A Practical Guide to Understanding the Specific Requirements of CPR* *REGULATION (EU) No 305/2011 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 9 March 2011 laying down harmonised conditions for the marketing of construction products and repealing Council Directive 89/106/EEC All rights reserved © May 2013 ORGALIME Editeur responsible: Adrian Harris, Director General ORGALIME The European Engineering Industries Association [email protected] / www.orgalime.org LIST OF CONTENTS click on the page number to see the chapter FOREWORD! 3 INTRODUCTION! 4 CHAPTER 1 - MAIN CONCEPTS! 5 DECLARATION OF PERFORMANCE! 5 Key facts to know about the Declaration of Performance! 5 Derogations from drawing up a Declaration of Performance! 6 How to supply the Declaration of Performance?! 6 In which language should the manufacturer supply the Declaration of Performance?! 6 Which performances should the manufacturer declare on the Declaration of Performance?! 6 Declaration of Performance and Hazardous Substances! 7 Declaration of Performance, what does it look like?! THE CE MARKING! 9 12 Key facts to know about CE marking for the CPR! 12 What does it look like?! 13 Derogations to use the CE mark! 13 BASIC REQUIREMENTS FOR CONSTRUCTION WORKS! 14 Sustainable use of natural resources! 14 Basic requirements: 7 requirements under the CPR! 14 SYSTEM OF ASSESSMENT AND CONSTANCY OF PERFORMANCE! How does it work?! 15 15 CHAPTER 2 - THE APPLICATION OF CPR AT A GLANCE! 16 CHAPTER 3 - ECONOMIC OPERATORS! 17 MANUFACTURER! 17 DISTRIBUTOR! 18 IMPORTER! 18 AUTHORISED REPRESENTATIVE! 19 THE CONDITIONS UNDER WHICH AN IMPORTER/DISTRIBUTOR BECOMES A MANUFACTURER! CHAPTER 4 - HARMONISED STANDARDS AND EUROPEAN ASSESSMENT DOCUMENTS! 19 20 HARMONISED STANDARDS! 20 EUROPEAN TECHNICAL ASSESSMENT! 20 CHAPTER 5 - SIMPLIFIED PROCEDURES! 21 How does it work?! 21 Who can be defined as a micro-enterprise?! 21 CHAPTER 6 - ADDITIONAL POINTS! 22 VOLUNTARY MARKS! 22 PRODUCT CONTACT POINTS! 22 SERVICE PROVIDERS TECHNICAL ASSESSMENT BODIES! 22 NOTIFIED BODIES! 23 TRANSITIONAL ARRANGEMENTS SUMMARISED! 23 GLOSSARY! 24 USEFUL LINKS! 26 ANNEX I - PRODUCT AREAS! 27 ANNEX II - ORGALIME MEMBERS! 29 ANNEX III - LIST OF EUROPEAN SECTOR ASSOCIATIONS AND OTHER CONTRIBUTORS PARTICIPATING IN THE DRAFTING OF THIS GUIDE! 33 2 FOREWORD Regulation (EU) No 305/2011 lays down the conditions for the placing or making available on the market of construction products (see annex I) by establishing harmonised rules for declaring their performance in relation to their essential characteristics and for CE marking those products. The old Construction Products Directive (CPD) was revised because it was not applied in a harmonised way throughout the EU (in some member states, for example, the CE marking was not compulsory). Whereas a Regulation applies directly without need for national transpositions, from which such discrepancies can arise. So this revision was deemed necessary to remove remaining technical barriers to trade, and also to align with the principles of the New Legislative Framework. On 26 May 2008, the European Commission tabled the proposal for a new regulation and after years of discussion between the three institutions, the Regulation was finally adopted on 9 March 2011 and published in the Official Journal of the EU on 4 April 2011. The Regulation entered into force 20 days later, and becomes fully applicable from 1 July 2013. The purpose of this Orgalime guide is to explain the main changes and obligations for all economic operators arising from this Regulation, and to help Orgalime industries prepare to meet the new requirements, where necessary. This guide reflects the best knowledge of industry experts across Europe and the state of the art at the time of writing. It represents our best understanding; a binding interpretation of Community legislation, however, remains the exclusive competence of the European Court of Justice. Orgalime, the European Engineering Industries Association, speaks for 38 trade federations representing some 130,000 companies in the mechanical, electrical, electronic, metalworking & metal articles industries of 23 European countries. The industry employs some 10.3 million people in the EU and in 2012 accounted for some !1,840 billion of annual output. The industry not only represents some 28% of the output of manufactured products but also a third of the manufactured exports of the European Union. 3 INTRODUCTION From 1 July 2013, the new CPR will bring changes for those Orgalime member companies who already manufacture and place on the market products which are covered by a CPD-harmonised European standard (hEN) or European Technical Assessment (ETA). Other Orgalime members will be relatively unaffected. The affected members and products are predominantly in the electromechanical sector of Orgalime, however some electrical sector products are the subject of a CPD mandate, cables for example. The old CPD had different scope wording but essentially the same meaning, to be within the scope of the new CPR, a product must firstly be destined for permanent incorporation in construction works and have some bearing on the ability of the building or works to meet the expectations of occupants that it will not pose various risks to their safety nor be a source of harm to others. To be required to bear the CE mark and to have the new documentation for the CPR from July 2013, such a product must also be within the scope of a CPD-standards mandate, or be the subject of an ETA. This guide explains the changes for Orgalime members’ products within one of the product families for which a CPD mandate for harmonised standards is in place, or for which an ETA has been established. For those products – most low voltage products or gas appliances for example – which may meet the basic scope definition but for which there is no ETA nor a CPD mandate which includes them, their position with regard to the new CPR should not change, unless mandates do. The Guide should therefore be read in this context. It is a living document and should mandates change or new product family mandates be issued, the Guide will be updated accordingly. 4 CHAPTER 1 - MAIN CONCEPTS The Construction Product Regulation (CPR) places more emphasis on the supply chain and imposes legal obligations on manufacturers, importers and distributors and on those companies in the supply chain which either place a product on the market under their own name, or trademark or modify a construction product already placed on the market so as to change its essential characteristics. A full description of the obligations placed on the supply chain is given in chapter 3. The CPR also imposes some new changes for manufacturers who want to place a construction product on the market. DECLARATION OF PERFORMANCE The previous requirement for a Declaration of Conformity (DoC) has been replaced by a requirement for a Declaration of Performance (DoP). The manufacturer will have to draw up a DoP when a product, whether covered by a harmonised standard (hEN) or by a European Technical Assessment (ETA), is placed on the market. Key facts to know about the Declaration of Performance 1 The DoP is one of the key features of the CPR. In this document, the manufacturer provides information about the essential characteristics of the product he wants to place or make available on the market. The essential performance characteristics are given in the relevant harmonised standard to which he should refer in drawing up his DoP. A complete list of harmonised standards supporting the CPD/R is available from the New Approach Notified and Designated Organisations (NANDO) website and a list of ETAs is given in the European Organisation for Technical Approvals (EOTA) website. Drafting a Declaration of Performance is also one of the pre-requisites for manufacturers to CE mark their products. By drawing up a DoP, the manufacturer assumes the responsibility for the conformity of the construction product with the declared performance. So manufacturers must take particular care in drafting their DoP and in declaring the intended use of the product and at least one of the relevant essential characteristics for each of the declared intended use. For those characteristics where there is no performance declared, the term ‘No Performance Determined’ (NPD) should be reported. From the information provided in the DoP, the user is then able to decide which product is most suitable for his purposes. All the information the DoP should contain is described in Annex III of the Regulation. 