Euralarm releases position paper on revised Construction Products Regulation (CPR) proposal
Euralarm represents Europe’s electronic fire safety and security industry, a sector whose products are already largely subject to the existing CPR and an industry, that relies on European Union harmonization legislation to provide the consistent and reliable products needed to realize safe and effective fire and security systems in buildings.
Our industries welcome the publication of the Commission’s proposal for a new Regulation on construction products (hereafter “the new CPR”). We note that the legal framework proposed is very flexible and, contrary to the consultation process, makes fundamental changes to the CPR. However, the times scale for the introduction of the new legislation, coupled with complexity of options and need for delegated acts to establish the details and consequences for our sector, fail to address the core issue which is that the EU standardization process has stagnated under the weight of the legal interpretations and obligations of the current CPR.
Notwithstanding this fundamental observation we provide input into the Commission’s proposal consultation to address key points for our industry.
We welcome:
- CE-marking being still a part of the new CPR and a stronger Single Market
- Increased focus on sustainability
- The use of digital tools
- Empowerment to adopt delegated acts to avoid double assessment of products
- Product requirements now being in the new CPR becoming mandatory by delegated acts
- We call for clarifications and ask for reconsideration on the following points:
- Complexity and missing simplification
- Scope
- Product requirements
- Double testing
