1. Are there any criteria to allow the use in class E1/E2 in certain areas, products, uses etc.?

    

2. What are the updated regulatory requirements in Greece regarding the use in class E1/E2?

    

3. Does the requirement to E0 exists in Europe, if it does, what are the criteria for its use(certain products/areas/conditions, etc.)?

    

Having regard to the relevant Greek provisions, such as:  

i) Common Ministerial Decision “Maximum formaldehyde limit for furniture, decorative objects and their raw materials of composite wood – Immigration of some elements from children’s furniture – Furniture Board” (Official Government Gazette 746/B/22-4-2009) and its amendment (Official Government Gazette 2650/B/09-11-2011), there is the national requirement of class E1 as maximum permitted limit. It is noted though, that the scope of the aforementioned provision excludes construction products. 

ii) Presidential Decree no. 90 “Exposure limit values and maximum exposure limit values of workers to certain chemical agents during their work in compliance with Commission Directives 91/322/EEC and 96/94/EC and the amendment and supplementation of the Presidential Decree 307/86 “Protection of workers health exposed to certain chemical agents during their work” (Official Government Gazette 135/A) as amended with the Presidential Decree 77/93 (Official Government Gazette 34/A)” (Official Government Gazette 94/A), the exposure limit value of workers during their duty to formaldehyde emission is defined at 2 ppm (2.5 mg/m3). 

1. Are there any national requirements in your country for the content of NH3 in the fly ash for concrete in case the concrete is to be used for living spaces/residential buildings?
2. Which national document contains the prescriptive value of maximum allowed amount of NH3 declared by the manufacturer?
3. What is the testing method for determination of the maximum declared amount of NH3 in fly ash for concrete?
4. Does the manufacturer declare the content of NH3 in the Safety data sheet or in some other document?

Having regard to the relevant Greek provisions, such as the Presidential Decree no. 90 “Exposure limit values and maximum exposure limit values of workers to certain chemical agents during their work in compliance with Commission Directives 91/322/EEC and 96/94/EC and the amendment and supplementation of the Presidential Decree no. 307/86 “Protection of workers health exposed to certain chemical agents during their work” (Official Government Gazette 135/A) as amended with the Presidential Decree 77/93 (Official Government Gazette 34/A)” (Official Government Gazette 94/A), the exposure limit value of workers during their duty to ammonia (for example workers in cement industry) is defined at 50 ppm (35.00 mg/m3). 

Regarding point (4) of your question, we consider that the declaration of ammonia in Safety Data Sheet of the regulation (EC) 1907/2006 is compulsory, since ammonia (anhydrous) is included in the list of harmonised classification and labeling of hazardous substances (Table 3.1) of regulation (EC) 1272/2008, with index no 007-001-00-5. 

According to the Greek Technical Specifications for public works (ETEP), we inform you the following: 

• There are no additional national requirements in force other than those derived from the harmonised standard ELOT EN 15651 – “Sealants for non-structural use in joints in buildings and pedestrian walkways”, for the essential characteristics of non-structural sealants, when placing or/and making available these products on the market. 
  
  
• The ΕΝ 14293 “Adhesives – Adhesives for bonding parquet to subfloor – Test methods and minimum requirements” has been adopted by the Greek Standardization Body (ΕLΟΤ) as a national relevant standard, but it has not been transposed into Greek law, and therefore it is not compulsory. 
  
  
• In addition, some technical characteristics of sealants and parquet adhesives, when they are intended to be used in public works, may be defined either as part of the project plan/design or in the relevant Greek Technical Specifications (ETEP) which prescribe the rules /specifications that should be applied for the construction of a building or civil engineering public work.With the Joint Ministerial Decision “Approval of four hundred forty (440) Greek Technical Specifications (ETEP) with mandatory application to all Public Works”, (Official Government Gazette (OGG) 2221/B/2012), the Technical Specifications have become compulsory. 
  
