Assessing the proposed CPR revision 29 September 2022

The proposed Construction Products Regulation (CPR) revision could potentially have a huge impact on the fixings sector. We therefore contacted one of the leading associations in the sector, the European Organisation for Technical Assessment (EOTA), to get President Sebastian Wall’s thoughts.

What is EOTA’s response to the European Commission’s proposal for a revision of the CPR and what are your thoughts on the general concerns voiced by the industry?

“EOTA welcomes the initiative of the European Commission to strengthen the internal market for construction products and transform the construction sector into a sustainable, resilient and smart industry. The proposal for the next Construction Products Regulation, published by the European Commission on 30th March 2022, is an important first step to achieve these goals.

Within the CPR framework, the European Technical Assessment (ETA) route offers a voluntary and agile path to CE Marking for innovative and non-standard construction products. The ETA route has been Europe’s very successful response to fostering innovation and promoting high safety, as well as environmental and climate protection standards for over 30 years. This is what has built the ETA route’s excellent global reputation.

Looking to the future, the ETA route will play a key role in achieving the EU’s Green Deal, Circular Economy and Digital Decade objectives, because Europe will need innovative, smart and sustainable construction products, which are not – and in some cases cannot be – covered by harmonised standards.

As the organisation in charge of coordinating the ETA route, EOTA encourages European decision makers to renew their commitment to facilitating product innovation in the European construction industry.

The most important uncertainty is linked to the unclear status of EADs. The ETA route offers a path to CE Marking and is therefore clearly a harmonisation tool. In the same way, EADs form part of the common technical language by providing harmonised assessment criteria for a multitude of innovative and other
non-standard products that would otherwise be excluded from the internal market. Introducing a distinction between harmonised and other technical specifications that serve as the basis for the declaration of performance, and CE Marking, could cause confusion and lead to market distortions. Irrespective of the harmonisation route used, manufacturers should enjoy the same high valuation and legal safety.

EOTA calls on European decision makers to place more focus on creating an innovation friendly legal framework and ensure fair and equal access to the internal market for all manufacturers. EOTA believes that EADs should be accorded the status of harmonised technical specifications or equivalent to reflect the fact that they serve the same harmonisation function and are subject to equally stringent technical, formal and legal requirements. They should be explicitly mentioned in all places where this is relevant, to avoid legal uncertainties and ensure fair conditions for manufacturers of innovative products.

EOTA also believes that the new CPR should include clear, ambitious and binding timelines for the citation of EADs. If these cannot be guaranteed, the current solution allowing issuance of an ETA and CE Marking prior to the publication of the EAD reference should be maintained to enable competitive ‘time to market’ for product innovations.

Manufacturers of innovative construction products competing EU wide or even globally, need a fast and proactive means for CE Marking as offered by the ETA route. They cannot wait for two years or more for the ‘intended’ adoption of harmonised technical specification (Art.35(2)(b)). This clause should be deleted.

The acquis of EADs should be preserved for the benefit of manufacturers of non-standard products, in particular by defining realistic transition periods, during which EADs remain valid and available as a basis for CE Marking. Addressing relevant new performance characteristics in the ETA route should still also be possible as they are an essential part of the innovation process.

EOTA shares the general concerns voiced by other stakeholders and requests the European Institutions to ensure a clear, sustainable and functioning balance of responsibilities between the Member States and the European Commission is found, whilst any bottlenecks in the citation of harmonised technical specifications and EADs, especially due to a multiplication of the responsibilities of the European Commission in combination with limited resources, are avoided.”

What role can the ETA route play in achieving the EU’s Green Deal – when it comes to  sustainability in the construction industry?

“As buildings account for 40% of the energy consumed, the energy embodied in construction products is key to its reduction. This aspect is even more important now – as the whole EU tries to decrease consumption of fossil fuels. Through the ETA route, manufacturers will be able to transparently declare the relevant performance of their product to help customers choose the right product for a construction project. 

The TABs in EOTA have considerable expertise in assessing sustainability, which is included in our Project Team 12 ‘Sustainability’. However, there is currently no AVCP system available for the assessment of requirements relating to environmental sustainability (BWR 7 of the current Construction Product Regulation). It is our understanding that such an AVCP system might be agreed upon by the Member States and consequently, it would be possible to implement the sustainable use of natural resources in ETAs for anchors and other construction products. 

In the future, it will be the set of criteria laid down in the proposal for the new CPR that will define the sustainability requirements. Going forward, the proposal for the new CPR shows that the Commission places high importance on transforming the EU construction sector into a sustainable industry. EOTA and its TABs will be happy to assist the Commission and the manufacturers in these endeavours by providing technical expertise.”

What is EOTA’s main focus over the next two years?

“Within the framework of the CPR review, EOTA has been developing a set of actions to raise awareness of the relevance of the ETA route for manufacturers who otherwise would not have a legally safe, reliable and agile access to the market. The aim is to promote an innovation friendly regulatory framework by ensuring fair and good conditions for the stakeholders of the ETA route. 

Furthermore, we are aiming at improving our internal processes to provide the best service possible to manufacturers, TABs, and business associations, who are looking to place innovative and
non-harmonised construction products on the market. Meanwhile our technical work continues unabated and together with the European Commission we strive to have several more EADs published in the Official Journal of the European Union this year.”

Deputy Editor

Claire Aldridge Deputy Editor t: +44 (0) 1727 743 889


Having spent a decade in the fastener industry experiencing every facet – from steel mills, fastener manufacturers, wholesalers, distributors, as well as machinery builders and plating + coating companies, Claire has developed an in-depth knowledge of all things fasteners.

Alongside visiting numerous companies, exhibitions and conferences around the world, Claire has also interviewed high profile figures – focusing on key topics impacting the sector and making sure readers stay up to date with the latest developments within the industry.