application of military standards in civilian areas’ (State Council, 2015).

SAC and MIIT priorities for 2020 and 2021

In their standardisation priorities for 2020 and 2021, SAC and MIIT have highlighted a wide range of digital technologies to focus on when it comes to standardisation. This reflects the country’s overall goal of excelling across the broad spectrum of digital technologies. Focus areas for standardisation include the following:

• High-end and intelligent manufacturing, covering areas such as digital twins, industrial robots, and additive manufacturing.
• IoT and related areas such as smart cities, smart homes, smart vehicles, and unmanned aerial vehicles.
• Cybersecurity, i.e. the security of networks, products, and services; the protection of critical information infrastructures; data security; and protection of personal information.
• Information infrastructure/networks. In addition to highlighting plans to strengthen standardisation in areas such as 5G and next-generation mobile networks, high-speed broadband, cloud computing, and next-generation internet, reference is also made to developing standards for IPv6+ (possibly an advanced version of the IP version 6), and ‘fostering standardisation in the field of new information infrastructure’.
• Industrial internet.
• Digital services, such as online education, smart tourism, digital health, and e-commerce.
• Advanced and emerging technologies in areas such as AI, big data, blockchain, quantum computing, and virtual and augmented reality.
• New materials, rare earths, and advanced semiconductor materials. 
• Environmental issues, including standards for new energy generation, energy internet, and energy efficiency (MIIT, 2021a; SAC, 2020a, 2021a).

14th Five-Year Plan for National Economic and Social Development

Unveiled in March 2021, the 14th Five-Year Plan for National Economic and Social Development has technology at its core. The plan – which includes long-term objectives for the next 15 years – aims to implement a dual circulation strategy that will boost the domestic market without abandoning the export strategy, and make China more technologically self-sufficient (National People’s Congress, 2021). 

In line with China’s ambition for tech supremacy, the plan sets the goal of achieving economic, scientific, and technological strength, allowing the country to become one of the most innovative nations in the world by 2035. The plan lists several ‘strategic emerging industries’ whose development and growth will be supported, including a new generation of IT, biotechnology, quantum computing, AI, future networks, genetic technology, and new materials. Also envisioned is support for R&D of innovative applications of key digital technologies in areas such as high-end chips and general-purpose processors, AI algorithms, sensors, cloud computing systems, big data, and network security. The country will also invest more in areas such as mathematics and basic science, which it sees as underpinning current and future technologies.

The plan includes several references to standards. For instance, within the overall goal of creating a good digital ecosystem, improving (cyber)security standards is seen as an important element towards strengthening the protection of network security. Strengthening the standards system for intelligent manufacturing, developing standards for new infrastructure, and establishing a uniform system of standards, certifications, and labels for green products (such as energy-saving household appliances) are also highlighted among the objectives.

Outline for National Standardisation Development, 2021

Issued in October 2021 by the State Council, the Outline for National Standardisation Development establishes goals and objectives dedicated to ‘promoting the development of standardisation’ in China. The document reiterates the role of standardisation in improving national competitiveness, and highlights the importance of advancing the ‘market-driven, government-led’ standardisation system. 

When it comes to digital technologies, the outline sets a series of objectives related to researching and developing standards covering a broad range of areas:

• Advanced technologies: AI, quantum information, and biotechnology. 
• High-end and intelligent manufacturing.
• IoT and related areas: intelligent/connected vehicles and robots, unmanned vehicles.
• Digital services, such as e-commerce, digital finance, the platform and the sharing economy, digital government services.
• New infrastructure.
• Data security, personal information protection, and cybersecurity.
• New materials.
• New-generation information technology.
• Big data, blockchain.
• New/green energy and green manufacturing.

China’s engagement in international digital standard-setting

Policy for international engagement and cooperation 

China wants to become a technological force, highly competitive on the international market. Self-reliance in science and technology is seen as a strategic priority underpinning national development (as highlighted in the 14th Five-YearPlan for National Economic and Social Development). But this self-reliance does not mean detachment. As Chinese Premier Li Keqiang noted, scientific development requires international cooperation; decoupling in this area as well as in supply chains will do no country any good (South China Morning Post, 2021).

Closely aligned with these policy goals is China’s strategy to open up its standardisation system. As highlighted in various standardisation policy documents, this strategy rests on three pillars: (1) active participation in international standardisation processes, (2) strengthened bilateral and multilateral standards cooperation, and (3) harmonisation of Chinese and international standards, through (a) the internationalisation of Chinese standards and technologies and (b) the transposition of international standards at the national level. These priorities are spelt out in the standardisation law, which notes that the ‘state shall promote participation in international standardisation activities, engagement in international cooperation and exchanges on standardisation, [as well as the] adoption of international standards, and the harmonisation of Chinese and foreign standards’ (National People’s Congress, 2017).

Participation in international standards development organisations: Dual focus on technology and governance

China is moving from being a taker and adopter of standards and technologies from abroad, to becoming a technology innovator and exporter, and, as such a more active contributor to international standard-setting. In short, it aims to shift from being a consumer of international standards to becoming a producer.

This is reflected in the country’s strengthened engagement in international SDOs. After a period of absence from key organisations, China has gradually rejoined the international standardisation scene starting in the late 1970s. For some 20 years, its participation tended to take a ‘learner’s approach’; this shifted starting in the early 2000s, with a new focus on not only learning, but also contributing to standard-making.²⁵ Interview with an SDO staff member, August 2021.

 This focus has been made clear in various standardisation strategies, plans, and policies. For instance, SAC made it a priority for 2020 and 2021 to enhance active participation in international standardisation work and governance, with a focus on ISO and the IEC. Ways to achieve this include proposing more international standards, enhancing the participation of Chinese experts in SDO technical bodies, and assuming more leadership and secretariat roles within such bodies (SAC, 2020a; 2021a). MIIT adds ITU and the World Forum for Harmonization of Vehicle Regulations (WP.29) to the list of SDOs to strengthen engagement in. And it also sets a more specific goal for 2021: Chinese actors to take the lead in formulating over 100 international standardisation projects (MIIT, 2021a).

Encouraging and supporting the participation of Chinese companies and experts in international SDOs is another goal for the government. The standardisation law requires state institutions to ‘encourage enterprises, social organisations, education institutions, research institutes, and other organisations to participate in international standardisation activities’ (National People’s Congress, 2017). Similar provisions also appear in MiC 2025, the Outline for National Standardisation Development (2021), and the annual priorities set by SAC and MIIT.

A system of rewards for engagement in international standardisation is implemented. Here, too, the standardisation law provides the overall framework, stating that ‘organisations and individuals shall be commended and rewarded for their outstanding contributions to standardisation work’. Central and regional governments are said to be providing annual stipends of up to one million yuan (US$155,000) for companies leading standards development within key SDOs (Pop et al., 2021). It is also argued that some of the mechanisms put in place tend to reward quantity over quality, in the sense that companies/individuals are offered incentives simply for proposing standards, without considering the quality of those proposals or whether the proposals are eventually adopted (Voo and Creemers, 2021). 

