The possible review of the Construction Products Regulation (CPR) was announced for the first time at the end of 2016 in the communication Clean Energy for all Europeans, only three years after the CPR fully came into force in July 2013.

During 2018, the European Commission launched the first Public Consultation for gathering experiences, views, and opinions of interested stakeholders and the public on the internal market for construction products. The results of this consultation were published in October 2019.

This CPR review process was confirmed by the European Green deal at the end of 2019 and by the Circular Economy action plan at the beginning of 2020.

In 2020 the European Commission started two parallel working lines, one on the CPR review and one on the review of the technical acquis of the CPR (i.e. the harmonised standards, the European assessment documents and the legal acts of the Commission).

During 2020 some consultation processes were launched. The kick-off was the Commission publication of a non-paper with refined indicative options to review the CPR (see Report núm. 24), to support the discussions on the CPR Review. Subsequently, a survey on the indicative options and a public consultation on their impact that ended in August 2020. Finally, a new public consultation on CPR review was launched between September and December 2020.

Besides, during 2020, but especially during its second semester, there have been several dialogues between the Commission, the stakeholders, and the Member States.In particular, the German Council Presidency of the European Union actively supported the discussions on the future CPR by focusing on three main topics:

1. “Sustainability and circularity aspects in the construction sector”,
2. “The future of standardisation of construction products” and
3. “Indoor emissions and environmental and health protection”.

On the other hand, IMCO (Committee on the Internal Market and Consumer Protection) has adopted an own-initiative resolution demanding harmonised marketing of construction products and better product safety and environmental standards (more information here), and it points five final recommendations:

”I. the further development of the internal market for construction products;
II. the optimisation of the CE marking and the Declaration of Performance;
III. the strengthening of market surveillance;
IV. clear guidance in case of overlap of specific product legislation with the CPR; and
V. the use of digital tools.”

This IMCO own-initiative proposal has been debated and adopted as a European Parliament Resolution between 8^th and 10^th March.
At the time of writing this EOTA Report, the following conclusions may be considered:

• The Review of CPR is a fact.
• Depending on the scope of the proposal for the CPR Review, its development combined with the update of existing technical specifications, may take many years. Therefore, a long transitional period is expected where harmonised technical specifications according to the revised Regulation will co-exist with the present Regulation ones.
• The European Commission is working on the development of this review of the CPR. A first Commission proposal is expected for the last quarter of 2021.

Figure: Timeline – Review of CPR

As we already commented in Report no. 24 when the survey for indicative options was launched, we are still especially concerned about:

• The introduction of radical changes in the construction sector while it is still assimilating the changes introduced by the current Regulation in relation to the Directive.
• The limitation of the harmonised field reduced to products and aspects considered as a priority. This will force manufacturers of the excluded products to address to each country where they want to market their products. This may be significantly detrimental to SMEs.
• The removal of ETA route, which today enables any manufacturer of an innovative product or a product without a harmonised standard to access the European market.
• A very long and complex transitional period would be needed, during which products under new rules will co-exist with products under current rules.
• The European construction products market no longer being a wide, complete, and accessible market to any product and manufacturer, whether SME or large enterprise.

For these reasons, we would like to reaffirm the concept that it would be very important to consider how to use all the potential of the present Regulation before taking a path that may have a very significant impact on the sector.

During the EOTA 17^th General Assembly meeting on 10th December 2020, Sebastian Wall was appointed as the new President of EOTA.

Sebastian, Director Plenipotentiary for Competitiveness Strategy at the Polish Technical Assessment Body Instytut Techniki Budowlanej (ITB), is well-known and highly regarded inside EOTA. He has contributed widely to EOTA work since 2013, serving, amongst others, as Treasurer and member of the Financial Working Group and of the Executive Board. Sebastian takes over from Karsten Kathage, Vice President of the German TAB DIBt, who, after having completed the statutory maximum of four years in office, passed on the baton to a trusted successor.