  

Such Specifications (ETEP) that include the products in question are mainly the following: 

ELΟΤ ΤP 1501-03-04-05-00:2009 “Sealing of building joints” 

ELΟΤ ΤP 1501-03-08-01-00:2009 “Wooden windows and doors” 

ELΟΤ ΤP 1501-03-08-07-01:2009 “Single layer and laminated glass glazing” 

ELΟΤ ΤP 1501-03-07-02-00:2009 “Ceramic tiles covering of indoor and outdoor surfaces” 

ELΟΤ ΤP 1501-03-08-01-00:2009 “Paving slabs and cobblestones for pedestrian areas” 

ELΟΤ ΤP 1501-03-07-01-02:2009 “Glued hardwood flooring” 

Moreover we notice that the technical characteristics of the products to be used in any public work resulting from the design of the project must meet the requirements of the applicable standards in each case, depending on the intended use, in accordance with the order of preference specified in articles 23 and 34 of Directive 2004/18/EC and 2004/17/EC respectively. 

The harmonised European Standard EN 14351 identifies material independent performance characteristics that are applicable to windows and doors. 

According to the relevant Greek provisions, such as the Regulation on the Energy Performance of Buildings: a) Law 4122/2013 “Energy Performance of Buildings – Harmonization with Directive 2010/31/EU of the European Parliament and of the Council and other provisions”(Official Government Gazette 42/A) and b) Ministerial Decision no. DEPEA/ οικ.178581/ 30.06.2017 “Approval of Regulation of the Energy Performance of Buildings” (Official Government Gazette 2367/B), the thermal transmittance Uw for windows and or Ud for doors is required to be declared at the declaration of performance for these products in Greek. 

We inform you that according the following existing legislative framework concerning construction products: 

a) Regulation 305/2011 of the European Parliament and of the Council of 9th March 2011 «laying down harmonised conditions for the marketing of construction products and repealing Council Directive 89/106/ΕEC» and its corrigendum. 

b) Ministerial Decision no. 27421/05.03.2019 (Official Government Gazette 958/ Β) «Additional measures necessary for the implementation of Regulation (EU) no. 305/2011 of the European Parliament and of the Council of 9 March 2011 laying down harmonised conditions for the marketing of construction products and repealing Council Directive 89/106/EEC». 

c) Ordinance no. DΤDG 1111251 ΕΞ 2018/2018/19.07.2019 of the Independent Authority for Public Revenue. 

The declaration of performance for construction products should be drawn up in Greek for the products available on the Greek market. 

Having regard to the relevant Greek Technical Specifications (ETEP) which prescribe the rules / specifications that should be applied for the construction of a building or civil engineering public work, there are no any specific national requirements that have to be fulfilled for small wastewater treatment plants in Greece, except of the fact that they are covered by the ELΟΤ EN 12566 harmonised standard. 

There is no reference at the Greek Technical Specifications (ETEP) for the use of penetration seals covered by the ETAG 026-2.  

However, some Greek Technical Specifications (ETEP) include requirements for materials used as sealants, such as:  

“stable unburnt material” (ΕLΟΤ ΤP 1501-04-01-01-00 “Building piping systems under pressure with copper tubes with seam” and ΕLΟΤ ΤP 1501-0103-00 “Building piping systems under pressure with copper tubes”, or 

“sealants should have the specific fire resistance rating of the relevant structural element of the building in which they are incorporated“ (ELOT TP 1501-04-20-01-02 “Plastic tubes of electrical installations”) etc.  

Furthermore, you may contact the Ministry of Environment and Energy, General Secretariat for Regional planning and Urban Development (email: gramchora@ypen.gr) for any further requirements regarding other national rules applying to your product. 

When your construction product is subject to the requirements of the (EU) No 305/11 Construction Product Regulation (CPR), it is not allowed to introduce other than CE marking attesting its conformity, with the declared performance in relation to the essential characteristics covered by that harmonised standard or by the European Technical Assessment, (art. 8 (3) of the CPR). Thus, that product cannot be placed on the EU market as well as on the Greek market. 

Following your question, we inform you the following: 

1. The issue of the production of construction products on behalf of another manufacturer (rebranding and subcontract manufacturer) falls under the provisions of paragraph 19 of Article 2 and Articles 11, 15 and 36 of Regulation (EU) 305/2011. According to these provisions, the final manufacturer (rebranding manufacturer), who does not manufacture the construction product himself, should draw up a declaration of performance and affix the CE marking, when such a product is placed on the market under his name or trademark.

    

2. If its construction product is subject to systems of assessment and verification of constancy of performance (AVCPs) 1+, 1 or 2+, a relevant certificate is required to be issued by a notified body on behalf of the final manufacturer, given that the physical manufacturer could not authorise the final manufacturer to use his certificate.

