After compiling the opinions of the construction sector stakeholders’ representatives in the surveys:

• for the initial impact assessment (see received comments here), and
• on the options for the Regulation revision (see results here),

at the beginning of September, the European Commission started a public consultation on the Construction Products Regulation (UE) 305/2011 revision. This consultation is open until 25 December 2020.

The consultation offers to all interested parties and users the opportunity to contribute to a possible Construction Products Regulation review. Its experience and perceptions will help to define the base line, evaluating the possible options for the future, and identifying the best way to be followed.

Access the questionnaire in English, here.

The survey includes two questionnaires, a brief one and a more extensive and detailed one. There is the option to answer the brief questionnaire on the CPR, which is more general, or to answer the extensive and detailed one, which requires a certain level of previous knowledge on the cited Regulation.

The decision on the working lines that are going to be undertaken in the Regulation revision will have an important impact on the market, products and construction sector stakeholders, therefore, sector stakeholders and construction products users in general, must be highly implicated.

Some observations:

• The options raised by the Commission are not the only possible ones, but objectives and actions have been grouped into 5 options to avoid excessive combinations.
• Between Option A and Option B there is an important distance that could be reduced with an intermediate option, by including objectives and actions of Option A –e.g. resolution of Basic Works Requirement number 7 (BWR 7) or revision of Annex A, without considering such a radical change within the legal framework.
• Option E, which involves the Regulation derogation, will have very negative consequences, because the mutual recognition procedure is not effective for the construction products. This would imply that the manufacturers should go to every country where they want to sell their products to apply for a certificate or a national assessment, as applicable.
• For Option B and its combinations, priorities will be introduced to determine which products are harmonised and which are not, depending on safety, environmental protection, European market entity and National regulations criteria. Products not considered as a priority should be assessed country by country.
• Likewise, for Option B and its combinations, a long transitory period is foreseen, in which products according to the revised Regulation and products according to the current Regulation will coexist. Elaboration, approval, and implementation of the Regulation, in addition to the transitory period could imply 10 years, because the current harmonised technical specifications will have to be adopted progressively.

To answer this survey, it is important to value the impact of the different options raised. It is necessary to consider effort and time needed to avoid a serious negative impact of the Regulation revision on the sector. The main objective of the Regulation, which is the free circulation of construction products, should not be overlooked.

EOTA published an open letter directed to the interested parties -mainly manufacturers and associations-, in which it expresses its concerns about the radical changes proposed by the European Commission for the Regulation revision and compiled in the document Refined Indicative Options for the Review of the Construction Products Regulation of 8 April 2020 (see here), and on its impact on the ETA route.

For more information, see EOTA news

This letter follows the initiative undertaken by the Spanish bodies which in the previous July sent an open letter to the Internal Market Commissioner, Sr Thierry Breton (see Report No. 24).

The interruption of the ETA route would remove the present system flexibility and would generate serious obstacles for the product manufacturers who do not have a harmonised standard available, e.g. innovative, complex, unique/special products or those on the ecological side. Some of these products without standards could even be totally blocked in the internal market and in its CE marking. This situation would possibly damage the European Union’s competitiveness, interfere with the competence between the upcoming products technologies and increase the uncertainty that manufacturers would have to accept to join the European Market. This would create aversion to innovation.

In view of the above, EOTA and its members recommend keeping the ETA route in the Regulation revision, as a key instrument for construction products innovation and improvement.

Likewise, some of the possible options raised by the Commission may affect the construction sector in a very negative way in terms of adaptation costs, punctuality and implementing viability, as well as international competitiveness. The improvement of the present system would be the best way to progress, better than a complete review of the whole system.

Report No. 23 dealt with the study EADs and ETAs: Added value to the construction sector by an independent body –CSIL- Centre for industrial Studies-, at the request of EOTA.

On September 21, EOTA published the final result of this study. The summary and the complete version can be downloaded from the EOTA website.

For more information, see EOTA news.

The objective of this study is to completely analyse the EOTA reality, as well as to clarify some points mentioned by the Commission in its report on EOTA, in November 2019.