1 Cf. page 11, n°8 Declared performance. 5 Derogations from drawing up a Declaration of Performance In some limited circumstances a DoP is not compulsory: Products individually manufactured or custom-made, in a non-series process and in response to a specific order and installed in a single identified construction work by a manufacturer who is responsible for the safe incorporation of the product in the construction work. Products manufactured on the construction site where they are to be incorporated. Products manufactured in a traditional manner or in a manner appropriate to heritage conservation of protected works/buildings. The derogation from drawing up a Declaration of Performance has a direct consequence on affixing the CE marking: if the manufacturer does not draw up a DoP, the product does not have to be CE marked. He might however have to CE mark if the product falls within the scope of other directives! How to supply the Declaration of Performance? The DoP can be supplied either in paper form, by electronic means or by using a website (this last possibility will be available as soon as the Commission has drafted the delegated act with the relevant criteria). At this stage, the delegated act will not be ready by 1 July 2013. If the construction product falls in the scope of other directives, the manufacturer should draw up a Declaration of Performance for the CPR and a Declaration of Conformity for the other directive(s). In which language should the manufacturer supply the Declaration of Performance? The DoP is to be supplied in the language or the languages required by the member state where the product is made available. Which performances should the manufacturer declare on the Declaration of Performance? Levels, classes and threshold applicable to the essential characteristics of the products are contained in the Harmonised Standards (hEN) or in European Technical Assessments (ETA). The DoP should therefore include the performance of the essential characteristics of the construction product which are related to the intended use or uses. When the manufacturer does not assess the performance vis a vis the listed essential characteristics, he should record ‘No Performance Determined’ (NPD). Be careful and check first, the European Commission can also indicate essential characteristics for which the NPD option is not allowed! This point is specified in the harmonised product standard. 6 Declaration of Performance and Hazardous Substances Where applicable, the DoP should be accompanied by information on hazardous substances in the construction product. The information should initially be limited to substances referenced in Articles 31 and 33 of the Regulation EC 1907/2006 (REACH). What are these substances and how should this information be given? According to Article 31, a Safety Data sheet is to be prepared by each supplier of substances or mixtures, where: They are respectively considered as hazardous in accordance with Regulation (EC)1272/2008 and dangerous in accordance with Directive 1999/45/EC. The substance is persistent, bioaccumulative and toxic or very persistent and very bioaccumulative. The substance is referred to in the candidate list of the REACH Regulation. The Safety report is to be supplied if the mixture is not dangerous according to Directive 1999/45/ EC but: Contains in an individual concentration of 1% by weight for non-gaseous mixtures and 0,2% by volume for gaseous mixtures at least one substance posing human health or environmental hazards; or Contains in an individual concentration of 0,1% by weight for non-gaseous mixtures at least one substance that is persistent, bioaccumulative and toxic or very persistent and very bioaccumulative; or Is a substance for which there are Community workplace exposure limits. The safety report is to be supplied in the language of the member state. The safety report is supplied free of charge! Article 33 of the REACH Regulation requires that the supplier of an article which contains a substance in a concentration above 0,1% weight by weight shall provide sufficient information to allow safe use of the article including, as a minimum, the name of the substance. The substances considered in this article 33 are subject to authorisation and include: Substances which are carcinogenic, mutagenic and toxic for reproduction (class 1A or 1B). Substances which are persistent, bio accumulative and toxic. Substances which are very persistent and very bio accumulative. Substances which have endocrine disrupting properties and those substances (persistent, bio accumulative and toxic or very persistent and very bio accumulative) which do not fully meet the criteria above but for which there is scientific evidence of serious effects on human health and which are identified on a case by case basis in accordance with the procedures identified in Article 59 of REACH. 7 These substances (generally referred to as Substances of Very High Concern) are referred to in the REACH candidate list. Please note there is no specific model for informing on these substances in articles. You can use the model provided in the Orgalime guide to REACH. Be careful! Some products, some cables for instance, are required also to comply with other directives on hazardous substances, RoHS in the case of those cables. By 25 April 2014, the Commission will assess the specific need for information on the content of hazardous substances in construction products and consider the possible extension of information requirements to other substances. Information on hazardous substances must accompany the DoP (paper electronic format, or using website are all acceptable). This chapter will be updated as new information becomes known. SOME PRACTICAL QUESTIONS Are manufacturers obliged to supply a DoP before 1 July 2013? Legally, manufacturers are not obliged to supply a DoP before that date but if they wish to do so, they can supply a DoP with their product based on the information reported in the declaration of conformity without additional test. As a manufacturer, I have placed products on the market before 1 July 2013 for which I have a certificate of conformity or a declaration of conformity with the CPD. What shall I do with these products? Products already on the market before 1 July 2013 in conformity with the CPD are deemed to comply with the CPR after. A manufacturer can, if he wishes, draw up a DoP on the basis of the pre-1 July 2013 conformity declaration. For products made available after 1 July 2013, you should draw up a Declaration of Performance and CE mark them in conformity with the CPR. But you do not need to carry out further testing (you can still use the specifications of the pre 1 July conformity document Declaration of Conformity to draw up the DoP) if nothing else has changed. As a distributor or an importer, if I have on my shelves products which have been made available before 1 July 2013, can I distribute them after the 1 July 2013? Yes, you can still distribute them after 1 July 2013, without any change! It is still possible that a customer might be reluctant to buy such products which do not conform to the new Regulation and may ask you to bring them to conformity! Make sure the DoP and CE mark follow the construction product, in whatever unit it is sold (traceability of the DoP). As from 1st July 2013, if you are placing your construction product on several EU member states, you will have to translate your DoP in the language(s) required by that member state. 8 Declaration of Performance, what does it look like? (click on the number to see the explanation) DECLARATION OF PERFORMANCE No. 001CPR2013-07-14 1. Unique identification code of the product-type: Positive pressure air/flue terminal with metal flue duct for C62- and C63-type gas appliances T120- P1- D-Vm-L40045- O50 2. Type, batch or serial number or any other element allowing identification of the construction product as required under Article 1(4): Positive pressure air/flue terminal with metal flue duct for C62- and C63-type gas appliances T120- P1- D-Vm-L40045- O50 3. Intended use or uses of the construction product, in accordance with the applicable harmonised technical specification, as foreseen by the manufacturer: Convey air for combustion, and the products of combustion from appliances to the outside atmosphere. 