For more information, see EOTA news

Before leaving the EOTA presidency, Mr. Karsten Kathage (DIBt, Germany), has looked back and to the future in an article published by EOTA (see EOTA news).

From this article, some important (although not always known) aspects of EOTA and the ETA route deserve to be highlighted:

“EOTA has always been about cooperation, technical excellence, mutual trust and working together for the success of the valuable European Technical Assessment (ETA) route.”

“While it is worth scrutinizing how we can make the European legal framework more effective and develop it further, it seems just as important to preserve, maintain and keep up-to-date the CPR acquis.”

“… the ETA route itself is a major CPR achievement and an integral part of this acquis. The EU has been successful in developing an assessment route of high international standing that keeps the market open for innovative and, more generally, non-standard construction products, making product performance comparable all over Europe and ensuring a high level of construction works’ safety.”

“EOTA and the ETA route owe a significant part of their success to their ability to find a fair balance between different interests. There are legitimate legal and regulatory demands not only with regard to the product itself but beyond that with regard to the safety of construction works. There is the manufacturers’ need for a trusted technical assessment recognised across Europe to launch new products on the internal market and give them credibility and visibility. Last but not least, there is the users’ need for reliable and comparable technical product information available to minimise liability risks.”

These four paragraphs summarize the purpose and aims of EOTA and the ETA route also highlighting the good work carried out by EOTA under the CPR frame.

ETAs which have been issued by UK TABs have lost their validity from 1st January 2021 and cannot be used anymore to draw up a DoP and for the CE marking of the related products.

Therefore, the manufacturer should request a new ETA to be issued by a TAB designated by an EU-27 Member State.

For this special case, EOTA has prepared some procedures and conditions to speed up the new ETAs issuing for those products for which the ETA is no longer valid after Brexit.

EADs of the three last ETAGs in conversion process are still in the publication phase. We expect they will be cited in the next batch.

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).

At the Technical Board meeting in the beginning of March 2021, Commission representatives present in the meeting announced that the next batch for citation of EADs in the OJEU points to June 2021.

All the cited EAD can be consulted on the EOTA website (www.eota.eu), under the heading “Our Publications”.

ITeC has fifteen EAD cited in the OJEU.

At present, it is working on sixteen more EAD, three of which are EAD amendments:

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

Note: the three conversion works from the ETAGs to EAD led or co-led by ITeC, ETAG 017, ETAG 028 and ETAG 034, (see Report No. 25) are included among the fifteen EAD already cited.

Between 07.11.2020 and 05.03.2021, ITeC issued eight ETA and has forty-five in process. The issued ETAs correspond to the following five EAD (see EOTA website, “Our Publications”).

• EAD 030350-00-0402 Liquid applied roof waterproofing kits
  • ETA 18/0296 MasterSeal Roof 2111, from BASF COATINGS GmbH
• EAD 090034-00-0404 kit composed by subframe and fixings for fastening cladding and external wall elements
  • ETA 20/0805 Kit FTS 501A, from LOUVELIA FAÇADE SOLUTIONS SL
  • ETA 20/0946 Kits FTS 502B and FTS 502B+, from LOUVELIA FAÇADE SOLUTIONS SL
• EAD 200059-00-0302 steel components for pallet racking systems
  • ETA 20/1333 of adjustable shelves system for MECALUX palletised load, from MECALUX SA
• EAD 350140-00-1106 renderings and rendering kits intended for fire resistant applications
  • ETA 13/0221 Igniplaster®, from PROMAT IBÉRICA SA
• EAD 350454-00-1104 fire stopping and fire sealing products – penetration seals
  • ETA 17/0614 KF-Collar C, from KNAUF SRL SAS
  • ETA 17/0615 KF-Multicollar, from KNAUF SRL SAS
  • ETA 17/0617 KF-Collar, from KNAUF SRL SAS

During 2020, four projects have been initiated (called 2^nd step ETAGs conversion) for improving the initial EAD version -00- obtained from ETAG conversions. This conversion basically focusses on the topics identified as leftovers in the 1^st step works and should be finished at EOTA level in one year.

