Construction Products Directive (CPD) 89106EEC

SAFETY INFRASTRUCTURE IN BOSNIA AND HERZEGOVINA
Safety Infrastructure Project

Bosnia and Herzegovina
EUSIP
Impacts of introducing the

Construction Products Directive (89/106/EEC)
into Bosnia-Herzegovina law
Regulatory Impact Assessment
in association with AENOR, B

This project is funded & Metrology Hellas
by the European Union
Bosnia and Herzegovina

November 2010
0
Impacts of introducing the

Construction Products Directive
(89/106/EEC)
into Bosnia-Herzegovina law
Regulatory Impact Assessment
Council Directive 89/106/EEC of 21 December 1988 on the approximation of laws, regulations

and administrative provisions of the Member States relating to construction products
Prepared by Dr. Peter Futo, Short Term Expert

Team Leader: Carsten Kudahl, Key Expert
Research Assistant: Anida Pasic.
EUSIP Project, Sarajevo, Bosnia-Herzegovina
6. December 2011
1
Table of Content
1. STRATEGY ISSUES.......................................................................................................... 5
1.1. Policy objectives............................................................................................................... 5
1.2. Policy alternatives............................................................................................................ 5
2. GAP ANALAYSIS.............................................................................................................. 7
2.1. Regulatory issues............................................................................................................. 7
2.2. Standards and European Technical Approvals.................................................................8
2.3. Conformity assessment, notified bodies and laboratories................................................9
2.4. Market surveillance.......................................................................................................15
3. STAKEHOLDERS AND MARKETS AFFECTED.............................................................17
3.1. Overall relevance of CPD in BiH....................................................................................17
3.2. Product overview of the construction materials industry in BiH......................................21
3.3. Construction materials industry in the entities................................................................24
3.4. The construction (building) sector..................................................................................25
4. COMPETITIVINESS ASSESSMENT................................................................................26
4.1. BiH company survey on expected impacts of introducing CPD......................................26
4.2. BiH company interviews on expected impacts of introducing CPD.................................32
4.3. United Kingdom: winners and losers of the full introduction of CPD...............................33
4.4. Winners and losers revealed by EU CPD RIA study.......................................................36
4.5. Applying the above findings to BiH: expected winners and losers..................................38
5. IMPACTS OF CPD IN TERMS OF COSTS AND BENEFITS...........................................38
5.1. Sectoral level cost analysis in the construction product sector of the UK.......................38
5.2. Applying the findings of the above cost calculation to BiH..............................................41
5.3. Company level cost analysis of CE marking for European brick factories......................41
6. SUMMARY AND CONCLUSIONS...................................................................................43
7. RECOMMENDATIONS....................................................................................................45
8. APPENDICES..................................................................................................................46
8.1. Appendix 1: Round Table Meeting on RIA of the Construction Products Directive.........46
8.2. Appendix 2: Methodological note on expected and observed impacts...........................49
8.3. Appendix 3: References.................................................................................................50
8.4. Appendix 4: List of interviewed persons.........................................................................52
8.5. Appendix 5: Relevant regulations in FBiH......................................................................53
8.6. Appendix 6: A selection of construction material companies in FBiH..............................55
8.7. Appendix 7: Cover letter of company survey on CPD.....................................................56
8.8. Appendix 8: Questionnaire of company survey on CPD.................................................57
8.9. Appendix 9: Abbreviations..............................................................................................62
2
Detailed Table of Content
1. STRATEGY ISSUES..........................................................................................................5
1.1. Policy objectives............................................................................................................... 5
1.2. Policy alternatives............................................................................................................5
2. GAP ANALAYSIS.............................................................................................................. 7
2.1. Regulatory issues.............................................................................................................7
2.1.1. EU............................................................................................................................7
2.1.2. BiH...........................................................................................................................8
2.2. Standards and European Technical Approvals.................................................................8
2.2.1. EU............................................................................................................................8
2.2.2. BiH...........................................................................................................................9
2.3. Conformity assessment, notified bodies and laboratories................................................9
2.3.1 EU............................................................................................................................9
2.3.1. BiH.........................................................................................................................11
2.4. Market surveillance.......................................................................................................15
2.4.1. EU..........................................................................................................................15
2.4.2. BiH.........................................................................................................................16
3. STAKEHOLDERS AND MARKETS AFFECTED.............................................................17
3.1. Overall relevance of CPD in BiH....................................................................................17
3.2. Product overview of the construction materials industry in BiH......................................21
3.3. Construction materials industry in the entities................................................................24
3.4. The construction (building) sector..................................................................................25
4. COMPETITIVINESS ASSESSMENT................................................................................26
4.1. BiH company survey on expected impacts of introducing CPD......................................26
4.1.1. Characterisation of the sample..............................................................................26
4.1.2. Existing company procedures regarding to product quality and safety.................27
4.1.3. Impacts of CE marking on the activities and effectiveness of the company.........29
4.1.4. Awareness and information sources on regulations and standards.....................30
4.1.5. Company recommendations as to the timing of the regulatory changes..............31
4.2. BiH company interviews on expected impacts of introducing CPD.................................32
4.3. United Kingdom: winners and losers of the full introduction of CPD...............................33
4.4. Winners and losers revealed by EU CPD RIA study.......................................................36
4.5. Applying the above findings to BiH: expected winners and losers..................................38
5. IMPACTS OF CPD IN TERMS OF COSTS AND BENEFITS...........................................38
5.1. Sectoral level cost analysis in the construction product sector of the UK.......................38
5.3. Company level cost analysis of CE marking for European brick factories......................41
6. SUMMARY AND CONCLUSIONS...................................................................................43
7. RECOMMENDATIONS....................................................................................................45
8. APPENDICES.................................................................................................................. 46
8.1. Appendix 1: Round Table Meeting on RIA of the Construction Products Directive.........46
8.1.1. Invitation to and programme of Round Table Meeting..........................................46
8.1.2. List of participants at Round Table........................................................................47
8.1.3. Comments and recommendations of Round Table participants...........................48
8.2. Appendix 2: Methodological note on expected and observed impacts...........................49
8.3. Appendix 3: References.................................................................................................50
8.4. Appendix 4: List of interviewed persons.........................................................................52
8.5. Appendix 5: Relevant regulations in FBiH......................................................................53
8.5.1. Law........................................................................................................................53
8.5.2. Regulations............................................................................................................53
8.5.3. Rulebooks..............................................................................................................53
8.5.4. Decrees.................................................................................................................54
8.6. Appendix 6: A selection of construction material companies in FBiH..............................55
8.7. Appendix 7: Cover letter of company survey on CPD.....................................................56
8.8. Appendix 8: Questionnaire of company survey on CPD.................................................57

8.9. Appendix 9: Abbreviations..............................................................................................62
4
1. STRATEGY ISSUES
1.1. Policy objectives
The introduction of the Construction Products Directive (CPD) is part of the Stabilisation and
Association Process between EU and BiH. The Stabilization and Association Agreement
(SAA) between Bosnia and Herzegovina and the European Union was signed on 16 June
2008. SAA, among others, stipulates as follows:
ARTICLE 75 of the Stabilization and Association Agreement

Standardisation, Metrology, Accreditation and Conformity Assessment.
Bosnia and Herzegovina shall take the necessary measures in order to gradually achieve
conformity with Community technical regulations and European standardisation, metrology,
accreditation and conformity assessment procedures. To this end, the Parties shall seek to:
(a) promote the use of Community technical regulations, European standards and conformity
assessment procedures; provide assistance to fostering the development of quality
infrastructure: standardisation, metrology, accreditation and conformity assessment”
The implementation of CPD in Bosnia-Herzegovina must ensure two major aims:

 Product Conformity. The Directive requires that construction products put on EU markets
should satisfy certain requirements regarding their mechanical resistance, stability, safety in
case of fire, hygiene, health, environment, safety in use, protection against noise, energy
economy including heat retention.
 Free trade. To implementation of CPD will remove obstacles and difficulties related to the
free trade of construction products between the European Community and BiH. Construction
products which satisfy the relevant essential requirements and carry the CE conformity mark
must be given free access throughout the EEC. The Directive has the primary objective of
helping to create a single European market in construction products. Manufacturers of
construction products should count on equal treatment, irrespective of the MS in which the
product is put on the market.
1.2. Policy alternatives
According to the SAA, BiH has no alternatives except the full introduction of CPD. However,
there are certain options open to the decision makers:
 Options regarding the transition period. BiH may introduce the Directive urgently, or
alternatively, it may introduce it only after a certain transition period. Unlike most other “new
approach” directives, the CPD does not have an explicit, dated transition period during which
producers have the choice between (a) complying with the directive or (b) complying with
national rules. 1 Instead, each European technical specification will make provisions for a
period of co-existence covering the products falling within its scope. Therefore, deciding for a
short transition period may bring certain risks with it. Namely, if BiH implements CPD and
afterwards, for a given technical specification the period of co-existence will be over, BiH will
not be able to allow those products satisfying pre-existing national provisions (e.g. Yugoslav
standards) to continue to be placed on its market any longer.
1
Source: EC Guidance Paper J 2002
 Options regarding the depth / fullness of the implementation of CPD. BiH may implement
CPD fully by making the essential requirements and conformity assessment procedures of
CPD mandatory for all construction products to be sold in the country. Alternatively, BiH may
implement CPD partially by opening the market for construction products complying with
CPD, but not making this compliance mandatory for products satisfying national regulations
of BiH. There are precedents for the latter strategy: the UK, Ireland, Finland and Sweden
have made CE marked products from other MSs fully acceptable on their respective markets,
but these countries have not made CE marking compulsory, and in this respect they have not
fully implemented the CPD Directive.
6
2. GAP ANALAYSIS
2.1. Regulatory issues
2.1.1. EU
Pseudo-New-Approach. The Construction Products Directive (CPD) is one of the New
Approach directives that aim to create a single European market by removing the technical
barriers to trade between Member States through the use of (a) Harmonized European
Standards and (b) European Technical Approvals.
 As in other New Approach directives, it formulates essential requirements (e.g. safety
requirements) and if a construction product satisfies these requirements, its free movement
throughout the Community is granted
 However, unlike most New Approach directives, once a harmonised standard for a
particular construction product has been published, the national standards have to be
withdrawn and compliance with the harmonised standard becomes mandatory.
Product scope. The Directive covers products incorporated permanently in construction

works, such as cement, ceramic tiles, chimneys and flues, fixed fire fighting equipment, geo-
textiles, insulation, masonry, reinforcing bar, sanitary appliances, structural steel, windows
and wood panels.
The essential requirements of the directive refer to the following features of construction
products: mechanical resistance, stability, safety in case of fire, hygiene, health, environment
and safety in use, protection against noise and energy economy including heat retention.
Contrary to other New Approach directives which establish essential requirements applicable
to those products within their scope, the essential requirements as defined in the CPD do not
directly concern construction products, but the final result of the construction action, i.e. the
works as a whole.
Duties of Member States. According to the Construction Products Directive, Member States
are not permitted to hinder the free movement and use of construction products if these meet
the requirements of the CPD. Member States also have to make regulations for enabling the
establishment of bodies for testing, inspection and certification in the attestation of
conformity. Member states must establish market surveillance organisations.
Country-specific implementation. Each EU Member States has implemented CPD2, but in

widely different ways.
 CE mark: mandatory or not? In most Member States in the community, CE marking under
the CPD is mandatory. This means that, if a harmonised standard is available for a particular
product, then that product must be subject to CE marking. However, the application of CPD
is voluntary in UK, Ireland, Finland and Sweden. In effect, in these countries, manufacturers
are free to place the product on the market without CE marking. Such an arrangement is
beneficial for countries with established home markets of construction products that have a
satisfied customer base not wanting CE marked products, where the majority of
manufacturers does not wish to export due to high costs of transport and large number of
‘relatively cheap traditional’ construction products.
2
For example in Hungary CPD was introduced by Joint Decree No. 3/2003 (I.25.) BM-GKM-KvVM on the
Detailed Rules of the Technical Requirements of Building Products, the Certificate of their Conformity, their
Marketing and Use provide for application of the provisions of the Directive on Building Products. (3/2003 (I.25.)
BM-GKM-KvVM együttes rendelet az építési termékek műszaki követelményeinek, megfelelőség igazolásának,
valamint forgalomba hozatalának és felhasználásának részletes szabályairól.)
7
 Other surviving marks and rulebooks. Moreover, many countries had mandatory or de
facto mandatory conformity marks before CPD, and in most cases the mandatory marks
remain for products not covered by CPD CE-marking. Several countries have rulebooks in
force which added additional safety requirements for construction products sold in the
framework of the public procurement.
2.1.2. BiH
BiH is still in the preparation phase of introducing CPD. The regulatory environment of
construction products industry is determined by the fact that it is regulated on the entity level,
whereby FBiH and RS maintain different laws.
 FBiH. In the entity Federation of Bosnia-Herzegovina the main law relevant to the safety
of construction products is “Law on Construction Products”3. This Law is in force since 2009
and the Federal Ministry of Physical Planning4 is responsible for its enforcement. Additionally,
in FBiH there is a wide range of laws, decrees and rulebooks relevant for the safety of
construction products and construction activity in force.5
 RS. The entity Republika Srpska the “Law on spatial planning and construction of
Republika Srpska, 19. May 2010” is the main legal document relevant to the safety of
construction products.6 This law is enforced by the Ministry of Physical Planning,
Construction and Ecology of Republic Srpska7.
Legal harmonization activities. According to Article 5 of “Decision on Activity Plan for

realisation of the Program of Technical Regulations Takeover” (Chairman of Council of
Ministers, 21.08.2006) a country level organisation is responsible for the transposition of
CPD: Ministry of Transport and Communication of BiH. The following organisations have
delegated participants to the Expert Group responsible for the transposition of CPD Directive
to BiH law:
 Ministry of Spatial Planning of the Federation BiH
 Ministry for Spatial Planning, Construction and Ecology of RS
 Ministry of Energy, Mining and Industry of the Federation of BiH
 Ministry for Spatial Planning, Construction and Ecology of RS
 Directorate for European Integration of BiH
 Market Surveillance Agency of BiH
 Foreign Trade Chamber of BiH
 Institute for Standardization of BiH
 Ministry of Foreign Trade and Economic Relations of BiH
 Ministry of Communications and Transport of BiH
2.2. Standards and European Technical Approvals

