CECE debates European Commission’s guidelines on industrialised products

The document presents the EC’s understanding on the implementation of the product rules of each CE marking Directive and Regulation. Nowadays, the guidelines have become one of the main reference documents explaining how to implement the legislation based on the New Approach, now covered by the New Legislative Framework (NLF).

CECE intends to send its comments to the European Commission by the end of October. Our members are providing specific feedback on many sections, including the concepts of placing and making available on the market, responsibilities of economic operators, software and the changes brought by the new Market Surveillance Regulation.

One of our key comments deals with how construction equipment manufacturers understand the concept of remanufacturing. For our members, remanufacturing is a process that cannot be performed in the field and involves dismantling a product, restoring and replacing components, and testing the individual parts and the whole product to its original design specifications. Remanufacturing is a process that does not affect the risk assessment of the original product and therefore does not create a new product.

On the role and use of Harmonised Standards, CECE suggests that the EC takes into consideration the existing debate and associate Member States and other stakeholders to the discussion. We should not take conclusive steps on it until there is an agreed and consistent interpretation of the judgment of the European Court of Justice about harmonised technical standards (“Elliott case”).

The comments are part of a larger strategy by CECE to position itself as a one of the drivers in the discussion on horizontal product legislation.

For more information on our position with regards to the “Blue Guide” discussions, please contact us at info@cece.eu.