Until now, the European Commission has carried out several studies on the Construction Products Regulation (CPR) based on surveys, interviews and technical platforms. The Commission has recently launched a new study to complement the earlier data collection – resulting from the previous studies – and its analysis, and to support any decision to be made on future options.

The starting point is a survey based on the issues identified in the CPR assessment carried out by the Commission. This survey has a relevant role in the future definition of potential options. Consequently, it is only addressed to experts, mainly to Advisory Group members and stakeholders who participated in the technical platforms for the CPR Revision.

The distribution of the corresponding questionnaire was initiated on 11 October, with an answer deadline on 31 October.

Apparently, the time estimated for the CPR revision is a first draft in 2021, the revised CPR publication in 2023 and its implementation in 2025.

Results of this survey will enable the definition of the approach that CPR revision must take into account to solve the problems identified by the Commission.

ITeC received and answered this questionnaire, as it did in the previous consultations and surveys, expressing its position as a technical assessment body and as a notified body, within the CPR framework.

Dated on 12 July, the following delegated regulation was published in the Official Journal of the European Union (OJEU), in force twenty days after its publication:

Delegated Regulation (EU) 2019/1188 of the Commission, on classes of performance in relation to resistance to wind load for external blinds and awnings, covered by harmonised standard EN 13561. This standard includes four classes of performance for this characteristic, but these are not sufficient to cover all the products currently available on the market, because the most recent offer a higher resistance to wind load. For this reason, three more classes of performance have been added concerning resistance to wind load.

Besides, the use of classes among subfamilies of products covered by standard EN 13561 is differentiated, particularly for folding arm awnings, external blinds with fabric running in lateral guide rails and pergola awnings.

Dated on 12 August, the following delegated regulation was published in the Official Journal of the European Union (OJEU), in force twenty days after its publication:

Delegated Regulation (EU) 2019/1342 of the Commission, on classes of performance in relation to air permeability for rooflights of plastics and glass and roof hatches. These products were partly covered by harmonised standards EN 1873 and EN 14963, but none included a performance classification for the essential characteristic air permeability.

To better serve market needs, new versions of those standards, EN 1873-1, EN 1873-2 and EN 1873-3 for rooflights – of plastic and glass – and roof hatches, as well as standard EN 14963, must include a performance classification for the essential characteristic air permeability. This classification will include three classes of performance.

Annex of Delegated Regulation (EU) 2019/1188 includes three tables with the classes of performance in relation to the resistance to wind load, depending on the nominal wind pressure and the security wind pressure p_N (N/m²), for the following subfamilies:

1. External blinds with fabric running in lateral guide rails and pergola awnings: seven classes, from 0 to 6
2. Trellis arm awnings, slide arm awnings, vertical roller blinds, marquisolettes, façade awnings, roof hatches, conservatory awnings and insect screens: four classes, from 0 to 3
3. Folding arm awnings: three classes, from 0 to 2.

Annex of Delegated Regulation (EU) 2019/1342 establishes three classes of performance – A, B and C – for air permeability (m³/h·m), depending on internal pressure lower and upper limit values (Pa).

The Commission observed an increasing number of ETA requests that require the amendment of EADs already cited in the Official Journal of the European Union (OJEU). This means the setting up of numerous updating processes to publish the amended EADs in the OJEU.

This situation generates inconveniences, both for manufacturers having an ETA issued from the initial EAD, and for notified bodies for this EAD. These inconveniences worsen when an EAD has a significant number of issued ETAs, as is the case of some EAD resulting from the conversion of ETA Guidelines (ETAG).

To respond to this situation, the Commission presented the document “EAD variants” in the Advisory Group meeting on 1 and 2 July.

In this document, the use of EADs variants for the extensions of EADs that do not affect the main EAD is proposed, i.e. that they modify neither the assessment methods nor the system of assessment and verification of constancy of performance (AVCP) defined. This solution would be applied in those EAD with a significant number of issued ETAs.

An EAD variant consists of a document that will have the same structure (chapters, sections, etc.) as the main EAD, but all those identical clauses will refer to the main EAD. It will only introduce information on those additional aspects related to the EAD extension. Therefore, an amendment of the main EAD will not be necessary. The EAD variant will be published in the OJEU, thereby avoiding the inconveniences caused by the main EAD amendment.