2.3. EU
 Methods of compliance. The Directive actually permits three methods of compliance:
Harmonised European Standards. The product may be manufactured in compliance
with Harmonised European Standards. Once a harmonised standard for a particular
construction product has been published, the national standards have to be
withdrawn and compliance with the harmonised standard becomes mandatory. There
are 594 harmonized standards on EU webpage under CPD.
3
Zakon o građevinskim proizvodima.
4
Federalno Ministarstvo Prostornog Uredjenja
5
See Appendix 1 of this study and the web page of the respective Ministry.
6
ЗАКОН О УРЕЂЕЊУ ПРОСТОРА И ГРАЂЕЊУ
7
Ministarstvo Prostornog Uredjenja, Gradjevinarstva i Ekologije Republike Srpske
8
 European Technical Approvals. The product also may be manufactured in compliance

with a European Technical Approval (ETA): Such ETAs are developed for innovative
products for which no harmonised standard is applicable. ETA is a harmonised
technical specification in line with the Community construction products directive. It
proves the fitness for use of innovative products listed by the European Union, for
products not covered by a harmonised European standard. CPD also refers explicitly
to European Technical Approvals that are documents giving the presumption of
conformity to the particular product types. ETA is applied to a product for a
determined use and is valid five years. In EU MSs the ETAs are issued by qualified
organisations, designated by the relevant State Authorities for the European
Commission, on the basis of criteria of competence and independence. There are
1909 valid ETAs on the website of EOTA (European Organisation for Technical
Approvals)
 National standards. In absence of existing European technical specification,
manufacture in compliance with a recognised national standard. Still there are many
products for which no harmonized standard or ETA is applicable. For the conformity
assessment such products national standards can be applied. There are several
thousands of such national standards for construction products.
3. BiH
In BiH the work of Europeanisation of standardisation in the construction product sector is

well proceeding, but the use of registered European standards is still limited, as compared to
old Yugoslav standards. Most companies in BiH still use old Yugoslav standards for product
certification purposes.
Up to April 2010 the number of BiH standards registered at the Standardization Agency of
BiH that are under the CPD Directive is 446. This represents 75% of the number of existing
relevant European standards that are listed on the website of the EC Enterprise and Industry
Directorate under the CPD Directive.
For construction products of Bosnia-Herzegovina which are to be exported to the EU,

European harmonised standards are used and the respective certifications are issued by
conformity assessment bodies recognised by the EU.
European Technical Approvals are not applied in BiH for the certification of product types.
3.1. Conformity assessment, notified bodies and laboratories
2.3.1 EU
For a particular product type, once a standard has been selected or the European Technical
Approval is obtained, the manufacturer must prove the products’ conformity with this
standard or ETA in order to receive the CE marking. To do that, the manufacturer must apply
the particular System of Attestation of Conformity that has been defined by the Commission
for the particular product.
Notified Bodies are organisations that have been notified by a Member State as being
competent to carry out testing and certification on one or more particular New Approach
directive.
9
A selection of NBs authorized for CPD in Central and Southern Europe:8
Notifying
Name of NB Country
Authority
ZAG Ljubljana
Slovenian Institute of Quality and Metrology – SIQ
Ministry of the
IRMA - Institut za Raziskavo Materialov in Aplikacije D.O.O. Slovenia
Economy
ZAG - Zavod za Gradbenistvo Slovenije
Institut za Metalne Konstrukcije
EMI KHT.
CEMKUT Cementipari Kutató-Fejleszto Kft.
Építésügyi Minőségellenőrző Innovációs Nonprofit KFT. Ministry for
Hungary
ÉMI-TÜV SÜD Minőségügyi es Biztonságtechnikai KFT. National Economy
TÜV SÜD KERMI Minőségellenőrző es Szolgáltató Kft.
Magyar Aszfaltipari Egyesülés, HAPA Tanúsító Iroda
Istituto per la Tecnologia delle Costruzioni
Anccp - Agenzia Nazionale Certificazione Componenti e
Ministero dello
Prodotti Srl
Italy Sviluppo
Organismo di Certificazione Europea Srl
Economico
Istituto Giordano S.P.A.
Certiquality S.R.L. - Istituto di Certificazione della Qualita'
Bautechnisches Institut
Oö. Boden- und Baustoffprüfstelle GmbH Bundesministerium
Austrian Standards plus GmbH für Wirtschaft,
ÖTI - Institut für Ökologie, Technik und Innovation GmbH Austria Familie und
TÜV SÜD SZA Österreich, Technische Prüf-GMBH Jugend - Abteilung
TÜV Austria Services GMBH I/12
Oesterreichisches Institut für Bautechnik
An example for a Notified Body in EU is a Hungarian organisation: “ÉMI Non-Profit LLC”.9

This is an organization appointed by the Ministry of National Development and Economy to
perform control and testing (Designation document number: 138/2009). “ÉMI Non-Profit LLC”
is also a body notified to the European Commission (Notified body number: 1415) and in this
capacity they issue certifications of conformity in accordance with the possible modes of
certification of conformity under CPD.
8
Source: Website of DG Enterprise and Industry. URL:
http://ec.europa.eu/enterprise/newapproach/nando/
9
Source: http://www.emi.eu/portal/dpwcm_emi.nsf/PageContentQuickPreviews/eqmuka_en.html
10
Systems of Attestation of Conformity.10 For construction products, the involvement of Notified

Body is mandatory in most cases, depending on the particular Systems (or Levels) of
Attestation of Conformity defined for the particular product. There are 6 such systems: 1,
1+,2, 2+, 3 and 4. All of these Systems of Attestation of Conformity include an initial type
testing of the product and certain elements of factory production control. The differences
between various Systems of Attestation of Conformity depend on the risks associated with
the particular product family. Some examples:
 AoC System 1 is the strictest System (or Level) of Attestation of Conformity, devised for
products associated with high risks. For such products the Notified Body must ensure
continuous surveillance of the production process, assess and approve the factory
production control, and audit-test of samples taken both at the factory, on the market or
on the construction site.
 AoC System 4 (or Level 4) is devised for products associated with less risks, and for such
products the involvement of a Notified Body is not mandatory, instead the manufacture
may issue a declaration on the conformity of the product to CPD.
The CE mark on the product label or data sheet must include the number of the European
Standard or the ETA which applies to that conformity. If a number contains the letters EN it
means that the product conforms to a harmonised standard and some other form of
assurance is required to ensure ‘fitness for purpose’. If it contains the letters ETA then
conformity is by way of a European Technical Approval.
3.1.1. BiH
All materials used in the BiH construction industry are subject to test requirements. These
can be accepted against manufacturers’ certification of quality and conformity, or they need
to be submitted for testing and approval to conformity assessment bodies, e.g. private
laboratories or expert institutes attached to universities. The standards used in most of the
cases are those of the former Yugoslavia.
BiH has 14 laboratories where materials (not only construction materials) can be tested.
Some organisations issuing conformity assessment documents about construction products
are laboratories attached to Universities or are private ones. Major examples for laboratories:
Institute for Materials and Structures of Engineering Faculty (Sarajevo), INZA Institute for
protection against fire and explosion (Sarajevo), GIT (Tuzla), IG Civil Engineering Institute
(Banja Luka), Kemal Kapetanović (Zenica), IGH-MOSTAR, Technical Faculty Bihac,
Laboratory of Construction Products (Bihac).
The demand for laboratory inspections is low. Therefore most laboratories use only a small
share of their capacities. Managers of several laboratories have expressed doubts that
having accreditation would improve their position on the market.
10
EC Guidance Paper K 2004
11
12
Some laboratories in BiH are accredited by the Institute for Accreditations 11 others are not. In
July 2010 the website of the Institute for Accreditations lists 19 testing laboratories, 7
calibration laboratories, 2 product certification bodies and 11 inspection bodies, covering all
technical areas, not only construction products..12 This finding was reinforced by a recent
survey13 on Conformity Assessment Bodies of BiH which covered all technical areas under
the New Approach Directives, not only construction products. Another recent study 14 has
identified three accredited conformity assessment bodies which carry out testing according to
harmonized standards in the field of construction products.
Examples for laboratories issuing certification documents for construction products are as
follows.
 Institute for Materials and Structures of Engineering Faculty. 15 The Institute is

working on scientific and educational, scientific research, teaching and professional activities
in the field of building materials and structures. The professional and research activities
satisfy the needs of the construction industry in Bosnia and Herzegovina. The Institute has
specialized laboratories for testing construction materials (e.g. bricks) and issues certificate
of quality and conformity assessment documents.
 INZA Institute for protection against fire and explosion16. INZA d.o.o. is accredited
according to BAS EN ISO/IEC 17025 standard. INZA d.o.o. also introduced the following
standards: ISO 9001, ISO 14001 and OHSAS 18001 and achieved an integrated quality
system. The Institute performs laboratory testing on thermal testing: fire, resistance testing,
e.g. testing of building materials, elements of building construction, equipment and systems
to protect against fire and explosion on the basis of the “Law on Protection from Fire Applies
control methods in order to issue certificates. The Institute determines the cause of the fire
and explosion at the request of state authorities and issues expert opinions on fires. Offers
consulting for construction design on installations preventing fire and explosion. INZA
Institute of fire and explosion protection testing laboratory possesses furnaces for fire testing.
They do not carry out any tests according to CPD but are able to easily upgrade their testing
methods for fire testing for different kinds of construction products.
11
Institut za Akreditacije.
12
List of accredited conformity assessment bodies on 2010-07-12. BATA 2010.
13
Assessment Report Conformity Assessment in Bosnia and Herzegovina. Quality Infrastructure in the Western
Balkans and Turkey. 2009. EU Project, CRIS Number: 2008/020-320.
14
Short Term Expert Mission Report of Ms Maja Metelko, Date of the Report: 1. July 2010. EUSIP Safety
Infrastructure Project Bosnia and Herzegovina, Component 3: Establishment of Market Surveillance System, Task
3.1.3.
15
IMK - Institut za Materijale i Konstrukcije Građevinskog Fakulteta. Address: Sarajevo,: Stjepana Tomića 5.
16
Institut za zaštitu od požara i eksplozije) Address: Sarajevo, Vitomira Lukića 12a. ”
13
 Institut GIT d.o.o. Tuzla, (Institute for construction, construction products and non-
metals Ltd.)17 is accredited according to BAS EN 45011. It tests and issues certification on
products such as cement, fraction stone, aggregate for concrete and asphalt. It performs
sampling of construction materials and semi-products. The Institute provides its customers
quality control of construction products and works, offers technical assistance, and advises
solutions to technical problems. GIT experts from the Institute are involved in the
development of technical regulations and standards in the field of construction and building
materials. They already provide testing according to the Construction Products Directive: are
accredited for the standard: BAS EN 197-1: 2002 Cement. Composition, specifications and
conformity criteria for common cements. They carry out also several non-accredited
methods: testing of pipes, concrete products, structures, bridges, styrofoam, paint, facades,
plasters, adhesives for tiles. In particular, the Institute controls the quality of the following
construction materials and technological processes and issues certificates about their quality:
 Cement, stone, aggregate and concrete, clay, tiles, bricks, blocks and slabs,
aggregates for concrete and asphalt, built-in asphalt
 Production of concrete in the concrete factory
 Installation of concrete in construction, concrete products
 Execution of repair and reconstruction of buildings and bridges
 Structural elements (legs, columns, floors and ceiling structures, plates, pipes,
chimneys, roof panels, etc.)
 Supervision of the construction of roads, buildings with different purposes
(construction, civil engineering, industrial facilities)
 Joinery
 IG Civil Engineering Institute.18 The Institute provides comprehensive technical

services to investors, contractors and sub-contractors of construction. The following activities
of the Institute are especially relevant to the safety of construction products:
 Testing and development of new technologies in the fields of civil engineering, raw
materials
 Quality control in accordance with appropriate standards and certificates
 Geo-mechanical testing of stones
 Geo-physical testing for slope reconstruction and special foundations
 Kemal Kapetanović. The Testing laboratory Metalurški institut “Kemal Kapetanovi in

Zenica is accredited according to BAS EN ISO/IEC 17025. The laboratory is a state institute,
a part of the University of Zenica, has 110 employees. The main scope of the labs is
mechanical and chemical testing of metal materials and calibration, metallography, chemical
analysis, testing of construction products (minerals, coal, other raw materials), non-
destructive testing, electron microscopy, calibration of industrial and laboratory instruments
for measurement of temperature and pressure, testing of welding equipment. In particular, it
performs tests of tensile, compression, hardness, bending, torsion, firmness, fatigue, reverse
bend test, chemical analysis of steel, iron, cast iron, and construction materials: natural
stone, stone aggregate, concrete, fire-proof materials. The Institute is interested to upgrade
and restructure the institute in order to become once a “Notified Body” in the frame of CPD
and other EU Directives such as Machinery Safety, Appliances burning gaseous fuels, Low
voltage equipment, Pressure equipment, and Toys safety.
17
Institut za Gradevinarstvo, Gradevinske Materiale I Nemetale d.o.o. Address: Tuzla, Ulica Kojšino 29.)
18
Address: Banja Luka, Integra Business Center, Kralja Petra I Karađorđevića st. 92-98.
14
 IGH-MOSTAR d.o.o. is an organizational unit within the Croatian Civil Engineering

Institute Inc. Zagreb, which deals with building technology, capacity, stability, usability and
durability of materials of all types of structures. IGH d.o.o. Mostar is accredited according to
BAS EN ISO/IEC 17025. They already carry out some testing according to the standards
within Construction Products Directive. They are prepared for accreditation for the following
standard methods: EN 1340:2003 Concrete kerb units, EN 1338:2003 Concrete paving
blocks and · EN 1339:2003 Concrete paving flags. Its laboratory tests construction materials
and semi-products such as stone aggregate, concrete, bitumen. They prepare
 Preliminary studies of material properties for design of the hull and deck construction
of roads,
 Checks of properties of materials used and the individual quality of their installation,
such as mechanical and physical properties of materials,
 Non-destructive testing of materials and structures,
 Geotechnical tests on mechanical and physical properties of disturbed and
undisturbed soil samples
 Technical Faculty in Bihac University – Laboratory for testing of construction

materials.19 This is a state owned laboratory with 9 employees. Main scope of the laboratory:
Testing of aggregates, cement and brick products. Laboratory is certified according to the
standard BAS EN ISO 9001. They are in the process of preparing for the accreditation
according to the standard BAS EN ISO/IEC17025 for test laboratories.
3.2. Market surveillance
3.2.1. EU
In every MS of the EU market surveillance authorities control whether product and

accompanying documentation satisfy requirements of the relevant EU Directives. Their major
task is to enforce CPD as it was transposed into the respective national law. However,
institutional arrangements differ in each country. Examples:
In Germany the construction market surveillance authorities are subordinated to the regional
governments (Laender). Their work is co-ordinated by a Coordinating Point20.
In Latvia21 the general supervision and coordination of construction in Latvia is competence

