EuroWindoor AISBL supports the European approach to create the Internal Market for products and to abolish technical barriers to the trade of products. The products bearing the CE marking can be traded in the European Economic Area (EEA) without restrictions.
For windows, doors and facades (curtain walling) the Construction Products Regulation (CPR) 2011/305/EU is the most important regulation giving the legal framework for Declaration of Performance and CE marking of cunstruction products. Therefore EuroWindoor AISBL and its members are participating to the implementation and development of the CPR.
EuroWindoor AISBL has regular contact to the European Commission and is appreciated as valued stakeholder of the window, door and facade (curtain walling) sector.
This paper is the clarification of questions of interpretation, especially the "Specific Technical Documentation" (STD) described in Article 37 of the CPR.
After the first citation of EN 16034 in the Official Journal of the EU the European Commission send a letter to CEN requesting changes in scopes of the product standards EN 14351-1, prEN 14351-2, EN 16361 and EN 13241-1 before the start of the co-existing period of EN 16034. Despite very quick action from CEN TC 33 the schedule could not be achieved and a joint letter sent from EuroWindoor, European Aluminium and EDSF did not change the opinion.
The result is a postponement of both the start of co-existing period to 1st September 2016 and the end of co-existing period to 1st September 2019 cited on the 13th November in OJEU. The letter also contained a requirement for merging of each of the before mentioned product standards with EN 16034, so only a single harmonized standard shall apply to e.g. an exterior pedestrian doorset with fire characteristics. EuroWindoor does not agree to merge the standards – an opinion which is shared by the majority of TC33 and European associations, as European Aluminium and EDSF.
EuroWindoor has together with these two associations written another letter to the European Commission with arguments against a merging of standards. One argument is that already today products exist that needs to comply with more than one harmonized product standard and this is done without any problems. EuroWindoor has in cooperation with European Aluminium and ift Rosenheim developed a guide which gives general guidance on how to comply with EN 16034 and shows examples of CE marking and DoPs with reference to two harmonized standards.
After another postponement the hEN 16034 (co-existence period 01.11.2016 - 01.11.2019) and hEN 14351-1/A2 (co-existence period 01.11.2016 - 01.11.2017) were finally published in the Official Journal of the European Union C398/2016 on Friday, October 28th, 2016. Because of the fact that EN 14351-2 (Internal pedestrian doorsets) is not yet harmonized EuroWindoor publish the Corrigendum CE.03/A2: 2016-11 for EuroWindoor Guidance Sheet CE.03: 2015-11.
EuroWindoor AISBL and its members accompanies European standards for windows, doors and facades (curtain walling). Standardisation for a common European technical language makes sure to abolish technical barriers to the trade of products caused by different national standards.
EuroWindoor shares the approach of the European Commission to have the European standards for construction products written in performance terms and not to exclude products which are legally placed today on the EU market. The mandates from the European Commission given to CEN have to be transferred siutable to the need of the practice.
Therfore EuroWindoor AISBL and its members participate actively in the standardisation process on European (CEN) and international level (ISO) to ensure the use of the standards by all actors (regulators, engineers producers, contractors) in a “common European technical language”.
Important European Standards for the fenestration sector are:
The processes of standardization for Construction Products Regulation (CPR) are more and more delayed and finished standards aren´t harmonized, because expectations and ideas especially of the European Commission and the Member States are divergent. EuroWindoor members see the need of more detailed input and permanent communication during the whole process between CEN/TC, CEN-CENELEC Management Centre (CCMC), European Commission (EC) and Member States (MS).
The industry and other relevant stakeholders for many years have invested a lot of time and money to develop high quality standards within the rules and framework provided. From the point of view of the industry participating at CEN/TC level in the actual development of the standards the standardisers don´t feel sufficiently trained in how to implement these changes correctly. As a consequence a lot of the hard work of the industry is being blocked in the system without a clear picture what it is supposed to do differently when other standards are being developed or revised to avoid these ending up also as being blocked.
Even the European Commission announced in its recently published report COM(2016) 445 final on the implementation of Regulation (EU) No 305/2011, that “there is potential for a quicker and a better streamlined standardisation process with standards responding better to the needs of their users through a close and efficient collaboration between CEN, Member States, the industry and the Commission”.
As an input to this process EuroWindoor has developed a proposal how EuroWindoor envisions the interaction of actors during the standardisation process in the future and shows that in Annex to the Position Paper on Principles of good cooperation and improvement of effectiveness of standardization for CPR.
CEN/TC 33 - Doors, windows, shutters, building hardware and curtain walling
CCMC Programme Manager: Ascensão Gonçalo
CEN Technical Secretariat: AFNOR
Chairperson: Mr Frédéric Wielezynski
Secretary: Mrs Nathalie Girardot