At the last Technical Board meeting, the Commission asked the EOTA to apply this proposal in some EADs, to verify the result of its application.

The above-mentioned extensions can be, for example, resulting from the introduction of additional products, kit components variants, or additional essential characteristics.

We think that the EAD variant can offer a good solution and, if an appropriate result is confirmed, it should be applied not only to particular EADs – with a large number of issued ETAs – but to any EAD object of extension. Some institutes expressed so – ITeC being one of them – at the last Technical Board meeting.

This solution can speed up the amending process of EADs and their publication – in extension cases – and reduce the amount of work of both the technical assessment bodies and the Commission in its EAD monitoring and validation tasks.

In the last Technical Board meeting, the issue of the hundred EAD not yet published in the Official Journal of the European Union (OJEU) – some of them for over a year – was addressed. The Commission informed that it would not be possible to publish these EAD if they were not in accordance with the last criteria and improvements introduced by the Commission. See in Report No. 20, “Introduction of improvements in European Assessment Documents”.

Considering this situation, the Technical Board agreed that each Institute would examine their EAD pending publication and revise those aspects not being in accordance with the last criteria and improvements introduced by the Commission. As EADs are being updated, they will be sent again to the Commission, indicating the date in which they were first sent for publication, and the AVCP system that applies. With this data, the Commission will be able to establish priorities for the publication of these EAD in the OJEU.

These criteria and improvements are related to the implementation of the Communication COM (2018) 764, which also applies to EADs. In this case, it mainly consists of applying the checklist for EADs provided by the Commission, incorporating the assessment methods of Technical Reports-TR cited in the EADs and indicating date in all the references which appear in the EADs. In the case of TRs elaborated within the Directive framework, its content should be updated according to the Regulation.

The publication of the Communication COM (2018) 764, the limited Commission staff monitoring the EADs publication and staff turnover, provoked this accumulation of EADs for publication.

We hope that the Commission will be able to redirect this situation. EOTA and its members are making a big effort to make the publication of all pending EADs possible.

At present, there are eighteen EAD published based on ETA Guidelines, of which the modification of one has already been published. From now on, they will be identified by their reference number.

Published EAD relation:

• EAD 030351-00-0402, for systems of mechanically fastened flexible roof waterproofing sheets (conversion from ETA Guideline 006): published in the OJEU, on 29.05.2019.

• EAD 090062-00-0404, for kits for external wall claddings mechanically fixed (conversion from ETA Guideline 034 parts 1 and 2): published in the OJEU, on 16.11.2018.

• EADs 160004-00-0301 and 160027-00-0301, for kits of post-tensioning systems for prestressing of structures (conversion from ETA Guideline 013): EADs published in the OJEU, on 15.12.2017.

• EAD 210005-00-0505, for internal partition kits for use as non-loadbearing walls (conversion from ETA Guideline 003): EAD published in the OJEU, on 29.05.2019.

• EAD 220089-00-0401, for self-supporting translucent roof kits with covering made of plastic sheets – except from the ones made of glass (conversion from the ETA Guideline 010): published in the OJEU, on 29.05.2019.

• EAD 330076-00-0604, on metal injection anchors for use in masonry (conversion from ETA Guideline 029): published in the OJEU, on 15.12.2017.

• EAD 330196-01-0604, on plastic anchors made of virgin or non-virgin material for fixing of external thermal insulation systems with rendering (conversion from ETA Guideline 014): modification published in the OJEU, on 10.11.2017.

• EAD 330232-00-0601, on mechanical fasteners for use in concrete (conversion from ETA Guideline 001 parts 1 to 4): published in the OJEU, on 9.12.2016.

• EAD 330499-00-0601, on bonded fasteners for use in concrete (conversion from ETA Guideline 001 part 5): published in the OJEU, on 15.12.2017.

• EAD 330747-00-0601, on fasteners for use in concrete for redundant non-structural systems (conversion from ETA Guideline 001 part 6): published in the OJEU, on 10.08.2018.

• EAD 340006-00-0506, on prefabricated stairs kits (conversion from ETA Guideline 008): published in the OJEU, on 13.05.2016.