of the Ministry of Economics. There is a three-stage supervision of construction process
 supervision provided by members of construction process;
 municipal Construction inspection;
 State Construction Inspectorate.
Officers of State Construction Inspectorate are performing market surveillance on
construction site and, if necessary at the production sites. Officers of the Consumers Rights
Protection centre are performing market surveillance on market places – distribution sites
and shops.
19
Tehnicki fakultet u Bihacu - Laboratorija za ispitivanje gradevinskih materijala
20
Deutsches Institut für Bautechnik - Koordinierungsstelle Marktüberwachung der Länder. Source: website of this
Organisation.
21
Implementation of Eurocode and market surveillance of construction products in Latvia. Andris Steinerts, Head
of Building regulation unit at the Building department. Presentation on the meeting of Consortium of European
Building Control, Riga, May the 12th, 2008
15
In Hungary the responsibilities of the building control authority as a statutory body are
delegated to the Construction Surveillance Departments of the respective Regional
Administrative Offices of the Government22. Their task is to enforce the legal norms by
monitoring construction sites, stores and markets, and if necessary, to apply sanctions.
3.2.2. BiH
In FBiH. Prior to the construction process, i.e. before beginning of the actual building works,
construction products are not controlled at the manufacturers’ site. Instead, when
construction works are controlled by inspectorates, part of this control covers document
control of product certificates about the conformity of construction materials. Inspectorates do
not take samples of construction products; neither do they send samples to laboratories.
Sampling and testing activities are under the responsibility of certification bodies / accredited
laboratories, and the Inspectorates control only the certifications issued by such
organizations. This means that inspections control construction materials by document
analysis.
In RS. 23 The Urban Planning, Construction and Ecology Inspection of RS is responsible only
for the quality control of certain types of construction materials such as asphalt and cement.
Manufacturers of other construction materials must obtain approvals from accredited
laboratories such as IMK Sarajevo, IG Banja Luka etc. In case of concrete and reinforced
concrete the Inspection uses a rulebook24 from 1987 which provides for rules on what
parameters of the material and technology to control and how. This Yugoslav rulebook is still
used in Croatia, BiH, Serbia.
22
Regionális Államigazgatási Hivatal Építésfelügyeleti Osztályai
23
Interview with Mr. Dragan Mijovic, Head Republic Urban Planning, Construction and Ecology Inspector
24
Pravilnik o tehničkim normativima za beton i armirani beton or PBAB 87
16
4. STAKEHOLDERS AND MARKETS AFFECTED
4.1. Overall relevance of CPD in BiH
Among the New Approach Directives CPD is one of the most relevant regulations for the
economy of Bosnia –Herzegovina. Construction material producing, exporting and importing
companies are the major stakeholders affected by the planned legal changes
Production. In BiH the yearly volume of construction products manufacturing amounts to

between 800 and 900 million KM, which in 2009 was equivalent with between 4 and 5 % of
the GDP of BiH. This estimation is based on official statistics 25 and includes both local sales
and exports. The major subsectors are metal structures and parts of structures, cement,
bricks, ready-mixed concrete, concrete products and windows.
Export. The yearly export of construction products from BiH amounts to 130 million KM ,
which in 2009 was equivalent with 2,3% of the total export of BiH. 26 The major export articles
are articles of cement, concrete and ceramic bricks. In spite of high transportation costs,
which are prohibitive in case of certain construction materials, there is a sizeable export
activity in this sector. Therefore any regulatory changes facilitating the free movement of
construction products across the borders are of high relevance both for export and import.
Import. The yearly volume of import amounts to 400 million KM which in 2009 was equivalent
with 3,2% of the total import of BiH. 27 The major import items are ceramic building bricks, tiles
and glass products. Consumers of imported construction products, among them
predominantly the local construction companies are interested in enjoying the benefits
following from European product conformity regulations.
Investment. Due to high investments and modernization needs, it is necessary to find

sources of funding or strategic partners to modernize production facilities, increase
productivity and thereby ensure greater competitiveness in foreign markets. Foreign owned
construction materials companies are present already in many sub-sectors, e.g. cement,
brick and concrete slab production. The owner international companies are highly interested
in working in a European-type regulatory and institutional environment in BiH, including the
use of European standards and the possibility of using the services European type
certification bodies.
25
Source: Industrial production in 2008. Agency for Statistics of Bosnia and Herzegovina, Sarajevo, 2009.
26
Source: Bosnia and Herzegovina Foreign Trade 2009: A Brief Review. Published by the Foreign Trade
Chamber of Bosnia and Herzegovina, February 2010.
27
Source: Bosnia and Herzegovina Foreign Trade 2009: A Brief Review. Published by the Foreign Trade
Chamber of Bosnia and Herzegovina, February 2010.
17
Production of selected construction products, Bosnia-Herzegovina 2008
Source: Industrial production in 2008. Agency for Statistics of Bosnia and Herzegovina, Sarajevo, 2009.
18
Foreign trade of selected construction materials in BiH

Articles of stone, plaster, cement, asbestos, mica or similar materials
(Product Class 68 according to the Harmonised System)
2009, thousands of KM
sorted by value of 2009 import to BiH
Source: Agency for Statistics of Bosnia and Herzegovina, Sarajevo, 2009.
19
Foreign trade of selected construction materials in BiH

Ceramic products
(Product Class 69 according to the Harmonised System)
2009, thousands of KM
sorted by value of 2009 import to BiH
Source: Agency for Statistics of Bosnia and Herzegovina, Sarajevo, 2009.
20
4.2. Product overview of the construction materials industry in BiH28
BiH has abundant natural resources such as forestry, stone, gravel (aggregates), sand, clay
and metal ores. These provide adequate support to a whole range of building material
producers located in clusters around most of the centres of population. The primary source of
material for much of the building material industry comes from quarrying and mining. Sand,
gravel and clay deposits offer ready-to-use materials, while quarries provide stone, gypsum
and lime. The mining industry provides bauxite for aluminium production and iron ore for iron
and steel products. Due to high transport costs, the producers are effectively only supplying
the construction industry located in their immediate vicinity. The capacities of the respective
companies are typically under-utilized.
A selection of construction products manufactured in BiH
Cement
Lime for industrial use
Brick and clay tile production
Asphalt for roads
Ceramic tiles and ceramic pipes
Reinforcing rods and meshes (i.e. metal networks) for ferro-concrete structures
Metal window frames and doors are manufactured from imported steel and aluminium
Plastic double-glazed windows
Timber - joinery products (e.g. roof frames and floor joists, window and doorframes, doors,
parquet flooring)
Cement-based products (e.g. concrete, concrete paving slabs, concrete blocks, light-weight
concrete block, pre-cast concrete lintels)
Gypsum-based products (e.g. gypsum boards)
Plastic products (e.g. water supply pipes, drainage pipes, Styrofoam insulation panels)
The following list gives an overview about the major product markets of construction products
in BiH.
 Cement producers in BiH are recently privatized companies. There are two large cement
plants (the Kakanj Cement Plant owned by HeidelbergCement and the LLC Cement Factory
Lukavac, majority owned by Alas International). They cover about 70% of the market of
Bosnia and Herzegovina and the remaining need for cement is covered by import, mainly
from Croatia.
28
A major part of the information contained in this chapter originates from the following publication: [BIH FIPA
2002]
21
 Stone products. According to data of the Chamber of Commerce of FBiH in the sub-
sector of production of stone (cutting, shaping and processing of stone) and stone products
the following major companies are registered: AG Stone D.O.O. Široki Brijeg, Dubint D.D.
Široki Brijeg, Granitmont D.D. Jablanica, Kamen Bihać i Granit D.O.O. Jablanica.
 Gypsum, plasterboard and plaster-based profiles are made in BiH, but also imported from
other countries, such as Italy.
 Lime for industrial use and for use in the construction industry is prepared in BiH. The
capacity of 110,000 tonnes per annum (65,000 non-burned and 45,000 hydrated) is sufficient
to meet current demands.
 Brick. Clays from local deposits provides the basic requirements for brick and clay tile
production. The local market absorbs all of the production of the businesses involved, using
a wide range of different shapes and coloured materials for wall and paving construction.
Hollow bricks are also imported from Serbia. Clay roof tiles are mostly imported. According to
data from the Chamber of Commerce in the Federation BiH there are 11 enterprises that
produce bricks and brick products. Among the largest are: "IGM" D.O.O. Visoko, TOP "25
Maj", Cazin, D.D. "Splonum" Sanski Most, "Termo Ziegel Nigma" D.D. Busovača , Tvornica
opeke D.O.O. Sarajevo i IGM Ciglana Grahovo D.O.O. Bosansko Grahovo.
 Asphalt for roads is prepared from locally quarried hard stone, such as granite, and
imported tars. The petrol-chemical industry of Croatia provides the bulk of the required
additives, although some tar and bitumen is imported from Hungary.
 Ceramic tiles and pipes are produced partly in BiH, from locally sourced materials, partly
imported. Certain ceramic products such as sinks and bathroom fittings are mostly imported.
 Iron and aluminium produced in BiH is not further refined in the country, with the
exception of the production of reinforcing rods and meshes for ferro-concrete structures.
 Steel components, such as structural steel beams, fixtures, fittings, pipes and rain gutters
are largely imported or fabricated in BiH from imported materials.
 Metal window frames and doors are manufactured from imported steel and aluminium by
local metal processing industry.
 Smaller metal items, ranging from nails and screws to door locks and hinges are
produced by small engineering business in BiH.
 Plastic components used in construction industry such as double-glazed windows and
doors, groundwork pipes, and connectors are made from imported basic materials. Also,
water supply pipes, drainage pipes and styrofoam insulation panels are made in BiH.
 Most installation products used in buildings such as air-conditioning, heating, plumbing
components and bathroom fittings are imported, primarily from Turkey and the EU.
 Timber and timber-based products, both in semi-finished and in finished forms, are
exported worldwide.
 Joinery businesses in BiH produce roof frames, floor joists, window frames, doorframes,
doors and other architectural items such as boards.
 Concrete made in BiH is used to make paving slabs, concrete blocks for walling, light-
weight concrete blocks for the local market and for export to neighbouring countries.
 Paint and coating manufacturing companies in BiH work from imported constituents.
22
23
4.3. Construction materials industry in the entities

FBiH. In 2009 a SWOT analysis was prepared about the construction product sector of FBiH,
based on a survey among construction product companies.29
Number of construction material manufacturing companies registered at the Chamber

of Commerce of FBiH
Sub-sector Number of companies

Production of bricks, tiles and similar products 11
Cement production 2
Production of lime 4
Manufacture of concrete products for construction - 98
Manufacture of plaster 1
Production of concrete mixtures 12
Cutting, shaping and processing of stones 72
Manufacture of other non-metallic mineral products 5
Source: Chamber of Commerce of FBiH
The study has underlined the importance of introducing European norms and standards and
to establish appropriate institutions for implementation of quality control, that are networked
with similar European partners. The study has analysed the state of construction products
industry in the entity.
 Strengths and opportunities. The study has stressed the following strengths and
opportunities: sufficient infrastructure, industrial tradition, a sufficient range products,
and the availability of raw materials for processing from local sources.
 Weaknesses and threats. The analysis has revealed the following weaknessess and
threats: unsatisfactory relationship between the primary material production and final
processing, outdated technology and equipment in the production process, redundant
and excessive involvement of human labor, unfair competition, and the lack of quality
control and control of origin of imported goods. The comparative advantages of
building material industry (a large supply of domestic raw materials) are not sufficient
for further development. The availability of skilled staff is very limited which makes it
difficult to revitalize the companies,
In the Republika Srpska the sector construction, construction material industry, communal
and servicing activities includes enterprises active in the area of high-raise buildings, low-
raise buildings, final and installation work in construction and projecting. Production of
construction material includes: stone, sand, gypsum, brick and concrete products, lime and
other materials. This branch of industry in RS includes 657 enterprises or 14, 7% of totally
registered companies. In RS there are 80 companies producing concrete and 20 firms
producing asphalt.
29
FBIH Industrial Policy 2009
24
Manufacture of selected construction products

Republika Srpska 2007 and 2008
Unit of
Product 2007 2008
measurement
Sawn timber, spruce and fir m3 289 556 313 700
Sawn timber, oak; blocks and elements m3 41 823 45 311
Sawn timber, beech; blocks and elements m3 151 384 150 404
Wooden windows Units 58 702 43 065
Parquet m3 307 866 424 358
Lime, hydrated T 45 082 21 678
Pipes, concrete T 9 427 12 398
Concrete, fresh T 364 449 443 079
Hot asphalt mass T 320 410 535 380
Ceramic insulators T 110 134
Iron castings T 4 231 4 196
Iron pipes T 114 593 113 573
Hydrated alumina for manufacture of
T 303 799 294 455
aluminium
Nets and grates for concrete reinforcing T 61 692 59 747
Metal constructions for construction (doors
T 62 403 55 792
and windows excluded)
Source: Statistical Yearbook of Republika Srpska 2009
4.4. The construction (building) sector
Construction companies are also affected by the planned legal changes, since they are the
major consumers of construction products. In BiH the construction industry constitutes an
important sector, which contributes to the GDP by 5.4 per cent. Construction industry was
favourably affected by the growth of foreign investments, both in terms of construction of
buildings and of infrastructure.
In 2008 the value of construction put in place in BiH was 1.722 million KM 30, of which 54,8%
amounted for buildings and the rest for Civil engineering works such a transport
infrastructure, Pipelines, communication, electricity lines, complex construction projects at
industrial sites.
It is estimated that there are some three thousand businesses in Bosnia and Herzegovina
engaged in construction spanning all sub-sectors of the construction industry employing
approximately 100,000 people. 31 In FBiH, according to data obtained from the Chamber of
Commerce construction works are performed by 1,800 business companies.
During the 2005-2008 period, the value of construction works completed has increased by
79.2 per cent in FBH and by 97.8 per cent in RS. During the recession year 2009 the value of
construction works completed in BiH was KM 725.4 million which compared to the previous
year was a decrease by 28.2 per cent in FBH and by 8.0 per cent in RS.
30
Source: Construction statistics 2008, Agency for Statistics of Bosnia and Herzegovina, Sarajevo, 2009.
31
Source: Annual Report of Centralna Banka Bosnie i Hercegovine
25
5. COMPETITIVINESS ASSESSMENT
5.1. BiH company survey on expected impacts of introducing CPD
The survey was implemented in September-October of 2010 among companies

manufacturing / trading construction products and among construction companies. More than
120 companies have been approached out of which however only 20 have responded. The
Cover Letter of the survey and the Questionnaire is included in the Appendix.
5.1.1. Characterisation of the sample
Distribution of the respondent firms by size of company

 small companies (up to 50 employees): 40%
 middle sized companies (50 to 250): , 20%
 big companies (more than 250 employees): 40%
Distribution of the respondent firms by turnover of company

 small companies (up to 5 mill KM): 40%
 middle sized companies (5 to 20 million KM): 30%
 big companies (more than 20 million KM): 30%
The professional profile of the respondents was as follows:

 Approximately one third of the respondents was manufacturing or selling construction
materials, but was not involved in construction (building) services.
 Approximately one third of the respondents was not involved in the manufacturing or
selling construction materials, but was involved in construction (building) services.
 Approximately one third of the respondents was manufacturing or selling construction
materials, but in the same time was also involved in construction (building) services.
Profile of responding CONSTRUCTION MATERIALS production, import and sales

companies
Product groups % of YES
AGGREGATES (e.g. road stone, crushed rock, sand, gravel) 20%

CEMENT AND CONCRETE (e.g. gypsum plasterboard, pre-cast concrete
50%
products such as blocks)
METAL PRODUCTS (e.g. structural steel, metal doors and central heating
40%
boilers, pumps, taps, valves)
PLASTIC PRODUCTS (e.g. rigid and flexible pipes and fittings, plastic doors
30%
& windows)
A respondent could answer with YES to more than one questions
26
Profile of CONSTRUCTION (BUILDING) companies
Product groups % of YES
Construction of buildings 30%

