European Commitee of Electrical Installation Equipment Manufacturers
CECAPI
The objective of CECAPI is to promote and to develop the collective and common technical, industrial, economical and political interests of the European electrical installation equipment manufacturing industry.
ID: 599743711223-32
Lobbying Activity
Response to Cyber Resilience Act
13 Jan 2023
First of all, CECAPI would like to thank the European Commission for the draft text given for the CRA to become a leading document aiming to improve the security on the European market and to be a legal reference framework for other legislations. In addition, CECAPI is glad to participate and would like to offer the below comments: TIME FRAME The draft CRA states that (Article 57): - CRA shall apply 24 months after the date of its entry into force. - Article 11 shall apply 12 months after the date of its entry into force. The current CRA draft offers no more than 24 months for products to declare their conformity to the requirements of the CRA after its adoption by the European commission. This timeline is clearly insufficient and would, if not significantly increased, put the market in a situation where: - Most of the electronic devices (products with digital elements) would have either to show their conformity or to be removed from the shelves of the European shops - Notified bodies would have insufficient resources to support the huge compliance effort needed by the industry mostly if no harmonised standards are available in due time - In some market segments, the absence of the appropriate harmonised standards (requirements and test methods for compliance) will remove the possibility to ensure a fair competition on the European market o Either through a self-assessment process o Either with the support of third-party agencies o Also, as a tool for market surveillance - Outlaw products not complying could remain on the market without any fear from the market surveillance as no relevant harmonised standard, in some market segments, would be available to serve as reference to the authorities. - Meanwhile, harmonised standards must be written and successful in the OJEU citation process. - After that the industry needs to have a sufficient time, considering the reality of industrial processes, that cannot be shorter than 48 months after the publication of the regulation. SCOPE Annex III includes physical network interfaces which maybe be understood as covering all products connected to a network. Such a network could be a private communication network or a power grid network. This interpretation would lead to 90 % of the products falling, in the CRA, under class1. We suggest that item 15 is replaced with the following: Public network physical interface We also have a concern about article 6 item 2 (a) (iii) that specifies control of Operational Technology and according to the definition of Operational Technology in Article 3 item 5, most of the products could fall into class 1 category in a future delegated act and this puts too much uncertainty from the industry point of view. Therefore, CECAPI is in favour to remove Operational Technology from Article 3 item 5. SECURITY PATCHES Annex I item 2 (2) requires that vulnerabilities are addressed without delay however requesting a third-party certification for security updates on class I and class II products. It creates a contradiction between the required speed (without delay) and the length of the required process (third-party certification). CECAPI suggest making an exception in allowing to proceed with a self-assessment for security updates.
Read full responseResponse to Review of the Construction Products Regulation
6 Jul 2022
The evaluation of the Construction Products Regulation (CPR), opinions of the REFIT platform as well as Member States and stakeholders feedback pointed clearly to the shortcomings of the framework, hindering the functioning of the single market for construction products, and therefore failing to achieve the CPR’s objectives
Therefore, CECAPI welcomes a revision of the CPR to improve the situation with a particular focus on two general objectives:
(1) achieving a well-functioning single market for construction products to facilitate the free movement of construction products and
(2) contributing to the objectives of a green and digital transition, particularly the modern, resource-efficient and competitive economy.
However, we request clarification regarding the scope of the proposal for revision of CPR (Proposal for a regulation - COM(2022)144).
The proposed scope and in particular the new definition of construction products and addition of Row 33 to Table 1 in Annex IV – “Construction Products not included in the product areas above” may lead to misinterpretation and confusion in the market.
CECAPI believes that it is not the intention of the EC to include within the scope of the new CPR electrical and electronic equipment installed in the electrical and control infrastructure that forms part of the construction work, for the following reasons:
- the single market for these products is functioning well, allowing for free movement as per the Low Voltage Directive (LVD – 2014/35/EU). EN standards for these products are harmonised, conformity assessment and market surveillance is working well. For LVD, Electromagnetic Compatibility Directive (EMCD – 2014/30/EU) & Radio Equipment Directive (RED – 2014/53/EU) products, CE marking has been in place for decades and the EC recently decided not to revise the LVD because it remains fit-for-purpose.
- the green and digital transition are already addressed through existing regulations (e.g. RoHS – 2014/863/EU, EPBD – 2018/844/EU, Ecodesign – 2009/125/EC, etc) and will be completed with the support of new dedicated regulations (ESPR, etc).
Considering these points, we request to add a new (f) bullet in Article 2 Scope of the new CPR as follows:
Article 2 Scope
3. This Regulation shall not apply to:
(a) lifts subject to Directive 2014/33/EU of the European Parliament and of the Council, escalators and their components;
(b) boilers, pipes, tanks and ancillaries and other products intended to be in contact with water for human consumption;
(c) systems treating waste water;
(d) sanitary appliances;
(e) traffic signalling products.
(f) electrical and electronic equipment
Read full responseResponse to Standardisation Strategy
7 Aug 2021
CECAPI thanks the European Commission for the opportunity to comment about the Roadmap of the European Standardisation Strategy and provides its position at the pdf document attached.
Read full response