Euralarm, the European association representing the electronic fire safety and security industry, has given feedback on the NLF. The association’s response to the questions of the European Commission were laid down in a Position Paper.
Improvements
Euralarm remains convinced that the New Approach and the New Legislative Framework (NLF) are the best tools to support the free movement of goods and the proper functioning of the European Single Market for Goods. The NLF in its broad setup is fit for purpose to deal with upcoming challenges through technological developments. Thus, Euralarm believes that changes should be made only in response to clear needs, within the existing framework.
Among the main benefits of the NLF Euralarm considers: strengthened coherence across different sectoral legislation, improved legal certainty, higher compliance levels, ease of compliance, improved level-playing field, strengthened CE marking use and functioning. When it comes to conformity assessments, Euralarm strongly believes that Module A, in combination with an effective market surveillance, provides a good and fair level playing field for manufacturers. The combination of modules (particularly the use of Module A, self-assessment), acceptable time to market and good market surveillance system is an essential element of the NLF and the most effective regime to preserve safety and the level-playing-field.
The introduction of the NLF has also been beneficial for SMEs in that it has opened the EU market to them, thanks to the use of hENs and module A. Having a stronger Single Market has further benefitted the global competitiveness of European industries and it has improved the speed of adoption of state-of-the-art technologies, as compared to the old approach. The NLF has set the basis for a strong market surveillance system, notably by providing for a Union framework for market surveillance comprising both competencies and obligations for national authorities and by organising effective administrative cooperation between these authorities on the one hand and with the EU Commission on the other hand.
In the Euralarm Position Paper Euralarm further explains its position towards CE marking itself, harmonised standards, conformity assessment procedures, notified bodies, the accreditation system and digitalisation of the information.
Based on this position, Euralarm believes that a full revision of the NLF might not be necessary to address problems with specific legislation.
The Euralarm Position Paper on NLF evaluation can be downloaded here.
About Euralarm
Euralarm represents the electronic fire and security industry, providing leadership and expertise for industry, market, policy makers and standards bodies. Our Members make society safer and secure through systems and services for fire detection and extinguishing, intrusion detection, access control, video monitoring, alarm transmission and alarm receiving centres. Founded in 1970, Euralarm represents over 5,000 companies within the fire safety and security industry valued at 67 billion Euros. Euralarm Members are national associations and individual companies from across Europe.
For more information, go to www.euralarm.org