Civil engineering (construction of roads and railways , sewage plants,
40%
electricity and telecommunications)
Demolition and site preparation 30%
Electrical, plumbing and other construction installation activities 20%

Building completion and finishing (e.g. plastering, floor and wall covering,
30%
painting, roofing)
Planning, design and consultancy in the field of construction industry 40%
A respondent could answer with YES to more than one questions
Export orientation. About 35% of respondents sells its products / services only in Bosnia-
Herzegovina, while the rest is involved in export activity, mostly to Croatia, Serbia and
Montenegro, but some respondents have recently exported to Germany and Slovenia. About
40% of the respondents have stated that there are certain well defined reasons why the
company does not sell its products / services to any other EU countries. These reasons are:
lack of permits, market distance / big transport costs and lack of competitiveness.
5.1.2. Existing company procedures regarding to product quality and safety
Problems with export and import regarding certificates. About one-third of the respondents
have stated that they have problems with export and import regarding certificates. The
following specific problems were identified:
 the firm cannot put CE mark on their products,
 they have problems with the application of particular standards (e.g. the Occupational
Health and Safety Management standard 18 001, or the Welding of Metallic Materials
standard EN 3834-3/2).
Share of products CE marked. About one-third of the respondents have stated that their
products are CE marked. One respondent company has CE mark since 2000 and other
companies since 2010. Most respondents will need a lot of time. One company is in the
process of putting CE mark on its products, another is starting soon. About one-third of the
respondents has products which do not need CE marking. Major example: cement sold on
the BiH market or even exported to Croatia still does not need CE mark.32
Quality management system. With the exception of one company, all respondents have ISO
9001 Quality Management qualification. Companies with a functioning quality management
system can relatively easily adapt to the requirements of a Factory Production Control
system as required by CPD.
32
This is an example of the changes BiH producers are facing. Cement will have to satisfy the requirements of
CPD after the ordinance implementing CPD enters into force and accordingly producers will be obliged to put a
national conformity mark, the so called C mark on it. Following BiH’s entry into the EU, this C mark will be
replaced by CE mark.
27
External laboratories and their services. About two-thirds of the respondent firms work with
external laboratories. Examples: GIT (Tuzla), IGH (Zagreb), ZAG (Ljubljana), IMK Faculty of
Civil Engineering (Sarajevo), IMS (Beograd), IRMA (Ljubljana), CSI (Italy) and IFT
Rosenheim (Germany). The spectrum of services obtained from laboratories ranges from
initial tests of products (e.g. of aggregates, concrete, cement), through audits and periodic
examinations of quality. The yearly costs spent for external laboratory services ranges from
5000 EUR to 100 000 EUR, whereby construction companies pay significantly less money
for external laboratory services compared to construction product companies. About one-
quarter of companies has an experience with initial type testing of their products. The
estimated fee to be paid for initial type testing of products per product type ranges from 5.000
to 20.000 EUR.
Internal laboratory. About only one-third of the respondent companies have their own
laboratory, typically the big construction product companies. The spectrum of services
performed by internal laboratories ranges from the control of products (e.g. concrete and
concrete components) through calibration of instruments to giving expertise for purchasing
equipment or commissioning external services.
Employees working in the quality management. In bigger companies usually 1-5 employees
per company are devoted to this task. Most members of the managerial staff are responsible
for some aspects of quality management.
Contacts to technical consultancies. About one-third of companies co-operate with external

Technical consultancies on quality and product safety issues? Technical consultancies
mentioned: Bureau Veritas, TÜV Germany and its offices in Slovenia and in BiH.
Specific problems encountered in the certification of products.

 There is a disturbing variety of the needs of different markets: it is difficult to adjust
parameters of quality for each country regarding the differences in their laws and
regulations. (Mentioned by a company producing reinforced concrete elements,
prefabricated steel structures, PVC and aluminium joinery products).
 There is a lack of testing laboratories accredited for the cement standard EN 197-1.
Transports of cement products must obtain certification in Croatia. (Mentioned by a
cement producing company).
 A recurring complaint is the high price of certificates.
28
5.1.3. Impacts of CE marking on the activities and effectiveness of the company
Expected impacts of the introduction of CE marking

listed in decreasing frequency of being mentioned
About two third of the respondents have
improve or change their quality management /
the opinion that the introduction of CE
production control system.
marking will:
improve their position to co-operate with other
About half of the respondents have the
companies as a subcontractor and improve their
opinion that the introduction of CE
position to comply with product safety/product
marking will:
conformity regulations.
About one -third of the respondents have improve their position to select subcontractors and
the opinion that the introduction of CE improve their position to co-operate with foreign
marking will: investors.
About one-quarter of the respondents
improve their position to export and will improve
have the opinion that the introduction of
their position to get better prices for their products.
CE marking will:
About one-sixth of the respondents have
the opinion that the introduction of CE improve their position to reduce marketing costs.
marking will:
a technical upgrading of the products, in the
Most respondent companies have the introduction of additional product types, in the
opinion that the introduction of CE phasing out of existing product types or in
marking will NOT result in: changing the number of competitors on their
markets.
Expected organisational changes attributed to CE marking. About one-third of the

respondents have stated that as a result of new harmonised European standards and CE
marking there have been some changes to their company procedures, quality policies or
marketing strategies, e.g. hiring of new people, training of personnel, involvement of external
laboratories or quality attestation firms, etc. About half of respondents expect further such
changes. Certain respondents have highlighted that such changes – e.g. co-operating with
external laboratories, training employees or entering further specialization - are expected
with the joining of their company with some European companies. About half of the
respondent firms has purchased or plans to purchase new equipment in order to improve
quality and product safety. The immediate reason of spending on this investment was (is) to
improve the quality control of products or to improve productivity in order to facilitate export.
Expected costs and benefits attributed to CE marking. At the beginning of CE marking

process companies expect higher costs but later the associated costs will be reduced. The
additional costs will be due to certification fees, expenses associated with production control,
laboratory expenses, purchasing of new tools and training of staff. About one-quarter of
respondent companies expect some savings on the long run as a result of CE marking. This
improvement will result due to an unification of production and test methods, due to a
decrease of duplicated (parallel) processes in the field of production, quality control, storage
and packaging.
Expected sales benefits attributed to CE marking. About two-thirds of respondent companies

have highlighted the benefits of CE mark in export. One respondent has stressed the
importance of quick adaptation: most of his competitor companies still do not have their
products CE marked which results in an increased competitiveness for this particular firm on
the European market.
29
Expected impacts on competition attributed to CE marking. About two-thirds of respondent

companies think that CE marking process will increase competition. However, since many
smaller, partly illegal businesses will not be able to survive in the new regulatory
environment, competition will decrease in the first phase of this transition.
Expected impacts on foreign direct investment (FDI) attributed to CE marking. Most

respondents agree with the statement that mandatory CE marking will definitely encourage
foreign investors to invest in the construction industry and in the construction products
industry BiH.
Expected impacts on SMEs (small and medium companies) attributed to CE marking. About
half of the respondents have opinion on this issue, most of these respondents think that
since smaller companies do not export, their competitiveness will be decreased due to
mandatory CE marking.
5.1.4. Awareness and information sources on regulations and standards
The need for an information campaign about New Approach regulations and the
accompanying conformity assessment procedures cannot be over-emphasised. Companies
expect such information from Government authorities, chambers and laboratories alike.
Level of awareness of firms about regulations and standards

 On regulations and standards. About half of the respondents think that their company is
sufficiently informed about (a) the present BiH regulations on the safety of construction
products (b) about the EU Directive on Construction Products (c) about the use of CE
mark in the field of construction products (d) about harmonised European standards in
the field of construction products.
 On ETAs and Eurocodes. But only about one-quarter of the respondents thinks that their
company is sufficiently informed about (a) European Technical Approvals in the field of
construction products (b) Eurocodes (standards of construction design).
Existing information sources of firms. Regarding the above issues, the companies obtain
information (a) from the manufacturer/supplier of products (b) from laboratories and quality
oriented technical consultancies. Respondents claim that no relevant information was
received from the Government, from Market Surveillance or from Chambers of Commerce.
Expectations of firms from Government organizations. Respondents expect from the

Government
 to be effective in issuing good laws, offering a sufficiently long transition period, providing
good support to producers (including financial support to help in the adaptation process)
 to establish good contacts with EU institutions, to eventually harmonize national
standards with European standards, to achieve a mutual recognition of regulations,
standards and conformity assessment results
 to make regulatory decisions on the level of the whole BiH, and not partially or on entity
level (as it now works),
Expectations of firms from Chambers of Commerce. To offer educational help in European

product conformity issues e.g. by conducting seminars.
30
5.1.5. Company recommendations as to the timing of the regulatory changes
Summary opinions about the urgency of introducing CPD. About five-sixth of respondents
have the opinion that the sooner these technical regulations are introduced, the better. Some
of the respondents – typically bigger, foreign owned companies - are definitely impatiently
waiting for these regulatory changes. (Opinions: „We cannot allow the luxury of losing more
time“ , “The introduction of CPD in BiH is very good news for us.”). However, about half of the
respondents think that companies need a transition period to prepare and about one-quarter
of respondents think that it is the Government which needs preparation – and more time - for
implementing these regulatory changes.
31
5.2. BiH company interviews on expected impacts of introducing CPD

As part of the RIA efforts, a smaller sample of construction firms, construction product
manufacturing companies and laboratories were visited. The aim of these interviews was to
reinforce the results obtained from the questionnaire based survey. Most interviews took
place on the site of the respective stakeholders. Companies were asked about their product
portfolio, about the range of their activities to ensure product quality and conformity, and
about their opinion on the planned introduction of CPD. Below is an overview of the typical
responses.
Company attitudes to the introduction of CPD to BiH
32
Stakeholder and its description Company level impacts
“Tile Import Company A” (Sarajevo.)

Quality and conformity costs will not increase
because all products bear CE mark. They
Importer / distributor of roof tiles. Subsidiary of
welcome the introduction of CPD and hope
international company. Yearly approximatively 30
that it will enhance free trade and fair
million peaces of tile sold in BIH. Imported tiles from EU
competition.
countries, most are CE marked.
“Light Concrete Manufacturer Company B” (Tuzla)

Quality and conformity costs will not increase
because they assess the conformity of their
Production of light concrete products such as wall
products already according to CPD: there is
blocks, thermal blocks, wall plates. Company part of
no CE mark on their products, but products
multinational group, holding centre in Germany.
are certified according to EU harmonized
Conformity assessment of products with the help of
standards. They welcome the introduction of
IGH Mostar (a laboratory), a Notified Body in Croatia
CPD and hope that it will enhance free trade
and the mother company in Germany. Tuzla Plant has
and fair competition.
ISO 9001 certification.
“Clay Brick Manufacturer Company C” (Sarajevo)
Producer of clay bricks. 70 employees. Company part

of multinational group. Sales in BiH, export to Croatia Quality and conformity costs will increase
and Montenegro. Conformity assessment of bricks (approximately double) mainly due to
formerly with the help of ZAG (Slovenian National increased frequency of testing.
Building and Civil Engineering Institute) and by
Slavonija Industrija Gradevnog Materala (Croatia).
Sarajevo plant has ISO 9001 certification.
“Construction Company D” (Gracanica) They welcome the rapid introduction CPD.

Expectations: transparent markets, improved
400 employees. Construction of buildings, production quality of construction products, easier export
and installation of reinforced concrete structures, into the EU, easier selection of
manufacture and installation of steel structures, PVC subcontractors, easier compliance with
and aluminium joinery. Export of construction services product safety/product conformity regulations.
into Germany, Norway, Sweden, Italy “There is no reason to wait, it would be too
late”.
They expect the CE mark to improve their
position to export, to reduce the number of
their competitors on their markets, to improve
“Gate Company F” (Visoko)
their position to select subcontractors, to co-
operate with other companies as a
82 employees. Produces metal and plastic products.
subcontractor, to comply with product
Main products are PVC and aluminium gates. They
safety/product conformity regulations and to
export to Croatia and Serbia.
co-operate with foreign investors
5.3. United Kingdom: winners and losers of the full introduction of CPD
33
In 2008 the Department for Communities and Local Government of the United Kingdom has
published a Review of the operation and impact of the Construction Products Directive in the
UK. CPD was implemented in the UK through the Construction Products Regulations 1991,
and by 2008 a wide body of experiences has been accumulated about the impacts of the
regulation among companies.
Background of the study. The UK has introduced CPD in 1991 without requiring mandatory
CE mark to be put on construction products, but made CE marked products from other MSs
fully acceptable on the UK market. This position was taken for protecting those local SMEs
who see no benefits of CE marking, in order to relieve them from the regulatory and cost
burdens that CE marking would entail. After the turn of the century, there has been a shift
towards greater acceptance of CE marking, and UK manufacturers have increasingly
accepted the possibility of mandatory CE marking being introduced in the UK. One of the
reasons of was that the quality of European Standards has been improved: manufacturers
have reported that in many cases new European standards have provided better technical
documentation as compared to the British Standards that they had replaced. However, in
some sectors there were SMEs who have still resisted unless the UK regulatory framework
would take care of their concerns.
Research question. For the above reasons, the aim of the research was to contrast the
benefits of obligatory and non-obligatory CE marking.
Method. The research was based on detailed consultations with 24 manufacturing

stakeholders from 18 product groups, and the findings were used in a cost-benefit analysis.
Results of consultation. While the companies accounting fro the bulk of turnover of
construction products have supported mandatory CE marking, there was a clear
segmentation among firms affected by the regulation regarding mandatory CE marking. The
following two tables highlight the attitudes of various groups of companies on mandatory CE
marking.
34
Companies likely favouring mandatory CE marking

Stakeholder type Impacts / Company attitudes
CE marking costs per product family are broadly similar for the largest and
smallest companies in absolute terms, irrespective of turnover. Hence the
Larger companies
cost per product type tends to be relatively higher for the smaller
enterprises.
For these companies the costs of CE marking are justified by the widening
of their market to the majority of the EEA countries where CE marking is
Companies exporting to compulsory. In particular, construction products for which the unit prices can
EU justify transport costs in case of larger distances, such as cement, structural
steel, reinforcing and prestressing steels, and wood panels, geo-textiles and
ceramic tiles which are widely imported to and exported from the UK.
CE marking has removed the need for a multitude of national and voluntary
Multinational
marks, creating significant savings for multinational manufacturers, e.g. in
companies
the cement manufacturing sector.
Typically such companies face price competition with products of doubtful

Companies facing
quality/conformity. Such companies want obligatory CE marking and
import competition from
proactive market surveillance for enhancing fair competition (e.g. timber,
outside of the EEA
geo-textiles/geo-membranes, and fire fighting systems/components).
Companies already
There is a synergy between certification to ISO 9000 and CE marking, and
having a functioning
manufacturers benefit if they go for both as opposed to the overall cost of
Factory Production
each one individually – especially if the same Notified Body (NB) can also
Control (FPC) system in
certify to ISO 9000.
place.
Source: [UK CPD Review 2008].
35
Companies likely opposing mandatory CE marking
Stakeholder type Impacts
For small companies it is more costly to familiarize with new legislation

