European Mortar Industry Organisation
EMO
EMO is a non-profit-making association.
ID: 775299618501-45
Lobbying Activity
Response to Revision of the Standardisation Regulation
21 Jul 2025
Harmonised European standards have been the backbone for placing our products on the EU Single Market since 20 years. The process has been slow and could be improved, but unlike other areas, the construction sector is and will remain very much ruled by national and regional laws, regulations and administrative provisions, unless Member States volunteer to align. For our construction products, the development of common European standards began in the 1980, long before the Construction Product Directive (89/106/EEC) was adopted and Mandate M/116 for developing harmonised standards for our products was issued. It followed a bottom-up approach where technical standards were adopted in a consensual, democratic, technically and scientifically driven process involving all stakeholders, big and small, and including regulators, with a view to providing an interconnected set of technical standards that allowed designing buildings according to the applicable requirement and specifying appropriate products. Consequently, given the different traditions and experiences, the process of developing the first set of harmonised construction product and supporting test standards took time. The first set of harmonised product standards were ultimately achieved by imposing predominantly a performance-based approach at the expense of the best practice and state of the art approaches that were well-established in many Member States. However, while an approximation of the technical foundation was achieved, the aim of the Construction Product Directive (89/106/EEC) was to approximate the laws, regulations and administrative provisions of the Member States. This goal was not achieved due to the subsidiarity and a lack of willingness to adapt. The Construction Product Regulation (EU) 305/2011 therefore no longer aimed at approximating Member States laws, regulations, etc., but on providing a common technical language for placing construction products on the Single Market. However, even this goal was never fully achieved, partly because of a lack of transparency and willingness of some Member States to engage in the process of notifying requirements as a condition for developing and completing an exhaustive common technical language. With the new CPR (EU) 2024/3110 and the revision of the CPR Aquis, hopes are high that this common technical language may finally be achieved. However, the way to achieving it is by including any performance information requirement claimed by any Member State in the respective Standardisation Request, without allowing the Technical Committee (TC) to question it. The role of technical experts in the TCs has thereby deteriorated to becoming fulfilment agents, subordinating their expertise to the strict conditions and requirements specified in the Standardisation Request by the Commission and the Member States. What was and in other areas still is a bottom-up approach has become a top-down approach for our standards. To deliver to the objectives of the CPR fast under the given circumstances: - Member States need to engage to ensure that the Standardisation Request are complete and need to engage in the standardisation process, to ensure the deliverables meet their requirements and understand necessary compromises. - The Commission needs to provide the financial means for the TCs to be managed professionally and to ensure that assessment methods are reproduceable and repeatable. The industry already bears the costs for delegating experts and supportive research and it can no longer be burdened with costs for the TC secretariats. - SMEs in our and other sectors have deliberately chosen and delegated the representation of their interest to their national and European associations, who ensure that information is shared with, and feedback is collected from them. Associations like ours must be recognised as the legitimate representatives of SMEs in standardisation and be eligible to financial support by the Commission.
Read full responseResponse to Review of the Construction Products Regulation
12 Jul 2022
A clear, lean and reliable legal framework is an essential prerequisite for an effective and economic functioning of the internal market for construction products as well as to contributing to affordably, green and digital objectives
The persisting problems with the citation of CEN standard deliverables in the EU Official journal as well as with the revision of Mandates/Standardisation Mandates has put the construction products sector in a difficult situation. These ongoing difficulties are hindering the supply of products and product information as demanded by the market are therefore damaging the trust in and the support of European internal market for construction products among all stakeholders. These difficulties are also a reason why national and voluntary approaches continue playing an important and increasing role.
EMO continues supporting and believing in the benefits of the single market for construct products and is fully committed to the objectives of the green and digital transition. We therefore welcome that the European Commission has presented a proposal for a new Construction Product Regulation, initiating the legislative process that is expected to offer solutions for the long-known issues and enable the green and digital transition of the construction sector as a whole. We look forward to engaging and contributing in a constructive manner to improving the proposal.
We welcome that the European Commission’s proposal inter alia
• maintains the concept of the “common technical langue” for which harmonised standards shall continue playing a key role
• addresses sustainability and circularity objectives in construction
• seeks to strengthen the single market for construction products, by obliging Member States to respect the harmonised zone
• respects at the same time the competences of Member States by foreseeing a procedure to implement requirements that are not yet covered by the harmonised zone
• aims at functioning as a “one-stop shop” for legal requirements related to construction products and the related economic operators, by integrating aspects of the ESPR and the GPSR
• suggests a procedure aimed at facilitating the timely delivery and citation of CEN deliverables
• simplifies the CE marking and allows fulfilling information obligations digitally by default
• aims at strengthening Market Surveillance
• clarifies the procedures to develop EADs/ETAs and limits the overlap of competences In contrast to the positive aspects and intentions that we identify in the proposal, we also identify issues of concern, such as the:
• readability, comprehensibility and clarity of the legal text
• extensive powers the proposal is giving the European Commission to amend and specify articles
• modified scope and modified/new definitions
• stepwise implementation of the proposed new Construction Product Regulation
• procedure for assessing and adopting CEN standardisation deliverables
• exclusion of EADs from the definition of harmonised technical specifications
• missing common digital format for the content of the declaration of performance and conformity
• common database
• administrative burden for economic operators
• possibility for Member States to exempt certain products from their territory
• exemptions for used and remanufactured products
• central complaints portal
• random checks as proposed in the new Annex V
• unclear reference to environmental product declarations (EPDs)
• extensive information and requirements
• sensible application of traffic light systems for construction products
(see attached feedback document for further elaboration on the issues of concern)
Read full responseResponse to Simplification and digitalisation of labels on chemicals (CLP, Detergents, Fertilising Products)
20 Sept 2021
The European Mortar Industry Organisation (EMO) strongly supports using digital means for supplying relevant product information.
