2.

Scope of CPR based harmonisation

2.1.

Should we have more or fewer construction products covered by hENs?

We do not consider that, at this point, any mandates should be withdrawn.

However, broadening the scope of the hENs, by adopting new mandates, should be studied on
an individual case basis, not has a overreaching objective.

2.2.

Should there be more or fewer topics covered by BWRs?

We do consider that, at the moment, the BWRs, as presented in Annex I, of the CPR, should be
extended to include the Minimum Technical Aptitude for Intended Use, which could lead to
the inclusion of the so-called voluntary requirements (specifically, on a hEN, all the
requirements not included on the ZA Annexes), thus eliminating the dubiousness of having
mandatory and voluntary requirements within the same document.
Also, Points 3 and 7, are needlessly complex, and should be reviewed and simplified to focus
more on the end-users needs.

2.3.

What should be the depth of hENs?

The current depth of the hEN, as described on Article 17, is perfectly suited for the current
reality. Removing any of current parts will drastically reduce the usefulness and reliability of the
hEN, while adding anything else could introduce unnecessary requirements that would not
benefit none of the critically involved stakeholders (namely manufacturers and end-users).

2.4.

Should the use of concepts in hENs be freed from CPR restraints?

We believe that the concepts, as presented within the hEN, should not be freed from the
constraints present in the CPR. In addition, there should be an active effort to urgently replace
any already existing hEN which deviate, in any degree, from the CPR. Any delay in this will
deepen the divergence in the technical language.
This, in our view, is the only way to ensure a full harmonization of the technical language, and
to avoid that different actors interpret technical terms differently.

3.

"Voluntary" or "mandatory" hENs

In our view, this should not even be up for discussion. hENs, once approved and published are,
and should remain, Mandatory, for the products covered by said standards.

This is linked to point 2.4, as the technical language must be harmonised and common, to avoid
that some actors exclude certain specific products from the scope of a hEN, due to language
interpretation. Therefore, not interpretation liberties should be allowed.
As for the existence of any degree of voluntary application, it would open the door to
individual MSs creating national requirements, using different methods and/or systems, thus
creating a barrier to free flow of goods, which could revert the market to pre-EC days, in which
a manufacturer could be forced to submit its products to different approval systems, for each
country to which it intended to market it.

4.

Exhaustiveness of hENs

We believe that any new hEN, resulting from a new mandate, should consider all the BWRs,
and, if technically feasible without creating undue economical hurdles to the critical
stakeholders (manufacturers, end-users), should consider the inclusion of essential
characteristics regarding all the BWRs.
Already existing hENs, should be gradually adapted to the same, as stated above. However in
this case, care should be taken to consider the already existing technical data, and avoid
sudden changes in already existing requirements, which would have undue negative financial
and economical impacts on the market, as a whole.
As the question of voluntary content, we stand by what we stated when commenting Point 2.2.