ITeC actively participates in three of these four projects, one as the leader (Convenor) and, in the other two, as a working group member. The projects are:

• 2^nd step ETAG 034 conversion project for façade cladding kits mechanically fixed.

EAD 090062-00-0404 “Kits for external wall claddings mechanically fixed”, result of the 1st step ETAG 034 conversion, was cited 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.

This EAD covers kits for external wall claddings mechanically fixed for both ventilated and non-ventilated façades, as ETAG 034 did, now substituted by this EAD.

2^nd step ETAG 034 conversion project started during the 2^nd semester of 2020, and it is being led by ITeC once again after its first step (years 2016 to 2018).

The main topics considered in this 2^nd step ETAG 034 conversion project are: the extension of the scope (e.g. other cladding element materials), the extension of the intended use (e.g. covering kits under seismic actions), and the improvement of the assessment methods’ descriptions. The result of this project will be the EAD 090062-01-0404.

• 2^nd step ETAG 017 conversion project on prefabricated units for external wall insulation.

EAD 040914-00-0404 “Veture kits – Prefabricated units for external wall insulation and their fixing devices”, result of the 1^st step ETAG 017 conversion, was cited 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.

2^nd step ETAG 017 conversion project started during the 2^nd semester of 2020. ITeC is member of this Working Group.

The main topics considered in the 2^nd step ETAG 017 conversion project are: the extension of the scope, the extension of the intended use, and the improvement of the assessment methods’ descriptions. The result of this project will be the EAD 040914-01-0404.

• 2^nd step ETAG 004 conversion on external thermal insulation composite systems (ETICS) with renderings.

EAD 040083-00-0404 “External thermal insulation composite systems (ETICS) with renderings”, result of the 1^st step ETAG 004 conversion, was cited 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 for external thermal insulation composite systems (ETICS) with renderings, as ETAG 004 did, now substituted by this EAD.

2^nd step ETAG 004 conversion project started during the 2^nd semester of 2020. ITeC is member of this Working Group.

The main topic considered in the 2^nd step ETAG 004 conversion project is the improvement of the assessment methods’ descriptions. The result of this project will be the EAD 040083-01-0404.

Note: the fourth 2^nd step ETAG conversion project corresponds to ETAG 032, which was split in the following current EADs: EAD 120093-00-0107 “Flexible asphaltic plug expansion joints for road bridges”, EAD 120109-00-0107 “Nosing expansion joint for road bridges”, EAD 120110-00-0107 “Mat expansion joint for road bridges”, EAD 120111-00-0107 “Cantilever expansion joints for road bridges”, EAD 120112-00-0107 “Supported expansion joints for road bridges”, and EAD 120113-00-0107 “Modular expansion joints for road bridges”. The full text can be consulted in the section “Our Publications” of the EOTA website.

An EAD is structured in four main chapters subdivided in clauses and annexes. The following points summarise the content provided for each one:

Chapter 1 – Scope of the EAD

This chapter describes the product and the intended use for which the EAD applies. Products or intended uses that have not been specifically considered are excluded unless they could be considered as an extension of the EAD scope according to agreed EOTA internal procedures (see Report no. 23).

Clause 1.1 – Description of the construction product

This clause gives specific information on:

– Description of the product covered by the EAD and, when relevant, description on the material, form, and geometric characteristics. In case of kits, description of each kit component and, when relevant, minimum kit components or specific components combination.

– Justification on why the EAD is considered for the product. E.g. “the product is not covered by a harmonised European standard (hEN)” or “the product is not fully covered by the following harmonised technical specification: [hEN year and/or EAD year-month]”.

– Any other relevant information on the product.

– General information concerning product packaging, transport, storage, maintenance, replacement, repair, installation, and relevant manufacturer’s stipulations.

