WHY IS CECIP IMPORTANT FOR YOU FOR YOU UKWF 11 th April 2013 1. - - PowerPoint PPT Presentation

WHY IS CECIP IMPORTANT FOR YOU FOR YOU

UKWF

11th April 2013

• 1. How CECIP works: CECIP activities
• n metrology, market surveillance

11 April 2013 Why is CECIP important for you

• n metrology, market surveillance

and EU legislation.

CECIP represents the European manufacturers of weighing instruments Founded in 1958 CECIP has today 15 member associations: Austria, Czech

Republic, France, Germany, Hungary, Ireland, Italy, Netherlands, Poland, Romania, Russia, Slovak Republic, Spain, Switzerland and

11 April 2013 Why is CECIP important for you

Poland, Romania, Russia, Slovak Republic, Spain, Switzerland and United Kingdom.

• Ca. 700 companies active in the production of weighing

instruments 50.000 people Turnover of 3 billion Euros in 2008 + 4000 – 5000 micro companies (10.000 employees)

11 April 2013 Why is CECIP important for you

UK and thus UK business (UKWF) is represented in all WGs (LMG and BTG) and in the Board of CECIP. Importance of the UK within CECIP:

The opinion, problems and solutions of the UK business might be different from those of continental EU Member States: Enrichment.

11 April 2013 Why is CECIP important for you

different from those of continental EU Member States: Enrichment. The UKWF has a very active, effective and expertise role within the BTG, LMG and Board. Its input is well recognised and highly appreciated. The BTG, LMG and Board is aware of the problems faced by the UK weighing instruments industry→effective solutions.

It is important that UK and the UK business remain active within CECIP and involved in all its activities.

CECIP activities in BTG focus on Market Surveillance. Background: Action: In 2009 tests on scales manufactured by NON- EU manufacturers.

11 April 2013 Why is CECIP important for you

EU manufacturers. Result: 37 scales tested 36 failed the tests. Conclusion: Market surveillance is poor in the EU. Solution: CECIP wants to raise attention and take measures on market surveillance.

Decisions of the BTG : Press release Presentation at WELMEC WG 5 (Market Surveillance) DG ENTR & Industry major Conference November 2011 Meetings with EU ministries

11 April 2013 Why is CECIP important for you

Meetings with EU ministries Contacts with MEP: Mr. Harbour, Chairman of IMCO (Internal Market and Consumer Protection Committee) European Commission very interested request on unveiling details (manufacturers, points of entry, types/models of scales tested…)

Example of active and efficient role of the UKWF within the BTG and the UK business:

Action: Contacting Mr. Malcolm Harbour (MEP for the West Midlands, Chairman of the Internal Market and Consumer

11 April 2013 Why is CECIP important for you

Midlands, Chairman of the Internal Market and Consumer Protection Committee and a vice-president of the Trading Standards Institute) to make him aware, among others, of the problems on MS faced by the weighing instruments industry at national (UK) and EU level. Result: He is involved in the problem and proactive for finding a solution.

LEGAL METROLOGY GROUP CECIP LMG group focuses on Technical and standardisation work:

11 April 2013 Why is CECIP important for you

CECIP experts are present in WELMEC and OIML groups. Coordination of inputs to technical committees is ensured by Brussels Secretariat.

CECIP LMG focuses on New Approach Legislation (NLF): Alignment NAWID and MID Directives to the New Legislative Framework (NLF to be adopted early 2013):

CECIP advocated for non integration of NAWID into MID Directive. CECIP positions presented directly to the Commission during meetings of wgMI and CECIP-EC meetings.

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meetings of wgMI and CECIP-EC meetings.

MID revision

CECIP participated in the EVALUATION of the Directive. CECIP provided inputs on how to modify the MID.

Blue Guide (to be finalised by September 2013):

CECIP participates in the discussion of the Commission’s Guide. CECIP provides inputs on the structure and content of the Guide.

WELMEC working groups

Working group Rapporteur Co-rapporteur rotating basis Support team WG 2: Directive Implementation (2009/23/EC) LMG President Participation on a rotating basis:

• Daniel Meier
• Ian Turner

WG2 subgroup Guide 2.2 Daniel Meier WG2 subgroup Guide 2.3 Ian Turner WG2 subgroup Guide 2.4 Veronika Martens WG2 subgroup Veronika Martens WG2 subgroup Guide 2.6 Vincent van der Wel 2.6/1 Checkweigher: Ian Turner 2.6/2 gravimetric filling instruments: Ian Turner 2.6/3 discontinuous totalizer: V. van der Wel

