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Certification of products for drinking applications

in Europe – two independent projects aiming at

quantifying Article 10 market impacts

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Volker Meyer

Managing Director of figawa

5/13/2016

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Who we are!

• figawa - the „Association of Companies for

Gas and Water Technologies“ based in

Germany

• figawa is a technical scientific association

and works as the common voice of the

companies in many national and international

standardisation bodies.

• figawa was established in 1926 and has

over 1000 companies as members.

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What we did!

In September 2015 we started our survey

dealing with the costs for product approvals

(certifications) and product tests for products

in contact with drinking water in the EU

among our Members. The survey was

finished in February 2016!

We seperated between mechanical and

hygienic testing costs. Also the audit costs

were inquired in the survey. Only the

external costs are collected (Test house

and Certification Body)!

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Example

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Name of product: Superflex

XY45DW4567

Germany TestInspection specifications/

product norm

Cost for certification

in TEUR (average)

hygienic

KTW Leitlinie, DVGW W 270,

Elastomerleitlinie,

Beschichtungsleitlinie,

Schmierstoffleitlinie,

Metallbewertungsgrundlage

20 T€

mechanical EN 13618 30 T€

TestCost per year

in TEUR (average)

hygienic 2 T€

mechanical 1 T€

Europe TestInspection specifications/

product norm

Additional cost for retesting

in TEUR (average)Cause for retesting

Period until granting of registration mark/

certification mark

(in months)

hygienic same as in Germany 5 T€Elstomers are tested

according to XYZ6

mechanical same as in Germany none none none

hygienic

mechanical

Number of certification/ registration :

Inital registration

Bulgaria

Audits

Belgium

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Categories

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Safety valves

Hydraulische Sicherheitsgruppe EN 1487

Sicherheitsventil für Expansionswasser EN 1491

Druckminderer EN 1567

Thermostatischer Mischer für Warmwasserbereiter EN 15092

Sicherheitsgruppe für Expansionswasser EN 1488

Sicherheitsventil EN 1489

Kominiertes Druck-Temperaturventil EN 1490

Enthärter EN 14743

Filter mit aktiven Substanzen EN 14898

Membranfilteranlage EN 14652

Water treatment

Filter, rückspülbar (80 µm bis 150 µm) EN 13443-1

Filter, nicht rückspülbar (80 µm bis 150 µm) EN 13443-1

Dosiersystem EN 14812 / EN 15848

Kugelhähne EN 13828

Ventile mit Geradsitz EN 1213

Hoses

Flexible Schlauchleitungen EN 13618

Gerät mit Quecksilberdampf-Niederdruckstrahlern EN 14897

Nitratentfernungsanlage EN 15219

Isolation valves

Schrägsitzventile EN 1213

Taps and fittings

Entnahmearmaturen EN 200 / EN 816 / EN 817 / EN 1111

Pipes and fittings

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Categories for the survey:

• Group 1 - Safety- and Protection Valves

• Group 2 - Water Treatment

• Group 3 – Taps

• Group 4 – Pipes and Fittings

• Group 5 – Tanks and Pumps

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Results

• Group 1 – Safety- and Protection Valves

• 10 companies

• 216 product groups

• 11 000 employees

• 2,1 Billion Euro Annual Sales

• 60 % Market Coverage (Germany)

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Results

• Group 2 – Water Treatment

• 4 companies

• 29 product groups

• 5 000 employees

• 1,1 Billion Euro Annual Sales

• 65 % Market Coverage (Germany)

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Results

• Group 3 – Taps

• 4 companies

• 67 product groups

• 15 000 employees

• 3,1 Billion Euro Annual Sales

• 45% Market Coverage (Germany)

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Results

• Group 4 – Pipes and Fittings

• 12 companies

• 167 product groups

• 37 000 employees

• 8,1 Billion Euro Annual Sales

• 60% Market Coverage (Germany)

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Results

• Group 5 – Tanks and Pumps

• 2 companies

• 14 product groups

• 8 000 employees

• 800 Million Euro Annual Sales

• 10% Market Coverage (Germany)

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Results

• Over ALL:

• 32 companies

• 493 product groups

• 76 000 employees

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Results

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Results

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Results

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Results

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Results

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Results

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Over all costs – 4 MS in Million

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Summary of the figawa survey

Costs:

• 32 Companies with 493 product

groups pay today in total 57,64 Million

Euro only in the 4 MS states.

• When you have a mutual recognition

between only this 4 countries, you will

have a cost saving of 60%.

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Summary of the figawa survey

Time to the market:

• 40% of all need up to one year time

to bring new products to one of the 4

MS markets.

