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KSB SAS

KSB

We are producers of Pumps and Valves and accessories for many markets and deeply involved in the French and European professional organisations (EVOLIS, FIM, Elanova, GIFEN, FRANCE HYDROGENE, EVOLEN, AFM in France and EUROPUMP and CEIR, members of ORGALIM, in Europe).

Lobbying Activity

Response to Drinking water - conformity assessment procedure

16 Nov 2023

KSB is an international industrial group of more than 150 years old or more than 15.500 employees. We are developing, producing and selling pumps and valves for many different markets and specific ones for drinking water applications. We are committed to participate to the revision of the DWD in order to give the view and contribution of companies managing the different certification schemes of many countries since decades (ACS, WRAS, KTW, KIWA, ). We are pushing for an harmonized scheme for Europe by considering the return of experience of the existing national ones and without overregulation. The satisfactory application of national regulations that have showed their efficiency for the citizens and the environment must be the reference. The French ACS has shown its efficiency with a pragmatic approach. The Drinking Water Directive (EU) 2020/2184 aims to harmonize the rules applicable to products in contact with drinking water in Europe, particularly as regards to minimum hygiene requirements for materials coming into contact with water intended for human consumption. Harmonization aims to eliminate obstacles to the European principles of free movement of products and to guarantee a high level of health safety for all European consumers. However, the provisions envisaged for the product conformity assessment procedure are complex and could lead to distortions between players. In particular, the rules governing product classification, and especially the system based on "Conversion Factors - CF" defining risk levels according to the type of equipment seem extremely complex to implement, or even to apply and control, and therefore ultimately ineffective. In order to certify products in the most efficient way meaning applicable and with possible control, in particular assembled products such taps and valves, we ask that these products be certified according to the following: first, organic material testing on material samples and not on each finished component, then, the conformity assessment procedure according to modules "B+C", based on internal quality control (cf. system B: type testing +C: internal quality control). It must be taken into account that there is no comparison between pipes and products with a large surface area in contact with water and presenting the greatest risk and single products like pumps and valves. Considering that, we have the following general comments and the table of more detailed ones in the next table : 2. DA: an update of the positive lists to reflect current proven and certified practices, 4. IA: the withdrawal of the concept of "sum of symmetrical components", a sum which will conduct to a certification scheme that will be disproportionate for valves & taps, 5. DA: a change in certification scheme for category grope RG2 : B+D system is actually disproportionate for taps & valves and the existing French ACS has shown its efficiency without such a heavy scheme, 6. DA: a feasible marking, without stars or the phrase "suitable for drinking water". And in addition, we request a 5-year timeframe for implementation of such a regulation, that will require the modification of hundreds of products (numerous sizes) for our company.
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Response to Drinking water - procedures and methods for testing and accepting final materials

16 Nov 2023

KSB is an international industrial group of more than 150 years old or more than 15.500 employees. We are developing, producing and selling pumps and valves for many different markets and specific ones for drinking water applications. We are committed to participate to the revision of the DWD in order to give the view and contribution of companies managing the different certification schemes of many countries since decades (ACS, WRAS, KTW, KIWA, ). We are pushing for an harmonized scheme for Europe by considering the return of experience of the existing national ones and without overregulation. The satisfactory application of national regulations that have showed their efficiency for the citizens and the environment must be the reference. The French ACS has shown its efficiency with a pragmatic approach. The Drinking Water Directive (EU) 2020/2184 aims to harmonize the rules applicable to products in contact with drinking water in Europe, particularly as regards to minimum hygiene requirements for materials coming into contact with water intended for human consumption. Harmonization aims to eliminate obstacles to the European principles of free movement of products and to guarantee a high level of health safety for all European consumers. However, the provisions envisaged for the product conformity assessment procedure are complex and could lead to distortions between players. In particular, the rules governing product classification, and especially the system based on "Conversion Factors - CF" defining risk levels according to the type of equipment seem extremely complex to implement, or even to apply and control, and therefore ultimately ineffective. In order to certify products in the most efficient way meaning applicable and with possible control, in particular assembled products such taps and valves, we ask that these products be certified according to the following: first, organic material testing on material samples and not on each finished component, then, the conformity assessment procedure according to modules "B+C", based on internal quality control (cf. system B: type testing +C: internal quality control). It must be taken into account that there is no comparison between pipes and products with a large surface area in contact with water and presenting the greatest risk and single products like pumps and valves. Considering that, we have the following general comments and the table of more detailed ones in the next table : 2. DA: an update of the positive lists to reflect current proven and certified practices, 4. IA: the withdrawal of the concept of "sum of symmetrical components", a sum which will conduct to a certification scheme that will be disproportionate for valves & taps, 5. DA: a change in certification scheme for category grope RG2 : B+D system is actually disproportionate for taps & valves and the existing French ACS has shown its efficiency without such a heavy scheme, 6. DA: a feasible marking, without stars or the phrase "suitable for drinking water". And in addition, we request a 5-year timeframe for implementation of such a regulation, that will require the modification of hundreds of products (numerous sizes) for our company.
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Response to Drinking water - establishing the European Positive Lists of starting substances

