International Confederation of Inspection and Certification Organizations
CEOC International
CEOC International was created in 1961, as a not-for-profit organisation registered under Belgian law that represents 31 independent inspection and certification organization in 19 countries.
ID: 96818506624-46
Lobbying Activity
Meeting with Carl-Christian Buhr (Cabinet of Commissioner Mariya Gabriel) and TIC Council
11 Sept 2018 · Cybersecurity
Response to Evaluation of the Toy Safety Directive
2 Aug 2018
The independent Testing, Inspection and Certification (TIC) sector welcomes the initiative by the European Commission to evaluate the Toy Safety Directive 2009/48/EC.
Data shows that there are still too many (potentially) unsafe and non-compliant toys in the EU market:
With the publication of the Goods package (December 2017), the European Commission published alarming data: “as many as 32% of toys, 58% of electronics, 47% of construction products or 40% of personal protective equipment inspected do not meet the requirements for safety or consumer information foreseen in EU legislation.”
The RAPEX figures of the last 5 years show a significant and increasing trend regarding non-compliant toys (and related):
- the highest category of non-compliant product category notified in 2017 was toys (29%)
- In 2016 the two most common product categories notified were childcare articles and children’s equipment (31%) and toys (26%) with injuries related to toys as the most common risk notified
- In 2015 the most notified product category were toys (27%)
- In 2014 and 2013 the most notified product categories were toys (25%) and clothing, textiles and fashion items (25%)
These figures have not improved despite significant efforts of the European Commission as well as at Member State level through cooperation programs with China in order to raise awareness, training on European toys regulation, conformity assessment etc.
The TIC sector recommendations:
The TIC sector strongly recommends that the evaluation of the Toy Safety Directive focuses on achieving the following key
objectives:
- Protecting European consumers health and safety
- Securing a level-playing field for industry by deterring rogue, non-compliant economic operators
To such end, the evaluation of the Toys Safety Directive:
1. Should not be limited to the requirements set forth in the directive but also look at the conformity assessment procedure (self-declaration with the EU harmonized standard EN71 – Module A vs. EC-type examination and certification – Module B for the design phase plus Module C for the production phase) since the high noncompliance levels are directly linked to the conformity assessment procedure provisions in the regulation.
2. Digitalization is a substantial part of our lives today. The European Commission should consider looking at risks associated with connected toys since inadequately protected connected devices on the market might lead to
serious cybersecurity threats impairing safety and data privacy. Connected toys and devices are being hacked more and more frequently and children are being increasingly exposed to imminent danger.
IFIA and CEOC International strongly advocate for robust measures to be implemented to prevent non-compliant toys from entering the European market.
(for more information read the document enclosed)
Read full response19 Mar 2018
Globalization has drastically transformed the international trade landscape with the opening of the international markets and while European consumers are benefiting from a growing range of products, at the same time they must be able to trust that the products they are buying are safe and compliant. Likewise, whilst European industry is benefitting from a wider market, it must also be protected from unfair competition from rogue operators who cut corners and do not pay the price of compliance. To give EU consumers the peace of mind they deserve and to protect the level playing field of the EU industry, Europe needs to implement a robust regulatory framework for the European single market.
The independent Testing, Inspection and Certification (TIC) sector welcomes the Goods Package as a small step in this direction. However, given the alarming data published by the European Commission: “as many as 32% of toys, 58% of electronics, 47% of construction products or 40% of personal protective equipment inspected do not meet the requirements for safety or consumer information foreseen in EU legislation.”, we believe that the draft regulations on compliance and enforcement and mutual recognition, as well as the soft-law options identified in the European Commission’s Communication fall short of achieving the following key objectives:
- Protecting European consumers health and safety
- Securing a level-playing field for industry by deterring rogue, non-compliant economic operators
Market surveillance in Europe continues to show serious weaknesses in practice, especially as it is performed with varying resources and intensity by the authorities in the individual member states. Since 2008 various reports by the EC have identified inadequate Market Surveillance as the cause of a high level of non-compliance.
