EuroWindoor appreciate the opportunity to give feedback to the proposal from the European Commission for a new regulation laying down harmonised conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 (market surveillance regulation) and repealing Regulation (EU) 305/2011 (CPR).
EuroWindoor is a firm supporter of the concept of the single European market for construction products and sees the EU Construction Products Regulation as the main instrument to obtain a well-functioning internal market.
1 General comment
EuroWindoor welcomes the outspoken aim to strengthen a smooth functioning of the single market for construction products based – as the main route – on harmonised standards as the instrument for technical language and harmonised assessment methods. We also support the increased focus on a level playing field, expressed among others through increased focus on the functioning of the market surveillance and of the Notified Bodies. The inclusion of sustainability is furthermore appreciated by EuroWindoor.
However, we also consider that many aspects of the draft CPR are too complicated and many areas are too open for interpretation. The complicated structure of the regulation and referencing between different articles make it difficult to read and understand, which may cause huge problems for implementation by manufacturers. This does to some extend make it difficult to give concrete input to all specific articles, as the consequence of them depends in a high degree on the practical implementation. Additionally there are numerous places where the Commission is empowered to develop delegated acts. EuroWindoor fully recognize that, if the Commission had this power under the current CPR, some of the identified problems could have been handled without starting a revision process. However, EuroWindoor believes this option to deliver delegated acts needs to be used with great care, as it does introduce a high degree of uncertainty and risk especially for the economic operators who will need to comply to an ever-changing rulese
EuroWindoor feedback on the proposal for a new regulation replacing the Construction Product Regulation – CZ