In our sector, it is common practice to print all mandatory (regulatory) information, but also all necessary/relevant information for the final preparation and use of the product a priory on the packaging, which is ordered in large amounts. The pieces of information provided with the product often target professional users as well as consumers, sometimes even designers (engineers/architects) and always market authorities. Adapting this pre-printed information to accommodate revised or new legal requirements is always a challenge. It can even cause the disposal of unused packaging of products with low sales volumes, where the ordered packaging may last for several years. Digital means not only provide flexibility regarding the adaptation of information, but also open a wide range of possibilities for providing better targeted information for the different user groups as well as supplementary information. Furthermore, while certain products are produced only for certain Member States or regions and the information on the packaging is therefore provided only in the relevant languages, the common market for construction products permits distributing and using products across Europe without the manufacturer knowing it. Digital access to information can help overcome language barriers, especially if the accessible information is provided in a common digital format. We therefore fully support and welcome a simplification and digitalisation of the applicable the applicable labelling requirements (in our case mainly CLP related requirements, but not only).
However, as many other products, our products are subject to various Regulations, respectively Directives, that impose labelling and/or information requirements on manufacturers. Construction Products, such as mortars, firstly need to comply with the Construction Product Regulation (CPR, Regulation (EU) No 305/2011) as a condition for being placed on the market. The CPR not only requires products to be CE labelled, but in contrast to other market regulation, requires manufacturers to provide information on the products’ performances with the CE marking. As a condition for CE marking, manufacturers of construction products also need to issue a so-called Declaration of Performance which may be made available in a digital format. Where the construction products are subject to information requirements according to Article 31 respectively Article 33 of REACH (Regulation (EC) No 1907/2006) the CPR obliges manufacturers to also supply a copy of the Safety Data Sheet “at the same time and in the same form as the Declaration of Performance, so as to reach all potential users of construction products.” Hence, where access to the Declaration of Performance is granted through a e.g. QR code or a weblink, if applicable, this digital link must also grant access to the safety data sheet. While information according to REACH is not the focus of this consultation, the example shows the already existing overlap of obligations and approaches with regards to communication of information along the supply chain. Adding to this, as part of the Sustainable Products Initiative, it is also being investigated how to best provide relevant product information, such as the presence of harmful chemicals in products, along the supply chain to improve their sustainability, i.e. in particular their recycling/re-use at the end of service life.
Evidently the benefits of digitalising information are at risk if each legislation follows its own approach especially if these require specific forms (QR code, RFID, …) or formats for accessing the information. Therefore we insist on the necessity for a coordinated, cross-legislative approach, which ideally results in a single digital product label (e.g. QR code) to all type of information.
(see attached full text)
Read full response8 Feb 2019
The European Mortar Industry Association (EMO) represents the European manufacturers of dry mixed and ready to use (wet) mortars. Our industry uses TiO2 as a pigment predominantly in plasters, renders and smoothing mortars for internal and external uses. Mortars, as construction products in general, are intermediate products that are combined on site with other products to form structural elements in construction works, like buildings, which meet the technical and esthetical demands of the owners and final users.
Our products are predominantly used by professional users, but some are also available via DIY markets. Based on the frequency of use however, long term exposure to any kind of dust or droplets of private users from processing our products is evidently several orders of magnitude lower than of professional users. As for many other harmonised construction products the safety data sheets (SDS) of our products are not only supplied to professional users, but in accordance with the Construction Products Regulation (Regulation (EU) 305/2011) are also supplied along with the declaration of performance. By means of the SDS as well as accompanying instructions and safety information, all users are advised to wear the appropriate personal protective equipment.
Our industry shares the views of many other sectors, that
• the observed effects in overdose lung tests on rats, which led to the proposed classification of TiO2 as category 2 carcinogen for inhalation, are dust effects and not intrinsic properties of TiO2 as a substance and that consequently
• the same effects from lung overdose could be observed with similar solid or poorly soluble particles.
Critical levels of exposure are only potentially relevant to workers in production facilities and professional users, where national occupational exposure limits (OEL) for dusts apply. Our industry takes exposure to dust and the potential risks very seriously. EMO is one of the signatories of the Social Dialogue "Agreement on Workers' Health Protection Through the Good Handling and Use of Crystalline Silica and Products Containing it" (the so-called NEPSI Agreement). Our companies regularly monitor and control dust exposure at work place. They participate in the bi-annual NEPSI reporting and can demonstrate that the measures in place ensure compliance with the applicable OELs.
The observed overdose lung effects not being intrinsic TiO2 properties, the CLP is the inappropriate legal instrument to address the related hazards and a classification as proposed would be unproportionate. There is no equivalent alternative to using TiO2 as a pigment in our products. Other, less performing alternative pigments would require a significantly higher dosage and consequently a potentially higher exposure to fine particle dust. A classification of TiO2 as proposed would therefore fail to achieve the envisaged effects. On the contrary such a classification would have a number of negative effects and consequences for our products, such as:
• potentially higher exposure to other types of solid or poorly soluble pigments
• negative impacts on circular economy targets through a classification of plasters and renders containing TiO2 as hazardous waste, including parts building structures to which the plasters and renders are applied
EMO therefore objects to the proposed classification of TiO2 as cat II carcinogen for inhalation and supports the demand of the (German) Federal Ministry of Labour and Social Affairs (BMAS) to elaborate an overall concept for the safe handling of inert dusts.
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