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2.6/4 continuous totalizer: V. van der Wel 2.6/5 automatic rail weigh bridges:V. van der Wel 2.6/6 automatic weighing of road vehicles in motion: Denis Senyansky 2.6/7 multidimensional measuring device: Daniel Meier WG2 subgroup WG 4: General Aspects of Legal Metrology WG 5: Metrological Supervision BTG (Urs Widmer) WG 6: Prepackages Vincent van der Wel Ian Turner WG 7: Software Ian Turner

• Karlheinz Banholzer

WG7 subgroup: Control of software

Reiner Letsch WG 8: Measuring Instruments Directive Daniel Meier

• Veronika Martens

Ian Turner on any aspect of WG8

European Commission working groups

Working group Documents/Projects covered Priority Rapporteur Co-rapporteur Support team wgMI: working group

• n measuring

instruments High LMG President

• General Secretary
• Daniel Meier

Ian Turner Blue Guide Group High Daniel Meier

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Example of active and efficient role of the UKWF within the LMG and the UK business:

Actions:

Contacting Mr. Malcolm Harbour to raise the issue of the collaboration between conformity assessment faced by the weighing instruments industry at national (UK) and EU level.

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industry at national (UK) and EU level. Contacting MEPs to request them to raise to the Commission the question of the clarification of the legal definition of the term “manufacturer”.

Results:

He is involved in the problem and proactive for finding a solution. Questions were answered by Commissioner Tajani (DG Enterprise) and the legal definition of the term “manufacturer” has been clarified.

• 2. Lobbying group within CECIP:

How lobbying is done at EU level

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How lobbying is done at EU level

• What is lobbying?

What is lobbying?

At EU level, lobbying means all activities carried out with the objective

• f influencing the policy formulation and decision-making processes of

the European institutions.

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• Who is involved in lobbying?

Who is involved in lobbying?

• dynamic process which demands that actors from different institutions

and interest groups collaborate Institutional actors business

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Actors from private and public interest groups interests non-business- interests

• Who are the EU’s institutions?

Who are the EU’s institutions?

11 April 2013 Why is CECIP important for you

• Who are the EU’s institutions?

Who are the EU’s institutions?

European Parliament

• Representing the EU’s citizens
• Debating and passing European laws together with the Council
• Scrutinizing other EU institutions
• Debating and adopting the EU's budget together with the Council

Council of the EU

• Representing the governments of the individual member countries
• Passing EU laws
• Coordinating the broad economic policies of EU member countries

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• Coordinating the broad economic policies of EU member countries
• Signing agreements between the EU and other countries
• Approving the annual EU budget
• Developing the EU's foreign and defence policies
• Coordinating cooperation between courts and police forces of member countries

European Commission

• Representing the interests of the Union as a whole
• Managing the day-to-day business of implementing EU policies and spending EU funds
• Proposing new laws to Parliament and the Council
• Managing the EU's budget and allocating funding
• Enforcing EU law (together with the Court of Justice)
• Representing the EU internationally

• How are decisions taken at EU level?

How are decisions taken at EU level?

11 April 2013 Why is CECIP important for you

• Where, when and how to interfere as a lobbyist?

Where, when and how to interfere as a lobbyist?

Two routes of influence: national route (at Council and MEPs level) European route (at Commission and Parliament level)

Where? When? How? Whom? Commission Prevention Coercion Commissioner and Cabinet and at DG level

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Cabinet and at DG level (Head of Unit, Policy officers) Parliament Reaction Encapsulation MEPs, MEP assistants, rapporteur, shadow rapporteur Council Action Advocacy National relevant Ministries and, in some cases, at the level of the relevant national authorities Argumentation

• Contact persons for CECIP: In general and including

Contact persons for CECIP: In general and including Market Surveillance Market Surveillance

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• Contact persons for CECIP: In general and including

Contact persons for CECIP: In general and including Market Surveillance Market Surveillance

DG Enterprise and Industry

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• Mr. Hans Ingels – Head of Unit C1

Unit C1 Internal Market and its International European Commission 1049 Brussels BELGIUM Phone +(32) 2 2966441 Fax +(32) 2 2959784

Contact persons for CECIP: Additionally for Contact persons for CECIP: Additionally for Market surveillance Market surveillance

11 April 2013 Why is CECIP important for you

• Contact persons for CECIP: Additionally for

Contact persons for CECIP: Additionally for Market surveillance Market surveillance

DG Health and Consumers (SANCO)

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• Mr. O. Vasile – Head of Unit B3

Unit B3 Product and Service Safety European Commission 1049 Brussels BELGIUM Phone +(32) 2 2995157

• Contact persons for CECIP: Working Group of

Contact persons for CECIP: Working Group of weighing instruments ( weighing instruments (wgWI wgWI – European Commission) European Commission)