The study is summarised in a total of 10 key points and 6 recommendations. The following important points of the study are highlighted:

• The majority of those interviewed consider that the ETA route is a valuable alternative to the CE marking due to a lack of harmonised standards (hEN). Around 70% of manufacturers surveyed, and business associations consider that EADs satisfy manufacturer’s needs to a large extent.
• EOTA is complying every day better with the assigned tasks in the Construction Products Regulation – CPR. The interested parties consulted, i.e. manufacturers, business associations and TABs, are especially satisfied with the process confidentiality and punctuality, which is considered effective to guarantee the introduction on the market of more innovative products. More than 80% of TABs consider that EOTA carries out its tasks effectively.
• Around 73% of the surveyed (manufacturers, enterprise associations and TABs) agreed that the ETA route contributes to the improvement of manufacturer potential for the innovation of products. An important part of those surveyed (between 65% and 90%, depending on the type of interested party) consider that the ETA route objectives concerns new or improved products, at least in part. The duration of the process for developing harmonised standards (hEN) is not aligned with the constant innovation increase in some product areas which, therefore, makes the ETA route more relevant for the needs of the product manufacturer.
• The majority of the interested parties agreed that European Technical Assessments – ETAs could not be replaced by any other third-party assessment body without a loss in product credibility. Approximately 70% of those surveyed indicated that revoking the ETA route would be harmful for enterprise economic development.

On October 9, the European Organisation for Technical Assessment (EOTA) celebrated 30 years of service to the construction sector.

On this anniversary, EOTA published on its website an article debating both on the way travelled and future challenges. This article was written by one of the main authors of the EOTA launch, Mr. Paul Caluwaerts, Secretary General of EOTA from 1992 until 2012.

For more information, see EOTA news.

This is the moment to think about the way travelled during this time in which multiple challenges have been met, thanks to the collaboration of EOTA members to reach consensus in a multidisciplinary context keeping an eye on industry needs in a construction sector undergoing constant change.

We must be aware of the present and future demands and challenges, although they are surmountable as long as the interested parties, with a true European spirit, keep appreciating the values and aspirations of the ETA route, of high scientific value, objectivity and capacity to meet the market needs.

From ITeC we want to congratulate EOTA for the work done during these three decades, of which we feel participants, and to encourage and support EOTA to keep working to meet the demands of the industry in the construction sector through the ETA route.

Since October 31, Santiago del Pozo is no longer in charge of ITeC’s EOTA Office as he has retired at his retiring age. From November 1 on, María Bento is leading this Office.

Santiago devoted himself to European tasks related to EOTA activity for 23 years, holding different positions in this organisation, coordinating ITeC’s experts works in the institute, providing support to the ETAs and EADs writers, and writing all the previous EOTA Reports.

Santiago, we wish you all the best for the future.

Comment from Santiago
It has been a pleasure for me to develop ITeC’s EOTA Office activities, including the Reports published since 31 May 2014. I want to thank all the people who helped and participated.

With the publication of the additional EADs of nine ETA Guidelines (ETAGs), there are thirty-seven EAD published based on ETAGs, of which the modification of two has already been published (EAD 330196-01-0604 and EAD 330499-01-0601).

All published EADs can be consulted on the EOTA website under the heading ‘Our Publications’.

With this publication the conversion of 90% of ETAGs (for which the conversion has been initiated) is covered. At present, the publication of the last three EAD on the Official Journal of the European Union OJEU is pending (ETAG 002, ETAG 009 and ETAG 020), see next section of this Report.

EADs of the three last ETAG in conversion progress are at the publication phase. We hope that they will be published shortly.

EADs pending publication:

• EAD on structural sealant glazing systems (conversion from ETAG 002 parts 1 and 3).
• EAD on non-loadbearing permanent shuttering systems based on hollow blocks or panels of insulating materials and concrete (conversion from ETAG 009).
• EAD on plastic anchors (conversion from ETAG 020).

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

EAD 350865-00-1106 “Fire retardant products”: reference published in the OJEU, dated on 29.10.2020, by means of the Communication 2020/L 359/13. The full text can be consulted in the section “Our Publications” of the EOTA website.

This EAD covers paints and varnishes, intumescent paints, encapsulation coating systems and surface treatments to improve the protected surfaces reaction to fire, as ETAG 028 did, now substituted by this EAD.

