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UL Solutions

A global leader in applied safety science, UL Solutions transforms safety, security and sustainability challenges into opportunities for customers in more than 110 countries.

Lobbying Activity

Response to Omnibus Regulation Aligning product legislation with the digital age

25 Aug 2025

UL Solutions respectfully submits these comments in response to the proposed regulation regarding digitalization and standard specifications. This proposal suggests introducing common specifications for accreditation standards within Regulation (EU) No. 765/2008. We believe this is unnecessary, as the existing harmonized standards for conformity assessment bodies are already fully adequate and effective. Furthermore, European Accreditation (EA) has developed the document EA-2/17 M:2020 Accreditation for Notification Purposes, which outlines how conformity assessment standards apply to accreditation notified bodies. Rather than introducing new common specifications, we recommend enhancing and harmonizing the EA-2/17 document. This approach would empower EA to align requirements across national accreditation bodies, supporting consistent implementation of harmonized legislation in the European Union. We also wish to highlight a concern regarding the current lack of transparency and details about the methodology the European Commission used in drafting the proposed common specifications. Greater clarity would benefit stakeholders and improve confidence in the process.
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Response to Omnibus Directive Aligning product legislation with the digital age

25 Aug 2025

UL Solutions respectfully submits these comments in response to the proposal for a directive regarding digitalization and common specifications. UL Solutions recognizes the proposals value, and particularly its support for economic operators (EOs) and consumers. The initiative aligns several directives with requirements already present in recent regulations, such as the Battery Regulation and the General Product Safety Regulation (GPSR). To foster complete alignment among EOs, avoid confusion and provide clear guidance on acceptable compliance methods, we strongly recommend prioritizing updating the European Union (EU) Blue Guide. We have noted concerns from EOs regarding the digital contact provisions introduced by the GPSR. While an FAQ document has addressed some of these concerns, the next edition of the EU Blue Guide should include comprehensive and authoritative guidance. As a provider of conformity assessment services, UL Solutions acknowledges the lack of harmonized standards for products covered under the directives referenced in the Omnibus IV package. We commend the European Commissions willingness to address this gap through innovative mechanisms such as introducing common specifications. However, we believe the core challenge lies more in the harmonization process than in developing standards by European standardization organizations. In most cases, the absence of harmonized standards does not stem from a lack of existing European standards, which industry already uses widely. Therefore, an alternative to introducing common specifications could be to focus on improving the efficiency and effectiveness of the harmonization process. Parallel efforts should be made to accelerate this process. Within the framework of EU harmonized legislation, common specifications should remain a fallback option, used only when harmonized standards are unavailable. Common specifications, adopted by the Commission through implementing acts, are intended as an interim fix to promote consistency within the EU single market. However, we regret the lack of transparency and detail regarding their development and adoption. While common specifications have been used in the context of the Medical Devices and In Vitro Diagnostics Regulations and referenced in other legal acts such as the EU Artificial Intelligence (AI) Act, there is limited information on the Commissions methodology in drafting them. For example, although Article 41 of the AI Act mentions consultation with an advisory forum, the Omnibus IV proposal (COM(2025) 503 final) does not provide a clear framework for the broader use of common specifications across EU harmonized legislation. We recommend that common specifications refer to existing European or international standards (per the definition of the World Trade Organization Technical Barriers to Trade Agreement) that are consensus-based, transparent and open, such as those developed by European standardization organizations (like the European Committee for Standardization (CEN), the European Committee for Electrotechnical Standardization (CENELEC) and the European Telecommunications Standards Institute (ETSI)) and other international standards developing organizations (such as the International Organization for Standardization (ISO), the International Electrotechnical Commission (IEC) and UL Standards & Engagement) or other recognized technical specifications (like CEN/CENELEC technical specifications, IEC technical specifications, publicly available specifications) or conformity assessment body-developed technical specifications such as UL Solutions Outlines of Investigation. In any case, adopting common specifications should follow a clear and transparent process. EOs must be able to access and apply these specifications effectively. We suggest creating a centralized database of adopted common specifications and recommend that sufficient transition periods be provided once harmonized standards become available.
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Meeting with Kamil Talbi (Cabinet of Commissioner Dan Jørgensen)

