On December 13, 2017, a Delegated Regulation was published in the Official Journal of the European Union-OJEU, in force after 20 days of its publication:

The Commission’s Delegated Regulation (EU) 2017/2293, related to the conditions for classification, without testing, of cross laminated timber products covered by the harmonised standard EN 16351 and laminated veneer lumber products covered by the harmonised standard EN 14374 concerning their reaction to fire.

Tests have shown that these products have a stable and predictable reaction to fire performance provided that they meet certain conditions regarding the form of the product as well as its installation, mean density and thickness.

The annex to the Delegated Regulation (EU) 2017/2293 establishes reaction to fire classes according to minimum layer or veneer thickness, surface layer (floorings), minimum overall density and thickness for both types of product, depending on whether the product is used for walls and ceilings (table 1) or for floorings (table 2).

The European Commission has assigned the elaboration of a supporting study for the joint evaluation and impact assessment for the CPR review. The executors are: Joint Institute for Innovation Policy (JIIP), Valdani Vicari & Associati (VVA), Danish Technological Institute (DTI) and Global Data Collection Company (GDCC).

The overall objective of the study is to provide a retrospective analysis of the CPR performance and the extent to which it has met its original objectives. The study will also examine whether it will be appropriate to propose a revision of the CPR.

It includes a series of actions, some of which are already being implemented, like surveys or interviews with several EU Member States stakeholders, concerned with the application of the Regulation. The study is expected to be completed by June 2018.

As a Technical Assessment Body and Notified Body in the CPR framework, ITeC has received and completed the survey. Some outstanding aspects:

• European Assessment Documents and European Technical Approvals have favoured access to the European market for any product -whether innovative or not- not covered by a harmonised standard. It has also made CE marking possible for products produced by a small number of manufacturers. Finally, it has also favoured marketing products outside the EU.
• Some adjustments of the Regulation may be required at a technical coherence level -e.g. critical characteristics for the intended use of a product should always be defined together with its performance -and also at a procedure level- e.g. revision of Annex II on the EAD adoption procedure, according to the proposal made by EOTA.
• It is recommended to improve the Regulation implementation together with punctual adjustments in those areas where needed.

For months, the publication of nine ETA Guideline or guideline part conversions in the Official Journal of the European Union-OJEU was pending decision on clauses to assess dangerous substances. This is the Commission’s condition regarding these guidelines -already completed by EOTA- in which the inclusion of these clauses was planned in a second phase of the conversion.
In November, EOTA presented the proposal for the nine documents. After several adjustments, the dangerous substances clauses have been agreed to and the nine EADs have been published in the OJEU (15.12.2017).

These conversions correspond to the following EAD:

• ETAG 001-5 – EAD 330499-00-0601 Bonded fasteners for use in concrete
• ETAG 013 – EAD 160004-00-0301 Post-tensioning kits for prestressing of structures
• ETAG 013 – EAD 160027-00-0301 Special filling products for post-tensioning kits
• ETAG 018-2 – EAD 350402-00-1101 Reacting coatings for fire protection of steel elements
• ETAG 018-3 – EAD 350140-00-1106 Renderings and rendering kits for fire resisting applications
• ETAG 018-4 – EAD 350142-00-1106 Fire protective board, slab and mat products and kits
• ETAG 026-2 – EAD 350454-00-1104 Penetration seals
• ETAG 026-3 – EAD 350141-00-1106 Linear joint and gap seals
• ETAG 029 – EAD 330076-00-0604 Metal injection anchors for use in masonry

New clauses have been written based on the Commission’s revised document “Guidelines for the use of the EAD format” concerning dangerous substances assessment. This revision prioritizes assessment for VOC emissions, according to EN 16516, in scenarios in which products can have direct or indirect contact with indoor air, and assessment for dangerous substances leaching, in cases where the product can have direct contact with ground and surface water.

At the 18^th meeting of the EOTA Technical Board, the state of the conversion works from the first set (priority A) was analysed. Eleven of these conversion works have already been published in the OJEU.

Detailed situation of the conversion works:

• EAD on mechanical fasteners (conversion from ETAG 001 parts 1 to 4): published in the OJEU, on 9.12.2016 (*).
• EAD on bonded anchors (conversion from ETAG 001 part 5): published in the OJEU, on 15.12.2017, once solved the clauses to assess dangerous substances requested by the Commission (*).
• EAD on mechanical fasteners for multiple use for non-structural applications (conversion from ETAG 001 part 6): the progress in this document will possibly be dealt with during a February meeting.
• EAD on prefabricated stair kits (conversion from ETAG 008): published in the OJEU, on 13.5.2016.
• EAD (2 doc.) on post-tensioning kits for prestressing of structures (conversion from ETAG 013): published in the OJEU, on 15.12.2017, once solved the clauses to assess dangerous substances requested by the Commission.
• EAD on reactive coatings for fire protection of steel elements (conversion from ETAG 018 part 2): published in the OJEU, on 15.12.2017, once solved the clauses to assess dangerous substances requested by the Commission.
• EAD on fire protective renderings (conversion from ETAG 018 part 3): published in the OJEU, on 15.12.2017, once solved the clauses to assess dangerous substances requested by the Commission.
• EAD on fire protective boards (conversion from ETAG 018 part 4): published in the OJEU, on 15.12.2017, once solved the clauses to assess dangerous substances requested by the Commission.
• EAD on penetration seals (conversion from ETAG 026 part 2): published in the OJEU, on 15.12.2017, once solved the clauses to assess dangerous substances requested by the Commission.
• EAD on linear joint and gap seals (conversion from ETAG 026 part 3): published in the OJEU, on 15.12.2017, once solved the clauses to assess dangerous substances requested by the Commission.
• EAD on mechanical fasteners for use in masonry (conversion from ETAG 029): published in the OJEU, on 15.12.2017, once solved the clauses to assess dangerous substances requested by the Commission (*).

