- Non-compulsory CE marking of individual and non series products;
- Easier and cheaper CE marking of products in order to improve SME access.
The current draft proposal for a Regulation revising the Construction Products Directive 83/106/EEC (CE marking of Construction Products) does not address the issues faced by SMEs manufacturing individual and non-series products.
The CE marking procedure for construction products has been conceived for industrial production in series (large quantities of the same product). It is not at all adequate for the enterprises that manufacture individual and non-series products. Testing non-series products implies testing each individual product whereas in the case of a large-series production one only needs to test once for hundreds or thousands of identical products. The cost of testing (between 5000 and 20000 €) is disproportionate to the cost of production of individual or non-series products.
The EBC proposals have already been partially acknowledged in documents released by the Commission and the Council. Indeed, when the CPD was adopted in 1988 the Council had authorised Member States to exempt single application products from the requirements of the directive. More recently, in May 2005 DG Enterprise published a Guidance Paper that included specific provisions aiming to facilitate SME access to CE marking.
"It would be unacceptable if the current revision would not include these elements. This would not only be contrary to the objective of simplification stressed by the European Commission but would, in fact, represent a step backwards from the present situation", declared David Croft, the EBC President.
Last year, DG Enterprise and Industry (Construction Unit) commissioned an impact study on the implementation of the Construction Products Directive in the framework of the revision process.
The study has shown that for windows, costs of CE marking for all manufacturers (around 50.000) in Europe will be approximately 250 Million Euros. Even more striking is the reply to the following question: "How many years of production are needed to recover the initial cost of CE marking for windows?" The answer clearly written in the study is "never".