29 Apr 2025 · Software services

Response to European Water Resilience Strategy

27 Feb 2025

UL Solutions, a global safety and sustainability science leader, welcomes the opportunity to provide feedback on the European Commissions call for evidence for the development of the European Water Resilience Strategy. Please read our full response to the consultation in the attached document.
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Response to Carbon footprint methodology for electric vehicle batteries

28 May 2024

UL Solutions welcomes the opportunity to give feedback on the draft delegated act laying down the methodology for calculating and verifying the life-cycle carbon footprint of electric vehicle batteries, as required by the EU Battery Regulation. The suggestions provided by UL Solutions, a global leader in applied safety science, are informed by our global experience and expertise in battery performance and safety testing. We note that the European Commissions initial draft is not fully aligned with the methodology proposed by the Joint Research Centre (JRC) report from June 2023 on battery calculations with Product Environmental Footprint (PEF). Our recommendation is to clearly specify the verification and validation techniques under paragraph 3.2 (Verification Rules, set in the Annex to the delegated act) with a view of better interfacing them to the PEF methodology. The proposed verification requirements are directionally in line with the verification procedures that conformity assessment bodies such as UL Solutions apply for Lice Cycle Assessments based product declarations, however this initiative may be duplicating approaches that already exist and are currently utilized. To that end, we recommend to better align with the general Product Environment Footprint, and to adopt a risk-based approach in line with international standards and verification approaches, to keep assessment efforts reasonable. UL Solutions remains available to discuss these recommendations if desired. About UL Solutions A global leader in applied safety science, UL Solutions (NYSE: ULS) transforms safety, security and sustainability challenges into opportunities for customers in more than 100 countries. UL Solutions delivers testing, inspection and certification services, together with software products and advisory offerings, that support our customers product innovation and business growth. The UL Mark serves as a recognized symbol of trust in our customers products and reflects an unwavering commitment to advancing our safety mission. We help our customers innovate, launch new products and services, navigate global markets and complex supply chains, and grow sustainably and responsibly into the future. Our science is your advantage.
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Response to Drinking water - conformity assessment procedure

15 Nov 2023

UL Solutions welcomes the proposal of the Commission as laid out in the draft document relating to the conformity assessment procedures for products that come into contact with water intended for human consumption and the rules for the designation of conformity assessment bodies involved in those procedures and more specifically article 2 on conformity assessment procedures. After careful review and consideration, we believe this approach is adequate to uphold consumer safety, and we are pleased to express our agreement with the general terms outlined in the draft proposal. We appreciate the comprehensive nature of the proposed assessment options, which align well with our own approach of conformity assessments.. As we move forward, we anticipate a collaborative and productive partnership in implementing the process. We are confident that the outlined assessment options will contribute significantly to the effectiveness and the credibility of the overall scheme. Thank you for your attention to this matter. Sincerely, ABOUT UL SOLUTIONS: A global leader in applied safety science, UL Solutions transforms safety, security, and sustainability challenges into opportunities for customers in more than 100 countries. UL Solutions delivers testing, inspection and certification services, together with software products and advisory offerings, that support our customers product innovation and business growth.
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Response to Revision of the Toy Safety Directive

9 Oct 2023

UL Solutions welcomes the possibility to comment on the European Commissions legislative proposal regarding the Toy Safety Regulation. A global safety science leader, UL Solutions helps companies to demonstrate safety, enhance sustainability, strengthen security, deliver quality, manage risk and achieve regulatory compliance. UL Solutions has a solid experience with regards to toy safety globally and with the European Unions requirements specifically as it operates as a Notified Body in Italy (body number 0376) under Directive 2009/48/EC Safety of toys. Following the publication of the draft legislative proposal we would appreciate if the European Commission would consider the points and feedback enclosed in the attachment in its discussions with the co-legislators. UL Solutions with its science-based safety expertise is committed to engaging in a dialogue with the EU Institutions and all relevant stakeholders as a trusted partner. UL Solutions is grateful for the opportunity to provide these comments and is available at any time to discuss the recommendations enclosed if desired.
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Response to Environmental claims based on environmental footprint methods