    

3. If its construction product is subject to system of assessment and verification of constancy of performance (AVCP) 3, the rebranding manufacturer could base the declaration of performance on test results obtained by the physical manufacturer only after having obtained an authorisation of that manufacturer, provided that the conditions laid down in Article 36 for reliability and stability of the test results are met.

    

4. Additionally, it is required a contract with the physical manufacturer that will allow the rebranding manufacturer to fulfill its obligations as legal manufacturer regarding factory production control. E.g. for applicable system of assessment and verification of constancy of performance (AVCP) 2+, the certificate of conformity of the factory production control issued by a notifying body in the name of the final manufacturer, should take into account the rebranding and subcontract manufacture

Following your question, we inform you the following: 

1. According to paragraphs 2 and 3 of article 28 of regulation (ΕU) 305/2011 «By means of delegated acts in accordance with Article 60, the Commission shall establish and may revise, taking into account in particular the effect on the health and safety of people, and on the environment, which system or systems are applicable to a given construction product or family of construction products or a given essential characteristic» and «The system or systems thus determined shall be indicated in the mandates for harmonised standards and in the harmonised technical specifications».

    

2. Delegated acts no. 95/204/EC, 1999/91/EC and 2001/596/ΕC have been issued and are in force for thermal insulation products.

    

3. Thermal insulation products of extruded and expanded polystyrene (EPS and XPS), which fall into class E of reaction to fire, should be assessed according to system of assessment and verification of constancy of performance (AVCP) 3 (Table ZA.2 of Annex ZA of harmonised standards ELOT EN 13163 and ELOT EN 13164).
    
4. Thermal insulation products, having other reaction to fire performance e.g. classes A1, A2, B, C and intended for uses subject to regulations on reaction to fire, should be assessed by system 1, as specified in relevant harmonised standards.

    

5. Therefore, manufacturers should not apply different system of assessment and verification of constancy of performance (AVCP) than standards define. Systems are determined for all Member States by the Commission acts, which are directly applicable, delegated by Regulation (EU) 305/2011 or Directive 89/106/EC. In that way, harmonisation framework and the common technical language of the EU Member States are ensured. 

For systems (kits), such as External Thermal Insulation Composite Systems (ETICS), their performance could be optionally assessed as a whole on the basis of European Assessment Documents (EAD), if any. The European Technical Assessment (ETA) of this system, issued by a TAB, is an assessment element of the specific final product performance, and not of its individual components performance from which this system is constituted. The manufacturer then shall draw up a declaration of performance and shall affix the CE marking for the system, for placing the system on the market. 

In order to place on the market the individual components of the system, which are covered by harmonised standards of Regulation (EU) 305/2011, these should bear their CE marking and get accompanied by their declaration of performance, after the assessment of their performance in the basis of relevant harmonised standards solely. 

According to presidential decree no. 41/ 04.04.2018 “Fire protection Regulation” (Official Government Gazette 80/A), there are minimum requirements of fire resistance and reaction to fire for several construction products.  

For example, table no. 7 (p. 22) includes minimum requirements of fire resistance index depending on the building use. Table no. 8 (p. 23) includes minimum required criteria of performances of fire resistance indexes for various construction elements. Especially for your products, roof openings, requirements for integrity and resistance to heat passage criteria exist. Table no. 13 (p. 3) includes minimum requirements of reaction to fire depending on the building use. Especially for your products, roof openings, exist the requirements of the 5th column of the table, where for residencies there is the requirement of C-s1,d0, etc. 

Furthermore, we inform you that the competent Greek authority for the aforementioned “Fire protection Regulation” is the Ministry of Environment and Energy, General Secretariat for regional planning and urban development, email: gramchora@ypen.gr.

Following your question, we inform you the following: 

1. Distributors or importers are considered as manufacturers according to article 15 of the Regulation (EU) 305/2011, when they repackage bulk products in small packages of e.g. 4-5 kg and place them on the market, either under their own name or nameless.

    

2. Furthermore, manufacturers should ensure that construction products, which they have placed on the market, are in conformity with their declaration of performance or in compliance with other applicable requirements in this Regulation. Otherwise they should ensure their withdrawal or their recall according to paragraph 7 of Article 11 of Regulation (EU) 305/2011.

    

3. Therefore, repackaged products should be CE marked and accompanied by the relevant declaration of performance under the name of the economic operators concerned, as well as any other element required by the applicable system of assessment and verification of constancy of performance (AVCP), depending on the product.