4. Name, registered trade name or registered trade mark and contact address of the manufacturer as required under Article 11(5): AnyCo SA, PO Box 21 B-1050 Brussels, Belgium Tel. +32987654321 Fax: +32123456789 Email: [email protected] 5. Where applicable, name and contact address of the authorised representative whose mandate covers the tasks specified in Article 12(2): Anyone Ltd Flower Str. 24 West Hamfordshire UK-589645 United Kingdom Tel. +44987654321 Fax: +44123456789 e-mail: [email protected] 6. System or systems of assessment and verification of constancy of performance of the construction product as set out in CPR, Annex V: System 2+ 7. In case of the declaration of performance concerning a construction product covered by a harmonised standard: Notified factory production control certification body No. 5678 performed the initial inspection of the manufacturing plant and of factory production control and the continuous surveillance, assessment and evaluation of factory production control and issued the certificate of conformity of the factory production control. 8. Declared performance Essential characteristics Compressive strength Resistance to fire Gas tightness/leakage: • of the flue • of the air supply duct Flow resistance coefficient: • of the flue • of the air supply duct Thermal resistance of air/flue terminal: • with separate air/flue configuration • with concentric air/flue configuration Performance Harmonised technical specification Pass [N] [1] [2] [3] [4] [5] [6] [7] [8] 50 ! 0,006 l s-1 m-2 (under a positive pressure of 200 Pa) ! 0,28 l s-1 m-2 (under a positive pressure of 40 Pa) EN 14989-1: 2007 1,5 (declared) 2,5 (declared) 0,5 m2K/W (declared) 0,35 m2K/W (declared) Thermal shock Pass Flexural tensile strength Pass Durability: • against chemicals • against corrosion • freeze thaw Pass Pass Pass 9. The performance of the product identified in points 1 and 2 is in conformity with the declared performance in point 8. This declaration of performance is issued under the sole responsibility of the manufacturer identified in point 4. Signed for and on behalf of the manufacturer by: ……………………………………………………………………………………………………………………………… (name and function) …………………………………..……………" …………………………………..…………… (place and date of issue)# (signature) [9] 9 [N] Number Reference number of the DoP assigned by the manufacturer. The reference number enables identification of the DoP in relation to a specific product-type. [1] Unique identification code Reference number assigned by the manufacturer to help identify the product for which the DoP has been drawn up. The manufacturer can use the same number for the DoP and the unique identification code. [2] Type, batch or serial number or any other element allowing identification of the construction product The manufacturer has to give a type, batch or serial number to his product, for its identification. This information can be the same as the unique identification code, or the manufacturer can use another code which allows the user to technically identify the product. [3] Intended use or uses of the construction product The manufacturer will find this information in the Annex ZA of the harmonised standard of the product. The technical specifications can define one or several intended uses in relation to the relevant essential characteristics. [4] Name, registered trade name or registered trade mark and contact address of the manufacturer The manufacturer has to give these details (name, address, etc…) on the DoP so all economic operators in the supply chain know who is responsible for the conformity of the product with the declared performances. [5] Where applicable, name and contact address of the authorised representative If an authorised representative is acting on behalf of the manufacturer, the name and address of this authorised representative has to appear on the DoP. [6] System or systems of assessments and verification of constancy of performance of the construction product (AVCP) The manufacturer has to indicate which system has been applied to the product. This information is found included in Annex ZA of the relevant harmonised standard.. 10 [7] In case the assessment and verification of constancy of performance involves a notified body It is necessary to report the name and the identification number of any notified body involved, the tasks performed and the document(s) issued at the end of the assessment (certificate of constancy of performance, certificate of conformity of the factory production control, tests, calculations…) should be included on the DoP. If a European Technical Assessment (ETA) has been issued for the product, the name of the Technical Assessment Body has to be given, also the reference number of the ETA and the European Assessment Document. [8] Declared performance2 Column 1 (essential characteristics): should include the list of essential characteristics given in the harmonised technical specification for the declared intended use(s). Column 2 (performance): in relation with each essential characteristic listed in the first column, the manufacturer should declare the performance, by level or class or in a description. This information also is found in the Annex ZA of the relevant harmonised standard. If no performance is declared, the DoP should state ‘No Performance Determined’ (NPD). Column 3: for each essential characteristic listed in column 1, the manufacturer should indicate the reference number and date of issue of the harmonised standard for the product or the ETA used for the assessment of each essential characteristic. [9] Signature Each original DoP is to be signed by the manufacturer or by the responsible person appointed by the manufacturer, including name, function, place and date of issue. 2 Cf. page 5, Declaration of Performance. 11 THE CE MARKING The CE marking is a passport to free circulation. Not a quality mark, it is merely a statement that the product complies with the applicable legislation. On a construction product, it indicates that the product conforms to an hEN or an ETA. Key facts to know about CE marking for the CPR Under the CPR, the CE mark is now compulsory for manufacturers placing construction products covered by such a harmonised standard on the EU market. Under the CPR (as for the old CPD) there is no alternative route to CE marking if such a harmonised standard exists, making these standards quasi mandatory. If the product is not fully covered by a harmonised standard, the manufacturer may apply for a European Technical Approval, which will assess that a particular product can be CE marked for and placed on the market under CPR. The CE marking symbol is to be used in accordance with the general principles set out in Article 30 of Regulation (EC) No 765/2008 and shall be affixed visibly, legibly and indelibly: To the product. To a label attached to it. To the packaging (if not possible on the product itself). To the accompanying documents (if not possible neither on the product or on the packaging). It is accompanied on the product/packaging/documents by other information. I am a UK manufacturer. It was not compulsory for me to CE mark my products under the CPD. What shall I do now? If your construction products are already on the market before 1 July 2013, they still can be sold on those markets (UK, Ireland and Sweden) where the CE marking is not mandatory. If not yet on the market before 1 July 2013, in order to sell them after that date, you can use the certification of conformity of the CPD to draw up the declaration of performance and therefore CE mark your products. 12 What does it look like? CE marking, consisting of the ‘CE’ symbol 0123 Identification number of the product certification body AnyCo Ltd, PO Box 21, B-1050, Brussels, Belgium Name and the registered address of the manufacturer, or identifying mark 13 Last two digits of the year in which the marking was first affixed 00001-CPR-2013/05/12 Reference number of the DoP EN 123 - 5: 2009 No. of European standard applied, as referenced in OJEU (see note 14) Product A Unique identification code of the product-type intended to be used in (e.g. curtain walling, fire compartmentation, etc.) Intended use of the product as laid down in the European standard applied essential characteristic 1: 50N/cm2 essential characteristic 2: Pass essential characteristic 3: Class A1 essential characteristic 4: RE 60 essential characteristic n: xxx durability of essential characteristic 1: expressed as indicated in the DoP durability of essential characteristic n: expressed as indicated in the DoP dangerous substance X : Less than 0,2 ppm Level or class of the performance declared Derogations to use the CE mark Similarly to the DoP, there are three circumstances in which a manufacturer is not obliged to affix the CE marking for construction products placed on the market: The product is individually manufactured or custom-made, in a non-series process and in response to a specific order and installed in a single identified construction work by a manufacturer who is responsible for the safe incorporation of the product in the construction work. Products manufactured on the construction site for incorporation in that construction work. Products manufactured in a traditional manner or in a manner appropriate to heritage conservation. These derogations only apply in the absence of European or National provisions (i.e. national building regulations). Some CPR products are excluded from a CPD standards mandate where other measures already cover the relevant requirements, because they are meeting the requirements of the Gas Appliances Directive or the Low Voltage Directive for example, and are therefore CE marked according to these directives. 