14 Jul 2023

UL Solutions welcomes the possibility to comment on the European Commissions legislative proposal on environmental claims with the aim to require companies to substantiate claims they make about the environmental footprint of their products/services by using standard methods for quantifying them. A global safety science leader, UL Solutions helps companies to demonstrate safety, enhance sustainability, strengthen security, deliver quality, manage risk and achieve regulatory compliance. Please find our response to the EU public consultation enclosed. UL Solutions with its science-based sustainability expertise is committed to engaging in a dialogue with the EU Institutions and all relevant stakeholders as a trusted partner. UL Solutions is grateful for the opportunity to provide these comments and is available at any time to discuss these recommendations if desired. Please do not hesitate to contact me with any questions or additional requests for information.
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Response to Revision of the Directive on Driving Licences

31 May 2023

UL Solutions respectfully submits these comments in response to the legislative proposal on Driving licenses, amending Directive (EU) 2022/2561, Regulation (EU) 2018/1724, and repealing Directive (EU) 2006/126/EC & Regulation (EU) No 383/2012. UL Solutions (hereafter ULS) helps companies to demonstrate safety, enhance sustainability, strengthen security, deliver quality, manage risk, and achieve regulatory compliance. ULS maintains expertise in all areas of security and provides validation and verification services in personal identification, transit, financial transaction, mobile telecommunications, PKI (Public Key Infrastructure) management, cryptography, tokenization, and related domains. ULS is accredited as a lead auditor for ISO 27001 Information Security Management. In the personal identification space, ULS has a track record on e-MRTD (e-Passport) and electronic drivers license validation and verification, including the PKIs (Public Key Infrastructure) used. ULS has been working globally with governments and agencies having jurisdiction to develop properly secured mobile driver licenses (mDL). Our experience with the Netherlands Vehicle Authority (RDW) as well as U.S.-based Departments of Motor Vehicles (DMV) in Iowa and Florida, and Austroads (the collective of Australian and New Zealand Transport Agencies) contributed to our expertise and helped validate the feasibility of the ISO/IEC 18013-5 standard (Personal Identification Mobile Driving License application), by assessing the implementation of critical mDL features through an open source mDL proof-of-concept. ULS commends the European Commission for its referencing of ISO/IEC 18013-5 in the Annex to its legislative proposal for test methods, compliance of applications and systems. We also believe that the European Commission should rely on third-party testing with laboratories certified to ISO/IEC 17025 and certification to ensure a consistent level of security and interoperability across all implementations of mobile drivers licenses and readers, as well as provide trust for digital credentials. UL Solutions is grateful for the opportunity to provide these comments and is available at any time to discuss these recommendations if desired. About UL Solutions: A global leader in applied safety science, UL Solutions transforms safety, security and sustainability challenges into opportunities for customers in more than 100 countries. UL Solutions delivers testing, inspection and certification services, together with software products and advisory offerings, that support our customers product innovation and business growth. The UL certification Marks serve as a recognized symbol of trust in our customers products and reflect an unwavering commitment to advancing our safety mission. We help our customers innovate, launch new products and services, navigate global markets and complex supply chains and grow sustainably and responsibly into the future. Our science is your advantage.
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Meeting with Elina Melngaile (Cabinet of Executive Vice-President Valdis Dombrovskis)

