Comité Européen de l'Outillage e.V.
CEO
- Representing the interests of the European tool industry consisting of - Handtool Manufacturers - Length Measuring Tool Manufacturers - Construction Fixings Manufacturers - constrcution fixings with official organisations and authorities both, inside and outside Europe and with the public. - Providing any information for the European tool manufacturers, which are of major relevance for the companies. - Providing statistical information for the member companies, enabling them to analyse their actual situation in business. - Maintaining regular contacts among the member companies for exchange of experience and information. - The manufacturer of Construction Fixings get together in the CEO sub-organisation 'Construction Fixings Europe' (CFE).
ID: 809113325185-91
Lobbying Activity
Response to Review of the Construction Products Regulation
12 Jul 2022
CFE represents manufacturers of anchors, wood screws and similar construction fixings. Each of our member companies holds at least one European Technical Assessment. The following positions are focussed on issues related to EADs and ETAs.
1. Harmonised Technical Specifications and Harmonized Zone
CFE appeals to include EADs again in the definition of harmonised technical specifications, which would mean that they become also part of the new introduced Harmonised zone.
2. Confidentiality of EAD development
CFE appeals to maintain the current practice of the publication and citation of EADs after the first ETA was issued, in order to maintain agility and momentum in the ETA process.
3. DoP for products covered by an ETA
CFE appeals to allow the reference to more than one ETAs/EADs in a DoP, as this is the case for references on Harmonised technical specifications (Annex II 8.).
4. Influence of the European Commission on EAD development
CFE appeals to limit the power for the European Commission to “abandon or modify the development of a certain European Assessment Document, including merging or splitting” at any stage of EAD development, as foreseen in Annex III 5, to clearly defined exceptional cases.
5. Member states consultation during the EAD development
CFE appeals to modify Annex III 6. in a way that member states are obliged to introduce national requirements in the EAD development process to make sure that EADs and ETAs cover all national requirements on the respective product.
6. Dedicated design methods as part of EADs
CFE appeals, that for cases where the design methods for a product covered by an ETA are not fully covered by the Eurocodes, the EAD format should allow to include information on specific design methods for the products covered by this EAD.
7. Mechanisms for conflict resolutions
CFE appeals to introduce conflict resolution mechanisms on EU level. The EU wide validity of such solutions would provide legal certainty for all stakeholders and a level playing field for all manufacturers.
For more details and justifications please refer to the attached position paper.
Read full responseResponse to Review of the general product safety directive
4 Oct 2021
CEO represents leading European manufacturers of hand tools and accessory tools for power tools. Most of them are SMEs.
Product safety is one of the moist important issues for our members and our association.
The safety requirements for most of our products are defined by ISO standards or national standards.
In the past years, most of the questions raised by our member companies regarding the implementation of the General Product Safety Directive (GPSD) were about marking and user information, because both requirements lead to higher internal efforts and costs for the companies, while the additional value for the end user is not always clear.
Therefore, our comments on the proposal for a General Product Safety Regulation are focussed on those aspects. Some of the new or tightened requirements on marking and user information in the proposal could lead to higher costs for the end users, in addition to the recent cost increases caused by higher prices for material and energy.
Another issue with the GPSR are differences in the national implementation. Therefore, we welcome the proposed conversion of the present directive into a regulation.
We would also welcome to harmonise the proposal for the GPSR as far as possible with the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on machinery products (ref. COM(2021) 202 final,2021/0105 (COD)).
Please find our detailed comments in the annexed table.
Read full responseResponse to Review of the general product safety directive
1 Sept 2020
Our association represents European manufacturers of hand tools, tools for stationary and handheld machines and similar products.
In our opinion, it would be desirable to convert the directive into a regulation in order to rule out national differences in implementation in the future (option 3).
Additional comments:
Article 3 (2)
In absence of European or national standards, also conformity with technical rules issued by European industry associations should be accepted to demonstrate that a product is safe.
Article 5 (1a)
The obligation to indicate the identity and details of the producer, should be facilitated by the option of providing a website, QR code etc. instead of the full postal address.
Read full responseResponse to Review of the Construction Products Regulation
11 Aug 2020
A revision of the CPR needs to be built on a “reliable standardization process” and an “alternative way” which considers the innovation dynamics for new products and / or applications.
The alternative approach to the hEN route on construction products – called ETA route – has started with the implementation of the CPR on 01.07.2013. The last approvals from the previous CPD process expired on June 30th, 2018. Since the beginning of the CPR journey substantial efforts from all stakeholders (European Commission, Industry Associations, MEP, Member States, TABs etc.) have been taken to optimize and improve the processes and the communication to the construction industry. Optimization took place on processes and documents (EAD, ETA, DoP). The industry has provided continuous constructive feedback and invested in the respective automation of processes in all sectors.
Today the general EAD / ETA process is transparent even though there are some areas which still deserve improvements. Some roles and responsibilities and the timing of process steps are to be further developed.
In summary the current limited deficiencies in the EAD / ETA route to arrive at a CE mark would clearly justify a revision / improvement of the CPR in the current general framework.
From a European industrial strategy and business point of view the EAD/ETA route to CE Marking for construction products is a success story for products which are not covered by hEN and whole product areas which are characterized by innovation and evolution regarding products and intended uses.
The key success factors are elaborated based on the observation in the sector of fastening industry:
1. Stimulation to develop into technological leadership: The European anchor manufacturers are worldwide market leaders with the most innovative and reliable products. Compared to other regions, the European anchor industry has the biggest variety of manufacturers including a lot of SMEs, which use ETAs for their innovative products in the same way as bigger companies. More than 6240 ETAs have been issued already until 2018.
2. ETAs stand for quality worldwide: ETAs have a good reputation worldwide. Important Non European countries (Australia, Singapore, India, China, Japan, Hongkong, Korea, etc.) recognize ETAs for construction products (e.g. fastening systems) as accepted documents when national documents are not available. Some countries take reference to European EADs in an explicit way. This enables European manufacturers to sell their product in a lot of third countries without additional testing or assessment.
3. Safety in construction: Unlike in other countries there has been no major failure of fastening applications in Europe, which proves the quality of the ETA product assessment procedures.
4. The EAD/ETA route is suitable for manufacturers of all sizes: The close cooperation between the manufacturer and a TAB and the confidentiality during the development of an EAD and the granting of an ETA makes the EAD/ETA route a perfect tool also for SMEs to demonstrate the reliability of their products, to simplify the distribution throughout the EU and worldwide and to maintain competitive advantages.
In summary, the product sectors represented by CFE would be served most by the maintenance of the present legal framework with some procedural refinements, namely of Annex II of the CPR.
Concepts like the preliminary CE marking for products, which are not covered by hEN, or their exclusion from the scope of the CPR, are not acceptable for the manufacturers and end users of those products.
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