With an increasingly complex global supply chain, insufficient resources and lack of cooperation between the national authorities makes it virtually impossible to adequately control the range and number of products imported and traded in the EU. Therefore, it is urgent that market surveillance and other mechanisms be urgently improved and raised to a consistently high level in Europe. In addition, the scope of market surveillance activities and the frequency of checks should no longer be left solely to the discretion of the respective European Member States.
To such end, the independent TIC industry should be considered as a partner that can contribute to providing an effective and viable solution. The TIC industry has the expertise and resources to play an essential role in raising the compliance rate to provide protection to consumers’ health and safety while levelling the playing field for the manufacturers who are willing to follow the rules and invest in compliance.
THE TIC INDUSTRY RECOMMENDATIONS ON THE MUTUAL RECOGNITION REGULATION:
1. The mutual recognition declaration, as established under Article 4, does not create additional trust.
2. Conformity according to national law should be presumed when products have been assessed by an accredited third party.
We share the view that the Single Market is built on trust, and that robust measures should be implemented to prevent non-compliant products from entering the European market. Conformity with the requirements on products and services is the key for a smooth functioning of the European Single Market as well as for the protection of the health and safety of European citizens. In addition, only conforming products are able to compete in international trade. Therefore, the benefits of the Single Market can only fully unfold for all economic operators if the conformity of the products traded in the Single Market increases significantly and sustainably.
Read full responseResponse to Proposal for a Regulation on Enforcement and Compliance in the Single Market for Goods (Goods package)
19 Mar 2018
The independent Testing, Inspection and Certification (TIC) sector welcomes the Goods Package as a small step in this direction. However, given the alarming data (on non-compliant products) published by the European Commission, we believe that the draft regulations on compliance and enforcement and mutual recognition, as well as the soft-law options identified in the European Commission’s Communication fall short of achieving the following key objectives:
- Protecting European consumers health and safety
- Securing a level-playing field for industry by deterring rogue, non-compliant economic operators
With an increasingly complex global supply chain, insufficient resources and lack of cooperation between the national authorities makes it virtually impossible to adequately control the range and number of products imported and traded in the EU. Therefore, it is urgent that market surveillance and other mechanisms be urgently improved and raised to a consistently high level in Europe. In addition, the scope of market surveillance activities and the frequency of checks should no longer be left solely to the discretion of the respective European Member States.
To such end, the independent TIC industry should be considered as a partner that can contribute to providing an effective and viable solution. The TIC industry has the expertise and resources to play an essential role in raising the compliance rate to provide protection to consumers’ health and safety while leveling the playing field for the manufacturers who are willing to follow the rules and invest in compliance.
THE TIC INDUSTRY RECOMMENDATIONS ON THE COMPLIANCE AND ENFORCEMENT REGULATION:
1. Enlarge the scope in order to align all existing provisions for market surveillance:
- The proposal should cover all harmonized products, not only those listed in the ANNEX 1;
- The proposal should include the provisions for consumer products still regulated in the General Product Safety Directive (2001/95/EC);
- The provisions for market surveillance in regulation 765/2008 shall be maintained.
2. Adopt stricter and more precise requirements for national market surveillance authorities:
- Precise and concrete requirements for sampling (Art. 15.1) with the aim to harmonize the intensity of market surveillance controls;
- “Adequacy” of resources (Art. 11.4) (e.g. personnel and financial means) of the market surveillance authorities is too vague;
- “Adequacy” of sanctions (Art. 61) has to be translated into concrete figures and minimum requirements for sanctions.
3. Due to limited resources, market surveillance authorities should presume conformity of products that have been assessed by an accredited third party.
4. (Art. 20) It should be possible for accredited third-party conformity assessment bodies to be designated as Union Testing Facilities.
Maintaining cutting-edge laboratories requires extensive resources in terms of funding and skills. The private sector conformity assessment industry currently provides these accredited independent and impartial services. The proposal to create, design, build, and staff Union Testing Facilities would spend public funds (taxpayer money) to duplicate what already exists in the private sector. There is no funding for such facilities within the current proposals. Further, the previous system of Member State owned Notified Body laboratories was recognized to be unnecessary many years ago, which resulted in privatization of those Bodies. This proposal is a step backward that will not contribute to the improvement in either compliance or market surveillance activities. If the EC is finally serious about making changes to the current inadequate system they should focus on leveraging the private sector resources that currently exist.