24 May 2023 · Trade and Technology Council, new technologies, new technology standards

Response to Promoting sustainability in consumer after-sales

22 May 2023

UL Solutions welcomes the European Commissions intention to reduce waste and achieve a high level of consumer and environmental protection through the right to repair and reuse legislative proposal. A global safety science leader, UL Solutions helps companies to demonstrate safety, enhance sustainability, strengthen security, deliver quality, manage risk and achieve regulatory compliance. At UL Solutions we promote responsible circularity in the interest of maximizing sustainable societal benefit for resources, protecting the planet and promoting equity for future generations. Circularity without maintaining safety is not sustainable, and safety without responsible circular pathways will increasingly become insufficient. We support safe and sustainable pathways for the global market, which means discouraging practices that might put consumers at risk and promoting appropriate and transparent representations of products in the marketplace. We also want to stress that we cannot be aware of the safety implications of after-market actions on products we have certified unless we have specifically evaluated the modified product. Hence co-managing safety and sustainability in the legislation is essential. Taking into account the need to balance safety and sustainability imperatives, we would like to highlight that the products in the scope of this legislative proposal should not create additional safety risks for repairers. When it comes to repairs, it is crucial to ensure that a classification system is put in place depending on the complexity of the repair. More precisely, we strongly recommend that guidelines are in place regarding the qualifications of the repairers to safely repair. For instance, it should be clarified whether the repairers have been approved by the OEM, or the repairers have received relevant training, or whether the repair is simple and can be performed by the consumer. Furthermore, we would like to recommend that further clarifications are provided regarding the reuse of spare parts that may have been certified by independent third-party certification organizations. What is more, we would like to ask further clarifications regarding the certification of products or reused/spare parts and liability that stems from this. In addition, we strongly recommend that the components to be used should be verified against the product safety standard (e.g., IEC 60335-x for electrical products). Moreover, we would like to suggest that the co-legislators take into account the already-existing European Standards (e.g., DS EN 45554 general methods for the assessment of the ability to repair, reuse and upgrade energy-related products), which are developed by technical experts. As far as ensuring safety is concerned, we strongly suggest that the product components destined for reuse in the circular economy should be certified as fit for use in repair applications, according to common standards and through repeatable / measurable test methods. Lastly, it would be important to clarify the ways that the existing available services are being used to repair products. This will ensure that there is no unnecessary duplication and that the current draft legislation provides added value. At this point we would like to provide some further information on the UL Solutions Reconditioned Equipment Program Requirements (available in the attachment). UL Solutions with its science-based sustainability expertise is committed to engaging in a dialogue with the EU Institutions and all relevant stakeholders as a trusted partner. The aim will be to ensure that the initiative encourages producers to design goods that last longer and are easily reparable, helps reduce unsustainable consumption and its negative impact on the global environment and climate and helps build a circular economy. UL Solutions is grateful for the opportunity to provide these comments and is available at any time to discuss these recommendations if desired.
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Response to Ecodesign for Sustainable Products - Product priorities

9 May 2023

A global safety science leader, UL Solutions helps companies to demonstrate safety, enhance sustainability, strengthen security, deliver quality, manage risk and achieve regulatory compliance. UL Solutions welcomes the European Commissions intention to improve the EU products circularity, energy performance and sustainability, as envisioned under the proposal for the Ecodesign for Sustainable Products Regulation. Considering the scope of this public consultation we would like to highlight the following: - End-use products: Overall, we are in line with the Joint Research Centers identification of the end-use product priorities, in particular, the textile (apparel and accessories) as well as the footwear industries. Before these products are placed on the market, they should comply with material efficiency (e.g., durability etc.) and the use and presence of hazardous chemicals shall be minimized as they can also hamper the recycling of textile waste. - Intermediary products: When it comes to intermediary products, e.g. plastic, or recycled content related to any intermediary products, there is value in third party testing that can help counter misleading claims by determining that indeed the product complies with specific standard. This would be in line with the European Commissions proposal on substantiation and communication of explicit environmental claims, which recognizes third party conformity assessment bodies as key actors in ensuring the reliability and credibility of environmental claims to empower consumers and fight greenwashing. - Horizontal measures: We would like to suggest that the European Commission defines the practical ways to evaluate the horizontal measures (in terms of how the standards translate into test methods). We are also seeking clarity and guidance on the comparability criteria for durability. Durability is based on comparison of specific criteria. Hence, we believe it would be significantly important to establish a common way to identify how we test durability according to the upcoming legal requirements. Clear requirements and clear ways of measuring would be essential. As far as durability is concerned, we strongly recommend that any upcoming guidance includes safety provisions for repairable or durable products. Hence co-managing safety and sustainability in the legislation is essential. We would also like to propose the inclusion of, as an additional horizontal measure, sustainable chemistry. Chemical management will be required for product manufacturing, which at the moment is not standardized. Sustainable chemistry is also linked to recyclability. For example, plastics with halogenated flame retardants or those containing PFAS cannot be recycled since they contain ingredients that are mostly banned or restricted. Lastly, some guidance should be developed regarding the possible compromise that organizations may need to make when choosing for e.g., between durability, reparability and recyclability. Overall, we believe that more guidance and more reference to already existing, international, as well as national standards, will be essential in ensuring a common understanding of the criteria for durability, recyclability and sustainable chemistry. UL Solutions with its science-based sustainability expertise is committed to engaging in a dialogue with the EU Institutions and all relevant stakeholders as a trusted partner. The aim will be to ensure that the Ecodesign for Sustainable Products Regulation delivers benefits to businesses, consumers and the environment as envisioned by the European Commission.
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Meeting with Malte Gallée (Member of the European Parliament)