Another practice is to have TCs/SCs from ISO and the IEC mirrored at a national level. The mirror committee mechanism – a practice also implemented in other places, such as the USA and European states – allows national stakeholders to come together and, where possible, develop standard proposals for submission at the international level, and coordinate positions on issues discussed within SDOs’ TCs/SCs. According to SESEC (no date-b), around 870 ISO/IEC TCs/SCs have mirror committees in China. For instance, TC260 on information security mirrors the ISO/IEC JTC1/SC27 on information security, cybersecurity, and privacy (US-China Business Council, 2020).

Beyond a more active engagement in the development of international standards, China is also interested in contributing to ‘improving’ and/or ‘reforming’ the standardisation environment. In 2016, in his message to the 39th General Assembly of ISO (held in Beijing), Chinese President Xi Jinping noted China’s readiness to ‘improve the system of international standards’, ‘together with all countries in the world’ (Gasiorowski-Denis, 2016). Similar references appear in several policy documents. For instance, SAC notes in its 2020 priorities that China is to ‘propose Chinese solutions in the governance reform and improvement of governance capabilities of international standardisation organisations’ (SAC, 2020a). In 2021, the administration sets more detailed objectives: ‘strengthen research into new ISO governance models and major policy rules and procedures’, ‘fully participate in the reform of the IEC governance system and in formulating new IEC strategic planning’, and ‘promote a new layout for international standardisation, in which governments indicate the way and enterprises play the leading role in collaboration with universities and research institutes’ (SAC, 2021a). This last objective, which seems to indicate a desire for an international standardisation system resembling the Chinese one (e.g. state-led, industry-driven), is also reiterated in the Outline for National Standardisation Development released by the State Council in October 2021. To what extent China has put forward concrete proposals for reforming SDOs remains unclear. 

When it comes to international engagement related to digital standards, the policy documents we have looked at tend to frame focus areas in broad, encompassing terms, such as new technologies and the digital domain. There are, however, a few references to specific fields such as intelligent manufacturing, digital currencies, data security, and quantum computing (Table 3). What the government has highlighted is a focus on areas where gaps exist in international standardisation.

Table 3. Digital standards: Objectives and focus areas for China’s international engagement as reflected in recent policy documents.

Policy document	Digital standards: Objectives and focus areas for international engagement
SAC: Main Points of National Standardisation Work in 2020	Carry out extensive international cooperation in the fields of new energy, new materials, quantum computing, digital twins, and intelligent manufacturing.
SAC: Main Points of National Standardisation Work in 2021	Focus on areas lacking domestic and international standards.Submit international standardisation proposals in the field of new technologies.Encourage more advanced technologies and innovative achievements to be converted into international standards.
National People’s Congress: 14th Five-Year Plan for National Economic and Social Development (issued in 2021)	Actively participate in the formulation of digital technology standards in areas such as data security and digital currencies.
State Council: Outline for National Standardisation Development (issued in 2021)	Promote the development of international standards in the field of sustainable cities and communities […], green finance and the digital domain.

Harmonisation of Chinese and international standards

China is aware that its economic growth depends not only on national resources, but also on its ability to be a key player in international markets. Standards play an important role in this regard, and the country has been placing an increasing emphasis on achieving some level of harmonisation between domestic and international standards, aware that Chinese technologies would better compete on international markets if they adhered to international standards. 

On the one hand, China aims to enhance the compatibility between domestic and international standards, and to accelerate the adoption of the latter. The standardisation plan issued by the government in 2021 set a specific goal of aligning 85% of its domestic standards with international ones (State Council, 2021). One of MIIT’s standardisation priorities for 2021 is to increase the conversion rate of international standards in key areas to up to 90% (MIIT, 2021a). Despite these goals, it is reported that only around one-third of the national standards issued by SAC are based fully or partially on international standards (US-China Business Council, 2020). 

On the other hand, China works to advance the internationalisation of domestic standards and technologies. In SAC’s and MIIT’s words, respectively, this means ‘encouraging more advanced technologies and innovative achievements to be converted into international standards’ and ‘promoting the internationalisation of Chinese technology, products, and services’ (SAC, 2021a; MIIT, 2021a). Promoting the ‘mutual recognition of Chinese and foreign standards’, as well as the ‘coordinated development of domestic and international standardisation’ are other goals set by the State Council (2021). The country is also focusing on publishing translations of domestic standards into foreign languages; by the end of 2019, 721 foreign language versions of Chinese standards had been published (SAC, 2020b). 

Promoting one’s technologies through standards is a goal that many participants in international standardisation share. For China, the government is counting on the fact that Chinese tech companies innovate at a fast pace, and its goal is to have at least some of these innovations reflected in international standards. This could help strengthen the competitiveness of Chinese products and services on global markets.

Bilateral and multilateral standards cooperation

Advancing bilateral and multilateral standards cooperation – with both developed and developing countries – is another important goal for China’s overall standardisation policy. 

When it comes to standards cooperation with countries like Germany and France, the focus is on specific areas; for instance, smart cities and sustainable urban development with France (Seaman, 2020), and industry 4.0 (i.e. high-tech manufacturing) with Germany (Fuchs and Eaton, 2021). Cooperation with developing countries and emerging economies covers broader areas, is sometimes connected with trade agreements, and is seen as an opportunity for China to internationalise (or export) domestic standards.

By the end of 2019, China had concluded 97 bilateral and multilateral cooperation agreements with 54 national and regional standardisation bodies and international organisations. It also participated in the work of regional SDOs such as the Pan American Standards Commission (COPANT), CEN/CENELEC in Europe, PASC in the Pacific area, and ARSO in Africa. The country has also established 12 regional standardisation research centres to serve as support for international standardisation cooperation and carry out bilateral and multilateral exchanges and cooperation. Examples include the Central Asia Standardization (Shaanxi) Research Center, the South Asian Standardization (Chengdu) Research Center, the BRICS Standardization (Zhejiang) Research Center, the American Standardization (Shanghai) Research Center, and the Heilongjiang China-Russia Standards Research Center of Province (SAC, 2020b).

In 2020, SAC outlined as objectives the establishment of standardisation cooperation mechanisms among BRICS countries; deepening cooperation mechanisms with the EU, the African Union, the Association of Southeast Asian Nations (ASEAN), Northeast Asia, Central Asia, and South Asia; and strengthening cooperation with Canada, France, Germany, Russia, Saudi Arabia, the UK, and the USA (SAC, 2020a). In 2021, the focus was on intensifying cooperation in Northeast Asia, and with Germany, Russia, and the UK; expanding cooperation with other countries and regions such as Pakistan, Costa Rica, and ARSO; actively participating in PASC standardisation activities, the Asia Pacific Economic Cooperation’s (APEC’s) Sub-Committee for Standards and Conformance, and COPANT; and broadening cooperation with regional standards organisations in Europe and the Gulf region. A more general goal was to strengthen cooperation with ISO and IEC members in key fields of global technological innovation (SAC, 2021a).Complementing the annual priorities set by SAC, the State Council highlighted among the objectives of its multi-year Outline for National Standardisation Development, the promotion of standardisation cooperation with countries part of the BRI,²⁶The Belt and Road is an initiative driven by the Chinese government to improve the connectivity and the economic cooperation between Asia, Europe, and Africa. The initiative involves substantive investments in the development of various types of infrastructures (e.g. roads, railways, ports, telecommunication networks) across partner countries. strengthening standardisation dialogues among BRICS and APEC countries, and deepening standardisation cooperation in North-East Asia, Asia Pacific, Pan-American, European, and African regions.