13 BASIC REQUIREMENTS FOR CONSTRUCTION WORKS The ‘Essential Requirements’ set out in the Construction Products Directive have been renamed ‘Basic Works Requirements’ in the Construction Products Regulation. The wording for each requirement is unchanged with the exception of the third Basic Works Requirement for ‘Hygiene, health and the environment’. Here a reference has been added to the effect that the construction works should “not have an exceedingly high impact, over their entire life cycle, on the environmental quality or on the climate during their construction, use and demolition”. However, the most significant change is the addition of a seventh Basic Works Requirement on the ‘Sustainable use of natural resources’. This additional requirement is elaborated below: Sustainable use of natural resources The construction works must be designed, built and demolished in such a way that the use of natural resources is sustainable and ensure the following: Recyclability of the construction works, their materials and parts after demolition. Durability of the construction works. Use of environmentally compatible raw and secondary materials in the construction works. The inclusion of this requirement will allow member states to regulate for the use of sustainable products and for a sustainability characteristic to be included in the DoP and the CE marking. However, for this to happen the member state will need a method for assessing the product’s performance. Basic requirements: 7 requirements under the CPR 1. 2. 3. 4. 5. 6. 7. Mechanical resistant and stability. Safety in case of fire. Hygiene, health and environment. Safety and accessibility in use. Protection against noise. Energy economy and heat retention. Sustainable use of natural resources. Discussions are currently taking place in order to decide how the 7th Basic Requirement will be declared in the DoP. It seems that when Environment Product Declarations exist, these could be used as they provide a list of characteristics representing the environmental aspects. Unless an additional essential characteristic is included in a harmonised standard for sustainability, there is no need to define, nothing changes for the manufacturer. A request heard by a manufacturer in real life: you need to run a burglar resistance performance evaluation! Please note that burglar resistance is not part of the basic requirement on safety and accessibility in use. Refer to Annex I, clause 4 of the Regulation, which clearly states that it is the construction works that must be designed in such a way that they do not present unacceptable risk in case of burglaries, and not the components. Therefore, be careful if you are asked to include such a burglar resistance performance in relation to basic requirement no 4. 14 SYSTEM OF ASSESSMENT AND CONSTANCY OF PERFORMANCE This is the system which the manufacturer uses to assess the performance of his construction product in relation to its essential characteristics. Once this process is finished, the DoP can be prepared, which is then kept with the technical file of the product. This documentation might be supported by a certificate of constancy of performance, certificate of conformity of the factory and production control, test laboratory reports or certificates, and/or a manufacturer’s own test results, depending on the system of Assessment and Verification of Constancy of Performance (AVCP) required for that product. How does it work? This procedure is carried out in accordance with one of the systems described in Annex V of the Regulation. The bodies involved in the system of assessment and verification of constancy of performance are: Product certification body carried out by a body having the competence to carry out a product certification in accordance with given rules of procedure. Factory production control certification body carried out by a body having the competence and responsibility to carry out factory production certification in accordance with given rules. Testing laboratory carried out by a notified laboratory which examines, measures and determines the characteristics or performance of materials or construction products. The European Commission (through the adoption of delegated acts) could revise the system or systems to be applied to a family of construction products taking into account their impact on health and safety. The table below summarises Annex V of the Regulation which describes the systems to be used, the items to be carried out by the manufacturer and the involvement of notified bodies: Actor involved Manufacturer Task to be carried out Factory Production Control Sys.1+ ! Sys.1 ! ! Sys.3 ! ! Type-testing Notified body Sys.2+ Declaration of Performance ! ! ! Initial Inspection ! ! ! Continuous Surveillance ! ! ! Type-testing ! ! Audit Testing ! Sys.4 ! ! ! ! ! 15 CHAPTER 2 - THE APPLICATION OF CPR AT A GLANCE Is my product in the scope of the CPR? NO YES Is it covered by hEN or conformed to ETA? YES NO No DoP necessary No CE necessary Do I want ETA? DoP Derogation YES I request for an ETA to a TAB [art.19] Is my C.P. fully covered by an EAD? YES (assess the verification and constancy of performance) TAB prepares an ETA Draw up DoP NO The manufacturer prepares technical file and sends it to the TAB [Annex II] TAB defines a workprogramme [Annex II] The organisation of TABs adopts the EAD [Art. 22; Annex II] The TABs modify and adjust the EAD TAB prepares an ETA YES Do the manufacturer or the EC present comments? NO The organisation of TABs adopts the EAD [Art. 22; Annex II] 16 CHAPTER 3 - ECONOMIC OPERATORS The CPR makes it clear that obligations apply all along the supply chain, and it imposes certain legal requirements on the manufacturer, the importer, the distributor and any manufacturer’s authorised representative (a legal entity instructed by the manufacturer to act on his behalf). The CPR also clarifies under what conditions a distributor/importer becomes a manufacturer. Under those conditions the manufacturer’s responsibilities will fall on the distributor/importer. It is therefore extremely important for all companies along the supply chain to be aware of these conditions as failure to comply is a criminal act and subject to penalties. The definitions given in the CPR for manufacturer, importer, distributor and authorised representative and the legal requirements on each party are explained below. The definitions came into force on 24 April 2011 and are now part of European law. However, the requirements do not come into force until 1 July 2013. MANUFACTURER 'Defined as any natural or legal person who manufactures a construction product or who has such a product designed or manufactured and markets that product under his name or trademark' i.e. those companies who make or design and make construction products (e.g. include a list of products). Also, those who put products already CE marked, on the market under their own name/trademark (e.g. include a list of products). The requirements on the manufacturer include: 1. Drawing up a Declaration of Performance (DoP). 2. Affixing the CE marking to the construction product, a label attached to it or the packaging. 3. Drawing up technical documentation describing all relevant elements related to the required – system of assessment and verification of constancy of performance. 4. Keeping technical documentation and the DoP for 10 years (the contract under which the product is purchased might include a liability period which goes beyond 10 years). 5. Putting in place and maintain a certified Factory Production Control System. 6. Ensuring that all the products must bear a batch or serial number. This can be on the product, the packaging or the accompanying documentation. 