Clause 1.2 – Information on the intended use(s) of the construction product

Description of the intended use(s) for the product. An EAD may include several intended uses for a product.

Clause 1.3 – Specific terms used in this EAD

Description of the specific terms to be used in the EAD. This clause is very important for an adequate EAD content understanding.

Chapter 2 – Essential characteristics and relevant assessment methods and criteria

This chapter gives information on how to carry out the assessment of the product for the intended use.

Clause 2.1 – Essential characteristics of the product

The table(s) included in this clause summarise(s) the list of essential characteristics to be considered for the product and the type of the expression of the results applicable to each essential characteristic (could be Level, Class or Description). The essential characteristics are grouped by each relevant Basic Work Requirement (BWR) according to those given in Annex I of Construction Product Regulation (EU) No 305/2011.

This table is the base for the DoP to be prepared by the manufacturer once the ETA is issued and the activities of AVCP are completed.

Clause 2.2 – Methods and criteria for assessing the performance of the product in relation to essential characteristics of the product

This is the longest clause of the EAD because it contains, in different subclauses, the description of each essential characteristic given: the purpose of the assessment, the description of the assessment method (mainly tests or calculations) and the way to express the results obtained from the assessment.

In many EADs the specific test or calculation method is described in an Annex (see below).

Chapter 3 – Assessment and verification of constancy of performance (AVCP)

This chapter gives information on the activities of AVCP applicable to the product according to those defined in Annex V (as amended by Delegated Regulation 568/2014)).

Clause 3.1 – System(s) of assessment and verification of constancy of performance to be applied

This clause specifies the applicable European legal act which indicates the systems applied to the product for the AVCP activities.

Clause 3.2 – Tasks of the manufacturer

This clause includes information (usually in tables) with the detail of the cornerstone actions to be undertaken by the manufacturer of the product in the procedure of AVCP.

The EAD should handle the cornerstones of the factory product control (FPC) without considering any specific manufacturing technology because they should be applicable for several manufacturer’s productions.

The Control Plan, to be agreed between the TAB (Technical Assessment Body) and the manufacturer during the ETA development, is the document that gives the specific tasks (adjusted to the specific manufacturer’s production) and based on EAD cornerstone tasks. This Control Plan is to be followed by the manufacturer and, when relevant, by the Notified Body (NB) to carry out the certification activities.

Clause 3.3 – Tasks of the notified body

This clause includes information (usually in tables) with the cornerstone actions to be undertaken by the NB in the procedure of AVCP.

It is important to remark that the documents to be followed by the NB are the issued ETA and the corresponding Control Plan which give the specific product performance and control tasks, not so much the EAD which gives general information by means of cornerstone tasks.

Clause 3.4 – Special methods of control and testing used for the assessment and verification of constancy of performance

This clause only appears in EADs when the description of specific control methods is necessary (e.g., specific tests for FPC different than those tests already included in the EAD).

Chapter 4 – Reference documents

List of reference documents (most of them, EN standards) used in the EAD.

Annexes

Most of the EAD contain annexes in which the assessment methods are described in detail. By doing this, the EAD is clearer for the reader because there is a certain similitude with respect to the concept of “product standard” (information given in EAD clauses) and “test or calculation standards” (information given in EAD annexes).

Other interesting information on EADs included in FAQ sections:

• What does the EAD number mean? (see Report No. 19)
• Are EAD mandatory? (see Report No. 20)
• In which cases the European Assessment Document route does not apply? (see Report No. 22)

• General Assembly of EOTA, 10 December 2020, videoconference meeting.
• Technical Board No. 30, videoconference meeting, 15 December 2020.
• Technical Board No. 31, videoconference meeting, 2 March 2021.

• General Assembly of EOTA, Brussels, 22 April 2021 (*)
• Technical Board No. 32, Brussels, 9 and 10 June 2021 (*)
• Technical Board No. 33, Brussels, 21 and 22 September 2021 (*)
• Technical Board No. 34, Brussels, 30 November/01 December 2021 (*)