Promoting the role of standards in international trade and global governance also seems to be a key goal for China (SAC, 2020a). Following up on WTO-related issues, participating in activities related to standardisation issues in the context of free trade zone negotiations, and exploring standardisation coordination and cooperation in the framework of the Regional Comprehensive Economic Partnership (RCEP)²⁷RCEP is a trade agreement (to enter into force in 2022) among several Asia-Pacific countries: Australia, Brunei, Cambodia, China, Indonesia, Japan, Laos, Malaysia, Myanmar, New Zealand, the Philippines, the Republic of Korea, Singapore, Thailand, and Vietnam. are highlighted as priorities for SAC in 2021 (SAC, 2021a).

International standardisation cooperation is seen not only as a matter of state responsibility, but also an area the private sector can contribute to. MIIT, for instance, highlights the importance of encouraging industry associations – along with professional standardisation organisations – to strengthen exchanges and cooperation with international counterparts (MIIT, 2021a).

Participation in the IEC, ISO, and ITU: What do the numbers say?

China started placing more emphasis on its involvement in international standardisation once it joined the WTO in 2001. As noted previously, the TBT Agreement calls on countries to base their regulations on international standards as a way to prevent unnecessary barriers to trade. In practice, this means that countries should not be placing trade barriers against products and technologies that abide by international standards. And although WTO does not specify what is meant by international standards, those developed by the IEC, ISO, and ITU are generally understood as being relevant in the framework of the TBT Agreement. This is one of the reasons behind China’s growing involvement in these three SDOs.

In this section, we look at what the numbers say regarding the involvement of Chinese actors in the IEC, ISO, and ITU, focusing on overall participation and the number of leadership and/or secretariat positions within technical groups. We compare these with the participation of actors from other countries, and, where possible, provide historical data to showcase the dynamism of the standardisation landscape. 

Participation in ISO

China joined ISO in 1978. Since 2008, the country (through SAC) has been one of the 20 members of ISO’s Council, the governing body of the organisation. China is also a member (until 2023) of the Technical Management Board (TMB), together with 14 other countries. The Board ensures the general management of TC structure (including establishment, coordination, and dissolution of ISO’s technical bodies), the supervision of their activities, and the development and maintenance of the rules for the work of ISO’s TCs. Between 2015 and 2018, Zhang Xiaogang, a Chinese national, served as ISO President.

Participation in technical committees and subcommittees

As of 1 November 2021, China is a participating member of 732 TCs and SCs, and an observing member of 13 additional committees (Figure 1).²⁸Members decide whether they want to join a committee as a participating member (with an obligation to vote on all issues submitted for voting and to contribute to meetings) or as an observer (with the right to receive documents, submit comments, and attend meetings, but without the ability to vote). This places China at the top of the countries with the largest number of TCs and SCs they are fully active in; it is followed by the UK (714), Germany (703), Japan (646), and France (633).²⁹Data for ISO includes 20 out of the 22 ISO/IEC JTC1 subcommittees. The other two subcommittees (SC25 and SC41) are serviced by the IEC, so they are included in IEC statistics.

Figure 1. Participation in ISO TCs and SCs: Top 20 most active countries by TCs and SCs they are active in as participating members (November 2021).

Based on ISO membership data

Secretariat positions

Mere participation in committees does not necessarily translate into influence. What countries tend to look at to measure and compare their weight in ISO is the number of secretariat positions held within TCs and SCs.³⁰The study only focuses on secretariat positions, and not on chairperson positions for the following reasons. According to ISO directives, the chairs of the TCs/SCs are nominated by the secretariat of the respective committee and approved by the Technical Management Board. In the majority of cases, the chairs come from the same country as the secretariat. (By comparison, IEC directives encourage secretariats to appoint chairs from a country/national committee other than their own.) Moreover, ISO does not provide information about the national committees that chairs are associated with. Providing a secretariat position reflects the desire of a member to get more involved and allocate more resources to standardisation work (AFNOR, 2021).³¹According to ISO rules, secretariats are expected to act in a purely international capacity, and not reflect the views and positions of the SDOs they represent. The same applies to the IEC. For more details, see Annex 1. 

Here China occupies 6th place (with 68 secretariat positions,³²And an additional three twin secretariats. around 9% of all positions), after Germany (132), the USA (98), Japan (81), France (79), and the UK (77) (Figure 2).

Figure 2. Distribution of ISO TCs and SCs secretariats: Most active countries (November 2021). 

Based on ISO membership data

The number of secretariat positions held by China has risen significantly, from 6 in 2000 to 79 in 2019; this was followed by a decrease in 2020 (to 66), and then a slight growth in 2021, to 68 (Figure 3). By comparison, the number of secretariat positions held by Japan also grew constantly between 2000 (35) and 2021 (81). The Republic of Korea, too, has seen an overall increase in secretariat positions (from 0 in 2000 to 20 in 2021). France, Germany, and Canada were relatively constant in the number of secretariats held. The UK registered a decrease in secretariat positions up to 2012, followed by an increase up to 2017 and then a relatively constant number. For the USA, the number of secretariats has been oscillating over the years, but with a visible decreasing trend (from 139 in 2020 to 98 in 2021).

Figure 3. Evolution of ISO TCs and SCs secretariat positions held by selected countries between 2000 and 2021.

Based on ISO annual reports, ‘ISO in figures’ publications, and ISO membership data

Participation in digital-related committees

Beyond this general overview, we have also looked at China’s participation in TCs and SCs that are focused on, or are related to, digital technologies. Our analysis has identified 100 such committees, dealing with issues ranging from cloud computing and AI, through intelligent transport systems and health informatics, to nanotechnologies and additive manufacturing. Also included are committees whose main focus is not on digital technologies, but which touch on digital-related issues (e.g. security of financial services, digital photography, medical software). 
China is a participating member in all 100 committees, but holds the secretariat for only 7, representing 7% of all positions (Figure 4). The USA (24%), Germany (16%), and Japan (14%) are in the lead. Worth mentioning is that China holds no secretariat position within the ISO/IEC JTC1 on information technology, although it participates in all 22 SCs.³³Among the 22 SCs of the ISO/IEC JTC1 on information technology, the USA holds 7 secretariat positions, Japan 5, and the Republic of Korea 3. The rest are distributed between Germany (2), the UK (2), Australia (1), France (1), and India (1). The USA also holds the secretariat position for the overall JTC.

Figure 4. The distribution of secretariat positions within 100 digital-related ISO TCs and SCs (November 2021).
Based on ISO TC/SC information

Participation in the IEC

China joined the IEC in 1957. The country is present in several of the organisation’s management bodies. It has one member³⁴With a term of office ending at the end of 2021. on the IEC Council Board. Three of the 11 members of the Market Strategy Board represent Chinese companies. In addition, 1 of the 15 members of the Conformity Assessment Board represents China. ³⁵With a term of office ending at the end of 2021.The same applies to the Standardization Management Board, with 1of the 15 members representing China.³⁶With a term of office ending at the end of 2021. Yinbiao Shu currently serves as IEC President (2020–2022), having acted as President-Elect in 2019, and Vice-President between 2013 and 2018.