7. Ensuring that all the products must bear the name and address or trademark of the manufacturer. This can be on the product, the packaging or the accompanying documentation. 8. Ensuring that all the products are accompanied by safety instructions. 9. Identifying non-conforming products and either put them right or withdraw them from the market. 10. Providing national authorities with all information necessary to demonstrate conformity with the DoP, upon a ‘reasoned’ request. 17 DISTRIBUTOR 'Defined as any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a construction product available on the market' i.e. those companies that buy and sell construction products within the EU. The distributor must: 1. 2. 3. 4. 5. 6. 7. 8. 9. Act with due care in relation to the requirements of the CPR. Ensure that the product bears the CE mark. Ensure that the product is accompanied by the appropriate documentation. Ensure that the product has the safety instructions in the appropriate language. Ensure that the manufacturer and importer have complied with their requirements and that they do not put products on the market that do not conform to the requirements. Inform the manufacturer or the importer and the market surveillance authorities where the construction product presents a risk. Ensure that the storage and transportation of the product do not jeopardise the performance of the product. Take corrective action and/or withdraw non-conforming products. Provide national authorities with all information necessary to demonstrate conformity with the DoP, upon a ‘reasoned’ request. IMPORTER 'Defined as any natural or legal person established within the Union, who places a construction product from a third country on the Union market' i.e. those companies that import construction products e.g. steel sections, structural bolts, from manufacturers based outside the European Union. The importer must: 1. Only place construction products on the market that comply with the CPR. 2. Ensure that the assessment and the verification of constancy of performance have been carried out by the manufacturer. 3. Ensure that the manufacturer has drawn up the technical documentation. 4. Ensure that the manufacturer has drawn up the DoP. 5. Ensure that the product bears the CE marking. 6. Ensure that the product is accompanied by the required documentation. 7. Not place on the market construction products that do not conform to the regulation. 8. Place his/her name and address on the product. 9. Ensure that the product is accompanied by the safety instructions. 10. Ensure that the storage and transportation do not jeopardise the performance of the product. 11. Carry out sample testing. 12. Take corrective action and/or withdraw non-conforming products. 13. Retain records for 10 years. 18 AUTHORISED REPRESENTATIVE ‘Defined as any natural or legal person established within the Union who has received a written mandate from a manufacturer to act on his behalf in relation to specific tasks’ An authorised representative can be appointed by the manufacturer to act on his behalf to carry out some of the tasks necessary to comply with the CPR. For example affix the CE marking, drawing up the DoP and act as a contact point for the national authorities. However, the authorized representative cannot take responsibility for the factory production control system. This remains the responsibility of the manufacturer. “Authorised representative” should not be confused with a manufacturer’s commercial representative, who plays no part in ensuring the product complies with the CPR. An authorised representative must be established within the European Community, and work under the authorisation of the manufacturer. There must be a written agreement between the two parties. THE CONDITIONS UNDER WHICH AN IMPORTER/DISTRIBUTOR BECOMES A MANUFACTURER Article 15 of the CPR sets out the conditions under which an importer/ distributor becomes a manufacturer. ‘An importer or distributor shall be considered a manufacturer for the purpose of this Regulation and shall be subject to the obligations of a manufacturer under Article 11, where he places a product on the market under his name or trademark or modifies a construction product already placed on the market in such a way that conformity with the declaration of performance may be affected.’ This requirement lists two scenarios under which an importer or a distributor is considered a manufacturer. The first of these is where a company buys a product made by another party and places it on the market under his own name or trade mark (for example a CE Marked steel section may be placed on the market by a steel manufacturer). In this case even though the company does nothing to the product to change its declared characteristics, that company becomes the manufacturer and is subject to the requirements on the manufacturer as set out above. This is sometimes called ‘badge engineering’. The second scenario is where a company buys an already CE marked construction product (for example a CE marked steel section), modifies that product (for example a service centre may part fabricate the steel sections before selling it to the steelwork contractor) and places it back on the market. Under this scenario, that company becomes the manufacturer of the modified construction product. That company is entitled to assume that the original manufacturer has correctly CE marked the product and can communicate onwards the un-modified performance characteristics details without repeating the Initial Type Testing (ITT) on the basis that it has done nothing to change those characteristics. However, that company will have to perform further ITT for any characteristics that have been changed (for example any drilled/punched holes must conform to the essential tolerances given in BS EN 1090-2; similarly shot-blasting and painting the section will affect the durability and reaction to fire). 19 CHAPTER 4 - HARMONISED STANDARDS AND EUROPEAN ASSESSMENT DOCUMENTS HARMONISED STANDARDS Harmonised standards are established by European Standardisation Bodies (in practice for CPR, it is generally CEN which is responsible for issuing a hEN) which receives a mandate from the European Commission. It is those standards which must then be followed. There is no “or equivalent” alternative route. The harmonised standard: Will help the manufacturer to assess technically the performance of its product in relation to the essential requirements and to finally draft the DoP. Will contain the intended use of the products it covers. Will determine which factory production control system should be applied. Will include the technical details necessary for the implementation of the ACVP. The Annex ZA of the hEN contains all the harmonised provisions which have to be applied to fulfil the obligations of the CPR. (It is understood that the current Annex ZAs, already drafted under Commission mandates, may have to be adapted/amended in order to meet the changed requirements of the Construction Products Regulation.) Harmonised standards produced under those mandates are then published by the Commission in the Official Journal of the EU, and are added to the NANDO CPD/R list EUROPEAN TECHNICAL ASSESSMENT When a product is not covered by a harmonised standard, when at least one of its essential characteristics is not assessed appropriately or when no assessment method is provided in the harmonised standard for at least one essential characteristic, then a manufacturer is entitled (but not obliged) to request a European technical assessment for his product. This request is addressed to technical assessment bodies. The ETA will enable the manufacturer to draft the declaration of performance and to consequently CE mark his product for the CPR. As is the case with harmonised standards, the European Technical Assessment will be published in the Official Journal of the EU. Contrary to an ETA issued before 1 July 2013, ETAs issued after that date will have no time limit on their validity. If you have an ETA for a specific product issued before 1 July 2013, you can use it for its full 5-year validity period). 