Construction Fixings

By Thomas Holland-Letz, Construction Fixings Europe

Many members of the European ‘anchor community’ – manufacturers, institutes and TABs – will have been surprised by some statements in the article: ‘CE Marking on post-installed fasteners: Why not a European standard?’ in the September 2019 edition of Fastener + Fixing Magazine.

The standard, which was proposed to CEN/TC 185, will not become a hEN, unless the European Commission issues a standardisation request. Therefore, the proposed standard cannot be used as basis for CE Marking and will be useless for the industry and any work for this standard will be wasted.

The ETA route to CE Marking of anchors is a success story. The European anchor manufacturers are worldwide market leaders with the most innovative and reliable products. Compared to other regions, the European anchor industry has the biggest variety of manufacturers including a lot of SMEs, which use ETAs for their innovative products in the same way as bigger companies.

ETAs have a good reputation worldwide. Important third countries have taken over the assessment methods from the ETA system, which enables European manufacturers to sell their products in a lot of third countries without additional testing or assessment. Unlike in other countries there has been no major failure of fastening application in Europe, which proves the quality of the ETA product assessment procedures.

Should we put this proven and reliable system at risk now by moving to the standardisation of anchors? Let’s check myths and facts on hEN and EADs:

The development of new EADs is done by (mostly big) companies:
No. The decision, if a new EAD is developed to deal with an ETA application is done by EOTA, based on the provisions of the Construction Products Regulation (CPR).

EAD versions are changing frequently, which leads to a waste of money for the update of ETAs:
No. Until today, only one EAD for anchors was updated by citation of a new version in the Official Journal of the European Union.

SMEs will benefit from the standardisation:
No. Experience shows that once a product is standardised, it is more difficult for SMEs to compete against bigger companies and importers. For most of the customers, all standardised products are comparable, and they will decide on the product with the lowest price.

SMEs will have more influence in standardisation:
No. Today, manufacturers of all sizes can influence the EAD content via their European associations, which are present in the EOTA Expert Group Fixings, or in direct contact with a TAB. Under a standardisation regime, only the national mirror committees decide on the content of the EN. This would oblige all manufacturers to become a member of their national mirror committee, where they have to convince the other committee members. Bigger manufacturers or importers could dominate the standardisation process by sending representatives of their national subsidies into mirror committees in countries where no manufacturers exist.

Standardisation will prevent the proliferation of EADs:
No. The number of EADs will even increase under a standardisation regime, because the standardisation process is less flexible than the EAD process. According to the CPR, manufacturers can apply for an ETA for products and intended uses (e.g fatigue loads), which are not (fully) covered by a Harmonised European Standard (hEN) and the responsible TAB together with EOTA will develop a new EAD. This will happen also after a conversion of the present EADs into a standard.

Standardisation will lower the costs for CE Marking:
Partly. Under the presumption that the current safety level, as defined by the EADs and the AVCP system as determined by the European Commission will be maintained, the costs for testing, evaluation and third party production control will not change. The only costs that would be saved are the fees for the elaboration and the publication of the ETAs by the TABs. On the other hand, these costs are compensated by the additional value of an official document like an ETA compared to a simple DoP based on a hEN.

Standardisation would be a chance to get rid of “useless” tests and assessments in the EADs:
No. The tests and assessment methods in the EADs have been evaluated and confirmed by the European Commission before the EADs were cited in the Official Journal. Therefore, it is very unlikely that the European Commission would accept the deletion of tests and assessments, when the EADs are converted into an EN. Consequently, the respective proposal to CEN seems to intend a 1:1 conversion of the EAD content into standards.

Mandatory CE Marking based on standards will be a benefit:
No. The intention of the CE Marking under the CPR is only to simplify the marketing of a product in the EU and to treat manufacturers equally. CE Marking is not necessary if an anchor is designed to meet the national requirements in only a single member state. This can save unnecessary costs. Therefore, CE Marking for anchors should remain voluntary.

ETAs are not intended for customers:
Formally correct, but: For complex products such as anchors, specifiers and end users are still used to work with the ETAs, even six years after the CPR came into force. The ETA gives a lot of additional information, e.g end conditions, under which the performance values are reliable and which have to be taken into account for the design of the fastening.

‘Bilateral’ EADs are not based on research and science:
No. Such a statement undermines the reliability of the whole EAD/ETA system. In fact, each EAD is developed by competent TABs, then circulated among all EOTA members, then adopted by the EOTA Technical Board and finally endorsed by the European Commission, before it is cited in the Official Journal. In each of these steps, the consistency and reliability of the EAD is checked by experts. In several cases, the content of EAD drafts had to be changed based on detailed comments by other TABs or by the European Commission. The same steps apply in cases where a ‘basis’ EAD was developed by an EOTA WG, e.g as conversion of a former ETAG.

Only big manufacturers can develop new EADs:
No. Firstly, the manufacturer applies not for a new EAD, but for an ETA. It is then up to the EOTA and the European Commission to decide if a new EAD has to be developed by EOTA. Secondly, there are a number of EADs that were developed based on ETA applications by small companies.

Post installed fasteners are “mature” to be standardised:
No. Just the existence of several EADs for anchors shows that this sector is still very dynamic, regarding innovative products and new intended uses. According to Recital 18 of the CPR, hEN can be developed based on EADs only, “once a sufficient level of technical and scientific expertise on all the relevant aspects is attained”. This condition is not yet fulfilled for the different types of anchors for concrete and masonry.

CFE welcomes any fact-based discussion on the pros and cons of EADs versus standards for post installed fasteners, which should also take into account the experience of European manufacturers, end users, specifiers, and national legislators, with standards for other products compared to their experience with products covered by ETAs.

About the author

Thomas Holland-Letz is project manager at Construction Fixings Europe (CFE), responsible for technical and legal affairs. CFE represents European anchor manufacturers of all sizes and national associations of anchor manufacturers. The main goals of CFE are to maintain the high reliability of anchor fixings, to level the playing field for European manufacturers independent from their size and to encourage innovation.

thl@construction-fixings.eu

www.construction-fixings.eu