5. Increase market surveillance authorities’ reliance on accredited third parties to perform their tasks.
For more details please read the document enclosed.
Read full responseResponse to Evaluation of the Low Voltage Directive 2014/35/EU
27 Nov 2017
CEOC-ETICS-IFIA-VdTÜV: THE TESTING, INSPECTION, CERTIFICATION (TIC) FEDERATIONS CALL FOR A RE-VISION OF THE LOW VOLTAGE DIRECTIVE 2014/35/EU
CONFORMITY ASSESSMENT OF LVD PRODUCTS SHOULD BE REVIEWED TO RAISE COMPLIANCE
The level of conformity of LVD products in the internal market does not provide assurance that products comply with the requirements for protection of safety and health. In the context of market surveillance, it can be traced over a longer period of time that electrical products are often not compliant.
RESPOND TO INCREASED RISK POTENTIAL OF ELECTRICAL PRODUCTS
Through innovation, products in the course of their development, must satisfy new functional expectations. In short, products need new requirements and the European legislator has to adapt the regulatory framework for that.
Increasing risks with significant hazards can be observed in the area of mobile products such as battery operated products with increasing energy densities and dangerous electro chemicals used on or nearby the human body (for example: smart phones, tablets, power banks, Power tools, electronic cigarettes) and for laser operated products with high emitted energies (for example, Laser and LED bicycle (ultra) bright light, Lane laser, Laser distance laser pointer, LED (laser) flash light, Laser-LED head lamp).
As a consequence of accidents with batteries (esp. Li-Ion) and LED/Laser in mobile devices a review of the directive should consider:
1. To decrease the low voltage limit to 1 V DC / AC or less
2. To assess and to adapt the applicable conformity assessment procedures in accordance with the risk potential of these products (based on the relevant conformity assessment modules).
3. To stipulate that an independent body (Notified Body) will be mandatorily involved
New function can particularly be observed in the context digitization and Internet of Things (cyber-security). In the context of the LVD products become increasingly smart and requirements need to be adapted.
In reviewing the LVD the European Commission is urged:
1. To include the aspect of information security in safety requirements for products, including smart products, in the respective annexes to swiftly close regulatory gaps.
2. To put the risk potential presented by products through a fundamental reassessment, while taking information security into account.
3. To assess and to adapt the applicable conformity assessment procedures in accordance with the newly determined risk potential of the product (based on the relevant conformity assessment modules).
4. To stipulate that an independent body (Notified Body) will be mandatorily involved where the risk potential of the product is significantly increased by the ICT components.
5. To grant this body suitable access to the product’s source codes/software when the product is to be assessed by a Notified Body.
- please see complete position paper attached -
Read full responseResponse to Review of ENISA Regulation and laying down a EU ICT security certification and labelling
25 Jul 2017
CEOC, representing the European independent testing, inspection and certification sector, support the preliminary policy option 3 for certification as this option would support a coherent regulatory framework across the Single Market. Harmonizing the diverging certification schemes currently in existence would ease the burden on industry and ensure trust for users.
A coherent regulatory framework with clear requirements will help guide businesses in the design and creation of their products while demonstrating evidence that these products are at the level of compliance expected by users. The conformity assessment methods used to demonstrate compliance should be based on a risk assessment and on confidence needs, i.e. policy makers need to determine the confidence needed based on the risk of non-compliance and on what market-driven mechanisms exists as mitigation tools for non-compliance. Third part conformity assessment is a cost-effective policy solution as it provides the highest level of confidence and helps governments leverage scarce resources. At the same time it allows users to have confidence in their choice of products and enables a fair competition between manufacturers and distributers.
CEOC and our members are available to cooperate with the European Commission, ENISA and the standardization bodies in developing the necessary standards and requirements as well as the required conformity assessment methods to ensure the ICT security of specific products and services.
Read full responseMeeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)
26 Feb 2015 · Introductory meeting