20 CHAPTER 5 - SIMPLIFIED PROCEDURES In order to alleviate the financial burden and administrative burden of preparing the DoP on very small firms, the Regulation has laid down simplified procedures for micro-enterprises. If you are a micro-enterprise and manufacture construction products covered by a harmonised standard, you can use other methods to determine the product type on basis of type-testing for system 3 (with notified bodies) or system 4 (without notified bodies). You can also treat your products belonging to system 3 with the provisions of system 4. When the manufacturer uses this simplified procedure, he should then demonstrate by means of Specific Technical Documentation that the construction product complies with the requirement and that the procedures used are equivalent to those described in the harmonised standard. How does it work? If you want to use the simplified procedure (you must be a micro-enterprise!), when determining the product type you can replace type-testing or type-calculation using Specific Technical Documentation. You have to demonstrate: One or several essential characteristics or the construction product can achieve a level or class of performance without testing or calculation in accordance with the conditions described in the relevant harmonised standard. The construction product placed on the market corresponds to the product-type of another construction product already tested by another manufacturer to the relevant standard. In this case, you can declare the performance corresponding to the test results of the other product. But you need the authorisation of the other manufacturer! The construction product is a system made of components and these components have already been tested for one or several characteristics (always in accordance with the relevant standard). In this case you can declare the performance corresponding to the test results (all or in part) for the system. Again, you need the authorisation of the other manufacturer! Who can be defined as a micro-enterprise? A micro-enterprise is defined by a Commission Recommendation of 6 May 2003. An enterprise can be a micro-enterprise if: It employs less than 10 persons and It has an annual turnover and/or annual balance sheet total which does not exceed !2 million. 21 CHAPTER 6 - ADDITIONAL POINTS VOLUNTARY MARKS It is important to repeat, as CPR is very clear on this point, that the CE marking is the only mark required to guarantee that a construction product has been put on the market meeting the requirements of the CPR. Nevertheless, manufacturers can use voluntary marks together with the CE marking, provided that: These voluntary marks do not bring confusion with the CE mark. They do bring an added value. For instance, they could follow from assessing some characteristics which are not covered in the CE marking and give a third party guarantee that the construction product complies with the declared performance, or declare that a product is fit for a specific use, provided this is not already included in the harmonised standard for the product. PRODUCT CONTACT POINTS The CPR regulation envisages that product contact points will be set up in each member states and their details communicated to the other member states and to the Commission. These product contact points should provide information on the technical rules applicable to a specific product in the territory in which this contact point is established. In a word, these contact points are set up to help the economic operators and/or national authorities with any information relevant to the applicability of the Regulation in a member state. The information provided by these contact points is provided free of charge. The Commission will draw up and regularly update the list of Product contact points and publish it in the Official Journal of the EU. SERVICE PROVIDERS TECHNICAL ASSESSMENT BODIES In the framework of the CPR, these service providers (notably notified bodies and technical assessment bodies) have several obligations to meet. As a manufacturer, when you make a request for a European Technical Assessment (this means that your product is not falling in the scope of a harmonised standard and/or an assessment method is not included in the harmonised standard for at least one essential characteristic), the European Assessment Document, under which the ETA is conducted, drawn up by the Technical Assessment Body (TAB) should respect some main principles: It should be transparent for the manufacturer. It should define appropriate mandatory time limits in order to avoid any delay. It should take into account the protection of his commercial secrets and confidentiality. It should be cost-effective for the manufacturer. 22 Last but not least, the TAB should bear the full costs of the development and adoption of the European Assessment Document! Technical Assessment Bodies are designated by their member states. The name and address of each TAB and the product areas for which it is designated should be communicated to both the European Commission and other member states. NOTIFIED BODIES Notified bodies carry out third party tasks in the process of assessment and verification of constancy of performance. They also have obligations vis-à-vis the manufacturers, for carrying out AVCP with transparency as regards the manufacturer, and avoiding unnecessary burden for all economic operators. TRANSITIONAL ARRANGEMENTS SUMMARISED The Regulation foresees that Construction Products placed on the market in accordance with the CPD before 1 July 2013 are deemed to comply with the Regulation. In consequence: A manufacturer may draw up a Declaration of Performance based on the Certificate of Conformity issued before 1 July 2013. Guidelines for European Technical Approvals published before 1 July 2013 may be used as EADs. ETAs issued in accordance with the CPD before 1 July 2013 may be used as ETA throughout the period of validity (usually 5 years from the date of issue). Those manufacturers who are in the ETA process before 1 July 2013 should contact their Technical Assessment Body for these specific cases. 23 GLOSSARY Authorised representative Any natural or legal person established within the EU who has received a written mandate from a manufacturer to act on his behalf in relation to specific tasks. Assessment and verification of constancy of performance The assessment and verification of constancy of performance under the Construction Products Regulation is carried out in order to demonstrate that the construction product is in conformity with the technical specification of the Regulation (either through a harmonised standard or a European Technical Assessment. The assessment and verification of constancy of performance is carried out through type-testing and analysis of how the product behaviours through Factory Production Control (FPC). The system of assessment and verification of constancy of performance is set by the European Commission. Certificate of constancy of performance The certificate of constancy of performance is the document delivered at the end of the assessment and verification of constancy of performance which demonstrates that a product conforms to the harmonised technical specifications. Construction product Any product or kit which is produced and placed on the market for incorporation in a permanent manner in construction works or parts thereof and the performance of which has an effect on the performance of the construction works with respect to the basic requirements for buildings and civil engineering works. Distributor Any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a construction product available on the market. Essential characteristics Refer to those characteristics of the construction product which relate to the basic requirements for building and civil engineering works. European Assessment Document A document adopted by the organisation of Technical Approval Bodies (TABs) for the purposes of issuing European Technical Assessments (ETA). 24 European Technical Assessment The documented assessment of the performance of a construction product, in relation to its essential characteristics, in accordance with the respective European Assessment Document (EAD). Factory production control Means the permanent internal control of production exercised by the manufacturer. The aim is to maintain and control the behaviour of a product so that it complies with the declared performance of the essential characteristics. Harmonised Technical Specifications Harmonised standards and European Assessment Documents (EAD). Importer Means any natural or legal person established within the Union, who placed a construction product from a third country on the Union market. Kit Means a construction product placed on the market by a single manufacturer as a set of at least two separate components that need to be put together to be incorporated in the construction works. Life cycle The life cycle is the consecutive and interlined stages of a construction product’s life from raw material acquisition or generation from natural resources to final disposal. Making available on the market Any supply of a construction product for distribution or use on the Union market in the course of a commercial activity, whether in return of payment or free of charge. Manufacturer Any natural or legal person who manufactures a construction product or who has such construction product designed or manufactured, and markets that product under his name or trademark. Performance of a construction product The performance related to the relevant essential characteristics, expressed by level or class, or in a description. Placing on the market Means the first marking available of a construction product on the Union market. 