17 Jan 2023 · Green claims initiative

Response to Review of the Construction Products Regulation

12 Jul 2022

UL Solutions response to the Public Consultation on Construction Products – Review of EU rules UL Solutions respectfully submits these comments in response to the draft legislative proposal for a regulation laying down harmonised conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011, published in March 2022. The suggestions and feedback provided by UL Solutions are informed by its experience implementing, conducting, and administering multiple safety certification programs with construction products, especially with regards Regulation (EU) 305/2011, including as an independent entity providing product certification pursuant to the Construction Products Regulation, namely as it relates to fire safety (detection, smoke alarms, etc.), floorings, doors, and building hardware. We welcome the opportunity to submit feedback as we have done since the publication of the inception impact assessment. Our comments primarily focus on suggested rules applicable to EU Notified Bodies (NBs). UL Solutions shares the Commission’s views that there needs to be a rigorous framework to ensure consistency and performance. However, in our view, the proposed changes would introduce considerable unfair new requirements that Notified Bodies will have to meet in relation to construction products which should be considered unduly arduous and incompatible with current and future practices pertaining to organisations. If applied, this would entail a risk of restricting the number of available Notified Bodies (with no impact of competencies and/or overall safety improvements), which in turn could create bottleneck situations for manufacturers as well as reduce consumer choice. In particular: - proposed Article 50 (§6-a), as well as Article 55 (§2), would pose serious human resources issues to NBs. Local staffing requirements create unfair conditions for smaller Member States (such as Denmark and Netherlands). The current situation allowing the employment of staff across multiple owned locations, where the control of competencies of staff is rigorously maintained through contracts between the Notified Body and the staff employed under its responsibility has proven to be an efficient model. In our views, requirements should rather focus on ensuring competency, not on geographical considerations, - proposed Article 60 (§7) should at least distinguish between large and smaller Notified Bodies. The proposed mandatory rotation rule is impractical within small NBs, where staff has specific expertise they need to maintain to perform their duties to the highest level of excellence. Rotation should be encouraged, not imposed. We encourage the Commission and co-legislators to amend the proposed regulation to ensure adequate Notified Body capacity at the EU level, drive competition in the market place and promote a higher level of competence and safety across the Single Market. UL Solutions is grateful for the opportunity to provide these comments and is available at any time to discuss these recommendations if desired. About UL Solutions: A global leader in applied safety science, UL Solutions transforms safety, security and sustainability challenges into opportunities for customers in more than 100 countries. UL Solutions delivers testing, inspection and certification services, together with software products and advisory offerings, that support our customers’ product innovation and business growth. The UL Certification Marks serve as a recognized symbol of trust in our customers’ products and reflect an unwavering commitment to advancing our safety mission. We help our customers innovate, launch new products and services, navigate global markets and complex supply chains and grow sustainably and responsibly into the future. Our science is your advantage.
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Response to Revision of the Toy Safety Directive

