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The initial proposal of the European Commission as well as the Position of the Council foresee Simplified Procedures e. g. for “micro-enterprises” with max. 10 employees.

This would mean less testing for their products than for products of bigger companies to get a CE mark. Is this the right way?

No other comparable European Directive or Regulation like the Machinery or the Low Voltage Directive has such simplifications – for good reasons.

We believe, that the proposed Simplified Procedures lead to:

  • Distortion of competition.
  • Less safety for construction products and construction works.
  • Confusion for the end user, because it becomes more complicated to decide if a CE marked construction product is really fit for a given application.
  • Liability problems for manufacturers and end users of construction products.

Therefore, we are opposing this proposal.

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