European Coordinating Committee of Manufacturers of Electrical Switchgear and Controlgear
CAPIEL
CAPIEL is the Coordinating Committee for the Associations of Manufacturers of Switchgear and Controlgear equipments for industrial, commercial and similar use in the European Union, that work in the range of voltages until 1 kV a.c.
ID: 492532816900-02
Lobbying Activity
Response 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, CAPIEL 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.
CAPIEL 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 Revision of the Machinery Directive
16 Aug 2021
Please see comments in enclosed document.
Read full responseResponse to Evaluation of the Electromagnetic Compatibility Directive
18 Feb 2020
CAPIEL is the Coordinating Committee for the Associations of Manufacturers of Switchgear and Controlgear equipment for industrial, commercial and similar use in the European Union.
With regard to the EMC Directive, we appreciate that the directive should be assessed, particularly as it has been in force for over 20 years. However, we believe that the EMC Directive has thoroughly demonstrated that it is fit for purpose over this period, both with regard to scope and requirements.
It is our opinion that the directive should remain technology neutral. We strongly believe that harmonised standards are the best means for addressing the technical requirements arising from existing, as well as emerging technologies, such as AI, 5G, etc. The directive should continue to only specify the high-level essential requirements.
In the experience of CAPIEL members, the EMC Directive interacts well with other legislation, such as the Low Voltage Directive and the Machinery Directive, and should continue to apply horizontally. The potential alignment of the Machinery Directive with the NLF will only improve this situation.
In summary, CAPIEL considers that the EMC Directive is still fit for purpose today and no major changes are necessary.
Read full responseResponse to Revision of the Machinery Directive
4 Feb 2019
Capiel - The Coordinating Committee for the Associations of Manufacturers of Switchgear and Controlgear equipment for industrial, commercial and similar use in the European Union.
With regard to the Machinery Directive, stability is our central requirement. We accept that “option 1” can limit the administrative burden by aligning the Machinery Directive to the New Legislative Framework and helping to ensure its consistent application across all member states.
It is our opinion that the directive/regulation should be technology neutral. We strongly believe that harmonized standards are the best means for addressing emerging technologies (AI, IoT, etc.). The directive should continue to only specify the high level essential requirements.
Machinery using complex digital technology is not a new phenomenon. The Machinery Directive has already demonstrated its fitness for purpose, by ensuring the safety of such machinery for many years.
Read full responseResponse to Ecodesign requirements for (other) electric motors
19 Nov 2018
CAPIEL welcomes the draft Regulation on Electric Motors (Lot 30) and would like to give its feedback concerning a possible final correction of recital 13 of the draft Regulation. CAPIEL welcomes the introduction of fixed speed in the recital, however it does not fully agree on the choice of keeping in brackets constant load. CAPIEL believes that “fixed speed” would be better suited than “constant load”, in order to read “in fixed speed applications a variable speed drive induces additional costs and energy losses”. Indeed, in fixed speed applications, the varying load levels of the duty profile are automatically balanced by motor torque, so the speed is fixed by the supply network frequency and the load may vary. Where the application needs a variable speed, with or without constant load, a variable frequency drive is necessary.
Read full response