Smaller companies and standards, with CE marking documentation. Also it is more costly to
change the promotional literature and delivery notes of their products.
Companies whose markets are regional or national and have no

intention to export to EU see little benefit from CE marking their
Companies operating products. For example, windows, masonry, sanitary fittings, chimneys
within the local / regional / and flues, and thermal insulation products are sold predominantly on the
national market only national / regional / local markets. However, such companies must also
pay significant direct costs and devote management time to CE mark
their products.
Many (mostly smaller) companies see no market demand to have ISO

Companies without a 9001 certification or other voluntary quality mark(s). Such companies
certified factory production would face significant additional (a) internal management costs in case
control system (FPC) they were obliged to have a written FPC or (b) costs of testing by a
commercial laboratory to have CE mark on their products.
Companies not (currently)

Sectors which are not facing competition from non-EU countries see no
faced with heavy
advantage in the regulation which requires mandatory CE marking to be
competition of imports from
put on construction products.
developing countries
Companies with little For some construction products aesthetic considerations are critical and
demand for product safety considerations are negligible, therefore CE marking is of little
marking from customers value.
There is a wide range of firms manufacturing sensitive products which

are then exported to countries where the regulations still demands to
Companies with de facto
obtain quality marks irrespectively of CE mark. (Examples: UK: BSI
obligation to obtain quality
Kitemark, Germany: Ü-Mark). Such companies face anyway costly
marks
testing and certification procedures and see no additional benefits from
CE marking.
Source: [UK CPD Review 2008].
Large vs. smaller companies. It is recognized that regulatory measures may impact
differently on SMEs than on larger enterprises. These findings have been supported by many
RIAs made in various European countries.33 Some of these differences are as follows.
33
E.g. [UK CPD Review 2008], [CPD RIA EU 2007] for CPD. For other New Approach Directives see [Lithuania
LVD RIA 200], [Croatia LVD RIA 2001], [Ukraine LVD RIA 2008], [Georgia LVD EMC Lift RIA 2010]
36
Factors influencing the compliance behavior of large and small companies
Large manufacturers SMEs
Are able to afford Are frequently members of trade associations, but lack
representation on standards of human resources prevents them to spend time at
committees. standards committees, away from their business.
Are able to afford expensive

Are frequently challenged by lack of resources
test methods called up in
necessary for testing.
harmonized standards.
Are more likely to already
have in place quality marks or Have frequently less use for a written factory
ISO 9000 certification production control (FPC).
systems.
Are more likely to be export
Operate frequently solely on the local market,
oriented, therefore are easy to
satisfying local requirements; therefore pay less
reach with information about
attention to European regulations.
the CPD.
It is exactly for the above reasons that the EU Commission has acknowledged the particular
difficulties for SMEs and reduced the burdens associated with compliance to CPD. In
particular, in 2005, the Commission reduced the potential costs of initial type testing (ITT) by
introducing the institutions of “ITT cascading” and “ITT sharing” whereby companies may
pass on ITT results to other co-operating firms working on the same product, or alternatively,
may share the same ITT results with other companies.34
Conclusions of the UK study. The study arrives to the conclusion that up to 2008 the UK has
optimised benefits from CE marking by keeping it voluntary. However, in the future the
benefits of mandatory CE marking may exceed its costs, due to globalisation of trade, due to
the continuous improvement of the quality and quantity of harmonised EU standards and due
to the possibility of the above mentioned simplification practices in conformity assessment
that have been allowed since 2005.35
5.4. Winners and losers revealed by EU CPD RIA study
In 2006-2007 a major RIA project was implemented by the PRC consulting company on
behalf of the EU Commission covering the impacts of CPD in EU Member States. 36 The
study was based on extensive consultation activities across EU Member States and on a
wide range of case studies.37
34
[EC Guidance Paper K 2004] and [EC Guidance paper M 2005]
35
Sharing of Initial Type Testing (ITT) results: Since 2005 an individual manufacturer may use the
ITT results obtained by another designer or manufacturer to justify his own declaration of
performance for an identical product under certain conditions. Sources: [EC Guidance paper M
2005] and [GNB-CPD AG position paper 2006].
36
[CPD RIA EU 2007]
37
The PRC team has carried out around 80 interviews and workshops, and approximately 100 telephone
interviews. Around 100 questionnaires were received. The project included 4 regional workshops in 2006 (Paris,
Copenhagen, Vienna, Bonn) where representatives of the industrial associations of Austria, Belgium, Czech
Republic, Denmark, France, Germany, Greece, Italy , Ireland, Norway, Poland, Portugal, Romania , Slovenia,
Spain, Sweden and the UK have participated. Companies of the following industries were represented: insulation
products, aggregates, valves & taps, ceramic tiles, cement, mineral wool, hardware for doors, bricks & ceramic
tiles, mortars, pre-cast concrete products, doors & windows, masonry and extruded polystyrene.
37
Results of consultation. CE mark makes products more easily accepted and provides
additional security for designers and installers against liability claims. In spite of this, the
study has revealed a wide range of distributional effects and competition distorting impacts
and subsequently voiced a series of recommendations based on justified complaints. The
following list is a summary of the revealed impacts.
 Winners and losers of CPD. Export oriented EU companies have realised the
benefits of European standardisation in terms of reduced costs of testing and
certification. Outside of the EU, CE-marking is seen as a good marketing tool, especially
if it is based on good EN standards. Testing and certification costs are minimal for big
firms and for well established firms which already have ISO9001 and well established
products. For other, smaller and less established companies Initial Type Testing (ITT) and
Factory Production Control (FPC) as stipulated by CPD brings the additional costs and
delays and is effectively a barrier to entry to the EU market.
 CPD used against low quality imported goods. Many companies in EU MSs
support CE-marking for protectionist reasons: some sectors of the construction product
industry feel threatened by cheap imports from low cost countries. Moreover, there are
many rumours on falsified certifications and markings. Therefore European companies
expect from market surveillance organisations to control the background of CE marking in
order to improve the detection of non-conforming products. Lack of enforcement and
market surveillance is seen by industry to be a major problem, leading to unfair
competition and inadequate protection against low quality imports. There is no common
EEA system of enforcement or guidance to surveillance authorities. National Market
Surveillance systems vary. There is no established system of sanctions for non-
compliance or false CE-marking.
 Surviving technical barriers to trade in spite of CE mark. In several EU MSs
CE-marking on its own is not enough to have a product accepted. For certain products
additionally there is a need for so-called application approvals of one sort or another, e.g.
certification to so-called national “residual standards”38, “application standards”, or special
requirements formulated by public procurement authorities. EU Member states
administrations, certification bodies or trade bodies have application rules or additional
requirements (such as the German ‘Bauregelliste’), and some require additional
certification against these (such as the German Ü-mark). Therefore, firms expect savings
in the medium term on the condition that the need for national marks will disappear. Until
national marks and national requirements are removed, most companies regard CE-
marking as an additional requirement.
 Effects of some EU countries not having mandatory CE mark. There are differences
among countries in whether CE-marking is mandatory. Suppliers for whom CE-marking is
mandatory think they are at a disadvantage in countries where it is optional. Such
companies – the majority in the EU - want mandatory CE-marking for all Member States
and all manufacturers in order to have a level playing field for all.
 Differences of compliance costs by risks associated with products. The involvement of a
Notified Body (NB) depending on the particular Attestation of Conformity (AoC) level
associated with the particular product type. Companies manufacturing products
associated with higher levels of risk must pay significant additional costs for tests and
certifications.
 Differences of compliance costs by previous existence of a quality management system.
Firms having ISO9001 Quality Assurance System and carrying out Quality Control (QC)
tests routinely encounter only minor additional costs by complying to CPD conformity
assessment requirements.
38
Residual standard (German: Restnorm): Many standards have been largely replaced e.g. by a European
standard, which however, does not contain all the contents / requirements of the phased out national standard.
Thus, there remains a residual national standard.
38
 Differences of compliance costs by innovativeness of the product. CE-marking with the

help of a harmonised European standard is relatively straightforward and typically the
initial costs may be around €10.000 per product. However, CE marking via an ETA is
more time consuming and may cost 10 to 30 times more. The additional burden which
accompanies ETAs appears only in case of innovative products for which no EU standard
exists. Moreover, innovative companies with frequent product changes must pay more
frequently for Initial Type Testing (ITT). Therefore and to this extent, CPD protects
established products.
5.5. Applying the above findings to BiH: expected winners and losers
As soon as the existing BiH legislation will be replaced with the EU legislation, all the
domestic companies will have to adapt themselves to a whole new set of procedures.
Companies will react to this challenge in widely different ways.
It is to be expected that the company reactions to introducing CPD in BiH will be

differentiated along very similar lines as it happened in the UK and in other MSs as reported
in the previously cited RIAs. In particular, the following segmentation of companies is likely:
 On the one hand, larger and/or multinational companies, companies already exporting to
the EU will favour the planned regulatory changes, due to expected competitiveness
benefits. These companies will find advantageous that they only will have to use one
conformity assessment system no matter if they want to place the product on the
European market or on the BiH market.
 On the other hand, smaller companies, companies operating within the local / regional /
national market only will oppose the introduction of CPD due to an expected increase of
compliance cost. A wide range of domestic SMEs will find that the initial costs for the new
system, including the initial costs for learning, new equipment, the changes to factory
production control (FPC) procedures and Initial Type Testing (ITT) will be substantial.
Moreover, they might face more competition and new competitors due to the fact that the
BiH market will become more attractive to foreign companies. Due to limited capacities
and capabilites of many small firms, these negative impacts will not be offset by the
advantages of being able to export.
6. IMPACTS OF CPD IN TERMS OF COSTS AND BENEFITS
6.1. Sectoral level cost analysis in the construction product sector of the UK
The above mentioned British study39 made in 2008 by the Department for Communities and
Local Government of the United Kingdom contains an enlightening cost calculation about the
costs of CE marking on various sub-sectors of the construction industry. The creditworthiness
of the calculation was enhanced by the fact that in the UK construction materials are
manufactured both with and without CE marking. Therefore the researchers were able to
compare both cost structures and the costs attributed to CE marking could be separated
from other costs.
39
[CPD Review UK 2008]
39
Cost calculation method. The cost analysis was based on company case studies covering 12
product families of construction products, such as cement, ceramic tiles, fixed fire fighting
devices, insulation materials, masonry, structural steel, windows and others. Companies
producing the above construction materials were asked to submit their sales figures and to
estimate their adaptation costs under the hypothesis that CPD was introduced in UK with
mandatory CE marking. The results of the sample were weighted by the total number of the
population of companies affected by the regulation. For this reason (a) Eurostat (b) UK Office
of National Statistics and (c) Construction Products Association data were used on the
number of enterprises, on the number of employees in the construction products industry and
on trade of construction products.
Results of cost calculation. The costs of adaptation to mandatory CE marking were clearly
depending on various factors.
 AoC. One of the most important factors was, what level of attestation of conformity (AoC)
was required for the particular products by CPD. Examples:
 Cement, and reinforcing and prestressing steels and fire fighting systems were
classified under “AoC “level 1” as products associated with higher levels of risk.
 Structural steel, chimneys and flues, wood-based panels and geo-textiles (as
fluid/gas barriers) were classified under “AoC level 2” as products associated with
somewhat lower levels of risk.
 Windows and most thermal insulation products were classified under “AoC level
3” as products associated with lower level of risk.
 Ceramic tiles, sanitary appliances and (most) masonry products were classified
under “AoC level 4” as products associated with the lowest levels of risk.
 Typical firm size. Another important factor was, whether the particular product was
manufactured predominantly by large manufacturing companies or rather by a larger
number of small companies. For example,
 Cement, structural steel, and reinforcing and prestressing steels were
manufactured by very large companies, partly multinationals
 Thermal insulation, wood panels, geo-textiles, windows, chimneys and flues,
masonry, ceramic tiles and sanitary appliances were manufactured by a mixture
of bigger, medium sized and smaller firms, whereby
 Windows were manufactured predominantly by a large number of small
manufacturers and by a small number of very large companies
Relative costs associated with adaptation / preparation to CE mark

by sector of the construction products industry
United Kingdom, 2008
Ongoing
Sub-sector of construction products Initial one-off costs
annual costs
industry % of sales
% of sales
Cement 0.08 0.00
Ceramic tiles 0.30 0.14
Fixed fire fighting 0.70 0.05
Insulation 0.25 0.17
Masonry 0.40 0.02
Reinforcing bar 0.01 0.00
Sanitary appliances 0.28 0.00
Structural steel 0.01 0.00
Windows 0.28 0.05
Wood panels 0.08 0.00
Total for construction products industry 0.18 0.03
(“Overall cost multiplier”)
40
Source: [CPD Review UK 2008]
Identifying benefits. The researchers of the UK and of the EU study were able to name the
benefits of CE marking, but they were not able to quantify them, i.e. to express benefits in
monetary terms. The explanation given was that the benefits relate to many intangibles,
including the value of enhanced competitiveness, etc.
The above costs are substantial but not significant if compared to the following benefits of CE
marking of construction products:
 The volume of trade should definitely increase, and prices and production costs decrease
reduce as a consequence of CE-marking. For most products there are big potential gains
from trade, due to differences between national markets in terms of price and quality.
 Competition should be enhanced and the transparency of the construction process
should improve as a result of more choice for designers and contractors. In particular,
compulsory CE marking leads to greater traceability of construction products, enabling
authorities to better enforcement and enhancing the EU-wide competitiveness of many
manufacturers.
 There are positive effects on health and safety due to consequent enforcement of CPD
and its essential requirements.
Stakeholder differentiation by balance of costs and benefits. The above costs and benefits
appear differently for the affected sectors and company size classes:
 The initial cost of CE-marking, for learning and for ITT is not significant for large
manufacturers of quasi-commodity products and materials with few product variants like
cement, masonry units, steel , timber products, and standard insulation boards.
 However, some other sectors with many small enterprises which typically do not trade
across borders , change their product portfolio frequently, and work with more design-
intensive products, face more costly attestation and new certification requirements.
Examples for such sectors are the windows & doors industry and the tiles industry.
6.2. Applying the findings of the above cost calculation to BiH
The findings of the above cost analysis can be applied to BiH construction products industry,
in the following manner. 40 The calculation is suitable only to estimate the approximate
magnitude of the BiH adaptation costs.
Let us apply the above “Overall cost multiplier” figures (in the last line of the above table) to
the overall sales data of BiH construction products industry. The inference is justified by the
fact that both in the UK example and in the BiH case the underlying scenario is the transition
from a previously widely applied national system of conformity assessment to the conformity
assessment system as defined by the CPD.
In a previous chapter of this study which was devoted to the description of stakeholders
affected by CPD it was shown that the total sales of BiH construction products industry
amounts to 800 to 900 KM per year. Consequently, the following estimated range can be
given for the adaptation costs:
 Initial one-off costs of adapting BiH construction products industry to CE marking ≈ 0,18%
of turnover ≈ approximately 1 to 2 million KM
 Annual recurring costs of adapting BiH construction products industry to CE marking ≈
0,03% of turnover ≈ approximately 0,2-0,5 million KM.
40
The justification of this inference method is discussed below in a separate chapter.
41
6.3. Company level cost analysis of CE marking for European brick factories
One of the case studies of the above mentioned European RIA study of 2006 41 offers an
enlightening example about the magnitude of CE marking adaptation costs to be paid by an
international chain of brick factories.
The brick factory chain Wienerberger has 163 plants in various European countries, and
manufactures on average 20 brick product types per plant. The adaptation process of
company procedures in order to put CE mark on products took 3 years. The cost calculation
took into consideration the costs of upgrading the quality system, enhancing testing activity,
and obtaining certifications. The result of the calculation was that the average adaptation
costs of a typical brick manufacturing plant amounted to
 a one-off cost of approximately 40 thousand EUR
 which however had to be followed by yearly recurrent cost of approximately 6 thousand
EUR.
The calculation was based on the following reasoning.
Costs of adapting brick factories to CE marking