• EAD 340059-00-0106, on falling rock protection kits (conversion from ETA Guideline 027): published in the OJEU, on 16.11.2018.

• EAD 350140-00-1106, on renderings and renderings kits intended for fire resistant applications (conversion from ETA Guideline 018 part 3): published in the OJEU, on 15.12.2017.

• EAD 350141-00-1106, on linear joint and gap seals (conversion from ETA Guideline 026 part 3): published in the OJEU, on 15.12.2017.

• EAD 350142-00-1106, on fire protective board, slab and mat products and kits (conversion from ETA Guideline 018 part 4): published in the OJEU, on 15.12.2017.

• EAD 350402-00-1106, on reactive coatings for fire protection of steel elements (conversion from ETA Guideline 018 part 2): published in the OJEU, on 15.12.2017.

• EAD 350454-00-1104, on fire stopping and fire sealing products – penetration seals (conversion from ETA Guideline 026 part 2): published in the OJEU, on 15.12.2017.

All the published EAD can be consulted on the EOTA website under the heading “Our Publications”.

At the Technical Board meeting No. 25 the current status of fourteen conversions presently in progress was considered.

As indicated in previous Reports four different basic phases can be distinguished in the conversion process from the ETA Guidelines to EAD:

1^st Elaboration and adoption by the working group;;
2^nd Adoption by EOTA – by the designated bodies;
3^rd Comments of the Commission – including their consideration;
4^th Publication – this may also include the comments of the Commission, in the final review of the EADs;

At this moment, all conversions are at the third or fourth phase.

Detailed situation of the conversions:

• EAD on structural sealant glazing systems (conversion from ETA Guideline 002 parts 1 and 3): sent to the Commission for the publication phase; pending Commission’s final review.
• EAD on external thermal insulation systems (conversion from ETA Guideline 004): after having considered the comments received at the Commission’s comments phase, and after having included the text of three Technical Reports (TR) which the EAD refers to, the revised document has been circulated to all the designated bodies; comments from some bodies have been received; as soon as they have been considered, the resulting document will be sent for confirmation.
• EAD on liquid applied roof waterproofing kits (conversion from ETA Guideline 005): sent to Commission for the publication phase; pending Commission’s final review.
• EAD on timber frame prefabricated building kits (conversion from ETA Guideline 007): sent to Commission for the publication phase; pending Commission’s final review.
• EAD on non-loadbearing permanent shuttering systems based on hollow blocks or panels of insulating materials and concrete (conversion from ETA Guideline 009): on 10 September, a working group meeting took place; the revised EAD has recently been sent for the designated bodies confirmation.
• EAD on wood-based composite beams and pillar (conversion from ETA Guideline 011): Commission comments have been received in the final Commission review; the document has been revised and sent for the designated bodies confirmation.
• EAD on three-dimensional nailing plates (conversion from ETA Guideline 015): sent to the Commission for the publication phase; pending Commission’s final review.
• EAD on prefabricated units for external wall insulation (conversion from ETA Guideline 017): see information in section ‘ITeC and the European Technical Assessment’.
• EAD on prefabricated wood-based panels bearing tensioned faces (conversion from ETA Guideline 019): Commission comments have been received in the final Commission review; the document has been revised and sent for the designated bodies confirmation.
• EAD on plastic anchors (conversion from ETA Guideline 020): Commission comments have been received in the final Commission review; the document has been revised and sent for the designated bodies confirmation.
• EADs on watertight covering kits for wet room floors and or walls (conversion from ETA Guideline 022 parts 1-3): sent to the Commission for the publication phase; pending Commission’s final review.
• EAD on fire retardant products (conversion from ETA Guideline 028): see information in section ‘ITeC and the European Technical Assessment’.
• EAD on connectors for structural joints (conversion from ETA Guideline 030): comments received in the Commission’s comments phase were considered and the revised document has been circulated to all designated bodies, for confirmation; comments received are under consideration.
• EAD on expansion joints for road bridges (conversion from ETA Guideline 032 parts 1-8): all EAD of the different parts in the conversion process have been sent to the Commission for the publication phase; comments have recently been received in the final review of the Commission, pending consideration in the working group.

• Conversion from the ETA Guideline for fire retardant products (ETAG 028)

In the publication phase, new comments from the Commission have been received. For one of them, a consultation has been addressed to the Commission, which is in progress.