Participation in technical committees and subcommittees

As of 1 November 2021, China is an active participant in 188 TCs and SCs (94% of all committees) (Figure 5)³⁷.Data for IEC includes 2 of the 22 ISO/IEC JTC 1 subcommittees (SC 25 and SC 41). The other 20 subcommittees are serviced by ISO. This is relatively similar to the participation of Germany (189 committees) and Japan (186 committees).

Figure 5. Participation in IEC TCs and SCs: Top 20 most active countries by TCs and SCs they are active in as participating members (November 2021).

Based on IEC membership data

Secretariat and chair positions

China holds the secretariat for 11 IEC TCs and SCs, representing 5.7% of all positions (Figure 6). In this regard, it occupies 7th place, after Germany (36 secretariats), the USA (27), Japan (23), France (22), the UK (19), and Italy (14). 

China occupies the same 7th place (5%) when it comes to the number of TCs and SCs it chairs (10 committees), after Germany (57), the USA (28), France (22), Japan (19), Italy (14), and the UK (13).

Figure 6. Distribution of IEC TCs and SCs secretariat and chair positions: Most active countries (November 2021).
Based on IEC membership data

Participation in ITU standardisation work

Overall participation

China joined ITU in 1920. Currently, it is the second country by the number of ITU members, after the USA (Figure 7).³⁸Compared with ISO and the IEC, where there is only one formal member per country (the national bodies/national committees), ITU has a more complex membership structure, including member states, sector members, associates, and academia. For more details, see Annex 1. In terms of high-level leadership positions, Houlin Zhao has been serving as ITU Secretary-General since 2015 (two consecutive mandates: 2015–2018 and 2019–2022). Before that, he served as Deputy Secretary-General for eight years, and director of the Telecommunication Standardization Bureau (TSB) for the previous eight years.

Figure 7. Top 5 countries with the highest number of ITU members (October 2021).
Based on ITU membership information

Participation in ITU-T

Study group chair and vice-chair positions

At ITU-T, the current study period (SP) (2017–2020), which should have ended in 2020, continues until spring 2022, due to the postponement of the World Telecommunication Standardization Assembly (WTSA).⁴⁰WTSA-20 was initially scheduled for November 2020. It is now planned to be held in March 2022 in Geneva. For this period, there are 11 SGs. Each SG carries its work within WPs, each dealing with a set of questions. Thirty-three WPs are exploring a total of 129 questions.

Among the 11 SGs, 2 are chaired by Chinese entities (Huawei and the China Academy of Information and Communications Technology (CAICT)), and 2 by a Japanese company (KDDI Corporation). The remaining 7 groups have chairs from Ghana, the Republic of Korea, the Russian Federation, Switzerland, United Arab Emirates, the UK, and the USA. In terms of SG vice-chairs, the largest number of positions are held by Chinese entities (10), followed by entities from the Republic of Korea (8), Argentina (7), Tunisia (7), and Japan (6) among the top five (Figure 8).

Figure 8. Distribution of ITU-T SG vice-chair positions | Top 10 countries.
Based on ITU-T SG information (SG management roles)

Working party chair, vice-chair, and rapporteur positions

Within the WPs, Chinese entities hold the most chair positions, followed by the Republic of Korea and Japan. When it comes to vice-chair roles, entities from China, Argentina, and the UK take the lead. The statistics differ slightly by one element: whether the entity in leadership position is associated with the country where it is registered (based on ITU membership information) (Figure 9) or with the country where its headquarters is based (Figure 10). 

Rapporteurs are individuals tasked by an SG with the responsibility to lead the work around a specific question or small groups of questions. For each question, there are usually several rapporteurs, co-rapporteurs, and/or associate rapporteurs. From a total of 317 such roles, 29% are held by representatives of Chinese entities, followed by entities from the Republic of Korea (13%), Japan (8%), the USA (5%), and Germany (4%) (Figure 11).⁴¹ The stats consider the location of the entities as indicated in ITU-T data. For instance, Ericsson Canada is counted as a Canadian entity; Futurewei is counted as a US entity. However, the share of rapporteur positions stays relatively similar if the entities are counted by the countries they originate from (e.g. Ericsson as Sweden and Futurewei as China).

Figure 11. Distribution of ITU-T rapporteur positions, by country where the entity is registered.

Based on ITU-T information (SG rapporteurs)

Study group roles: What changed between 2001 and 2021?

A comparison of the 2001–2004 and 2017–2020 SPs, in terms of distribution of chair, vice-chair, and rapporteur roles within ITU-T SGs and WPs among selected countries shows that the picture has changed substantially over the past 20 years. In the early 2000s, US entities had the largest share of roles: 22 chairs and vice-chairs (across SGs and WPs) and 60 rapporteurs. By comparison, Chinese actors had a very modest presence: 1 vice-chair and 3 rapporteurs. The situation is completely reversed in 2021: the US entities hold 5 chair and vice-chair roles and 16 rapporteurs, while Chinese entities lead, with 25 chairs and vice-chairs, and 89 rapporteurs. 

Besides the significant differences between Chinese and US representation in these roles, Figures 12 and 13 show two other notable changes relative to the 2001–2004 SP: (a) the UK has a decreased representation in key roles (11 vs 36), and (b) the Republic of Korea has a largely increased representation (56 vs 11).

Focus group chair and vice-chair positions

Besides the 11 SGs, ITU-T also hosts 8 focus groups (FGs) (as of November 2021) dedicated to ‘augmenting the Study Group work programme by providing an alternative working environment for the quick development of specifications’. FGs ‘address industry needs as they emerge, and when they are not covered within an existing SG’ (ITU-T, no date-b). Some of the topics they address include AI and IoT for digital agriculture, autonomous networks, AI for autonomous and assisted driving, and quantum information technology. FGs make their own decisions on working methods, leadership, financing, and types of deliverables. Within the FGs there are usually multiple working groups, topic groups, and ad-hoc groups focusing on specific issues. When it comes to leadership positions within FGs and their internal structures (e.g. working groups, topic groups), the largest number of chairs are held by entities from the USA (15), followed by China (14), Germany (11), Japan (4), and the UK (3). The situation is slightly different for vice-chair positions, most of them being held by entities from China (15), followed by Germany (5), India (5), Japan (3), and the Republic of Korea (4) (Figure 14).⁴² The stats consider the entities by the countries they originate in. There are two positions held by Huawei subsidiaries located in Germany and Belgium; these have been counted as Chinese entities.

Figure 14. Distribution of ITU-T FG chair and vice-chair positions (including within internal structures) | Top 5 countries.
Based on ITU-T information (FG structure)

Participation in ITU-R

Although ITU-T is known as the ITU standardisation arm, technical standards are also developed at ITU-R. 

There are six SGs at ITU-R, each with several WPs. The six groups are each chaired by an entity from Australia, Egypt, Japan, the Russian Federation, the UK, and the USA. When it comes to vice-chairs, Chinese entities have the same share of positions as those from India and Morocco (6 each), followed by France, the Republic of Korea, and the Russian Federation (5 each), while the rest of the 57 vice-chair roles are distributed among entities from 37 countries (Figure 15).

Figure 15. Distribution of ITU-R SG vice-chair roles | Top 6 countries.
Based on ITU-R information (SG leadership)

Within WPs, the largest number of chair positions are held by entities from the USA. The same goes for vice-chairs, where the USA is followed by China. The overall statistics differ slightly depending on one element: whether the entity in the leadership position is associated with the country where it is registered (based on ITU membership information) (Figure 16) or with the country where its headquarters is based (Figure 17).