Frequency Unit cost Cost
Cost item
of cost (1000 EUR) (1000 EUR)
Introducing / implementing the conformity
One-off cost assessment system for every plant ≈ (11.000 11.0 1 793
EUR/plant) *163 plant
Performing an ITT (Initial Type Testing) per
One-off cost product type ≈ (1.350 EUR/ plant/product type) 1.3 4 401
* 163 plant * 20 product type
Obtaining a certification for FPC (Factory
One-off cost Production Control) for every plant ≈ 1.200 1.2 196
EUR/plant * 163 plant
Total one-off costs for 163 plants 6 389
One-off costs for one plant 39,2
Additional product testing attributable to higher
than previous frequency (weekly frequency) of
Yearly
testing of bricks as required by the respective 5.2 847
recurrent cost
European harmonised standard ≈ 5200
EUR/year / plant * 163 plant
Yearly Renewal of FPC certifications ≈ 750
0.75 122
recurrent cost EUR/year/plant * 163 plant
Total recurrent costs 970
Average yearly recurrent costs per plant 5,95
Source: [CPD RIA EU 2006 Annex], Page 100.
6.4. Applying the findings of the above cost calculation to BiH

Based on the above cost calculation 42 it is very likely that for an average brick factory in
Bosnia Herzegovina the magnitude of transition / adaptation costs attributable to the
compliance with CPD will be
 between 50.000 and 100.000 KM one-off cost
 and between 5.000 and 10.000 KM yearly recurrent costs.
41
Source: [CPD RIA EU 2006 Annex], Page 100.
42
The justification of this inference method is discussed below in a separate chapter.
42
The adaptation costs will depend

 on the number of brick types manufactured in this particular plant
 on whether the company has an already established Factory Production System,
 on whether the testing of bricks already is performed with a weekly or higher frequency –
or alternatively, this will have be introduced as part of the upgrading procedure.
In BiH the survey and the interview method applied for this study was not sufficient to arrive
to analogous cost calculations. However, interviews made with quality managers of brick
factories in BiH have supported the following rough estimation. A typical brick factory in BiH,
of which the procedures are still determined by Yugoslav standards, in order to satisfy the
requirements of CPD will have to approximately double its quality and conformity costs. The
additional costs are mainly due to increased frequency of testing,
43
7. SUMMARY AND CONCLUSIONS

Bosnia and Herzegovina has obliged itself to take the necessary measures in order to
gradually achieve conformity with Community technical regulations and European
standardisation, metrology, accreditation and conformity assessment procedures. The
introduction of CPD is part of this process.
The gap analysis of this RIA has revealed that the challenges facing the institutional
environment are still large.
 The existing legal framework of construction product conformity is fragmented and
uneven across entities. Consequently the body of regulations needs not only
harmonization but also and deregulation and integration into fewer regulations. The legal
harmonisation work has started and an Expert Group consisting of state level and entity
level authorities, moreover of chamber organizations has been entrusted with the drafting
of the respective BiH technical regulation.
 Standardisation. The registration of EU harmonised standards is well developed, but
these standards are not yet widely applied in the conformity assessment practice. Most
construction product companies and conformity assessment bodies still work on the basis
of old Yugoslav standards. The application of European Technical Approvals has not yet
begun in BiH.
 Conformity assessment. There is a wide range of laboratories and conformity
assessment bodies of various specialisations that are capable of testing construction
products and issuing certifications on products and factories. Most laboratories are
capable to perform tests only according to the standards of the former Yugoslavia, but
some of theme are embedded into international networks and are able to issue
conformity assessment documents according to CPD. A wide range of existing conformity
assessment bodies plan to become a Notified Body, as soon as this will be legally
possible. Construction product manufacturing companies frequently rely on conformity
assessment bodies of the successor states of the former Yugoslavia, partly due to
surviving traditions and partly due to existing strong trade and ownership relations.
 Inspection activities are delegated to entity, cantonal and local level, which results in a
fragmented and uneven set of requirements, rules and enforcement practices. A Market
Surveillance organisation satisfying the requirements of New Approach technical
legislation has been established, is in the process of being developed, has co-ordinative
functions, but does not yet possess inspection rights.
The stakeholder analysis of this RIA has revealed that BiH has a relatively well developed
construction product manufacturing industry. There is a wide range of construction products
manufactured in BiH and exported, but the volume of construction product imports exceeds
the volume of exports. For the above reasons, CPD is a very relevant EU directive for the
country. The construction products manufacturing industry is very much segmented in terms
of firm size: besides a few large companies there is a wide range of small and medium sized
firms. Company procedures aimed to ensure the quality and conformity of construction
products correspond to the general level of development of the country. Authorities
responsible for the enactment and enforcement of CPD must take into consideration that the
adaptation of smaller companies to CE marking is more difficult than in case of their bigger
counterparts.
44
The competitiveness assessment section of this RIA is based on consultation and on the
application of lessons learnt on CPD in other countries. The research has revealed that
typical companies of the BiH construction product manufacturing sector are aware of the
expected regulatory changes. The adaptation process has begun in many companies,
especially in case of bigger, foreign owned and already exporting firms. These are the
expected winners of the changes which welcome or sometimes even urge the
Europeanization of the conformity assessment system. On the other hand, smaller firms and
firms selling only on the local market are more cautious, sometimes sceptical.
The cost and benefit analysis section of this RIA has revealed that the costs if introducing
CPD to BiH are rather limited both on macro-economic and on micro-economic level.
However, even if the adaptation costs for BiH companies will be somewhat higher than for
their counterparts in the European Union, these costs are worthwhile to pay, not only
because of the high export dependency of BiH construction product manufacturing
companies, but also due to political, trade, health, safety and environmental benefits of
integration into the European Union.
Construction Product Directive: a qualitative summary of expected benefits and costs
Possible costs Expected benefits

For manufacturers: For manufacturers:
 Additional testing where there were no  Direct cost savings due to less certification
mandatory requirements before costs, due to fewer inspections, audit tests,
 More demanding tests defined in EU simpler range of tests, fewer product
harmonised standards and in ETAs than in variants.
previously used technical specifications
 Need for product development where For designers, contractors and controllers:
product conformity to CPD requirements  Benefits through the economies of
insufficient standardisation
 New barriers to trade where there were no
mandatory requirements before For users/buyers of construction products:
 Training and learning costs where know  Health, safety and environment benefits
how of CE marking insufficient through more reliable testing and control and
 Need for new laboratory equipment where introduction of testing and certification where
existing lab infrastructure insufficient none existed.
 More competition due to fee trade, more
choice, shift of production to more efficient
producers.
45
8. RECOMMENDATIONS
It is recommended that BiH should introduce the Directive gradually.
 In the first phase BiH authorities should give the presumption of conformity to products
which bear the CE mark legitimately, but compliance with the essential requirements and
conformity assessment modules of CPD should not be made mandatory for all
construction products put on the market of the country, as long as they satisfy the
requirements of national regulations.
 Following a certain transition period, conformity with the provisions of CPD should be
made mandatory for all construction products sold in BiH.
Co-ordination. During the gradual introduction of CPD to BiH, regulations and institution
development must be fine tuned in order to maximise the benefits and to minimise the
adverse effects of the Directive. In particular, a uniform and well co-ordinated conformity
assessment organisation should be developed across entities and cantons, with full
inspection rights of construction products.
Information and training campaign. During the transition period an intensive information and
training campaign should be implemented in order to prepare construction product
manufacturing companies and construction companies for the new conformity assessment
system. Information provision should be co-ordinated between the Government organisations
of the state and of the entities (inspectorates / market surveillance / standardisation bodies),
involving state and entity level chambers of commerces and conformity assessment bodies.
SME development. Legal harmonization activity should be co-ordinated with small business
development measures. The Government may consider to give longer transition periods and
special grants to small and medium sized companies in order to facilitate their adaptation to
the new procedures.
Investment promotion. Legal harmonization activity should also be co-ordinated with

investment promotion measures. The responsible Government agencies and chambers in
their negotiations with potential investors should stress the advantages and duties arising
from the fact that BiH is in the process of introducing the New Approach directives of the EU.
Conformity assessment bodies. In principle the development of the existing laboratories,

conformity assessment bodies in terms of infrastructure and knowledge base is the
responsibility of their owners, whether public or private, local or foreign. However, it is
recommended that certain available national and European resources of development policy
should be channelled to facilitate the upgrading of laboratories, conformity assessment
bodies with a view of some of them becoming Notified Bodies.
Monitoring, consultation and statistics. The Government should periodically monitor the
impacts of CPD on the construction product industry and on the construction industry. This
can be done by preparing short and cheap ex-post RIAs, evaluations or monitoring reports.
Moreover, for monitoring purposes the existing forums of consultation should be used,
including the dialogue with chambers and the organisation of special events such as Round
Table meetings. The statistical system should be developed and enabled to collect data on
product related risks such as accidents. The monitoring reports should be disseminated and
their findings used for institutional development.
46
9. APPENDICES
9.1. Appendix 1: Round Table Meeting on RIA of the Construction Products Directive
9.1.1. Invitation to and programme of Round Table Meeting
To….
As a part of the preparations for the EU accession, Bosnia and Herzegovina has launched a
comprehensive transposition of EU technical regulations into BiH regulation.
The Construction Products Directive is one of the directives, which is currently in the pipeline
for implementation. As a part of this process, the EU-funded Safety Infrastructure Project has
developed a so-called Regulatory Impact Analysis, which puts light on the legal and
economic impacts caused by the new regulation both on the construction products
companies; the conformity assessment bodies and the authorities engaged in this field.
Before the analysis is presented for public discussion, we would like to invite a number of
private and public stakeholders - which will directly be affected by the new legislation - to a
"round table meeting” at which the analysis will be presented and discussed.
The meeting will take place on the 8th of December from 12:30-15:30 at
Hotel Europe, Vladislava Skarića 5, in Sarajevo
The meeting will proceed as follows:
12.30-13.30 Lunch in the restaurant

13.30-13.50 Overview of the Construction Products Directive – what are the main
changes? (Mr Carsten Kudahl, Safety Infrastructure Project)
13.50-14.10 Presentation of the Regulatory Impact Analysis for the Construction Product
Directive (Dr. Peter Futo, Safety Infrastructure Project)
14.10-14.25 Overview of the future conformity procedures for construction products (Mr
Matko Raić, IGH Institute, Mostar.)
14.25-15.25 Discussion of the consequences and potential interventions to mitigate
negative impact (all)
15.25-15.30 Conclusions (Dr. Peter Futo, Safety Infrastructure Project)
We look forward to a constructive and interesting meeting. Please confirm your participation
to our Office Manager Ms Selma Hadziahmetovic on telephone 033 236 173 or e-mail:
shadziahmetovic@eusip.ba not later than 29 November 2010.
Yours sincerly
Carsten Kudahl
Team Leader of EUSIP Project
47
9.1.2. List of participants at Round Table

List of Invited Participants – RIA Round Table Meeting (Construction Products
Directive)
8 December 2010 at 12:30-15:30 at Hotel Europe, Sarajevo
th
No Company Name and surname Settlement

1. Fabrika Cementa Lukavac Sead Ćatić Lukavac
2. Grupex d.d. Šefik Mustedanagic Velika Kladuša
3. HERING d.d. Mersiha Kupus Široki Brijeg
4. Tvornica Cementa Kakanj, d.d. Nurdin Salihbegović Kakanj
5. Tvornica Opeke Sarajevo Delic Almir Sarajevo
6. Institut za Građevinarstvo "IG" d.o.o. Đorđe Lajšić Banja Luka
7. Institut za Građevinarstvo "IG" d.o.o. Slobodan Stanarević Banja Luka
8. Institut za Građevinarstvo "IG" d.o.o. Duško Hinć Banja Luka
9. IGH Mostar d.o.o. Laboratory Mato Raić (speaker) Mostar
Department for RIA in the Ministry for
10. Economic Relation and Regional Banja Luka
Cooperation of RS Gordana Opačić-Zečević
11. Market Surveillance Agency of BiH Edin Čerimagić Sarajevo
Ministry of Transport and
12. Snežana Hadžić Sarajevo
Communications
13. MoFTER Radenko Čvoro Sarajevo
14. MoFTER Antun Larma Sarajevo
15. EU Trade Policy Project Carmen Fratita Sarajevo
16. EU Trade Policy Project Ulrich Schroeder Sarajevo
17. EUSIP Peter Futo Sarajevo
18 EUSIP Carsten Kudahl Sarajevo
19. EUSIP Anida Pašić Sarajevo
20. EU support to DEI TA project Darius Žeruolis Sarajevo
48
9.1.3. Comments and recommendations of Round Table participants

