"European rules on conformity assessment and certification are mainly fit for large-scale production and disproportionately expensive for small enterprises, which cannot benefit from economies of scale to cover the costs associated with marking", said Mr Gourtsoyannis. "The 'Marketing of Products regulation' is an excellent opportunity to redress this situation and put in place a workable framework for crafts and SMEs, without compromising the safety and quality of the products and services marketed in the European Union."
Mr Gourtsoyannis then went on to elaborate on the main problems facing SMEs, and on possible solutions to those issues. Compulsory CE marking is a first important aspect to be considered: the current "blanket approach" by which all products are submitted to marking must be modified. "CE marking should be compulsory only when mentioned in the relevant sectorial directive, when the product impacts health and safety and/or when the producer himself wants to obtain the CE mark", Mr Gourtsoyannis reminded MEPs. However, a declaration of conformity by the manufacturer could be sufficient for non- and small series productions that are subject to compulsory CE marking. Moreover, CE marking should be considered optional for all non- and small series products that have no significant impact on health and safety.
As the largest part of conformity assessment costs is generated by tests, UEAPME and NORMAPME asked MEPs to consider simplified versions of Initial Type Testing (ITT), i.e. the complete set of tests and procedures to determine the performance of products and services. In particular, Mr Gourtsoyannis insisted on the need to include in the "Marketing of products regulation" the possibility to use "shared" ITT, by which already existing test results are transferable between manufacturers producing functionally identical products, and "cascading" ITT, by which test results on a component can be re-used for any assembled product that contains the tested part.
Finally, Mr Gourtsoyannis asked the European Parliament to consider the possibility of using collective SME testing laboratories and certification bodies as a further cost-cutting measure. Moreover, the new European Accreditation system foreseen by the "Marketing of products regulation" should include simplified conformity assessment systems for small enterprises that are proportional to the size and risk involved.
"The 'Marketing of products regulation' will become the cornerstone of a significant number of sectorial regulations. We call on the European Parliament to include a clear-cut provision in this framework, which will ensure that SME-specific problems are properly taken into account by default in the forthcoming sectorial rules. It is crucial to act now to avoid a myriad of issues in the future", concluded Mr Gourtsoyannis.
