CFE position on the legislative proposal for the CPR revision

On 30th March, the European Commission has published a proposal for the revision of the Construction Products Regulation (CPR).

CFE has contributed to the public consultation with the following core positions:

  1. CFE appeals to include EADs again in the definition of harmonised technical specifications, which would mean that they become also part of the new introduced Harmonised zone.
  2. CFE appeals to maintain the current practice of the publication and citation of EADs after the first ETA was issued, in order to maintain agility and momentum in the ETA process.
  3. CFE appeals to maintain the current regulation that a DoP and CE marking is required for products covered by an ETA.
  4. CFE appeals to allow the reference to more than one ETAs/EADs in a DoP, as this is the case for references on Harmonised technical specifications (Annex II 8.).
  5. CFE appeals to limit the influence of the European Commission on the EAD development process to clearly defined exceptional cases.
  6. CFE appeals to modify Annex III 6. in a way that member states are obliged to introduce national requirements in the EAD development process to make sure that EADs and ETAs cover all national requirements on the respective product.
  7. CFE appeals, that for cases, where the design methods for products covered by ETAs are not fully covered by Eurocode standards, the EAD format should allow to include information on specific design methods for the products covered by this EAD.
  8. CFE appeals to introduce conflict resolution mechanisms on EU level. The EU wide validity of such solutions would provide legal certainty for all stakeholders and a level playing field for all manufacturers.