• Conversion from the ETA Guideline on prefabricated units for external wall insulation (ETAG 017)

EAD 040914-00-0404 “Veture kits – Prefabricated units for external wall insulation and their fixing devices”: reference published in the OJEU, dated on 29.10.2020, by means of the Communication 2020/L 359/13. The full text can be consulted in the section “Our Publications” of the EOTA website.

This EAD covers kits based on prefabricated units made of thermal insulation panels and renderings (discontinuous or continuous) of different materials, and their mechanical fixing devices, for the external thermal insulation, as ETAG 017 did, now substituted by this EAD.

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

EAD 090062-00-0404 “Kits for external wall claddings 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.

Regarding the second step of this Guideline conversion, an initial meeting was held on 17 June (kick-off meeting) by videoconference, led by ITeC. After this meeting, another more specific three were held, one on 15 July regarding the incorporation of an assessment method for the seismic actions kit strength, and two (on 15 September and 14 October) in order to analyse the incorporation of some thermal radiation properties and their assessment methods. Likewise, on 21 October a second general meeting was held. All the meetings were held by videoconference with the working group members very active participation.

ITeC has twelve EAD published in the OJEU.
At present, it is working on a further fifteen EAD, three of which are EAD amendments:

• three have been sent to the Commission for the publication phase.
• three have already been adopted by EOTA and the corresponding ETA is now under preparation
• the remaining nine are at different stages of elaboration

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

Between 04.07.2020 and 06.11.2020, ITeC issued twelve ETA and has forty in process. The issued ETAs correspond to the following six EAD and three ETAG (see EOTA website, “Our Publications”).

• EAD 040089-00-0404, of External Thermal Insulation Composite Systems with renderings for the use on timber frame buildings
  • ETA 19/0605 PRB THERMOBOIS COB, from PRB SA
• EAD 040287-00-0404, of kits for external thermal insulation composite system (ETICS) with panels as thermal insulation and discontinuous claddings as exterior skin
  • ETA 20/0246 Baumit CeramicSystem EPS, Baumit CeramicSystem MW, from BAUMIT BETEILIGUNGEN GMBH
• EAD 090062-00-0404, of kits for external wall claddings mechanically fixed
  • ETA 14/0413 Dekton^®, from COSENTINO SAU
• EAD 340452-00-0204, of building kit based on massive panels with metal frame structure
  • ETA 20/0409 Evowall, from EVOWALL TECHNOLOGY SL
• EAD 350402-00-1106, of reactive coatings for fire protection of steel elements
  • ETA 16/0689 Hempafire Pro 315, from HEMPEL A/S
• EAD 360001-00-0803, of ventilation system made of mineral wool covered with film on outside and inside
  • ETA 20/0122 CLIMAVER^® HVAC duct system, from SAINT GOBAIN ISOVER
• ETAG 004, of external thermal insulation composite systems with rendering
  • ETA 13/0836 webertherm acustic, from SAINT-GOBAIN WEBER CEMARKSA SA
  • ETA 14/0365 webertherm etics, from SAINT-GOBAIN WEBER CEMARKSA SA
  • ETA 19/0604 PRB THERMOBOIS, from PRB SA
  • ETA 20/0722 ECOSATE, from SAINT-GOBAIN ISOVER IBÉRICA SL
• ETAG 005, of Liquid Applied Roof Waterproofing Kits
  • ETA 20/0635 Mapegum S 1K system roof, from MAPEI SPA
• ETAG 022, of Watertight Covering Kits for Wet Room floors and or walls
  • ETA 19/0788 PRB Monocel, from PRB SA

Some EAD on specific products for refurbishment works are beginning to emerge, however, there are still a few, e.g. EAD 340392-00-0104 CRM (Composite Reinforced Mortar) Systems for strengthening concrete and masonry structures.

In general, most of the construction products may be used both in new and refurbishment buildings, although in most cases the EAD does not specify both uses.

Some examples where both uses are specified are products and systems for thermal insulation improvement ETICs (EAD 040083-00-0404, EAD 040287-00-0404, EAD 040427-00-0404, etc.), façade rendering systems and products (EAD 090062-00-0404, EAD 0900119-00-0404, etc.) or fire protection mortars (EAD 350140-00-1106).

• Technical Board No. 29, 22 and 23 September 2020 (*).

• General Assembly of EOTA, Brussels, 10 December 2020 (*)
• Technical Board No. 30, Brussels, 15 and 16 December 2020 (*)