(*) Revision and technical improvement works have started (2^nd phase of the conversion). The published EAD is the result of a conversion without technical changes, but including punctual changes in some cases.

At the 18^th meeting of the EOTA Technical Board, the state of the conversion works from the second set (priority B) was analysed. One of these conversion works has already been published in the OJEU.

Detailed situation of the works:

• EAD on structural sealant glazing systems (conversion from ETAG 002 parts 1 and 3): working group draft pending application of the new clauses to assess dangerous substances agreed to with the Commission.
• EAD on internal partition kits (conversion from ETAG 003): finalized EAD, pending EC consultant comments.
• EAD on external thermal insulation composite system (conversion from ETAG 004): new draft planned for December and working group meeting in January or February.
• EAD on plastic anchors for ETICS (conversion from ETAG 014): published in the OJEU, on 9.12.2016..
• EAD on plastic anchors (conversion from ETAG 020): comments on the draft circulated until October 21 were received and will be dealt with by the working group.
• EAD on falling rock protection kits (conversion from ETAG 027): an industry consultation has been carried out, with positive result. Next step can now be started.

At the 18^th meeting of the EOTA Technical Board, the state of the conversion works from the third set (priority C) was analysed.

• EAD on three-dimensional nailing plates (conversion from ETAG 015): there were no comments on these works at the meeting.
• EAD on dowels for structural joints (conversion from ETAG 030): the industry is interested in parts 2 and 3 of this guideline.
• EAD on cladding kits (conversion from ETAG 034 parts 1 and 2): EAD was sent to the Commission for publication; the Commission will provide some indications for the revision of the clauses to assess dangerous substances.

• ITeC will be the convenor of the ETAG 028 conversion works, on fire retardant products, which will start at the beginning of 2018. The work plan, prepared by ITeC, has been presented at the 18th Technical Board meeting.
• Conversion works led by ITeC on the ETAG 034 on kits for external wall claddings is currently at the publishing phase (EAD sent to the Commission on 17.10.2017).
• The Commission has informed EOTA that clauses to assess dangerous substances need updating in accordance with the final criteria agreed to in December for priority A ETA Guidelines.

• ITeC has five European Assessment Documents-EAD published in the OJEU. It is, at present, working on twelve other EAD:
  • One has been sent to the publication phase, as the first European Technical Assessment-ETA has been issued.
  • Five have been internally approved by EOTA and the corresponding European Technical Assessment-ETA are being prepared
  • The six remaining are at different elaboration phases

• Between 30.06.2017 and 17.10.2017, ITeC has issued three ETA and has twenty one under elaboration at present.
• The issued ETA are from the following ETAG and EAD (see EOTA’s website, under publications).
  • ETAG 001, part 5, on bonded anchors
    • ETA 17/0916 SINMAST EPOXYFAST ANCHOR from SINTECNO SA
  • ETAG 005, on liquid applied roof waterproofing kits
    • ETA 08/0241 PRENOTECH^® from IMREPOL SL
  • EAD 330232-00-0601, on mechanical fasteners
    • ETA 17/0871 VSP Anchor from VORPA SRL

A few published EADs have already been affected by this situation. Some of the criteria based on discussions that have recently taken place in EOTA are described below.

When a modification of an EAD is published, the inclusion of technical changes is very likely, e.g. changes in a testing method, an expansion of the scope or the intended use, an additional essential characteristic, etc.

If changes do not affect an ETA issued from the previous EAD version, the manufacturer’s decision of not modifying its product ETA is justifiable.

Moreover, if these changes affect the issued ETA -e.g. test method change – it is necessary to update the ETA, since it will not be covered by the modified EAD, which will supersede the previous one.

It is the manufacturer’s decision to modify an ETA, in view of the EAD changes. The Technical Assessment Body that issued the ETA will be available to assess and give all the necessary information.

At the last Technical Board meeting it was agreed to notify changes and dates at the beginning of modified EADs. This decision will be applied in the new EAD modifications.

• EOTA Event, Brussels, November 15, 2017
• EOTA General Assembly, Brussels, November 16, 2017
• Technical Board num. 18, Brussels, November 29 and 30, 2017

• Technical Board num. 19, Brussels, March 21 and 22, 2018
• EOTA General Assembly, Brussels, April 17, 2018
• Technical Board num. 20, Brussels, June 20 and 21, 2018