• 35% need one to two years.

• 25% need two to three years.

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Next Steps

• A final report of the study will be

published in the next weeks.

• If you have any questions please

contact:

Volker Meyer

meyer@figawa.de

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• Survey from on behalf of

• On behalf of the Dutch Ministry of Infrastructure and Environment, the Dutch policy research institute Panteia has finished a study on the economic effects of Article 10 of the Drinking Water Directive.

• Article 10 of the European Drinking Water Directive concerns the prevention of negative effects of products that are used for treatment, storage and distribution of drinking water (such as chemicals, taps and pipes). The Directive allows Member States freedom regarding the implementation. This lack of harmonization brings along costs.

• In order to map the effects of Article 10, Panteia has carried out interviews with companies to assess the effects, burdens and costs.

• The companies targeted in the study are those involved in production and trade of products that are used for drinking water distribution from source to tap, such as producers, distributors and importers.

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The study’s objectives are to assess:

• which and how many companies have to deal with article 10 of the DWD?

• which hindrance is encountered by the current implementation with national requirements?

• who bears the costs for testing, assessment and certification?

• what are the potential cost savings and other benefits of (European) harmonization?

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Results:

• The estimated number of enterprises that have to deal with national schemes implementing article 10 of the DWD is about 7,200 and the turnover is round € 43 billion per year.

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Results:

• To comply with national regulations costs a lot of time and money. In terms of time the enterprises need staff to change the products and to find out all the differences and to make sure these processes go well. In terms of money also large sums are needed to be paid for the tests of the products and for the certification at the certification bodies and audits with the certification bodies.

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Results:

• The current situation gives high threshold for market access. Some enterprises stay at the domestic market because exports mean high costs for additional testing requirements for products that have to be tested again for each additional country. This means export is quite difficult and some enterprises have chosen not to sell their products abroad.

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Results:

• Some enterprises state it as unfair that they have to comply the stringent regulations, but that the consumer can buy uncertificated products directly on the market and internet. There is too little control on this. Market surveillance is in general an important pointfor improvement.

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Results:

• Barriers for free trade for smaller firms. There is no difference in enterprise size, because all enterprises pay the same amount. For small enterprises this is a relatively high share of their turnover. This is experienced as a barrier for free trade within the EU.

• It is a recommendation for further research to look for possible specific provisions in legislation avoiding disproportionate burden on Small and Medium Enterprises (SMEs) in accordance with the EU principle of Think Small First.

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Results:

• We present the results over all 46 interviewed enterprises, because of the limited number of enterprises interviewed per MS.

• In general we can say that the German enterprises interviewed had the highest costs. Maybe the reason for this is that the German enterprises interviewed seemed to have more products related to drinking water in their assortment. France and the Netherlands had roughly similar lower costs compared with Germany, whereas the costs in the United Kingdom were much lower as in France and the Netherlands. A reason for this is that some enterprises interviewed in the UK acted more on the domestic market and had few imports and exports of related article 10 DWD products.

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Results:

• Based on the questionnaire results enterprises in the 4MS spend € 135,000 per enterprise on yearly internal wage costs associated with the approval processes.

• In addition enterprises spend € 165,000 per enterprise on yearly costs of evaluation, testing or certification of products.

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Results:• The assumption is made that costs of the other

24 Member States are two-thirds lower than in the 4MS based on the interviews with enterprises in the 4MS. The interviews have shown that the 4MS do have systems which are more demanding than the other 24MS. Some MS don’t have a system at all. This means that in case of additional certification requirements in those MS this will lead to extra costs for enterprises.

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Results:

• So the total costs are € 300,000 yearly per enterprise in the 4MS and € 100,000 per enterprise in the other 24MS.

The total amount on wage costs and evaluation or certification costs is approximately € 728 million yearly in the 4MS and € 480 million in the other 24MS or in total € 1.208 billion.

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Results:

• By means of mutual recognition enterprises estimate the cost savings on 55% of the total costs. Both for harmonisation throughout the 4MS and for all EU Member States.

• In total this would be a cost saving of € 664 million out of € 1.208 billion per year.

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Results:The following aspects are not included:• the positive effects because the time to market

can be shortened substantially• measures to achieve a more equal economic

playing field• the effect of a more certain environment for

investment and innovation• about suppliers who stopped producing drinking

water products, because it is too complex.

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• Both studies come in general to the same results!

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• It is a recommendation to achieve much more mutual recognition and harmonisation of national schemes implementing article 10 DWD, also with the help of the EC.

• This is urgently needed from point of view of transparency, free trade, equal economic playing field, certain environment for investment and innovation and time to market for new products.

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Thank you !

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