Austria

• Ms. Ulrike Fuchs

Bundesamt für Eich-und Vermessungswesen Ulrike.Fuchs@bev.gv.at France

• Mrs. Corinne Lagauterie

Ministère de l'économie - Bureau Métrologie corinne.lagauterie@finances.gouv.fr

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Spain

• Ms. Belén Martín Blasco

Consejera Técnica bmblasco@cem.mityc.es UK

• Mr. Richard Sanders

National Measurement Office richard.sanders@nmo.gov.uk corinne.lagauterie@finances.gouv.fr Germany

• Dr. Peter Ulbig

Physikalisch-Technische Bundesanstalt Peter.Ulbig@ptb.de

Example of active and efficient role of the UKWF in lobbying at national (UK) and EU level:

Actions:

Contacting Mr. Malcolm Harbour and other MEPs to raise the issue of the collaboration between conformity assessment, clarification of the legal definition of the term “manufacturer” and MS faced by the

11 April 2013 Why is CECIP important for you

legal definition of the term “manufacturer” and MS faced by the weighing instruments industry at national (UK) and EU level. Drafting the letters to the Commission regarding TACs and collaboration between conformity assessment. Providing expertise input for settling CECIP position in different topics: Blue Guide, WELMEC WGs, etc.

Results: successful.

• 3. Market Surveillance: Its importance

and how this has a direct effect.

11 April 2013 Why is CECIP important for you

Compliance: Weighing instruments must comply with the requirements of the European Directives in order to be allowed to put them in the market. Costs: The cost of having a product in compliance with the European requirements is very high for a company. Problem: Lack of Market surveillance. MS authorities

11 April 2013 Why is CECIP important for you

Problem: Lack of Market surveillance. MS authorities (national competence) do not check whether the weighing instruments that are put in the market comply with the European requirements → free entrance to non- compliance products Consequence: The non-complince products can be sold at a lower price→unfair competence situation=compliance companies will have a negative finacial impact (loses).

Solution offered by CECIP: Lobbying and information to the European Commission and the national MS authorities (specific cases). Direct effect on companies: Non-compliance products will

11 April 2013 Why is CECIP important for you

Direct effect on companies: Non-compliance products will be removed from the market→re-establishment of fair competence.

• 4. Sucessful stories within CECIP

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EN45501

Problem: Fast change requirement from 3v/m to 10 v/m (with no transition period). Consequence: SMEs would not have the resources to quickly adapt to the new stardard requirements. What to do with the 3v/m weighing instruments ready to be put in the market?=big loses=SMEs would

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instruments ready to be put in the market?=big loses=SMEs would close their business. Action/Solution: Lobbying done by CECIP at EU level informing about the problems that such change would cause mainly in the SMEs. Result: The adoption of the new standard was stopped and a transitional period of 3 years was approved in order to help companies to adap to the new requirement of 10 v/m=SMEs can still run their business and be competitive.

Action - Lobbying: Meeting with the Commission to inform that t is of high importance for the weighing instruments industry that the TACs’ validity will be of 10 years after the issuing date, even if the new standard EN45501 (10 v/m) is already into force.

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Effective and active role of the UKWF in the approach and solution

• f the issue.

Result: →Latest news: A note will be issued informing that existing type-approvals certificates will be allowed to expired (10 years after the issuing) rather than be cut short!

Collaboration within Conformity Assessment: The issue of the definition of the term “Manufacturer” General problem which affects all Member States. There is no doubt about the sole and indivisionable

11 April 2013 Why is CECIP important for you

There is no doubt about the sole and indivisionable responsibility of the "manufacturer". There is no explicit requirement that the manufacturer has to execute complete conformity assessment on his own. There are several types of collaboration between different actors foreseen in the relevant EU-regulation. CECIP promotes concepts ensuring proper collaboration.

Definition of the term “Manufacturer”: Directive 2009/23/EC - Art. 4(d): "‘manufacturer’ means a natural or legal person responsible for the conformity of the measuring instrument with this Directive with a view to either placing it on the market under his own name and/or

11 April 2013 Why is CECIP important for you

either placing it on the market under his own name and/or putting it into use for his own purposes;”.

Action - Lobbying: Raising some questions to the Commission by MPs in order to provide an interpretation of the legal definition:

Done by the UKWF: Effective and active role of the UKWF in the approach and solution of the issue. Successful result: The WELMEC guidance would seem too drastic an

• approach. The Commission is further looking into this matter and will

inform stakeholders of the outcome.

Collaboration defined by EC-Directive 2009/23:

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Action: Lobbying:

Type Evaluation: There is no benefit in repeating type evaluation with respect to safety and reliability of the design. Responsibility of the Manufacturer: Ensure is not equal to do it

• neself.

Market Analysis: No quality problems known.