1 Nov 2021

UL welcomes the opportunity to submit feedback on the European Commission’s Inception Impact Assessment regarding the Revision of the Toy Safety Directive (TSD). UL has a solid experience with regards to toy safety and is representing one NB under Directive 2009/48/EC Safety of toys. Sharing the Commission’s assessment of the situation, there are existing and future challenges that need to be addressed by revision of the TSD. We would appreciate it if the Commission would consider the following points in its continuing work. 1/ Derogations and limits for CMR and for other substances that will be added to the revised directive/regulation shall be clearly identified and easy to be applied/interpreted. 2/ UL is in favor of a clear and consistent approach on how to develop chemical safety assessment if this will include more substances (e.g. endocrine disrupters, PBT) and combination effects of chemicals. 3/ Regarding the intention to restrict substances like endocrine disrupters or PBT, a clear classification criteria for endocrine disrupters and PBT substances are needed to make sure that if included in the restriction of the TSD this will be applicable in a consistent way. 4/ Chemical restrictions that will be added in the revised directive/regulation (e.g. in Appendix C or also for toy for children >36 month) should be clear in their applicability and test methods to be applied. In case test methods need to be developed, the standardization process should be aligned with the timing of regulation. 5/ With regards to the intention of setting of chemical limit values for any toys and not only for those intended for children under 36 months, it is necessary to have legal certainty for the chemical requirements and not chemical assessment. 6/ With regards to the Digital Product Passport, UL is of the opinion that the Digital Product Passport could help speed up enforcement, but it is of utmost importance that it is clearly defined which are the documents/information it shall contain and the differences with technical documentation currently requested in TSD or with other compliance docs e.g. Declaration of Conformity. 7/ UL calls for harmonized requirements within EU with, if possible, no national deviations. Therefore, UL supports the ambition of the conversion from a Directive to a Regulation. 8/ UL stresses the need for speed up the timeframe from publication of standards to harmonization of them. UL respectfully submits our feedback and look forward to the upcoming public consultation. For further inquiries and discussions, we are always at your disposal. About UL: UL is a premier, global independent safety, sustainability and security science company that has championed progress for more than 126 years. Its nearly 16,000 professionals across 44 countries are guided by the UL mission to promote safe and secure working and living environments for all people. They do so through the application of safety science and hazard-based safety and security engineering. The application of these principles manifests itself in the safety and security evaluation of tens of thousands of products, components and systems for compliance to specific requirements. All our work, from independent research and standards development, to assessment, verification services and certification, to providing analytical and digital solutions, helps improve the well-being of people and places globally.
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Response to Revision of the Directive on Driving Licences

21 May 2021

UL’s response to European Commission request for input on the Revision of the Directive on driving licences. In this memo, UL would like to specifically respond to the following objective and policy option: Page 2, Objective 5: enable the recognition of digital driving licences among Member States of the European Union, with the corresponding policy option: to establish a framework for digital driving licences, from interoperability requirements to a common solution, including potential links to the national registries, to update the security features for physical licences. Our response: The 3rd driving licence directive enabled adding a microchip to the physical driving licence. The technical requirements for the microchip, as laid down in Regulation 383/2012, are based on the ISO/IEC 18013 series of standards for ISO-compliant driving licence. Specifically Parts 2 and 3 of this International Standard form the basis for the microchip requirements, and Part 4 forms the basis for the requirements for EU Type Approval. In the Inception Impact Assessment of the Revision of the Directive on Driving Licences, the Commission expresses the specific objective to “Enable the recognition of digital driving licences among Member States of the European Union”. The Commission adds that the Impact assessment will address policy options to establish a framework for digital driving licences, from interoperability requirements to a common solution, including potential links to the national registries. We would like to draw your attention to the ongoing work regarding ISO-compliant driving licences in ISO/IEC, with the active participation of a significant number of national standardisation bodies of EU Member States. To enable digital driving licences, Part 5 of the ISO/IEC 18013 Standard lays down the interoperability requirements for the so-called mobile Driving Licence (mDL), following up to ISO/IEC 18013-2/3 which already is currently being used in the EU for interoperability. Moreover, ISO/IEC prepares Part 6 of the standard, which lays down the test methods for implementations of ISO/IEC 18013-5, similar to the test methods in Part 4, which the Commission references in Regulation 383/2012. Adoption of this standard may not only facilitate EU-wide interoperability, but may enable EU citizens to use their digital EU driving licences around the world. (As an example, a recent request for information by the US Department of Homeland Security strongly suggests that the US government considers adoption of this standard as part of the Rulemaking under the REAL ID Modernization Act. Also, several states in the US and in Australia have contracted European vendors to support their implementation of this standard.) As the ISO/IEC standard was designed according to security-by-design and privacy-by-design principles, use of the data minimization features of the EU digital driving licence may help EU citizens protect their personal data when they travel abroad. UL urges the European Commission in their initiative to revise the Directive on driving licenses to review the work that’s been done in the international standards setting space to ensure that mobile drivers licenses (and other digital credentials) are trusted, interoperable, and secure. UL led the task force under ISO/IEC JTC1/SC17 (security devices for personal identification) and stands ready to support with this important effort. About UL Since its inception in 1894, UL serves a mission of promoting safe living and working environments for people everywhere and fulfills a promise of facilitating the flow of goods across borders. UL uses research, standards, and conformity assessment to continually advance and meet ever-evolving safety challenges, and partners with businesses, manufacturers, retailers, trade associations, and international regulatory authorities to provide solutions and to address the risks of increasingly complex global supply chain.
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Response to Review of the Construction Products Regulation

