Open letter CPR review continuation ETA route
(Read the full content of the Open letter)
The European Organisation for Technical Assessment (EOTA) is concerned over the radical changes proposed by the European Commission in the Refined Indicative Options for the Review of the Construction Products Regulation of 8 April 2020, especially with regard to the possible discontinuation of the ETA route.
While a targeted improvement of the Construction Products Regulation (CPR) would benefit all stakeholders, some of the Commission’s current suggestions risk affecting the construction sector very negatively in terms of adaption costs, timeliness and the practicability of implementation as well as international competitiveness.
The discontinuation of the ETA route, for instance, would remove considerable flexibility from the system and create major hurdles for manufacturers of non-standard products, such as innovative, complex, unique/niche or green products. Some non-standard products might even be blocked from the internal market and CE marking altogether. This situation risks harming the European Union's competitiveness, distorting the competition among upcoming product technologies, and increasing the uncertainty that manufacturers would have to accept in order to enter the European market. All in all, this would create an innovation-adverse climate.
The current ETA route, as a complement to main standardisation, presents major benefits to the construction sector:
• The ETA route is open to any (current or future) non-standard construction product, especially improved and innovative products, niche products and products for which there is as yet little on-site experience. The route thus ensures that these products have full, quick and unlimited-in-time access to the internal market and CE marking.
• The ETA route creates a climate for innovation.
• The ETA route has been very successful in aligning market needs with the regulatory requirements of the EU Member States.
• The ETA route provides manufacturers with an instrument of high international renown, giving them easy access to many third-country markets.
EOTA is convinced that the current two-track harmonisation system (the main standardisation route complemented by the EOTA route) renders the European construction sector, in principle, well-equipped to compete on the international scene and to take construction into a greener future. Any revision of the CPR should, therefore, focus on tapping the full potential of the current harmonisation framework.
EOTA would also like to highlight the importance of finding viable short- and medium-term solutions to the current harmonisation backlog and allocating sufficient resources to this cause. Valuable initiatives, such as the model clauses for sustainability (BWR 7), which were jointly developed by the European Commission and EOTA, or the JIS-5-Action at CEN level (regrettably discontinued), should be followed up on and consistently implemented.
In light of the arguments mentioned above, EOTA and its members strongly recommend maintaining the ETA route in any future CPR framework as it is a key instrument for innovation in the construction sector. An improvement of the current system, rather than complete change, will be the best way forward.