and SME-friendly Construction Product Regulation (CPR)
Brussels, 13 July 2022 – In response to the European Commission’s consultation, the European Builders Confederation (EBC) and Small Business Standards (SBS) publish today a position paper on the revision of the Construction Products Regulation (CPR). SMEs support the development of the CPR as the single piece of EU legislation regulating construction products supported by European harmonised standards, while highlighting areas for improvement.
The CPR is a major piece of legislation in the construction sector, which sets the legal conditions for the placing on the market and the circulation of construction products in the European Union. Assessing the performance of the CPR through a lengthy process of consultation since 2016, a proposal for its revision was published by the Commission as part of the Circular Economy package on 30 March 2022.
This proposal aims to boost the internal market for construction products and ensure that the regulatory framework enables the built environment to deliver on its sustainability and climate objectives, in the light of the EU Green Deal. As such, in addition to attempting to address the long-standing backlog of the citation of construction standards in the Official Journal, the revised proposal introduces multiple new elements such as the inclusion of used products in the scope of the regulation and efforts towards the digitalisation of information provision.
In view of the direct and indirect impact of the CPR on user and producer SMEs, EBC and SBS publish a joint position paper featuring the questions, suggestions and demands of SMEs in the construction sector. The document focuses on the challenges SMEs will face if the proposal is adopted as such at the end of the legislative process and proposes direct recommendations to facilitate its implementation and understanding.
Representing 99% of the sector, SMEs play a pivotal role in the achievement of the goals of the twin green and digital transition in the built environment. Therefore, EBC and SBS recommend that the CPR and related technical specifications provide an SME-friendly framework that is comprehensible and easy to practise while preventing red tape and excessive costs. To this end, the position singles out the following areas for improvement:
- CPR scope and definitions: The text needs to be clearer and better focused to avoid over-regulation and complexity.
- Sustainability and circularity requirements: Additional administrative, financial, and technical challenges for SMEs implied by the transition to a circular model should be avoided.
- Simplified procedures: Simplifying means clarity and pragmatism, while not resulting in less reliable products.
- Exemptions: Helpful for specific products, exemptions should not create confusions.
- The standardisation system: Reinforced harmonised standards are appreciated if they facilitate product compliance to SMEs.
- Streamlining information provision: To avoid overlaps between the Declaration of Performance (DoP), Declaration of Conformity (DoC) and CE marking is critical.
- Digitalisation of the construction sector: Adapted and accessible digital tools are welcomed to reduce administrative burdens, improve communication, and ease documentation.
- The role of Notified Bodies: The activity of economic operators should not be restricted by a disproportionate authority exercised by Notified Bodies.
- The European Assessment Documents (EADs): The priority given to standards in comparison to EADs is much welcome, but their legal status needs clarification.
- Market surveillance: A unified market surveillance system is encouraged, with a focus on assessing performance and conformity rather than documentation.
Commenting on the revision proposal, EBC Secretary General Fernando Sigchos Jiménez said: “Our construction SMEs and crafts are fully committed to making the built environment more sustainable. To realise these ambitions, we need a clear, stable, coherent, inclusive, and enforceable regulatory framework for the CPR that takes into account the constructive proposals of the key players of the value chain.” In turn, SBS Secretary General Maitane Olabarria stressed that “The success of the revised CPR in achieving its sustainability targets heavily relies on standards. To ensure the efficient implementation of the proposal, we call on the Commission to ensure that SMEs are adequately represented in standardisation. This is important to ensure these standards meet SMEs needs and the costs of their implementation are reduced.”To consult the joint EBC-SBS position paper on the CPR revision proposal in full detail, please click here.