Reviewing the numbers

Looking at the three organisations – the IEC, ISO, and ITU-T – it is clear that China is among the most active participants, including in terms of leadership positions. There are, however, some differences in how China ranks compared with other countries in the IEC and ISO, on the one hand, and the ITU-T on the other. 

At ISO, China is a participating member in the largest number of TCs and SCs (732), followed by the UK (714) and Germany (703). But it only occupies 6th place (9%) when it comes to secretariat positions within TCs/SCs. Germany is leading in secretariat positions (17%), followed by the USA (13%), Japan, France, and the UK (around 10% each). Among the 100 digital-related TCs/SCs analysed, China holds the secretariat for only 7%; the leaders are the USA (24%), Germany (16%), and Japan (14%). 

The situation is relatively similar at the IEC. China is a participating member in 188 TCs and SCs. By comparison, Germany is a full member in 189 committees, and Japan in 186. China holds the secretariat for only 5.7% of TCs/SCs, and the chair for 5% of the committees, occupying 7th place in both cases. Germany is again the leader in terms of both secretariat (18.6%) and chair (28.6%) positions. The USA, Japan, France, the UK, and Italy are also positioned ahead of China in terms of TC/SC chair and secretariat positions.

The high number of ISO and IEC committees China participates in can be seen as a reflection of the country’s interest in contributing to standard-setting processes across a wide range of areas. But this interest does not automatically translate into influence, especially because China holds significantly fewer leadership positions within TCs/SCs compared, for instance, with Germany, the USA, and Japan. This may mean different things. For instance, it may be that China is still going through what some experts call a ‘learning and adaptation phase’ within these SDOs. 

The situation is different at ITU-T. The USA leads by the number of ITU (118) and ITU-T (83) members, with China coming in second (86 ITU members and 76 ITU-T members). UK, Japan, and Germany are also among the top five countries by number of ITU and ITU-T members. But China is ranking higher in terms of leadership positions. While at parity with Japan for SG chair roles (2 each), China holds the largest number of SG vice-chair positions (10.4%), followed by the Republic of Korea (8.3%), Argentina (7.3%), Tunisia (7.3%), and Japan (6.3%). Chinese entities also have the largest number of WP chair and vice-chair positions, followed by the Republic of Korea, Argentina, Japan, and Egypt. When it comes to rapporteur roles, Chinese actors lead with 29%. Entities from the Republic of Korea come next with only 13%, followed by Japan (8%), the USA (5%), and Germany (4%). 

The fact that Chinese entities hold many chair, vice-chair, and rapporteur roles allows them to ‘have a prominent role in framing the parameters for standardisation processes’ (Voo and Creemers, 2021). But, when assessing the overall power that such positions offer, consideration should be given to the fact that decisions within the different ITU-T bodies are largely consensus-based. See Annex 1 for details on the standards approval process.

What is also important to note is that China’s growing involvement in these three SDOs has happened in the context of a shifting standardisation landscape, where some actors are less involved than they used to be, while others become more active. At ISO, for instance, the number of TC/SC secretariat positions held by China has increased considerably between 2000 and 2021, from 6 to 68. But Japan and the Republic of Korea have also seen an overall increase in the number of secretariat positions between 2000 and 2021 (35 to 81 for Japan, and 0 to 20 for the Republic of Korea). And while the number of secretariats has remained relatively constant for France, Germany, and Canada, it has been oscillating for the USA, but with a visible decreasing trend (from 139 in 2000 to 98 in 2021). At the ITU-T, the Western industry has reportedly reduced their participation, creating a void that was easy to fill in by the Chinese industry when they started becoming more active.

Criticism regarding China’s tactics in SDOs

In this section we look at some areas of criticism raised by various stakeholders regarding China’s participation in international standardisation.  

Many proposals, often of low quality

One criticism brought to Chinese stakeholders’ participation in SDOs is ‘They submit a large number of proposals that are low-quality or irrelevant to market needs in some industries. […] This takes valuable time and resources away from considering serious proposals’ (US-China Business Council, 2020).

Do Chinese actors submit many proposals in SDOs? They seem to do so. According to SAC (2020b), China put forward 238 new standard proposals at ISO and the IEC in 2019. A review of written contributions to three ITU-T SGs between 2009 and 2020 shows that China submitted the largest number of contributions (3021), followed by the Republic of Korea (2164) (Voo, 2020). At the IETF, the number of contributions submitted by Chinese authors has increased continuously since 2000, while the number of contributions from US authors has decreased. In 3GPP, Huawei is credited as being the largest contributor of draft documents. 

Irrespective of where one actor comes from, it is true that if it submits a large number of proposals, ‘everything becomes a numbers game’.⁴³Interview with an SDO staff member, September 2021. The more proposals there are, the less time and resources are available to tackle them. But the number of proposals should also be seen as a logical reflection of one actor’s interest in standardisation work and the resources it dedicates to it. In the case of China, it may be a combination of government encouragement and industry interests (including the incentives offered for contributions to SDOs) that drives the large number of proposals. But it does not automatically mean that there is an overarching strategy to overwhelm technical committees with proposals. Moreover, as an interviewee noted, ‘If there were more stakeholders contributing and bringing more proposals, there would be a more virtuous circle of interactions happening.’ ⁴⁴Interview with an SDO staff member, August 2021.

When it comes to the quality of Chinese proposals, there are complaints that some of them are neither technical nor do they address a real problem or suggest a real solution. This could be tied to different reasons, such as the fact that some of the actors are still on a learning curve when it comes to engagement in SDOs, and the reward system that seems to encourage quantity over quality. At the same time, it is said that low-quality proposals come from other actors as well. What tends to be different is that these actors find it easier to suppress their proposals if flaws are identified and it becomes clear that they cannot be supported. 

There are also observations that the quality of Chinese proposals has increased over the years (as resources have been allocated to training SDO participants), and that it is unfair to qualify the majority of them as trivial.⁴⁵Interviews with SDO participants, July–October 2021. 

One other aspect that adds complexity to standards development processes is that sometimes similar proposals are put forward in different SDOs. This would indeed mean taking resources away from other work, considering the need for a coherent standardisation ecosystem, with no duplication. But here, too, forum shopping is not a tactic employed only by Chinese actors. Further research into the extent to which forum shopping is carried out by different actors within different SDOs could provide additional insights into the complexity of the standardisation ecosystem.

Abusing leadership positions

One other concern is that Chinese actors may abuse leadership positions within technical groups and ‘leverage their authority to promote Chinese-led proposals without consensus or block certain proposals for the purposes of economic advantage or national prestige’ (US-China Business Council, 2020).

The extent to which this concern reflects reality seems to be unclear. When it comes to blocking proposals, opposing views argue that Chinese actors rarely block anything; and even if they do, it is within anyone’s right to express disagreement. And while there are anecdotes that sometimes chairs/vice-chairs/rapporteurs would use their roles to ‘push proposals through’, there are also arguments that such behaviour is not new within SDOs, and those manifesting it ‘don’t break the rules, but rather play with them cleverly’. ⁴⁷Interviews with SDO participants, July–October 2021.

In general, consensus rules are seen to be functioning relatively well in preventing any one actor from gaining an advantage because they have large delegations or hold leadership positions. The New IP proposal (covered later in the report) is an illustration of this. The work item was not approved because it did not gain consensus. What could help strengthen this is having more actors coming to the table and contributing to the debates. 