11 April 2013 Why is CECIP important for you

Market Analysis: No quality problems known. Costs: Approval&update by notified bodies; Internal effort of the companies (external costs); Loss of time: more than 1 or 2 months for each of them. No benefits: No improvement of safety and reliability of the instrument and no problem known being solved.

Conclusions:

Limitation of the use of type evaluation certificates by partner companies is:

Not compulsory by the two directives in force; In conflict to Decision 2008/768; Not justified by sector specific factors;

11 April 2013 Why is CECIP important for you

Not justified by sector specific factors; Non-instrumental in solving any problem; Putting at risk the existence of a relevant number of well established companies especially SME's; Restricting without any reason the freedom of operation, innovation capacity, international competitiveness for many companies.

Result: Effective lobbying: This issue will be raised in the next EC wgMI in order to (expectations):

Refuse the WELMEC request to limit the use of type evaluation certificates:

11 April 2013 Why is CECIP important for you

certificates:

Reflecting risk and impact assessment Cost/Benefit evaluation and Considering commensurate interpretation with respect to the targets and level of protection in the sector.

If deemed necessary and appropriate: Elaboration of guidance for a proper collaboration.

• 5. Conclusion: Why is CECIP

important for all Member States

11 April 2013 Why is CECIP important for you

important for all Member States

CECIP represents the European weighing intruments industry: it represents SMEs and big enterprises equally. The more members CECIP has, the more entitled will be to represent the European weighing intruments industry (more voices can represent before the EU Institutions). CECIP is the direct spokeperson to the EU Institutions

11 April 2013 Why is CECIP important for you

CECIP is the direct spokeperson to the EU Institutions and vice-versa (decision-making, public consultations, MS, information, contacts, etc.). Throughout CECIP, its members have the possibility of influencing the decision-making process in order to protect their interests.

CECIP members provide CECIP with high quality technical expertise: without active members CECIP would lose such added value (CECIP is well recognised). CECIP provides the Comission with expertise and informs about real problems in order to find effective solutions. CECIP bring its common position (rapporteurs) to the

11 April 2013 Why is CECIP important for you

CECIP bring its common position (rapporteurs) to the different WGs within WELMEC, MIwg, OIML, etc.): common possition→stronger position→more possibilities to be sucessful→protection of interests. CECIP provides support to its members: update on EU legislation, expertise, MS specific issues, etc.

Organization Topic Results Effect OIML

Mutual Acceptance Arrangement (MAA). OIML certificates are accepted in all participating countries without additional testing. No retesting for USA, China, Australia, Indiaetc.

OIML

Manufacturer Test Laboratories (MTL). Issuing labs can subcontract tests to certified test labs of the manufacturers. No retesting by the certification lab required.

European Commission (wgMI)

Merge of NAWI-D and MI-D no merge of the two directives.

European Commission (wgMI)

EMC - Immunity Level (30 V/m). 30V/m proposed by PTB, was rejected and 10V/m (specified by OIML R76:2006) is still accepted. No re-design of Instruments for 30V/m.

European Commission (Blue Guide)

Legal Manufacturer. legal entity issuing CE declaration of conformity hasn't to be identical to the owner keep OEM-business and avoid parallel certificates.

11 April 2013 Why is CECIP important for you (Blue Guide)

conformity hasn't to be identical to the owner

• f a type approval

parallel certificates.

WELMEC

Translation of complete approval and service documentation into all EU languages (for re-verification authorities). Only DoC and User documentation has to be translated. approval and service documentation hasn't to be translated.

WELMEC

Trend to establish requirements for complete check of conformity by re- verification authorities on site. Instrument and Type Approval Certificate have to include tools and procedures to test internal components (hard- and software) for their equivalence with the approved type. Avoid that "each change in design has to be approved by notified body and included in type approval documentation" and corresponding flexibility in change management.

WELMEC

Trend to increase risk level for Software od weighing instruments from class B to C Restricted flexibility in change management, more complex design, increased testing and documentation by the notified body needed. Avoid increased effort in development phase and costs of production.

All those activities would not be succesful/possible without the active support of CECIP members → active members = sucessful protection of interests throughout effective solutions.

11 April 2013 Why is CECIP important for you

→Special thanks to the UKWF:

Its role and expertise activity is key for CECIP and for the sucess

• f the protection of the interests of the weighing instruments

industry at national (UK) and EU level. It is important that UK and the UK business remain active in all the fields of the weighing instruments.

To access our website: www.cecip.eu To contact the Secretariat (Brussels): info@cecip.eu or +32 2 706 8215

11 April 2013 Why is CECIP important for you

info@cecip.eu or +32 2 706 8215

Thank you

Bárbara Morales Pascual – Secretary General

• f CECIP