16 Nov 2023

KSB is an international industrial group of more than 150 years old or more than 15.500 employees. We are developing, producing and selling pumps and valves for many different markets and specific ones for drinking water applications. We are committed to participate to the revision of the DWD in order to give the view and contribution of companies managing the different certification schemes of many countries since decades (ACS, WRAS, KTW, KIWA, ). We are pushing for an harmonized scheme for Europe by considering the return of experience of the existing national ones and without overregulation. The satisfactory application of national regulations that have showed their efficiency for the citizens and the environment must be the reference. The French ACS has shown its efficiency with a pragmatic approach. The Drinking Water Directive (EU) 2020/2184 aims to harmonize the rules applicable to products in contact with drinking water in Europe, particularly as regards to minimum hygiene requirements for materials coming into contact with water intended for human consumption. Harmonization aims to eliminate obstacles to the European principles of free movement of products and to guarantee a high level of health safety for all European consumers. However, the provisions envisaged for the product conformity assessment procedure are complex and could lead to distortions between players. In particular, the rules governing product classification, and especially the system based on "Conversion Factors - CF" defining risk levels according to the type of equipment seem extremely complex to implement, or even to apply and control, and therefore ultimately ineffective. In order to certify products in the most efficient way meaning applicable and with possible control, in particular assembled products such taps and valves, we ask that these products be certified according to the following: first, organic material testing on material samples and not on each finished component, then, the conformity assessment procedure according to modules "B+C", based on internal quality control (cf. system B: type testing +C: internal quality control). It must be taken into account that there is no comparison between pipes and products with a large surface area in contact with water and presenting the greatest risk and single products like pumps and valves. Considering that, we have the following general comments and the table of more detailed ones in the next table : 2. DA: an update of the positive lists to reflect current proven and certified practices, 4. IA: the withdrawal of the concept of "sum of symmetrical components", a sum which will conduct to a certification scheme that will be disproportionate for valves & taps, 5. DA: a change in certification scheme for category grope RG2 : B+D system is actually disproportionate for taps & valves and the existing French ACS has shown its efficiency without such a heavy scheme, 6. DA: a feasible marking, without stars or the phrase "suitable for drinking water". And in addition, we request a 5-year timeframe for implementation of such a regulation, that will require the modification of hundreds of products (numerous sizes) for our company.
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Response to Drinking water - methodologies for establishing and amending the European Positive Lists

16 Nov 2023

KSB is an international industrial group of more than 150 years old or more than 15.500 employees. We are developing, producing and selling pumps and valves for many different markets and specific ones for drinking water applications. We are committed to participate to the revision of the DWD in order to give the view and contribution of companies managing the different certification schemes of many countries since decades (ACS, WRAS, KTW, KIWA, ). We are pushing for an harmonized scheme for Europe by considering the return of experience of the existing national ones and without overregulation. The satisfactory application of national regulations that have showed their efficiency for the citizens and the environment must be the reference. The French ACS has shown its efficiency with a pragmatic approach. The Drinking Water Directive (EU) 2020/2184 aims to harmonize the rules applicable to products in contact with drinking water in Europe, particularly as regards to minimum hygiene requirements for materials coming into contact with water intended for human consumption. Harmonization aims to eliminate obstacles to the European principles of free movement of products and to guarantee a high level of health safety for all European consumers. However, the provisions envisaged for the product conformity assessment procedure are complex and could lead to distortions between players. In particular, the rules governing product classification, and especially the system based on "Conversion Factors - CF" defining risk levels according to the type of equipment seem extremely complex to implement, or even to apply and control, and therefore ultimately ineffective. In order to certify products in the most efficient way meaning applicable and with possible control, in particular assembled products such taps and valves, we ask that these products be certified according to the following: first, organic material testing on material samples and not on each finished component, then, the conformity assessment procedure according to modules "B+C", based on internal quality control (cf. system B: type testing +C: internal quality control). It must be taken into account that there is no comparison between pipes and products with a large surface area in contact with water and presenting the greatest risk and single products like pumps and valves. Considering that, we have the following general comments and the table of more detailed ones in the next table : 2. DA: an update of the positive lists to reflect current proven and certified practices, 4. IA: the withdrawal of the concept of "sum of symmetrical components", a sum which will conduct to a certification scheme that will be disproportionate for valves & taps, 5. DA: a change in certification scheme for category grope RG2 : B+D system is actually disproportionate for taps & valves and the existing French ACS has shown its efficiency without such a heavy scheme, 6. DA: a feasible marking, without stars or the phrase "suitable for drinking water". And in addition, we request a 5-year timeframe for implementation of such a regulation, that will require the modification of hundreds of products (numerous sizes) for our company.
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Response to Establishing harmonised marking to be used for products in contact with drinking water