25 Product-type The set of representative performance levels or classes of a construction product, in relation to its essential characteristics, produced using a given combination of raw materials or other elements in a specific production process. Specific technical documentation Documentation demonstrating that methods within the applicable system of assessment and verification of constancy of performance have been replaced by other methods, provided that the results obtained by those other methods are equivalent to the results obtained by the test methods of the corresponding harmonised standard. Threshold level A minimum or maximum performance level of an essential characteristic of a construction product. USEFUL LINKS European Commission - Construction Products Regulation (CPR) website [link] New Approach Notified and Designated Organisations (NANDO) [link] European Organisation for Technical Approvals (EOTA) [link] 26 ANNEX I - PRODUCT AREAS EN 4.4.2011 Official Journal of the European Union L 88/39 ANNEX IV PRODUCT AREAS PRODUCT AREAS AND REQUIREMENTS FOR TABS Table 1 — Product areas AREA CODE PRODUCT AREA 1 PRECAST NORMAL/LIGHTWEIGHT/AUTOCLAVED AERATED CONCRETE PRODUCTS. 2 DOORS, WINDOWS, SHUTTERS, GATES AND RELATED BUILDING HARDWARE. 3 MEMBRANES, INCLUDING LIQUID APPLIED AND KITS (FOR WATER AND/OR WATER VAPOUR CONTROL). 4 THERMAL INSULATION PRODUCTS. COMPOSITE INSULATING KITS/SYSTEMS. 5 STRUCTURAL BEARINGS. PINS FOR STRUCTURAL JOINTS. 6 CHIMNEYS, FLUES AND SPECIFIC PRODUCTS. 7 GYPSUM PRODUCTS. 8 GEOTEXTILES, GEOMEMBRANES, AND RELATED PRODUCTS. 9 CURTAIN WALLING/CLADDING/STRUCTURAL SEALANT GLAZING. 10 FIXED FIRE FIGHTING EQUIPMENT (FIRE ALARM/DETECTION, FIXED FIREFIGHTING, FIRE AND SMOKE CONTROL AND EXPLOSION SUPPRESSION PRODUCT). 11 SANITARY APPLIANCES. 12 CIRCULATION FIXTURES: ROAD EQUIPMENT. 13 STRUCTURAL TIMBER PRODUCTS/ELEMENTS AND ANCILLARIES. 14 WOOD BASED PANELS AND ELEMENTS. 15 CEMENT, BUILDING LIMES AND OTHER HYDRAULIC BINDERS. 16 REINFORCING AND PRESTRESSING STEEL FOR CONCRETE (AND ANCILLARIES). POST TENSIONING KITS. 17 MASONRY AND RELATED PRODUCTS. MASONRY UNITS, MORTARS, AND ANCILLARIES. 18 WASTE WATER ENGINEERING PRODUCTS. 19 FLOORINGS. 20 STRUCTURAL METALLIC PRODUCTS AND ANCILLARIES. 21 INTERNAL & EXTERNAL WALL AND CEILING FINISHES. INTERNAL PARTITION KITS. 22 ROOF COVERINGS, ROOF LIGHTS, ROOF WINDOWS, AND ANCILLARY PRODUCTS. ROOF KITS. 23 ROAD CONSTRUCTION PRODUCTS. 24 AGGREGATES. 25 CONSTRUCTION ADHESIVES. 27 EN L 88/40 Official Journal of the European Union AREA CODE 4.4.2011 PRODUCT AREA 26 PRODUCTS RELATED TO CONCRETE, MORTAR AND GROUT. 27 SPACE HEATING APPLIANCES. 28 PIPES-TANKS AND ANCILLARIES NOT IN CONTACT WITH WATER INTENDED FOR HUMAN CONSUMPTION. 29 CONSTRUCTION PRODUCTS IN CONTACT WITH WATER INTENDED FOR HUMAN CONSUMPTION. 30 FLAT GLASS, PROFILED GLASS AND GLASS BLOCK PRODUCTS. 31 POWER, CONTROL AND COMMUNICATION CABLES. 32 SEALANTS FOR JOINTS. 33 FIXINGS. 34 BUILDING KITS, UNITS, AND PREFABRICATED ELEMENTS. 35 FIRE STOPPING, FIRE SEALING AND FIRE PROTECTIVE PRODUCTS. FIRE RETARDANT PRODUCTS. Table 2 — Requirements for TABs Competence Description of competence Requirement 1. Analysing risks Identify the possible risks and benefits for the use of innovative construction products in the absence of established/consolidated technical information regarding their performance when installed in construction works. A TAB shall be established under national law and have legal personality. It shall be indeä pendent from the stakeholders and from any particular interests. 2. Setting technical criteria Transform the outcome of the risk analysis into technical criteria for evaluating behaviour and performance of the construction products regarding the fulfilment of applicable national requirements; (a) objectivity and sound technical judgement; provide the technical information needed by those participating in the building process as potential users of the construction products (manufacturers, designers, contractors, installers). 3. Setting assessment methods Design and validate appropriate methods (tests or calculations) to assess performance for essential characteristics of construction products, taking into account the current state of the article. In addition, a TAB shall have staff with: (b) detailed knowledge of the regulatory provisions and other requirements in force in the Member States where it is designated, concerning product areas for which it is to be designated; (c) general understanding of construction practice and detailed technical knowledge, concerning product areas for which it is to be designated; (d) detailed knowledge of specific risks involved and the technical aspects of the construction process; (e) detailed knowledge of the existing harmonised standards and test methods within the product areas for which it is to be designated; (f) appropriate linguistic skills. The remuneration of the TAB personnel shall not depend on the number of the assessments carried out or on the results of such assessments. 28 ANNEX II - ORGALIME MEMBERS AUSTRIA FEEI Fachverband der Elektro- und Elektronikindustrie Österreichs Mariahilfer Strasse 37-39 – 1060 Vienna Tel : (43) 1 588 39 0 – Fax : (43) 1 586 69 71 E-mail : [email protected] - Web : www.feei.at President: Brigitte Ederer Director: Lothar Roitner FMMI Fachverband Maschinen & Metallwaren Industrie Wiedner Hauptstrasse 63, Postfach 335 – 1045 Vienna Tel : (43) 5 90 900 3482 – Fax : (43) 1 505 10 20 E-mail : [email protected] - Web : www.fmmi.at President: Christian Knill Director: Berndt-Thomas Krafft BELGIUM AGORIA La fédération de l'industrie technologique – De federatie van de technologische industrie Diamant Building, Bd. A. Reyers 80 – 1030 Brussels Tel : (32) 2 706 78 00 – Fax : (32) 2 706 78 01 E-mail : [email protected] - Web : www.agoria.be President: Christʼl Joris Director: Paul Soete BULGARIA BASSEL Bulgarian Association of Electrical Engineering and Electronics P.O. Box 76 – 1407 Sofia Tel: (359) 2 963 3532 or 963 3437 - Fax: (359) 2 963 0727 E-mail : [email protected] – Web : www.bcee-bg.org President: Roumen Atanassov Director: Boris Gotchev DENMARK DI Confederation of Danish Industries H.C. Andersen Boulevard 18 – 1787 Copenhagen V Tel : (45) 33 77 33 77 – Fax : (45) 33 77 33 00 E-mail : [email protected] - Web : www.di.dk President: Jesper Moeller Deputy Director General: Thomas Bustrup FINLAND The Federation of Finnish Technology Industries Eteläranta 10 – 00131 Helsinki 13 Tel : (358) 9 19231 – Fax : (358) 9 624462 Web : www.teknologiateollisuus.fi President: Ole Johansson Director: Jorma Turunen FRANCE FIEEC Fédération des Industries Electriques, Electroniques et de Communication Rue Hamelin 11-17 – 75783 Paris Cedex 16 Tel : (33) 1 45 05 70 70 – Fax : (33) 1 45 53 03 93 E-mail : [email protected] - Web : www.fieec.fr President: Pierre Gattaz Director: Eric Jourde FIM Fédération des Industries Mécaniques Maison de la Mécanique, rue Louis Blanc 39-41 – 92400 Courbevoie Tel : (33) 1 47 17 60 00 – Fax : (33) 1 47 17 60 16 E-mail : [email protected] - Web : www.fim.net President: Philippe Frantz Director General: Michel Athimon GERMANY VDMA Verband Deutscher Maschinen- und Anlagenbau e.V. Lyoner Strasse 18, Postfach 71 08 64 – 60582 Frankfurt/Main Tel: (49) 69 6603 0 – Fax : (49) 69 6603 1511 E-mail : [email protected] - Web : www.vdma.org President: Thomas Lindner Director: Hannes Hesse WSM Wirtschaftsverband Stahl- und Metallverarbeitung e.V. Uerdinger Str. 58-62 – 40474 Düsseldorf Tel: (49) 211 957868 22 – Fax : (49) 211 957868 40 E-mail: [email protected] - Web : www.wsm-net.de President: Gerhard Brüninghaus Director: Christian Vietmeyer 29 ZVEI Zentralverband Elektrotechnik- und Elektronikindustrie e.V. Lyoner Strasse 9, Postfach 70 12 61 – 60528 Frankfurt/Main Tel: (49) 69 6302 