The consultation was organised around the following questions:
 What do you think: is your company ready for the introduction of CPD?
 What kind of benefits do you expect from the introduction of CPD?
 What is your expectation: what kind of costs will your company pay in order to satisfy the
requirements of the introduction of CPD ?
 What do you recommend: in what way should CPD be introduced? Is it a good idea that
CE marking shall be mandatory for all construction products sold in BiH?
 What kind of help do you expect from the authorities?
 Fom which organisation do you expect information regarding the EU Construction
Products Directive, CE marking, conformity assessment, product certifiation, and
harmonised European standards?
 Should the Government introduce CPD as soon as possible or on the contrary: the
Government should delay the introduction of the Directive. Why?
The consultation has confirmed the main findings and recommendations of the RIA.
Urgency. It was predominantly the representatives of bigger companies which have stressed
the need of urgently introducing CPD in BiH law. However, the average participants of the
consultation have supported the recommendation that the Directive should be introduced
gradually, with a reasonably long transition period, during which an intensive awareness
raising and training campaign should be implemented in order to facilitate the adaptation
process of the affected companies.
Costs and benefits. Bigger companies expect trade benefits and better product quality from
the legal changes, and some participants have even mentioned that in some cases
conformity assessment costs can be reduced by applying EU standards instead of old
Yugoslav standards (JUS). On the other hand, there were serious concerns raised that
adaptation costs for smaller companies would be high.
Supporting small firms. A series of recommendations has raised the issue of how small
companies will adapt to the new obligations. Small companies of the construction products
industry frequently manufacture a wide portfolio of product types. However, since more
product types lead to proportionally more attestation costs, many of these companies can
survive only if they specialize in order to have a more homogeneous product portfolio. This
type of adaptation should be supported by financial subsidies.
Conformity assessment. Representatives of companies have raised the problem is that

certification bodies in BiH can issue conformity assessment documents only if they co-
operate with a foreign based notified body recognised by the EU.
Market surveillance. Representatives of companies have raised the problem that there are
some construction products manufacturing companies in BiH which avoid attestation of their
products. For this reason they have urged the authorities to intensify inspection activities of
market surveillance.
Awareness raising. Participants of the consultation have agreed that the new laws and
standards should be widely advertised. Employees of companies should be trained about the
legal changes. This is the only way to replace the application of JUS standards with
harmonised EU standards.
49
An example as to how CPD can lead to cost reduction. There are construction product
companies in BiH which for conformity assessment parallel use JUS standards (for BiH
market) and harmonised European standards (when exporting to European markets). These
companies are capable to assess the difference between the two systems in terms of costs
and benefits. A representative of a cement company has recalled that in 2009 for testing two
cement products according to JUS standards, they had paid 50.000 KM , whereas for testing
for four products according to new EU standards had cost 60.000 KM. Another difference is
that according to JUS they must test 20 samples but by applying EU norms only 8 samples
must be tested. This illustrates the thesis that conformity assessment may be even cheaper
under CPD than under existing regulations. This factory is producing cement according to
EU standards science 2006. They even translated the respective standards on their own
cost. So they want the CPD Directive to be introduced as soon as possible in order to reduce
their costs.
9.2. Appendix 2: Methodological note on expected and observed impacts
The impact statements made by this RIA are based on two types of sources.
 Expected. On the one hand, interviews survey responses have revealed the expectations
of stakeholders in Bosnia-Herzegovina about future impacts of the regulatory changes.
These are impacts that have not been observed, because they have not yet been
materialised. However, the collection of such expectations is a necessary ingredient of
the consultation process.
 Observed. On the other hand, there is a wide body of observed impacts of CPD that have
already been materialised. Most of these impacts are changes in the competitiveness of
certain types of companies, supported by cost calculations. Most of these observations
are based on consultations and cost calculations made in other countries where CPD has
been either fully or partially introduced.
Applicability of impact observations made abroad. It is to be expected that the basic attitudes
of regulatory agencies, conformity assessment bodies and companies as observed in the EU
and in particular in the UK will also appear in Bosnia-Herzegovina. While the analogy
between EU companies and BiH companies regarding the impacts of introducing CE marking
is apparent but it should be applied carefully.
 Arguments justifying the analogy. On the one hand, the analogy is justified due to the
fact that in BiH most of the major construction product manufacturing companies have
been integrated into multinational firms, which has resulted in the introduction of standard
international company procedures, including the procedure aimed at ensuring quality and
conformity.
 Arguments against analogy. On the other hand, a major difference is that construction
products industry of BiH is more dependent on exports. However, the major differences
between the two systems will not be on the compliance side, rather on the enforcement
side: market surveillance and conformity assessment bodies in BiH will have to go a
much longer way to implement European best practices than their counterparts in the EU.
Therefore in BiH the transition from old Yugoslav-type standards and existing conformity
assessment procedures to CE marking may affect the industry in a somewhat different
manner, causing possibly more administrative burdens for firms, as compared with the
transition from the national conformity assessment systems of Western European
countries to CE marking.
50
9.3. Appendix 3: References
BIH FIPA 2002 Bosnia - Herzegovina Construction Industry Profile Report. Published by:
Foreign Investment Promotion Agency of Bosnia and Herzegovina, Sarajevo, 2002
[CPD Impact EU 2000] Effects of Regulation and Technical Harmonisation on the Intra-
Community Trade in Construction Products, Final Report, WS Atkins International. (2000)
URL:
http://ec.europa.eu/enterprise/sectors/construction/files/internal/atkins/final_en.pdf
[CPD Impact Sweden 2001] Impact and Importance of European Harmonisation governed by
the Construction Products Directive (CPD) and the Public Procurement Directive (PPD),
SNRA (2001)
URL: http://www.vv.se/PageFiles/21728/engelska.pdf?epslanguage=sv
[CPD Impact UK 2008] The European Commission’s proposed Construction Products
Regulation, Impact Assessment, Department for Communities and Local Government
(2008)
URL:
http://www.communities.gov.uk/documents/planningandbuilding/pdf/iaconstructio
nproducts.pdf
[CPD Review UK 2008] Review of the operation and impact of the Construction Products
Directive in the UK through the Construction Products Regulations. BD 2696. Department
for Communities and Local Government. London, August 2008.
URL:
http://communities.gov.uk/documents/planningandbuilding/pdf/reviewconstruction
products.pdf
[CPD RIA EU 2006 Annex] ANNEXES TO REPORT: “Study to evaluate the Internal Market
and competitiveness effects of Council Directive 89/106/EEC (Construction Products
Directive, CPD)” Final Report. PRC B.V. Division Bouwcentrum International Bodegraven,
Netherlands, 28 November 2006
[CPD RIA EU 2007] Study to Evaluate the Internal Market and Competitiveness Effects of
Council Directive 89/106/EEC (Construction Products Directive, CPD) Final Report. PRC
B.V. Division Bouwcentrum International, Bodegraven, Netherlands, 15 February 2007.
URL: http://ec.europa.eu/enterprise/dg/files/evaluation/summary_15022007_en.pdf
[Croatia LVD RIA 2001] Regulatory Impact Analysis of the Introduction of the Low Voltage
Directive (73/23/EEC) into the Croatian Law. A Case Study of the Harmonisation of EU
Technical Legislation. Pilot Study. Zagreb - Budapest, May 2001
[EC Guidance Paper D 2004] Guidance Paper D (Concerning The Construction Products
Directive - 89/106/Ec) Ce Marking Under The Construction Products Directive (2004)
URL: http://eurocodes.jrc.ec.europa.eu/doc/gpd.pdf
[EC Guidance Paper J 2002] Transitional Arrangements under the Construction Products
Directive (Revision Sep 2002) Guidance Paper J (concerning the Construction Products
Directive – 89/106/EEC). European Commission Enterprise Directorate-General,
September 2002.
[EC Guidance Paper K 2004] The Attestation of Conformity Systems and the Role and Tasks
of The Notified Bodies in the Field of the Construction Products Directive. Guidance
Paper K (Concerning the Construction Products Directive 89/106/Eec). European
Commission, Enterprise and Industry Directorate-General. Single Market : Regulatory
Environment, Standardisation And New Approach. Construction. December 2004.
[EC Guidance Paper L] Guidance Paper L (Concerning The Construction Products Directive -
89/106/Eec) Application And Use Of Eurocodes (2003)
URL: http://www.stalforbund.com/Eurokoder/ApplicationAndUseOfEurocodes.pdf
51
[EC Guidance Paper M 2005] Guidance Paper M Concerning Council Directive - 89/106/EEC
(CPD)) Conformity Assessment Under the CPD: Initial Type-Testing And Factory
Production Control (2005)
URL: http://ec.europa.eu/enterprise/sectors/construction/files/guidance-papers/gp-
m_en.pdf
[FBIH Industrial Policy 2009] Razvoj industrijske politike u FbiH. Mašinski fakultet
Univerziteta u Sarajevu , Fakultet strojarsva i računarstva Sveučilišta u Mostaru. Mostar,
2009.
[Georgia LVD EMC Lift RIA 2010] Impacts of introducing New Approach technical regulations
in Georgia to the product markets of electric appliances and lifts. Georgian-European
Policy and Legal Advice Centre (GEPLAC), Tbilisi, April 2010.
[GNB-CPD AG position paper 2006] Shared and cascading ITT . Guidance from the Group of
Notified Bodies for the Construction Products Directive 89/106/EEC. Issued: 14
September 2006.
[Lithuania LVD RIA 200] Regulatory Impact Analysis of the Introduction of the Low Voltage
Directive into Lithuanian Law. The Impacts of a "Free Movement of Goods" Directive.
Pilot Study Vilnius, May 2000.
[Ukraine LVD RIA 2008] Regulatory impact analysis of the introduction of the EC Low Voltage
directive into Ukrainian legislation. Ukrainian-European Policy and Legal Advice Centre
(UEPLAC), Kyiv, 10 April 2008.
Performance Based Building and the Construction Products Directive, Supporting document,
Final Report, PEBBU (2005)
URL: http://www.pebbu.nl/resources/allreports/downloads/22_CPD_finalreport.pdf
Proposal for a Regulation of the European Parliament and of the Council Laying Down
Harmonised Conditions for the Marketing of the Construction Products (2008)
URL: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?
uri=COM:2008:0311:FIN:EN:PDF
52
9.4. Appendix 4: List of interviewed persons

Name of company or institution Name of person Rank
Tvornica opeke Sarajevo d.o.o Mr. Delić Almir Head of Production and Quality
Laboratorija Instituta GIT d.o.o Tuzla Mr. Ahmet Imamovic Director of Institute
XELLA d.o.o., Tuzla Mr. Catovic Ademir and Mr. Nihad Begic Head of Product Development / Engineer
Market Surveillance Agency of BiH Mr. Edin Cerimagic Expert Advisor for Construction Products
Tondach Construction Material Trading Dr. Jasmin Hošo Director
Company d.o.o. mSarajevo
Agency for Standardisation of BiH (BAS), Ms Slavica Budimir and Ms Stana Buha , Coordinator of Institute / Standardisation
Sarajevo Expert
Integral Inzenjering d.o.o., Banja Luka Dr. Đorđe Lajšić and Mr. Slobodan Director / Chief Engineer
Stanarevic
Chamber of Commerce Republika Srpska, Ms. Dragica Ristic Director
Banja Luka
Ministry of Energy, Mining and Industry of Ms Eldara Sose and Mr Marinko Bosniak Senior Advisor / Assistant Minister
the FBiH, Mostar
Foreign Trade Chamber of BiH, Sarajevo Mr. Senad Hromic Head of EICC BiH
Market Inspection of Kanton Sarajevo Ms. Razija Huduz Chief Building Inspector
Statistical Agency of BiH, Sarajevo Mr Edin Sabanovic and Ms Ivona Bulic Head / Expert of Statistical Methodology
Department
53
9.5. Appendix 5: Relevant regulations in FBiH
9.5.1. Law
“Law on Construction Products”43
9.5.2. Regulations
Regulation about the duties of construction enterprises 44
9.5.3. Rulebooks
 Rule book on construction products certification, material and equipment used or built in
(“Official gazette of the Federation of B&H” No. 81/07)45
 Rule book on the procedure of an enclosed construction site or building enclosing and
marking (“Official gazette of the Federation of B&H” No. 83/07) 46
 Rulebook on technical inspection of the building ("Official gazette of FB&H No. 21/06,
23/08)47
 Rulebook on technical characteristics of concrete built in concrete constructions ("Official
gazette of FB&H No. 38/08)48
 Rulebook on technical conditions for chimneys in buildings (“Official Gazette of the
Federation of Bosnia and Herzegovina, No. 49/08”) 49
 Rulebook on technical provisions on steel and steel products to be embedded in steel
construction (“Official Gazette of the Federation of Bosnia and Herzegovina, No. 69/08”)
50
 Book of Rules on technical provisions related to construction products to be built in

concrete constructions (“Official Gazette of the Federation of Bosnia and Herzegovina,
No. 86/08”) 51
 Book of Rules on technical provisions related to construction products to be built in
masonry constructions (“Official Gazette of the Federation of Bosnia and Herzegovina,
No. 86/08”) 52
43
http://www.fbihvlada.gov.ba/bosanski/zakoni/2009/zakoni/45bos.htm
44
http://www.fmpu.gov.ba/content/view/160/145/lang,hr/
45
46
http://www.fmpu.gov.ba/pravilnici/pravilnik_oznacavanje_gradilista.pdf
47
http://www.fmpu.gov.ba/pravilnici/pravilnik_teh_pregled.pdf AND
http://www.fmpu.gov.ba/pravilnici/pravilnik_teh_pregled_izmjene.pdf
48
http://www.fmpu.gov.ba/pravilnici/pravilnik_cement.pdf
49
http://www.fmpu.gov.ba/pravilnici/pravilnik_dimnjaci.pdf
50
51
52
54
9.5.4. Decrees
 Decree on Building Structures and Interventions Important for the Federation of Bosnia
and Herzegovina and on Building Structures, Actions and Interventions that May Largely
Affect Environment, Life and Health of People in the Federation of Bosnia and
Herzegovina, for which the urban development approval is issued by the Federal Ministry
of Physical Planning ("Official Gazette of F B&H", No. 85/07 and 29/08)53 , 54
 Decree on technical features that built facilities must comply with in terms of their safety
and manner of usage and maintenance thereof ("Official Gazette of F B&H", No. 29/07)55
 Decree on development of building site, compulsory documentation at building sites and
participants/parties in building ("Official Gazette of F B&H", No. 48/09)56
 Decree on standards, criteria and manner of construction of the shelters and technical
norms for control of appropriateness thereof ("Official Gazette of F B&H", No. 21/05 and
59/07)57
 Decree on technical features that built facilities must comply with in terms of their safety
and manner of usage and maintenance thereof ("Official Gazette of F B&H", No. 29/07)
53
http://www.fbihvlada.gov.ba/bosanski/zakoni/2007/uredbe/43.htm
54
http://www.fmpu.gov.ba/uredbe/uredba_gradjevine_izmjene.pdf
55
56
57
http://www.fbihvlada.gov.ba/bosanski/zakoni/2005/uredbe/7bos.htm
AND
55
9.6. Appendix 6: A selection of construction material companies in FBiH
Company name Address

Cement production
D.D. Tvornica cementa – Kakanj Selima ef. Merdanovića 146
D.D. Fabrika cementa Lukavac Macan Marije bb, Lukavac
Brick production
"IGM" d.o.o.Visoko Donje Moštre, Visoko
25 MAJ TOP Cazin Ćoralići bb, 77220 Cazin
TERMO ZIEGEL Nigma d.d.Busovača Nikola Šubić Zrinski bb, 77260 Busovača
IGM Ciglana Grahovo d.o.o. Bosansko Grahovo Novotravnička bb, 80 270, Bosansko Grahovo
Tvornica opeke d.o.o.Sarajevo Rakovička cesta 194, 71000 Sarajevo
Splonum d.d. Sanski Most Muse Ćazima Ćatića bb, 79 260 Sanski Most
Stone and granite production

A.G. Kamen d.o.o.Široki Brijeg Visoka Glavica bb, 88220 Široki Brijeg
Ivankovića Dolac bb, 88260 Kočerin, Široki
Dubint d.d. Široki Brijeg
Brijeg
Granitmont d.d.Jablanica Betonsko naselje bb, 88420 Jablanica
Kamen d.o.o.Bihać Ivana Frane Jukića 19, 77000 Bihać
Non-ferrous construction materials production