13 Nov 2023

KSB is an international industrial group of more than 150 years old or more than 15.500 employees. We are developing, producing and selling pumps and valves for many different markets and specific ones for drinking water applications. We are committed to participate to the revision of the DWD in order to give the view and contribution of companies managing the different certification schemes of many countries since decades (ACS, WRAS, KTW, KIWA, ). We are pushing for an harmonized scheme for Europe by considering the return of experience of the existing national ones and without overregulation. The satisfactory application of national regulations that have showed their efficiency for the citizens and the environment must be the reference. The French ACS has shown its efficiency with a pragmatic approach. The Drinking Water Directive (EU) 2020/2184 aims to harmonize the rules applicable to products in contact with drinking water in Europe, particularly as regards to minimum hygiene requirements for materials coming into contact with water intended for human consumption. Harmonization aims to eliminate obstacles to the European principles of free movement of products and to guarantee a high level of health safety for all European consumers. However, the provisions envisaged for the product conformity assessment procedure are complex and could lead to distortions between players. In particular, the rules governing product classification, and especially the system based on "Conversion Factors - CF" defining risk levels according to the type of equipment seem extremely complex to implement, or even to apply and control, and therefore ultimately ineffective. In order to certify products in the most efficient way meaning applicable and with possible control, in particular assembled products such taps and valves, we ask that these products be certified according to the following: first, organic material testing on material samples and not on each finished component, then, the conformity assessment procedure according to modules "B+C", based on internal quality control (cf. system B: type testing +C: internal quality control). It must be taken into account that there is no comparison between pipes and products with a large surface area in contact with water and presenting the greatest risk and single products like pumps and valves. Considering that, we have the following general comments and the table of more detailed ones in the next table : 2. DA: an update of the positive lists to reflect current proven and certified practices, 4. IA: the withdrawal of the concept of "sum of symmetrical components", a sum which will conduct to a certification scheme that will be disproportionate for valves & taps, 5. DA: a change in certification scheme for category grope RG2 : B+D system is actually disproportionate for taps & valves and the existing French ACS has shown its efficiency without such a heavy scheme, 6. DA: a feasible marking, without stars or the phrase "suitable for drinking water". And in addition, we request a 5-year timeframe for implementation of such a regulation, that will require the modification of hundreds of products (numerous sizes) for our company.
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Response to Revision of the Drinking Water Directive (RECAST 2017)

28 Mar 2018

Dear Madam, dear Sir, The current proposal of the Commission is really not satisfactory. As Products in Contact with Drinking Water, we are waiting since more then a decade an harmonization of the European regulation to avoid huge time and cost consuming to be able to obtain the relevant but different agreements in all countries where we sell pumps and valves (including rubber parts). In addition, the regulation in the countries are evolving without coordination. The proposal based on CPR is not satisfactory for products which are not CPR relevant and CPR considers only the water circuit into the building; it means all products in contact with drinking water will not be treated with the same referential and standard ! It is not harmonization. How harmonized standards under CPR will take into account products out of CPR ? How harmonizing when all considerations are not taken into account ? A dedicated Directive or Regulation for Products in Contact with Drinking Water is the best solution to solve the problem. Why is it not considered by the Commission ? In summary : the harmonization will not exist with the current proposal and will not solve the difficulties of thousands of companies which will continue to support costs (internal and external) when their objective is to improve innovation and competitiveness position. My requirement : to prepare a dedicated regulation for all products in contact with drinking water. You can refer to positions of Companies associations (EDW, CEIR, EUROPUMP, ...). Best regards. Pascal Vinzio - KSB Company and Profluid President
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