Eurovent holds that an effective market surveillance is essential in order to ensure a level playing field and to protect the Common Market from non-compliant products. Within the general scope of the Ecodesign Directive, we believe that a flexible use of different modules for conformity assessment procedures as outlined within Decision 768/2008 can be an aide to effectively strengthen market surveillance. While a discussion on this subject should ideally be held on the level of the framework directive as this topic affects all implementing measures of the Ecodesign directive, we strongly encourage the Commission to assess solutions for conformity assessment on a case by case level. Only this can ensure that conformity assessments are executed in a manner, which is most efficient for individual and differing product groups.
Concerning fans, Eurovent agrees that the principle of self-declaration of conformity followed by market surveillance as adopted by the current ‘EU Fan Regulation’ remains appropriate and should be kept in the revised version.