Bitumenka d..o.o.Sarajevo Aleja Bosne Srebrene 2, Sarajevo
Stiropor d.o.o.Široki Brijeg Put za Mostar bb, 88220 Široki Brijeg
Siporex d.o.o.Tuzla Mihajla Popovića 3, 75 000 Tuzla
EPS Laštro Resnik bb, 71 260 Kreševo
Cinkarna-kvarc d.o.o.Tuzla 21.decembar bb, Tuzla
Miličević d.o.o.Kreševo Resnik bb, 71 260 Kreševo
Barit d.d. Kreševo Resnik bb, 71 260 Kreševo
Gypsum and lime production

Komar-Tvornica gipsa d.d. Donji Vakuf 770 SBBR bb, Donji Vakuf
Ingram d.d. Srebrenik Industrijska bb, 75 350 Srebrenik
56
9.7. Appendix 7: Cover letter of company survey on CPD
To the companies of the Construction Product Sector and Construction Sector of Bosnia and
Herzegovina
Company questionnaire on the impacts of the Construction Products Directive in BiH
Impact of CE marking on competition and competitiveness in the construction materials

industry and in the construction industry
Dear Sir /Madame
My name is Dr. Peter Futo and work as an expert for the EUSIP Project "Safety and quality of
infrastructure project in Bosnia and Herzegovina" , which was launched 11/03/2009. and
funded by the European Union. The overall objective of the project is further development of
quality infrastructure and product safety in BiH, including regulation, conformity assessment ,
market surveillance and standardisation. The project will contribute to creating an
environment that enable industries and manufacturers in BiH to improve their trade and
industrial relations with the EU.
Our project has a component of Regulatory Impact Assessment. We want to understand how
the introduction of the Construction Product Directive to BiH, the introduction of CE marking
and EU standards will affect the quality and safety of construction products, how the
competition and competitiveness on these markets will react to this change of regulatory
environment. Our beneficiaries are MOFTER and Agency for Market surveillance .
In the attachment you will find a questionnaire. We need your responses in order to
recommend a business-friendly way of introducing this Directive to BiH. Your responses will
be an important inputs for developing the respective regulation, conformity assessment,
market surveillance and standardisation.
The responses to this Questionnaire will be used only for the above mentioned research
purposes. Survey administrators shall keep completely confidential the names of
respondents and their companies. Every respondent will receive the full text of the results of
the survey. Every respondent will be invited to the Round Table which will be organised about
the introduction of the Construction Products Directive to BiH law.
Please send the completed questionnaire to the following address: Dr. Peter Futo , EUSIP
Project, Obala Bega Isakovic Isa-6, 71000 Sarajevo, or by e-mail address: futo@mixolid.hu,
until 24/08/2010. If you want to forward the form electronically, you can send us mail at the
above address.
Thank you very much in advance.
Sincerely,
Dr. Peter Futo

Specialist on Regulatory Impact Assessment
EUSIP Project Obala Bega Isakovic Isa-6, 71000 Sarajevo
Tel: 033 236 173
Email: EUSIP.Project@gmail.com
Sarajevo 27.07.2010
57
9.8. Appendix 8: Questionnaire of company survey on CPD
Company questionnaire on the impacts of the Construction Products Directive in BiH
Impact of CE marking on competition and competitiveness

in the construction materials industry and in the construction industry
The responses to this Questionnaire will be used only for research purposes. Every
respondent will receive the full text of the results of the survey. Every respondent will be
invited to the Round Table which will be organised about the introduction of the Construction
Products Directive to BiH law.
Company name:………. Name of parent company or group of companies or holding:……..

Size of company: approximate number of employees:……….
Approximate turnover of company in million KM:………
Name of person responsible for product certification and quality issues in the company:……
Phone: …………. E mail:……………..
Profile of CONSTRUCTION MATERIALS production, import and sales companies

Does your company produce (manufacture) construction materials in Bosnia-
Herzegovina? ………….If yes, please state the turnover in million KM……………..
Does your company import construction materials to Bosnia-Herzegovina?
………….If yes, please state the turnover in million KM………….
Does your company sell (retail) construction materials in Bosnia-
Herzegovina?................. If yes, please state the turnover in million
KM…………………
Please select the type of construction materials you have from the list below:
AGGREGATES (e.g. road stone, crushed rock, sand, gravel)
CEMENT AND CONCRETE (e.g. gypsum plasterboard, pre-cast concrete products
such as blocks, concrete reinforcing bars)
CLAY PRODUCTS (e.g. bricks and ceramic products)
TIMBER AND JOINERY (wood products, wooden doors, windows)
METAL PRODUCTS (e.g. structural steel, metal doors and metal windows, screws,
central heating boilers, pumps, taps, valves)
PLASTIC PRODUCTS (e.g. rigid and flexible pipes and fittings, plastic doors &
windows)
OTHER BUILDING MATERIALS (e.g. asphalt products, thermal or acoustic insulating
materials paints, lighting equipment, electric water heaters, kitchen furniture, etc.)
Please name the product type (or the group construction product types) which is most
important in your company.
58
Profile of CONSTRUCTION (BUILDING) companies
Please select the type of construction (building) service carried out by your company
from the list below:
Construction of buildings
Civil engineering (construction of roads and railways , bridges and tunnels , water
projects, sewage plants, electricity and telecommunications)
Demolition and site preparation
Electrical, plumbing and other construction installation activities
Building completion and finishing (e.g. plastering, floor and wall covering, painting,
roofing)
Planning, design and consultancy in the field of construction industry
Other, such as
Please name the construction (building) activity (or the group of construction activities) which
is most important in your company.
Company markets
Do you sell your products / services only in Bosnia-Herzegovina?..................
Do you sell your products / services to other Balkan countries? …………..If yes which
countries?................
Do you sell your products / services to other EU countries? …………..If yes, to which
countries?...........
Are there reasons why you do not sell your products / services to any other EU countries?
………..If yes, what are these reasons?............
Did you have problems with export and import (regarding certificates)? …………If yes,
what?..........
Questions on CE mark, standards, quality, product safety
How many different product types do you work with which need certification?................
Are your products CE marked? ………..If yes, since when are your products CE
marked?............... If not, what do you think, when will your company begin the CE marking of
its products?.......................
Do you have products which do not need CE marking? …………If yes, what are these
products and why not?
What certification or quality marks do you use, other than the CE mark?.................
Which standards do you use for your products?..................
Do you work with an external laboratory? …………If yes, which one?

…………………………… Please characterise the range of services and the costs spent on
external laboratory services.
59
Does your company have its own internal laboratory for construction products?....................
How many laboratory technicians work in your test laboratory? ……………Please
characterise the range of services and the costs spent on internal laboratory services.
How many employees work in the quality management of your company?.............. Does your
company co-operate with some technical consultancy on quality and product safety issues?
(e.g. a notified body or a quality management firm) …………..If yes which one?
…………………………. Does your company have any ISO 9001 qualification/certification?
……… …………..
What specific problem do you encounter in the certification of products?
Impacts of CE marking on the level of the company
As a result of CE marking do you expect that your company will:

….Make technical changes to your products?
….Introduce more product types?
….Stop the production/sale/marketing of some existing products.
….Improve or change your quality management or your production control
system?
….Be in a better position to export?
….Be in a better position to get better prices on your products.
….Be in a better position to reduce marketing cost?
….Have more competitors on your markets?
….Have less competitors on your markets?
….Be in a better position to select subcontractors?
….Be in a better position to co-operate with other companies as a
subcontractor?
….Be in a better position of complying with product safety/product conformity
regulations?
….Be in a worse position of complying with product safety/product conformity
regulations?
….Be in a better position to co-operate with foreign investors
Have there been any changes to your company procedures, quality policies or marketing
strategies as a result of new harmonised European standards and CE marking?
Do you expect such changes in your company? (e.g. hiring of new people, training of
personnel, involvement of external laboratories or quality attestation firms, etc.). ………If yes,
what?
Do you have experiences with initial type testing for your products? ……….What do you
estimate what was (or what will be) the cost of initial type testing for your products? Please
explain, why.
Did (or will) your company purchase new equipment in order to improve quality and product
safety? (E.g instrument for measurement etc..) ………What was (or what will be) the
cost?........ What was the immediate reason of spending on this investment
60
Do you expect any savings as a result of CE marking ?........ If yes, what and why?
Do you expect any increase of cost in transition period or later due to changes to products or
production and management processes as a result of CE marking ?........ If yes, what and
why?
Did you encounter (or do you expect) any benefits as a result of CE marking? (e.g ability to
export, ability to become subcontractor, competitiveness, transparency and compatibility of
company procedures etc.). Please explain in text.
Impacts of CE marking for the whole construction materials / construction sector in

BiH
And now let us speak about the whole construction materials / construction sector of Bosnia-
Herzegovina. In the construction materials / construction sector of Bosnia-Herzegovina, will
harmonised European standards and the introduction of CE marking….
Impact Why? Please answer in text.
….Increase or reduce competition?
….Encourage or discourage foreign
investors to invest in these sectors of BiH
….Bring any particular effect on small
companies or handicraft firms?
Awareness on regulations and standards, expectations from various organisations
Are you sufficiently informed about….

….the present BiH regulations on the safety of construction products?
….the EU Directive on Construction Products?
….the use of CE mark in the field of construction products?
…. harmonised European standards in the field of construction products
…. European Technical Approvals in the field of construction products?
…..Eurocodes (standards of construction design)
Regarding the above issues, where did you find information? What type of help did you get
from the Government, from Market Surveillance, from the Chamber of Commerce or from
other organisations regarding information and training?
Regarding the above issues, where would you try to find information? What type of help do
you expect from the Government, from Market Surveillance, from the Chamber of Commerce
or from other organisations regarding information and training?
Do you expect some barriers or obstacles to the introduction of the EU Construction

Products Directive, CE marking and harmonised European standards to BiH? ........ If yes,
what and why?
61
Summary questions
To what extent do you agree with the following statements?
Statement Ag-ree I have no Dis-
opinion, agree
do not
know
The sooner these technical regulations are introduced, the
better. We should not lose more time. The Government should
introduce the EU Construction Products Directive, CE marking
and harmonised European standards as soon as possible to
BiH.
Companies need more time to prepare. The construction /
construction materials industry of BiH is not yet ready to
comply with the European regulations on the safety of
construction products. The Government should delay the
introduction of the EU Construction Products Directive, CE
marking and harmonised European standards to BiH.
The Government needs more time to prepare. Market
Surveillance and conformity assessment in BiH is not yet
ready to enforce the European regulations on the safety of
construction products. The Government should delay the
introduction of the EU Construction Products Directive, CE
marking and harmonised European standards to BiH.
Please explain why you have agreed/disagreed with the above statements.
Thank you for your co-operation!
62
9.9. Appendix 9: Abbreviations
BiH Bosnia and Herzegovina

CEN European Committee for Standardization
CENELEC European Committee for Electrotechnical Standardization
CID Cableway Installations for Passengers Directive, 2000/09/EC
CPD Construction Products Directive, 89/106/EEC
D.O. Dionicko Drustvo (Limited partnership)
D.O.O. Društvo s Ograničenom Odgovornošću (LLC, Limited Liability Company)
DG Directorate General
EEC European Economic Community
EOTA European Technical Approval
ETA European Organization for Technical Approval
EU European Union
FBiH Federation of Bosnia and Herzegovina
FPC Factory Production Control
GPSD General Product Safety Directive
ITT Initial Type Testing
MID Measuring Instruments Directive, 2004/22/EC
MOFTER Ministry of Foreign Trade and Economic Relations
MS Member State
NB Notified Body
OECD Organisation for Economic Co-operation and Development
RIA Regulatory Impact Assessment
RS Republika Srpska
SAA Stabilization and Association Agreement
UK United Kingdom
URL Uniform Resource Locator (Internet address)
63

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SAFETY INFRASTRUCTURE IN BOSNIA AND HERZEGOVINA

Safety Infrastructure Project

Impacts of introducing the

Regulatory Impact Assessment

in association with AENOR, B

Bosnia and Herzegovina

Impacts of introducing the

Regulatory Impact Assessment

Council Directive 89/106/EEC of 21 December 1988 on the approximation of laws, regulations

Prepared by Dr. Peter Futo, Short Term Expert

EUSIP Project, Sarajevo, Bosnia-Herzegovina

8.8. Appendix 8: Questionnaire of company survey on CPD.................................................57

1.1. Policy objectives

ARTICLE 75 of the Stabilization and Association Agreement

The implementation of CPD in Bosnia-Herzegovina must ensure two major aims:

1.2. Policy alternatives

2.1. Regulatory issues

Product scope. The Directive covers products incorporated permanently in construction

Country-specific implementation. Each EU Member States has implemented CPD2, but in

Legal harmonization activities. According to Article 5 of “Decision on Activity Plan for

2.2. Standards and European Technical Approvals

 European Technical Approvals. The product also may be manufactured in compliance

In BiH the work of Europeanisation of standardisation in the construction product sector is

For construction products of Bosnia-Herzegovina which are to be exported to the EU,

3.1. Conformity assessment, notified bodies and laboratories

A selection of NBs authorized for CPD in Central and Southern Europe:8

An example for a Notified Body in EU is a Hungarian organisation: “ÉMI Non-Profit LLC”.9

Systems of Attestation of Conformity.10 For construction products, the involvement of Notified

 Institute for Materials and Structures of Engineering Faculty. 15 The Institute is

 IG Civil Engineering Institute.18 The Institute provides comprehensive technical

 Kemal Kapetanović. The Testing laboratory Metalurški institut “Kemal Kapetanovi in

 IGH-MOSTAR d.o.o. is an organizational unit within the Croatian Civil Engineering

 Technical Faculty in Bihac University – Laboratory for testing of construction

3.2. Market surveillance

In every MS of the EU market surveillance authorities control whether product and

In Latvia21 the general supervision and coordination of construction in Latvia is competence

4. STAKEHOLDERS AND MARKETS AFFECTED

4.1. Overall relevance of CPD in BiH

Production. In BiH the yearly volume of construction products manufacturing amounts to

Investment. Due to high investments and modernization needs, it is necessary to find

Production of selected construction products, Bosnia-Herzegovina 2008

Foreign trade of selected construction materials in BiH

Source: Agency for Statistics of Bosnia and Herzegovina, Sarajevo, 2009.

Foreign trade of selected construction materials in BiH

Source: Agency for Statistics of Bosnia and Herzegovina, Sarajevo, 2009.

4.2. Product overview of the construction materials industry in BiH28

A selection of construction products manufactured in BiH

4.3. Construction materials industry in the entities

Number of construction material manufacturing companies registered at the Chamber

Sub-sector Number of companies

Manufacture of selected construction products

4.4. The construction (building) sector

5.1. BiH company survey on expected impacts of introducing CPD

The survey was implemented in September-October of 2010 among companies

5.1.1. Characterisation of the sample

Distribution of the respondent firms by size of company

Distribution of the respondent firms by turnover of company