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Analysis of implementation of the Construction Products Regulation
CPR STAKEHOLDER WORKSHOP
23 March 2015
Tobe Nwaogu Principal Consultant, RPA
Background to Study
Aim: To analyse the implementation of the Construction Products Regulation (CPR) in Member States as regards their legal provisions and administrative practices, as well as at the EU Level
Specific Objectives: To gather, analyse, validate and summarise data in order to answer three key questions:
1. How and to what extent has the CPR been implemented at national/EU level?
2. To what extent has the CPR produced intended results/effects in terms of free movement of products, clarification, credibility and simplification?
3. To what extent has the CPR fulfilled the objectives of the Commission’s policy for products regarding competitiveness, sustainability and innovation, including in order to respond to future technological developments?
Reporting: Study findings are expected to feed into reporting obligation set out in Article 67(2) CPR
Approach to Study
Step 1: Project Inception
Task 1: Kick-off meeting & Inception Report
Step 2: Data Collection
Task 2: Online survey
Task 3: Literature review
Task 4: Telephone interviews
Task 5: Meetings/Stakeholder Workshop
Task 6: Interim Report
Step 3: Data Analysis
Tasks 7 – 9: Analysis of CPR implementation (study objectives)
Task 10: Final Report
Task 2: Online Survey (1)
Questionnaire 1: Companies
170 Responses, mostly manufacturers and SMEs
Good representation of UK, DE, NL, BE, FR. All EU/EFTA countries represented
Questionnaire 2: NBs, TABs & Standards Bodies
Total of 187 Responses
129 responses from NBs across 29 countries (~25% response rate)
23 responses from TABs across 15 countries (~60% response rate)
16 responses from National Standardisation Bodies (~50% response rate)
12 responses from National Accreditation Bodies (~35% response rate)
7 responses from Notifying authorities
Task 2: Online Survey (2)
Questionnaire 3: Public authorities
65 Responses
27 national/regional public authorities covering 17 Member States
28 Market surveillance authorities (~40% of responses from Poland)
3 Inspectors/Enforcement officers and 7 PCPCs also responded
Questionnaire 4: Associations, Organisations, Other
95 Responses
71 industry associations
11 responses from professional organisations
Responses also from NGOs, tendering authority, individual practitioners
Total Responses: 517
Task 3: Literature review
Aimed at collating information at the MS and EU levels, covering:
Relevant national legislation and guidance documents explaining the CPR
Documents and FAQs by enforcement bodies, industry associations or similar organisations on implementation of the CPR
Market information on the construction industry
Reports on market surveillance approaches for construction products
Reports on CPR implementation provided in 2014 by Member States and industry to the Commission; etc.
Task 4: Telephone Interviews
Telephone interviews were held from 12 to 26 January
169 interviews arranged across EU-28
Good response rate in many countries, although in some smaller countries it was difficult to identify willing/knowledgeable interviewees
Interviews were held with a range of organisations:
Companies, including SMEs
Public authorities
Industry associations (national level)
Notified Bodies/TABs etc.
Interviews were held with public authorities and other organisations that did not respond to the online survey
Task 5: Workshop
Aim
Present feedback on the key findings from the consultation undertaken to date
Obtain the views of stakeholders on some of the most topical issues which have been identified by several key stakeholders as impacting on CPR implementation
Note that the workshop is part of the ‘data collection’ (not final reporting!) and, as such, we are hoping for a positive and interactive discussion
Discussion Groups
The discussions are intended to:
Verify the problem definition/description
Exchange information on relevant experiences related to the problem areas
Address questions in blue boxes and discuss possible solutions to the problems
Step 2: Tasks Completed to Date
Task 2: Online survey
Started 6 November 2014 and closed on 23 January 2015
Task 3: Literature Review
MS literature review - completed 18 February
Task 4: Interviews
Telephone Interviews - completed 26 January
Task 5: Meetings/Workshop
Workshop in Brussels - 23 March
Task 6: Interim Reporting
Interim Report - 18 February
Topical Reports – uploaded 13 March
Awareness of CPR Concepts
Clarification of the Legal Framework
Obligations of economic operators
Obligations of economic operators
CE Marking
CE Marking – A problem?
CE Marking
Free Movement of Construction Products
Free Movement
Free Movement (Companies)
Free Movement (Public Authorities)
National marks – A problem?
France & Germany!!
Simplification of the Legal Framework
Declaration of Performance (DoP)
DoP (Companies)
DoP (Authorities)
Simplified Procedures – A problem?
Simplified Procedures
Mandatory Harmonised Standards
European Assessment Documents
European Technical Assessments
Assessment and Verification of Constancy of Performance
Requirements for Notified Bodies
Market Surveillance
Market Surveillance
Market Surveillance
Risk to health and safety
Risk to health and safety
Formal non-compliance
Formal non-compliance
Evidence on market surveillance
Co-operation with authorities
Overall Views on CPR
Impacts of the CPR on Legal Certainty
Increased Credibility of the CPR
Simplification of the Legislation
CPR Provisions and Free Movement
Relevance of the CPR
Overall Rating of Implementation of the CPR
Next Steps
Next Steps/Timelines
Phase III: Data Analysis – April/May 2015
A horizontal analysis across the EU looking at how the CPR has been implemented, applied and enforced and identifying cross-cutting EU wide issues
Where relevant, a more in-depth approach to explore issues specific to individual MS, products or circumstances in detail
Draft Final Report – 10 June 2015
Final Report – 10 August 2015
THANK YOU FOR LISTENING