SBMI Sveriges Bergmaterialindustri
SBMI
SBMI is the industry organization for producers and suppliers of aggregates as well as the industry's subcontractors.
ID: 396798841887-45
Lobbying Activity
Response to Review of the Construction Products Regulation
29 Jun 2022
SBMI notes that the new document is not shorter and clearer as was the intention of the revision, but instead longer and more complicated. The revised document adds new terms, concepts and processes that complicate rather than clarify.
Confidence between the Commission and standardization needs to be restored
According to the introduction to the document (EXPLANATORY MEMORANDUM) the revision process of CPR is characterized by a lack of confidence in standardization, and that the Commission feels that the link between regulations and harmonized standards does not work as intended. This may lead to increasingly detailed regulations being developed directly by the Commission. Among other things, the Commission wants to give itself greater opportunities to produce delegated acts on its own initiative to guide the content of the standards. Within standardization, there is the peak of technical competence, but there is a clear shift from technical to legal. Development needs to work together. The legal part needs to be involved at an earlier stage and be more active in the process. SBMI believes that it is of the utmost importance to restore trust between the Commission and European standardization so that standardization remains a relevant part of the EU's regulatory process. This is crucial for maintaining the technical competence in the regulations. To achieve this, it needs to be evaluated why the link between EU regulations and standardization has broken. In the document, a one-sided picture is communicated that it is the standardization apparatus' processes that have failed. In this analysis, the perspective needs to be broadened and supplemented as the industry perceives that the handling by the Commission via various HAS consultants has been inconsistent and scattered over time, which has largely contributed to the work of revising harmonized standards not advancing in the intended process. It has taken too long, and it has become too complicated.
SBMI points out that environmental performance should be declared with EPD
The document states that the Commission's intention is for CPR to provide tools for the green transition and digitization. To this end, it is important to establish clarity about how to declare environmental performance in the future. Here is a route choice between EPD and PEF. SBMI is critical of the fact that the EPD standards are not clearly designated as the tool that will primarily be used for this. The work we and other industries put into EPD would be in vain if the EPD system is not used.
SBMI stresses that building materials that are not put on the market cannot be CE marked.
The document states that all material, including that which arises and is used within the same project, must be CE-marked, even though it is not “put on the market”. SBMI considers that the proposal regarding the requirement to prepare a declaration of performance for construction products manufactured at the construction site for direct use in construction projects without being placed on the market needs to be impact assessed. This situation is common in our industry. The requirement to CE mark these products risks leading to significantly increased costs for construction, entails a significantly increased regulatory burden without corresponding benefit, and possibly contravenes national legislation.
SBMI proposes that the proposal for a common product database needs to be reworked
A database for the whole of Europe is something completely different from what is described in the assignment. Previously, DOP would be in the form of a paper, and the assignment states that one must “establish an opportunity to do this digitally”. An opportunity to declare fulfillment digitally is not the same as a requirement to register all products in a central database. This proposed database risks to significantly increase the administrative burden. For the construction industry's products, products often have project-unique properties.
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