• Conversion from the ETA Guideline on prefabricated units for external wall insulation (ETAG 017)- work led by CSTB-ITeC:

In the working group some issues were detected needing modification in the document for publication, which have been corrected; the amended document has been circulated to the designated bodies, for confirmation.

• Conversion of the ETA Guideline for façade cladding kits (ETAG 034)

EAD 090062-00-0404 “Kits for external wall cladding mechanically fixed”: reference published in the OJEU, dated on 16.11.2018, by means of the Communication 2018/C 417/07. The full text can be consulted in the section “Our Publications” of the EOTA website.

In addition to EAD 090062-00-0404, ITeC has twelve EAD published in the OJEU and is currently working on a further fifteen, four of which are EAD amendments:

• three have already been internally adopted by EOTA and the corresponding ETA is now under preparation
• the remaining twelve are at different stages of elaboration
  

Note: at this point, the conversion works from the ETA Guidelines to EAD indicated in the first item of this section, are not considered.

Between 11.06.2019 and 15.10.2019, ITeC issued ten ETA and has a further forty-four in process. The ten ETA issued correspond to the following five EAD and ETA Guidelines (see the EOTA website, “Our Publications” section).

• EAD 160004-00-0301, on post-tensioning kits for prestressing of structures.
  • ETA 19/0065 MeKano4 PT System TK, internal bonded post tensioning system with 4 to 37 strands, from MK4 WORLD WIDE SL.
• EAD 090062-00-0404, on kits for external wall claddings mechanically fixed.
  • ETA 16/0645 Faveker® FV from GRES DE ARAGÓN SA.
  • ETA 17/0355 Faveton® SAH (ceramic plates Ceram 20, Ceram 28 and Acqua 20), from FAVETON TERRACOTA SL.
• EAD 350140-00-1106, on renderings and rendering kits for fire resisting applications.
  • ETA 11/0185 Tecwool F® from TECRESA PROTECCIÓN PASIVA SL.
• EAD 350402-00-1106, on reactive coatings for fire protection of steel elements.
  • ETA 18/0689 Hempafire Pro 315 de HEMPEL A/S.
• EAD 350454-00-1104, on fire stopping and fire sealing products – penetration seals.
  • ETA 16/0771 AF Multicollar from AF SYSTEMS SRL.
  • ETA 16/0772 AF Collar C from AF SYSTEMS SRL.
  • ETA 16/0891 AF Collar from AF SYSTEMS SRL
• ETA Guideline 004, on External Thermal Insulation Composite Systems (ETICS) with rendering.
  • ETA 18/0218 PRB THERMO XL from PRB SA.
• ETA Guideline 005, on liquid applied roof waterproofing kits.
  • ETA 18/0296 MasterSeal Roof 2111 from BASF COATINGS GMBH.

The systems of assessment and verification of the constancy of performance[1] – 1+, 1, 2+, 3 and 4 – are the same, and its application for each product family is defined by means of the Commission Decisions published in the OJEU.

However, in the Delegated Regulation 568/2014 of the Commission – that amends Annex V of the Construction Products Regulation -, clause 1.6 of the Annex, a relevant clarification is introduced regarding the products with an ETA.

It is stipulated that the performance assessment carried out in ETAs – by a technical assessment body – must be considered for the assessment and verification of the constancy of performance tasks. Besides, notified bodies – in those systems in which their intervention is necessary – and manufacturers must not repeat the assessment and verification of the constancy of performance tasks carried out in the ETA.

In fact, when it comes to products with an ETA we can use “verification of the constancy of performance” instead of “assessment and verification of the constancy of performance”.

Note
ITeC is a technical assessment body and a notified body – body No. 1220. As a notified body, it operates in the EAD field and undertakes tasks of the verification of the constancy of performance in products with an ETA, when the intervention of a notified body is necessary.

[1] The definition of the systems of assessment and verification of the constancy of performance can be consulted in the Delegated Regulation 568/2014, in section 1 of its Annex.

• Technical Board No. 25, Rome, 18 and 19 September 2019

• General Assembly of the EOTA, Brussels, 20 November 2019
• Technical Board No. 26, Brussels, 11 and 12 December 2019