19 Aug 2020

UL welcomes the opportunity to submit feedback on the European Commission’s Roadmap regarding the Review of the Construction Products Regulation (“CPR”). UL has a solid experience with construction products, especially with regards Regulation (EU) 305/2011, including as an independent entity providing product certification pursuant to the Construction Products Regulation, namely as it relates to fire safety (detection, smoke alarms, etc.), floorings, doors and building hardware. Sharing the Commission’s assessment of the situation, there are existing and future challenges that need to be addressed by revisiting the CPR and our preference, as it relates to the policy options laid out in the Roadmap, goes to Option D2 which does aim at “repairing the CPR” in addition to product requirements matching the necessary objectives of health, safety and environment. The CPR undeniably helps facilitate trade within the European Union and fixing it appears the best option. There are several issues a revision should address: - in particular how to deal with innovative products. These take years to place on the EU Single Market – the pragmatic approach as illustrated by EOTA’s alternative route, appears unsatisfactory: for a standardization process to have two routes is not sustainable. Manufacturers should be able to rely on one single route, one flexible enough to allow for innovation (CEN would have to become more agile), - the existing framework for Declaration of Performance (DoP) does not ensure a level-playing field and needs to be enhanced, with DoPs relying more on standards. The idea of database for product performance could be explored, whether based on the Declaration, or else - regarding fire safety, it would be worth exploring a common language to enable products being sold in different countries. The CE Mark can coexist with voluntary compliance marks, - improving the efficacy of Notified Bodies, including a clearer framework for notification preventing a difference of treatment between bodies and in line with other harmonized legislation Delivering on the commitments of the European Green Deal and its New Circular Economy Action Plan requires to consider sustainability from a product performance angle, with clearer incentives: - The aspect of indoor air quality is mentioned in the CPR – Annex I makes a clear reference to Volatile Organic Compounds (VOC) controls but there is no clear method or acceptance criteria to drive compliance whilst solutions do already exist. The revision could encourage the use of voluntary certification programs, such as UL2821 GREENGUARD Certification Program Method for Measuring and Evaluating Chemicals Emissions From Building Materials, Finishes and Furnishings, - Control on recycled content of components and Environmental Product Declaration according to ISO14025 should be considered in the revision The European Green Deal also allows to consider a holistic approach and create a bridge with initiatives outside of DG GROW such as Level(s) – the European Framework for sustainable buildings. UL respectfully submits our feedback and look forward to the upcoming public consultation. About UL: UL is a premier, global independent safety, sustainability and security science company that has championed progress for more than 126 years. Its nearly 16,000 professionals across 44 countries are guided by the UL mission to promote safe and secure working and living environments for all people. They do so through the application of safety science and hazard-based safety and security engineering. The application of these principles manifests itself in the safety and security evaluation of tens of thousands of products, components and systems for compliance to specific requirements. All our work, from independent research and standards development, to assessment, verification services and certification, to providing analytical and digital solutions, helps improve the well-being of people and places globally
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