What Chinese actors may be better at compared with other actors is forming coalitions and gaining support for their proposals from other players (e.g. they can gain such support easier because they have the resources to participate across a large number of groups). But such practices are part of the game and others play it too. The fact that EU countries often tend to act as a bloc is an example. And it is worth mentioning that concerns about coordinated approaches leading to ‘bloc voting’ and the capturing of SDO processes also used to be raised (in particular by US actors) with regard to EU participation (Witte, 2003). 

Violating the spirit of SDOs

China’s active participation in SDOs is sometimes criticised as ‘violat[ing] the spirit of these organisations, making them less effective for other members and in some cases deliberately attempting to undermine U.S. technological leadership’ (USCC, 2020).While many of the concerns related to China’s growing involvement in standardisation may be legitimate, they do not mean that Chinese actors are not playing by the rules. China wants to be recognised as a centre of technological excellence and its participation in SDOs reflects this goal. If this participation involves large delegations, many proposals, and attempts to form coalitions, it does not mean that rules are being broken. As for ‘undermining’ others, ‘It might be a side-effect, but [it is] probably less of a master plan.’⁴⁸Interview with an SDO participant, July 2021.

Moreover, China’s participation in SDOs is not necessarily just an extension of the broader China-USA economic and tech competition. It is about companies going to the SDOs to have their technological developments recognised internationally; ultimately, this can generate economic advantages.

In international standardisation, all countries and all companies have interests they all try to defend. If one actor can get its standard proposals approved, it means it plays the game well. And if the standard was approved not necessarily because of its quality, but simply because of games well played, this may backfire if the market decides not to follow the standard. This is a risk that actors are well aware of and not necessarily willing to take. 

Generally speaking, SDOs have well-established procedures and practices meant to ensure that everyone participating in international standard-setting abides by the same rules and no one actor can manipulate the system to their advantage. As some actors become more involved, this may indeed put some pressure on the rules, and increase the need for the SDOs themselves and participants to ensure that breaches do not occur.

Case studies in international standard-setting

China’s involvement in the development of international digital standards relates to a wide range of technologies. Key areas of interest cover technologies seen as being of strategic importance for the country’s economy and national security, and closely aligned with industrial and innovation policies and with national standardisation priorities. 

China is pursuing two main goals. The first is to catch up and have a stronger presence in rather mature standardisation processes for technologies that have been around for a while. The second is to play a prominent role in the development of standards for new(er) technologies, where there are either gaps in standardisation or the standardisation processes are being shaped.⁴⁹This is a goal shared by other standardisation actors too. For instance, the European Commission’s rolling plans for ICT standardisation encourages European actors to engage in the identification of gaps in international standardisation for digital technologies, and to contribute to the development of related standards (European Commission, 2021). Such issues are also expected to be covered in the upcoming standardisation strategy. To illustrate, within the ISO/IEC JTC1, China took the initiative to convene work on smart cities, quantum computing, and brain-machine interfaces. 

In this section of the report, we explore five case studies of Chinese involvement in the development of international standards for digital technologies. The first two studies look at specific proposals put forward by Chinese actors at ITU (both of which have attracted significant media attention): a proposal for ITU-T to take up work on designing a new protocol (the New IP proposal) and a proposal for standardising facial recognition systems in visual surveillance. The other three case studies focus on the broader picture of the Chinese contribution to international standards development processes related to 5G, autonomous vehicles, and quantum computing. 

New IP: Designing a new internet architecture?

Proposals at ITU-T

In September 2019, a contribution titled New IP, Shaping Future Network was put forward at ITU-T’s Telecommunication Standardization Advisory Group (TSAG),⁵⁰TSAG acts as an advisory body to SGs, members, and staff. It reviews strategies and priorities of the ITU-T, its operational and financial plans, and serves as the preparatory group for WTSA. TSAG also reviews progress in the implementation of the ITU-T work programme and provides guidelines for the work of SGs. by Huawei, China Mobile, China Unicom, and MIIT. The contribution suggested that ITU-T considers ‘designing a new information and communications network with [a] new protocol system that satisfies and serves for the future’. Such work, it was said, was needed because the existing network is facing a number of challenges (e.g. with regard to performance, structure, security), which ITU-T should analyse and then ‘provide a development path for the future network for the next decade’ (Huawei et al., 2019). This contribution was accompanied by a presentation by Huawei that highlighted possible elements of such a new protocol system, called New IP (Huawei, 2019).

The mere idea that a New IP was promoted by Chinese entities attracted significant attention, making it rather difficult to differentiate hype from reality. But, as the Internet Corporation for Assigned Names and Numbers (ICANN) and others noted, there was no concrete proposal for a new standard, or sufficient public information to provide a clear description of what the New IP is, or a clarification of whether the New IP was meant to be deployed in specific scenarios or completely replace the existing protocol. What various documents (e.g. an overview Huawei (no date) published on its website) described was an architecture that would come with several elements, such as variable-length addresses; an approach enabling data packets to embed contracts to be enforced by intermediary network elements; and the concept of ‘Many Nets’ where a single network would be replaced with many networks interconnected via gateways (Durand, 2020). 

In addition to the proposal put forward at TSAG, Huawei and others also presented contributions at SG11 and SG13 (in the context of preparations for WTSA) proposing new questions for the groups to tackle during the next ITU-T SP. The four proposed questions introduced a new term – Future Vertical Communication Networks (FVCN) – but included elements of the previous New IP, such as deterministic networking and ManyNets. These, again, were not proposals for standards/specifications as such, but requests that FVCN-related issues be discussed by ITU-T SGs in the upcoming SP. The groups were not able to agree on approving the proposed questions or reach a consensus to continue discussions on these matters. 

Concerns and criticism

From statements arguing that the New IP leads to ‘more centralised, top-down control of the internet’ (Gross and Murgia, 2020) to worries about content monitoring, the New IP⁵³Although the name New IP was later dropped from presentations and proposals related to the new architecture, we will be using it in this section for consistency. idea raised several concerns. 

Compatibility. The technical community pointed out that the envisioned architecture cannot be compatible with the existing IP-based infrastructure. As such, it would either replace this infrastructure or run parallel with it. If it is done in parallel, it would require gateways to interconnect with the current network, generating complexity and significant costs for network operators. 

Insufficient evidence that the described challenges of the current system cannot be addressed in the current framework, or that the proposed architecture would address them effectively. For instance, it is argued that there is no need for a new architecture to enable interconnection between heterogeneous access networks, because the internet itself was designed, and is able, to interconnect different network types, and it has managed to adapt over time to the emergence of new network technologies. Many of the problems associated with interconnecting networks are not technical, and a new architecture would not solve them (Sharp and Kolkman, 2020). Overall, it was argued that the challenge described could be addressed by ‘continuing to evolve the existing IP protocol suite’ (IETF, 2020).

Reiterating proposals from the past. It was argued that the New IP came with technical proposals that were made in the past. Although they may work from a technical point of view, they were not deployed for various business reasons. It was not clear why approaches that failed to get deployed in the past would be deployed now. 

