Position papers

CEIR Contributions on behalf of the industry it represents

CEIR – FECS joint position paper regarding standardisation of Building Information Modeling (BIM)
This joint position paper provides CEIR & FECS comments on ongoing standardisation activities related to BIM, notably the integration of ISO 16757 into EN standards covering BIM. This integration raises strong concerns from our industry, notably in terms of feasibility, liability and compatibility. Click here to download.

CEIR comments on the draft ECHA guideline on the restriction of nickel  – April 2017

CEIR believes that sanitary taps, including shower-heads and hand-showers, do not fall within the scope of the nickel restriction (REACH Regulation, Annex XVII, entry 27). Therefore, CEIR asks ECHA to amend its draft guideline on nickel restriction: shower-head handles should be removed from the list of articles falling within the scope of the nickel restriction. Click here to download

Joint Declaration on EU Industrial Strategy - February 2017 - Click here to download

FECS & CEIR Joint Statement on Building Information Modeling (BIM) - May 2016 - Click here to download

CEIR comments regarding the New Legislative Framework implementation: new ATEX, Pressure Equipment, Low Voltage and Electromagnetic Compatibility Directives - September 2015 - Click here to download

CEIR comments regarding the restriction of lead and its compounds in consumer articles that can be mouthed by children: Sanitary taps do not fall within the scope of the REACH restriction of use of lead (Regulation (EU) 2015/628: Entry 63 of Annex XVII REACH) – June 2015Click here to download

CEIR response to the public consultation on the Drinking Water Directive Review:  the Drinking Water Directive should be reviewed to improve the marketing of products in contact with drinking water in Europe - September 2014 - Click here to download

CEIR comments on the JRC Study developing an evidence base and related product policy measure for "Taps and Showers" - Third questionnaire on Policy Options - February 2014 - Click here to download

CEIR comments regarding the application of the Machinery Directive 2006/42/EC to Actuated Valves - Updated Feb. 2014 IN PRINCIPLE VALVES SHOULD NOT BE CONSIDERED AS MACHINERY - Click here to download

CEIR comments regarding the Construction Products Regulation (EU) No 305/2011 - September 2013
ONLY PRODUCTS THAT ARE COVERED BY HARMONISED STANDARDS ARE IN THE SCOPE OF THE CPR Click here to download

CEIR comments regarding the Construction Products Regulation (EU) No 305/2011 - April 2013
INDUSTRIAL VALVES ARE NOT CONSTRUCTION PRODUCTS IN PRINCIPLE - Click here to download

CEIR Position regarding Directive 2011/65/EU on the Restriction of the use of certain Hazardous Substances in electrical and electronic equipment (RoHS 2)  - April 2013
CEIR MEMBERS BEAR NO OBLIGATION UNDER THE NEW ROHS DIRECTIVE AS FROM 2 JANUARY 2013 - Click here to download

Ecolabel and Green Public Procurement (GPP)

  • Ecolabel and GPP criteria development for taps and showerheads - December 2011
  • CEIR POSITION on EU Ecolabel / GPP criteria for sanitary tapware - Click here to download
  • Ecolabel and GPP criteria development for taps and showerheads - October 2011
  • CEIR comments on the 2nd technical background report (Working Document) for the development of ecological criteria for sanitary tapware - taps and showerheads - Click here to download  

CEIR comments on the lack of harmonisation in the field of materials and products in contact with drinking water in the EU- May 2011
This document aims at identifying the main difficulties faced by European manufacturers when introducing on the internal market products destined to be in contact with drinking water due to the lack of harmonisation of practices and rules in Europe. The facts developed below were identified after a survey conducted among all CEIR members - Click here to download

Ecodesign Working Plan 2012-2014

  • CEIR Contributions to the Study for an update of the Ecodesign Working Plan Amended Ecodesign Working Plan - April 2011 - Click here to download
  • CEIR Contributions to the Study for an update of the Ecodesign Working Plan Amended Ecodesign Working Plan - September 2011 - Click here to download

WEEE and RoHS - September 2005
CEIR position paper on the Directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE) and on the Directive 2002/95/EC on the Restriction of the use of certain Hazardous Substances in electrical and electronic equipment (RoHS), with regard to industrial equipment - Click here to download.