0 – Fax : (49) 69 6302 317 E-mail: [email protected] - Web : www.zvei.de President: Friedhelm Loh Director: Klaus Mittelbach HUNGARY MAGEOSZ The Hungarian National Association of Machinery and Power Engineering Industries 1012 Budapest, Kuny Domokos u. 13-15. Tel: +36 1 215 8868 – Fax : E-mail: [email protected] - Web : http://www.mageosz.hu/ President: László Deák Secretary General: Gábor Vadnai IRELAND IEEF Irish Engineering Enterprises Federation Confederation House, 84-86 Lower Baggot Street – Dublin 2 Tel: (353) 1 605 1676 – Fax : (353) 1 638 1676 E-mail: [email protected] – Web : www.ibec.ie/ieef President: Gerry Donovan Director: Marian Byron ITALY ANIE Federazione Nazionale Industrie Elettrotecniche ed Elettroniche Viale Lancetti 43, 20158 Milano Tel : (39) 02 326 41 – Fax : (39) 02 326 4212 E-mail : [email protected] - Web : www.anie.it President: Claudio Andrea Gemme Secretary General: Maria Antonietta Portaluri ANIMA Federazione delle Associazioni Nazionali dell' Industria Meccanica varia ed affine Via A. Scarsellini, 13 – 20161 Milano Tel : (39) 02 4541 8500 – Fax : (39) 02 4541 8545 E-mail : [email protected] - Web : www.anima-it.com President: Sandro Bonomi Director: Andrea Orlando LATVIA Association of Mechanical Engineering and Metalworking Industries of Latvia Ezermalas 6 - 1006 Riga Tel : (371) 755 48 25 - Fax : (371) 708 97 76 E-mail : [email protected] - Web : www.masoc.lv Chairman & President: Vilnis Rantins LITHUANIA LINPRA The Engineering Industries Association of Lithuania Savanoriupr 176 - 03154 Vilnius Tel : (370) 5 231 25 20 - Fax : (370) 5 231 25 20 E-mail : [email protected] - Web : www.linpra.lt President: Vaclovas Sleinota Director: Henrikas Mykolaitis LUXEMBOURG ILTM Industrie Luxembourgeoise de la Technologie du Métal B.P. 1304 – 1013 Luxembourg Tel : (352) 43 53 661 – Fax (352) 43 23 28 E-mail : [email protected] - Web : www.fedil.lu President: Jacques Lanners Director: Nicolas Soisson THE NETHERLANDS FME-CWM Association of Enterprises in the Technological Industrial Sector Boerhaavelaan 40, Postbus 190 – 2713 AD Zoetermeer Tel : (31) 79 353 1100 – Fax : (31) 79 353 1365 E-mail : [email protected] – Web : www.fme-cwm.nl President: Ineke Dezentjé Hamming Bluemink Director: Peter Bongaerts METAALUNIE Nederlandse Organisatie van Ondernemers in het Midden- en Kleinbedrijf in de Metaal Postbus 2600 – 3430 GA Nieuwegein Tel : (31) 3060 53344 – Fax : (31) 3060 53122 E-mail : [email protected] - Web : www.metaalunie.nl President: Michaël van Straalen Director: Jos Kleiboer NORWAY 30 Norsk Industri P.O. Box 7072 Majorstua – 0306 Oslo 3 Tel : (47) 22 59 0000 – Fax : (47) 22 59 0001 E-mail : [email protected] – Web : www.norskindustri.no President: Rassmus Sunde Director: Knut Sunde POLAND Polish Economic Chamber of Electrotechnics ul.Szubińska 17, 85-312 Bydgoszcz Tel/Fax : (48) 52 375 45 71 E-mail : [email protected] - Web : www.elektrotechnika.org.pl President: Janusz Nowak Managing Director: Janusz Nowastowski PORTUGAL AIMMAP Associação dos Industriais Metalurgicos, Metalomecanicos e Afins de Portugal Rua dos Platanos 197 - 4100 Porto Tel : (351) 22 616 68 60 - Fax : (351) 22 610 74 73 E-mail : [email protected] - Web : www.aimmap.pt Vice-President: Anibal José da Costa Campos General Manager: Rafael Campos Pereira ANEME Associação Nacional das Empresas Metalúrgicas e Electromecânicas Pólo Tecnológico de Lisboa, Rua Francisco Cortês Pinto, Nº2 (Lote 13 b),1600-602 Lisboa Tel : (351) 21 711 27 40 - Fax : (351) 21 715 04 03 E-mail : [email protected] - Web : www.aneme.pt President: José de Oliveira Guia Executive Vice President: João Reis SLOVENIA GZS-MPIA Metal Processing Industry Association C/o Chamber of Commerce and Industry of Slovenia Dimiceva 13 - 1504 Ljubljana Tel : (386) 1 58 98 000 – Fax : (386) 1 58 98 100 E-mail : [email protected] - Web : www.gzs.si President: Blaž Nardin Director: Janja Petkovšek (Mechanical and Metalworking) Director: Janez Renko (Electronics and Electrical) SPAIN CONFEMETAL Confederación Española de Organizaciones Empresariales del Metal Principe de Vergara 74 – 28006 Madrid Tel : (34) 91 562 5590 - Fax : (34) 91 562 8477 E-mail : [email protected] - Web : www.confemetal.es President: Javier Ferrer Dufol Director: Andres Sánchez de Apellaniz SERCOBE Asociación Nacional de Fabricantes de Bienes de Equipo Calle Jorge Juan 47 – 28001 Madrid Tel: (34)91 435 7240 – Fax : (34) 91 577 0910 E-mail: [email protected] - Web : www.sercobe.es President: Angel Lara Director: Antonio Garcíapons SWEDEN TEKNIKFÖRETAGEN The Association of Swedish Engineering Industries P.O. Box 5510 – 114 85 Stockholm Tel: (46)8 782 0800 – Fax : (46) 8 782 0900 E-mail: [email protected] - Web: www.teknikforetagen.se President: Leif Östling Director: Åke Svensson Communications: Jonas Cohen [email protected] SWITZERLAND SWISSMEM Schweizer Maschinen-, Elektro- und Metallindustrie Kirchenweg 4 – 8032 Zürich Tel : (41) 44 384 4111 – Fax : (41) 44 384 4242 E-mail : [email protected] - Web : www.swissmem.ch President: Hans Hess Director: Peter Dietrich UNITED KINGDOM BEAMA Federation of British Electrotechnical and Allied Manufacturers – Associations Ltd Westminster Tower, 3 Albert Embankment – London SE1 7SL Tel : (44) 207 793 3000 – Fax : (44) 207 793 3003 E-mail : [email protected] - Web : www.beama.org.uk President: Les Woolner Chief Operating Officer: Howard Porter 31 EAMA Engineering and Machinery Alliance 62, Bayswater Road - London W2 3PS Tel: (44) 20 7298 6450 – Fax: (44) 20 7298 6434 E-mail: [email protected] or [email protected] Web: www.eama.info Chairman: Martin Walder Alliance Secretary: Rupert Hodges GAMBICA Association for Instrumentation, Control, Automation and Laboratory Technology Broadwall House, 21 Broadwall - London SE1 9PL Tel: (44) 207 642 8080 – Fax: (44) 207 642 8096 E-mail : [email protected] - Web : www.gambica.org.uk President: John Bailey Chief Executive: Graeme Philp ASSOCIATE MEMBERS CROATIA CEA Croatian Employers Association Ulica Pavla Hatza 12 – 10000 Zagreb, Hrvatska Tel: (385) 1 48 97 571 – Fax : (385) 1 48 97 581 E-mail: [email protected] - Web : www.hup.hr Director: Ana Falak HGK Croatian Chamber of Economy Rooseveltov trg 2, 10000 - Zagreb, Hrvatska Tel: (385) 1 45 61 555 – Fax : (385) 1 48 28 380 E-mail: [email protected] - Web : http://www2.hgk.hr/en/ President: Mr. Nadan Vidošević Secretary General: Ms. Martina Velnić EUROPEAN SECTOR ASSOCIATIONS CEIR European Committee for the Valve Industry Diamant Building, 80 Boulevard A Reyers, 1030 Brussels, Belgium Tel: (32) 2 706 87 30 - Fax: (32) (32) 2 706 87 50 E-mail: [email protected] - Web: www.ceir.eu President: Bulent Haciraifoglu Secretary General: Guy van Doorslaer EFCEM European Federation of Catering Equipment Manufacturers c/o CESA, Ground Floor, Westminster Tower, 3 Albert Embankment, London. SE1 7SL. UK Tel. +44 (0)20 7793 3030. Fax +44 (0)20 7793 3031 E-mail: [email protected] - Web: www.efcem.org President: Evaldo Porro Secretary General: Fabio Gargantini EGMF European Garden Machinery Federation Diamant Building, 80 Boulevard A Reyers, 1030 Brussels, Belgium Tel: (32) 2 706 82 37 & Tel: (32) 2 706 82 30 - Fax: (32) 2 706 82 50 E-mail: http://www.egmf.org/en/about-egmf/contact-us/ - Web: http://www.egmf.org/ President: Hartmut Fischer Secretary General: Guy van Doorslaer EUROPUMP European Pump Industry Diamant Building, 80 Boulevard A Reyers, 1030 Brussels, Belgium Tel: (32) 2 706 82 37 & Tel: (32) 2 706 82 30 - Fax: (32) 2 706 82 50 E-mail: [email protected]/ - Web: http://www.europump.eu President: Dr Sönke Brodersen Secretary General: Guy van Doorslaer 32 ANNEX III - LIST OF EUROPEAN SECTOR ASSOCIATIONS AND OTHER CONTRIBUTORS PARTICIPATING IN THE DRAFTING OF THIS GUIDE BCSA - The British Constructional Steelwork Association CEO - Comité Européen de l'Outillage ECCA - European Coil Coating Association ECCS - European Convention for Constructional Steelwork EFCEM - European Federation of Catering Equipment Manufacturers ESTAL - Association for European Surface Treatment on Aluminium EURALARM - Association of European Manufacturers and Installers of Fire and Security Systems EUROPACABLE E.E.I.G. - European Confederation of National Associations of Manufacturers of Insulated Wire and Cable EUROPUMP European Association of Pump Manufacturers EUROVENT - European Committee of Air Handling and Refrigeration Equipment Manufacturers EWRIS - European Federation of Wire Rope Industries Industrieverband Schneid- und Haushaltswaren e.V. Independent Fixing Consultants Siemens AG - Sector Energy 33
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