Overlaps with ongoing work. It was pointed out that some of the elements that the new architecture would address are already being studied (and standards are being developed) by bodies such as the IETF, IEEE, 3GPP, and even ITU-T SGs themselves. ‘Creating overlapping work is duplicative, costly, and in the end does not enhance interoperability; proposals for new protocol systems and architectures should show why existing work is not sufficient’ (Sharp and Kolkman, 2020).

Uncertainty and costs. It was argued that, although the details of a New IP were not very clear, discussing a new internet architecture could generate uncertainty across the industry and affect investments in internet capacity and access technologies (Austria et al., 2020a). Moreover, deploying a new architecture would come with significant costs and economic burdens for governments (in particular in developing countries), businesses and consumers (Austria et al., 2020b; 2020c).

Privacy and content monitoring. Elements of the New IP proposal indicate that users’ privacy would be affected, and pervasive content monitoring could be made easier. As ICANN explains, ‘It would allow any intermediary element (router, switch, etc.) to have full access to exactly which user is doing what. Also, content providers would have access to the identity of every user connecting to them’ (Durand, 2020).

Top-down governance and central shut-down. The September 2019 proposal suggested that ITU-T ‘shoulder[s] the responsibility of a top-down design for the future network’. This generated fears that a new governance model for the internet is being envisioned, with top-down control. As one interviewee noted, ‘Governance for a technology tends to follow the structure of how the technology is standardised: if the development of the standard is top-down, the governance processes that follow would then tend to be the same.’⁵⁴Interview with a staff member of a technical organisation, July 2021. Huawei rejected such claims, saying the proposal has nothing to do with governance models. It did admit, however, that a ‘shut-off protocol’ is envisioned, but noted that its goal is to contribute to the prevention of distributed denial of service (DDoS) attacks, by allowing ‘the attacked network to signal to the attacker’s source network the request for preventing further attack traffic’. Such concepts, Huawei claims, are similar to other proposals put forward by US researchers or discussed at the IETF (Huawei, no date). Whether or not such statements hold water, standard proposals that would embed strict controls would have little (if any) chances to get approved at ITU, where consensus is required (Voo and Creemers, 2021).

Inadequate venue for discussion. On the process itself, there was discontent that ideas for new internet protocols and architectures were being discussed at ITU, as opposed to the IETF. There were concerns that this would be ‘an opportunity to steer away from the traditional bottom-up decision-making model’ (RIPE NCC, 2020) and that having the IP reinvented at ITU could eventually mean that the management of that protocol would fall under ITU’s remit. Critics argued that ‘new work at the ITU-T should focus on telecommunications aspects within its expert remit and not a fundamental re-design of the internet’s architecture’ (Austria et al., 2020b; 2020c).

What was said less (if at all)

Is the New IP the only thing to pay attention to? Proposals for new networks, including non-IP ones, are often put forward in SDOs. One example is the Non-IP Networking (NIN) discussed at ETSI, in the framework of a dedicated Industry Specification Group (ETSI, no date). Like the New IP, NIN claims that TCP/IP is no longer suitable for new types of applications. And, also like the New IP, it would not be compatible with the current IP-based system (Durand, 2021). NIN has not attracted anything close to the attention the New IP has, and this should be of concern. Because, if the goal is to preserve the internet as a global and interoperable network, and to avoid risks that could be posed by new networks, then attention should be paid to all proposals for new architectures, no matter where they are discussed and who puts them forward. 

Was internet surveillance the end goal of the proposal? This seems to be more of an assumption than a certainty. As the technical community noted, some of the envisioned elements could indeed make it easier to monitor internet content. And it is also worth mentioning that user identification and central shut-down – two of the concerns raised regarding the New IP – are in fact already possible in the current architecture, through the intermediaries (i.e. internet service providers ). The New IP might have led to a simpler, more ‘automated’ process. 

Then what is the real ‘game’? The idea that the IP needs to be updated is not new (other examples include the QUIC protocol proposed by Google, and Mozilla’s push for DNS over HTTP). One of the novelties in the New IP was that the proposal came from Chinese actors (previously less active in this space), whose ambitions to become trend-setters in research and engineering thus gained more visibility. The real game was most likely the possibility of Huawei shaping the standards development process in a way that would give them a jump-start in the market compared to others. 

Are Chinese actors playing according to the rules? In the whole debate on whether anything related to the internet architecture should be discussed at ITU or left only to the IETF, one thing was largely missed: Huawei wanted to discuss the overall proposal with others (for context, see Box 15). The company seemed ready to reach some compromise for pragmatic reasons; it cannot risk losing large markets due to standards incompatibility. Huawei did not break any written rules of the standardisation ecosystem; it invited others to ‘an open and free discourse’, following ‘the established path for developing internet technologies in standard bodies’ (Huawei, no date). 

Is the New IP dead? 

While the original proposals put forward at ITU-T were shelved, elements of the proposed architecture appear to show up in different places from time to time. For example, an internet draft titled Forwarding Layer Problem Statement was put forward at the IETF by Futurewei in March 2020; the draft was revised three times, the most recent version dating June 2021 (Bryant et al., 2021). Several side-discussions on Future Internet Protocol Evolution and 6G-and-IP have been happening on the margins of IETF meetings, ⁵⁵Such discussions happened, for instance, in the context of IRTF side-meetings co-located with IETF 108 in July 2020 (Perkins, 2020) and IETF 109, in November 2020 (IETF, no date-a). one of the intentions being to form research groups within the Internet Research Task Force (IRTF) to further explore these issues. At ITU-T, proposals on a polymorphic network (described as a new type of network architecture and a potential network model for 6G) were submitted at SG13 in March 2021 (ITU-T, no date-c).

Facial recognition in visual surveillance: A proposal for an ITU-T standard

Proposal at ITU-T SG16

In 2019, China Telecom submitted a proposal for an ITU-T recommendation on ⁵⁷Requirements for Face Recognition Application in Visual Surveillance.F.FRAVSReqs – Requirements for face recognition application in visual surveillance. The proposal was put forward in ITU-T SG16 (on multimedia coding, systems and applications), in the context of Question 12 (Q12/16) on intelligent visual systems and services, discussed within WP1 on multimedia content delivery (WP1/16). 

The proposal aimed to specify requirements for the application of face recognition in visual surveillance, for use by both the public and private sectors. It outlined use cases and scenarios of face recognition application, as well as requirements of functions, services, performances, and security. In terms of use cases, examples were given of applications used in public security (e.g. searching suspects and confirming their identity), key area management (e.g. in hotel registration, ID checks in airports, railway stations, and construction sites), business and service (e.g. identifying customers), and ‘data practical applications’ (e.g. being able to track the trajectory of certain individuals if they are found to appear frequently in certain periods of time at certain points within a mall). 

The proposed recommendation then outlined several requirements for facial recognition systems, such as:

• Detecting and structuring the features of the human faces from pictures and video, and storing the detected features in a database for retrieval and searching purposes.
• Performing various types of matches: 1:1 (comparing two images), 1:N (comparing one image against N images in a library), and n:N (comparing all n images in a library with all N images in another library to find matches). 
• Performing dynamic face recognition.
• Supporting diversification of data sources (e.g. mobile phone images, camera capture, photo scanning).

Following several rounds of controversial discussions within the dedicated working party, the proposal was discontinued in April 2021 (ITU-T, 2021a). 

