VVPs tilsvar på EU Kommisjonens forslag til revisjon av Construction Product Regulations (CPR)

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Feedback on the proposed revision of the Construction Products Regulation

VVP appreciates the possibility to give feedback on the proposed revision of CPR, Construction Product Regulation and will present our point of view below.

VVP is positive about the Commission’s efforts to modernize the CPR and include sustainability, environmental, and circularity demands to products. We also appreciate that CPR will make demands for digitalization and these parts of the proposal for revision of CPR we support.  However, we would like to emphasize the necessity of linking these important property areas to current and agreed standards, so that the environment should be documented by EN 15804 and the digitization of the environment by EN 22057 as well as technical characteristics according to EN 23386 and EN 23387. It is crucially important that digitalization is established by the above standards as several countries have a great commitment to adopt these standards and develop PDTs based on these, among others France and Norway (PDT Norway, an association where all disciplines within the Norwegian construction industry work together on the development of complete PDTs ).

We also appreciate the Commission’s suggestion for demand for 3D printed construction products to ensure quality and product liability.

When it comes to the suggestion of excluding many products within the trade of plumbing, sanitary, and heating, we are very concerned and disappointed.

The product category descriptions are very parent, so it is difficult to see which product categories are thought to be excluded. This will create great uncertainty in our industry about which of «our» products will be defined as building materials if the Commission’s current proposal is realized.

Sanitary appliances: Which products are covered and are thought to be excluded are not defined.  Toilets, washbasins, and bidets are examples of sanitary appliances that already belong to harmonized standards. Nevertheless, the Commission appears to be proposing to exclude these products from CPR. We find it difficult to understand the background.

However, we are deeply concerned about the proposal to exclude a large part of our industry’s most important products from CPR, as it appears that the Commission is proposing.

We are concerned about the exclusion of products intended to be in contact with water for human consumption, sanitary appliances, and systems treating wastewater from the CPR (article 2 (3.) (b, c, and d)). From our view, this exclusion will probably result in the removal of the requirement for product documentation and certification for these products. The possibility of non-compliant products entering the market will increase, due to a lack of market surveillance as these products will not be covered by the CPR. This can result in an increase in water leaks in buildings, hurt the indoor climate, and have negative health consequences.  Low-quality products for systems treating wastewater can also result in pollution in nature due to insufficient treatment performance, leaks, and spills.

The exclusion of these product groups is in contradiction to the aims pointed out in the proposal of the new CPR which is the improvement of the common market (Explanatory Memorandum (2.)). The exclusion of the product groups from the regulation and corresponding de-harmonizing of the market will hinder the free movement of these products within the EU due to trade barriers when CE marking is no longer possible. Also, the inclusion of non-compliant products in the market will negatively impact serious manufacturers due to competition with low-quality products.

Based on these considerations we ask that the decision to exclude products intended to be in contact with water for human consumption, sanitary appliances, and systems treating wastewater be reversed.

Yours Sincerely
VA og VVS Produsentene – VVP

Terje Røising

Oslo 11/7-22