Concerns and criticism

Human rights implications. Critics – in particular from European countries – saw the draft recommendation as being very broad in scope and interfering with fundamental rights and freedoms. For instance, the fact that the face recognition applications presented would be able to detect elements such as gender, age, race, skin colour, and physical features could create the risk of a discriminatory approach based on particular characteristics, as well as of wrongfully exposing and falsely indicting people belonging to certain groups. Another concern was that the proposal does not make it clear that biometric data resulting from facial recognition may not be sold, transferred to third parties or disclosed (unless with the consent of the data subject). 

Topic not suitable for technical standardisation. There were arguments that the draft recommendation was ‘crossing the line from technical specifications to policy recommendations, including outlining use cases and data requirements’ (Gross et al., 2019). It was also said that the proposal has policy and regulatory implications, and is not a purely technical standard nor should it be treated as one. Determining conditions and addressing safeguards for facial recognition to be legally deployed is beyond the scope of technical standardisation; such issues should be tackled within a legislative process. Moreover, because FRT is the subject of heated policy discussions around the world, and regulatory frameworks in this area are only starting to emerge, technical standardisation was considered to be premature. 

Inadequate approval process. Initially, the draft recommendation was subject to an alternative approval process (AAP). This approach was seen as not suitable by several member states, who pointed out that the deployment of FRT has policy and regulatory implications, and, as such, a traditional approval process (TAP) needs to be followed. The change from AAP to TAP was confirmed in June 2020 (ITU-T, 2021b). Why does this matter? Because the rules for approving a proposal under TAP are more stringent (Annex 1). 

Inappropriate choice of standardisation venue. As was the case with the New IP, there were concerns that ITU-T was not the place to discuss standardisation for FRT, and that such issues would be better off left to other standardisation bodies such as ISO and the IEC. There were also complaints that proposing an FRT recommendation in an SG that focuses on multimedia was misleading, and part of a strategy to attract as little attention as possible to the proposal.

What was said less

Was it a strategy to propose a recommendation on facial recognition in an SG dealing with multimedia? Although there were complaints along these lines (as noted earlier), there were also arguments noting that work on video surveillance systems has been happening in SG16 for many years, and it was natural that, as more techniques – such as AI and recognition of faces and patterns – become available, they would appear in standardisation work. ⁵⁸Interviews with SDO participants, July–September 2021.

The FRT proposal was rejected. How big of a win is this? One of the arguments in favour of rejecting the proposal at SG16 was that it was premature to propose standards for facial recognition. Instead, it was said that we have to wait for the technology to become more mature, to be able to fully understand its implications and devise mechanisms to avoid abuses. While this might be true, what was missed was the fact that several recommendations have already been adopted within ITU-T that contain provisions with potential relevance for FRT systems (Box 18).

The private sector is already developing and deploying specifications for FRT. Rejecting the proposed recommendation does not mean the technology will not continue to be deployed, or that relevant standardisation proposals are not discussed in other contexts. And while this particular proposal has probably received the attention it did because of the geopolitical context, it is important to also look carefully at what other players are proposing and doing in terms of FRT and standardisation. For instance, it is likely that some of the over 100 biometric standards already adopted in JTC1’s SC37 are or will be applied in surveillance technologies, posing at least some of the same challenges raised in relation to the Chinese proposal (e.g. in terms of discrimination, privacy) (Voo and Creemers, 2021).

Annex 3 Abbreviations

3GPP	3rd Generation Partnership Project
AAP	alternative approval process
AFNOR	French Standardisation Association (Association Française de Normalisation)
AI	artificial intelligence
ANSI	American National Standards Institute
APEC	Asia Pacific Economic Cooperation
ARSO	African Organisation for Standardisation
ASEAN	Association of Southeast Asian Nations
AV	autonomous vehicle
BMVI	Federal Ministry of Transport and Digital Infrastructure (Germany)
BRI	Belt and Road Initiative
BRICS	Brazil, the Russian Federation, India, China, and South Africa
BSI	British Standards Institution
CAICT	China Academy of Information and Communications Technology (China)
CATARC	China Automotive Technology and Research Centre (China)
CCSA	China Communications Standards Association (China)
CEN	European Committee for Standardization (Commission Européenne de Normalisation)
CENELEC	European Committee for Electrotechnical Standardization (Commission Européenne de Normalisation Électrique)
CESI	China Electronics Standardisation Institute
COPANT	Pan American Standards Commission (Comisión Panamericana de Normas Técnicas)
DECT	Digital Enhanced Cordless Telecommunications
DIN	German Institute for Standardisation (Deutsches Institut für Normung)
DIS	Draft International Standard
ETSI	European Telecommunications Standards Institute
FDIS	Final Draft International Standard
FG	focus group
FRAND	fair, reasonable, and non-discriminatory
FRAV	Informal Working Group on functional requirements for automated and autonomous vehicles (within WP.29)
FRT	facial recognition technology
GDP	gross domestic product
GRVA	Working Party on automated/autonomous and connected vehicles (within WP.29)
HTML	HyperText Markup Language
ICANN	Internet Corporation for Assigned Names and Numbers
ICT	information and communication technologies
IEEE	Institute of Electrical and Electronics Engineers
IEEE SA	IEEE Standards Association
IEC	International Electrotechnical Commission
IESG	Internet Engineering Steering Group
IETF	Internet Engineering Task Force
IoT	internet of things
IMT-2020	International Mobile Telecommunications-2020
IP	internet protocol
IRTF	Internet Research Task Force
ISG	Industry Specification Group
ISO	International Organization for Standardization
IT	Information technology
ITU	International Telecommunication Union
ITU-D	ITU Development Sector
ITU-R	ITU Radiocommunication Sector
ITU-T	ITU Telecommunication Standardization Sector
JTC1	ISO/IEC Joint Technical Committee 1
MiC 2025	Made in China 2025
MIIT	Ministry of Industry and Information Technology (China)
MS	member state
NB	national body
NC	national committee
NCSE	National Center of Standards Evaluation (China)
NDRC	National Development and Reform Commission (China)
NGO	non-governmental organisation
NIN	Non-IP Networking
OASIS	Organization for the Advancement of Structured Information Standards
ORU	other road user
PAR	project authorisation request
PASC	Pacific Area Standards Congress
PCG	Project Co-ordination Group
PDF	Portable Document Format
QIT	quantum information technology
QKD	quantum key distribution
R&D	research and development
RAN	radio access network
RCEP	Regional Comprehensive Economic Partnership
RFC	request for comments
RIPE NCC	Réseaux IP Européens Network Coordination Centre
SAC	Standardisation Administration of China
SC	subcommittee
SDG	sustainable development goal
SDO	standard-development organisation
SEP	standard-essential patent
SG	study group
SM	sector member
SME	small and medium-sized enterprise
SP	study period
STC	specific trade concerns
TAP	traditional approval process
TBT	technical barrier to trade
TC	technical committee
TMB	Technical Management Board
TSAG	Telecommunication Standardization Advisory Group
TSB	ITU Telecommunication Standardization Bureau
TSG	Technical Specification Group
TTC	Trade and Technology Council
UNECE	UN Economic Commission for Europe
USCC	U.S.-China Economic and Security Review Commission
W3C	World Wide Web Consortium
WP	working party
WP.29	World Forum for Harmonization of Vehicle Regulation
WTO	World Trade Organization
WTSA	World Telecommunication Standardization Assembly

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