FAQs on the European Technical Assessment (ETA)
Last updated: September 2019
As one of Europe's leading Technical Assessment Bodies, DIBt receives queries related to the European Technical Assessment (ETA) on a daily basis. We have compiled a list of the most important questions and their answers here. This list of questions and answers reflects DIBt's views and practices and is continuously evolving. We would be pleased to incorporate your suggestions and questions. Names of our ETA contacts are given at the right column of the website.
I. Basic information … How to obtain an ETA
I.1 What is an ETA?
A European Technical Assessment – or 'ETA' for short – is a document in which the performance of a construction product is assessed in relation to its essential characteristics. This assessment is carried out by a Technical Assessment Body which has been designated by the authorities for this purpose and whose technical competence and independence have been proven.
The ETA provides a route to CE marking for construction products that are not or not completely covered by a harmonised standard. The legal basis for the ETA procedure is the European Construction Products Regulation (Regulation (EU) No 305/2011, particularly Articles 19 and 26); the Construction Products Regulation has the rank of a European act with direct applicability in the Member States.
I.2 What is an EAD?
The European Technical Assessment (ETA) is issued on the basis of a technical specification containing the relevant assessment methods. This specification is called a European Assessment Document – or 'EAD' for short.
Like harmonised standards, EADs are considered to be harmonised technical specifications.
I.3 For which products can I request an ETA?
An ETA request can be submitted for all construction products within the meaning of the Construction Products Regulation which are not or not completely covered by a harmonised standard published in the Official Journal of the European Union.
Construction products within the meaning of the Construction Products Regulation are products that are intended for incorporation in a permanent manner in construction works and whose performance is relevant in relation to the fulfilment of the basic requirements for construction works (cf. Article 2 of the Construction Products Regulation).
I.4 What are the basic requirements for construction works?
The Basic Works Requirements (or 'BWR' for short) are described in Annex I of the Construction Products Regulation. The Construction Products Regulation distinguishes seven basic requirements:
- mechanical resistance and stability (BWR 1),
- safety in case of fire (BWR 2),
- hygiene, health and the environment (BWR 3),
- safety and accessibility in use (BWR 4),
- protection against noise (BWR 5),
- energy economy and heat retention (BWR 6) and
- sustainable use of natural resources (BWR 7).
These basic requirements result from the building provisions of the Member States.
I.5 Can an ETA be issued if a harmonised standard is being prepared?
Yes. Especially if the standardisation process has come to a halt, this can be a good path to take.
I.6 Can an ETA be used to cover characteristics missing from a harmonised standard?
Yes. An ETA can be useful to show that the performance of the product corresponds to the requirements for a specific use in the Member States. An ETA makes it possible to match the performance to be declared to the requirements in the Member State in which the construction product is to be marketed.
Product Contact Points provide information about the requirements in the individual Member States. DIBt has been designated as the Product Contact Point for Construction (PCPC) – Germany. For further information, please refer to https://www.pcpc-germany.de/en/product-contact-point-for-construction/
A complete list of Product Contact Points in all EU Member States and for all product areas can be found at: https://ec.europa.eu/growth/single-market/goods/free-movement-sectors/mutual-recognition/contacts-list_de
I.7 Can an ETA be issued if a product can be fully assessed for the intended use in accordance with a harmonised standard?
No, in this case an ETA may not be issued.
I.8 Who is permitted to issue ETAs?
ETAs may only be issued by Technical Assessment Bodies designated for this purpose by a Member State. DIBt has been designated as a Technical Assessment Body in the Construction Products Act (Bauproduktengesetz). Technical Assessment Bodies are often referred to as 'TABs'. They are to be distinguished from notified bodies which assume other tasks under the Construction Products Regulation (see question III.5).
I.9 How do I obtain an ETA?
I.10 Is the ETA voluntary?
Yes. An ETA is only issued upon request. However, if the manufacturer places a construction product for which he has obtained an ETA on the market, use of the ETA is no longer optional. The manufacturer is then obliged to draw up a declaration of performance and affix the CE marking to the product (see question I.17).
I.11 How much does an ETA issued by DIBt cost?
The costs for an ETA are comparable to those for a national technical approval.
I.12 How long does it take to prepare an ETA?
The processing time for an ETA depends on the complexity of the product and the testing requirements; usually you will be looking at a processing time of a couple of months.
If no EAD has been developed for the product area in question yet, an EAD will first be prepared (see question I.2). The Construction Products Regulation allows a processing time of 9 months maximum for this procedure.
I.13 How long is the ETA valid for?
European Technical Assessments are valid for an unlimited duration.
I.14 Where is the ETA valid?
The ETA is valid in the EU, the Member States of the European Economic Area (Iceland, Liechtenstein and Norway) and in Switzerland and Turkey.
I.15 Who can apply for an ETA?
Any manufacturer. However, the 'manufacturer' within the meaning of the Construction Product Regulation is not necessarily the person who physically manufactures the product. Anyone who has a construction product manufactured and marketed under his or her own name or tradename is considered to be a manufacturer under the Construction Products Regulation and thus has all the associated rights and obligations.
For more information, please refer to the FAQ Catalogue – Construction Products Regulation and Market Surveillance issued by the German market surveillance authorities and DIBt.
I.16 What are the advantages of an ETA?
The ETA offers manufacturers the opportunity to market their products all across Europe with the CE marking even if the products are not or are only partially covered by a harmonised standard. The ETA can also be used if essential characteristics are not reflected in the harmonised standard or the harmonised standard does not provide an appropriate assessment method. The ETA can hence be tailored to your product.
I.17 Which obligations result from an ETA?
The ETA holder is obliged to draw up a declaration of performance and affix the CE marking to his product when placing it on the market.
The ETA is also linked to a system of assessment and verification of the constancy of performance (AVCP) – still known to many manufacturers under the former name of 'attestation of conformity procedure' (please also see Chapter III).
I.18 What do I as a manufacturer have to heed in relation to CE marking?
Good and precise answers to questions related to CE marking are provided in the FAQ Catalogue – Construction Products Regulation and Market Surveillance issued by the German market surveillance authorities and DIBt.
I.19 Harmonised standards must be applied by all manufacturers after a certain transition period (coexistence period). Does this also apply to EADs?
No. The fact that an EAD has been developed for a product area at the request of a manufacturer does not impose any obligations upon other manufacturers. The EAD/ETA route to CE marking is optional (cf. question I.10). However, many manufacturers are happy to make full use of the advantages of the ETA which allows them to market their product throughout Europe.
II. What happens during the ETA or EAD procedure?
II.1 What happens during the ETA procedure?
II.2 Who are your partners in the ETA procedure?
DIBt is your direct contact for all ETA matters. However, there are other actors playing background roles in the preparation of an ETA and (if applicable) an EAD.
The other European Technical Assessment Bodies designated for the product area in question contribute their technical and building supervisory expertise to the EAD and ETA development process via the EOTA consultation procedure. EOTA is the European Organisation for Technical Assessment.
The role of the European Commission includes adopting AVCP decisions (see Chapter III) and publishing the EAD references in the Official Journal of the European Union.
DIBt liaises with the European partners on your behalf.
II.3 Which tests do I have to have performed?
A glimpse into the technical specification serving as the basis for the ETA, i.e. the EAD, will give you an idea of the scope of testing. If no EAD is available for your product yet, we will develop it in coordination with you (please also see question I.2).
Please discuss the tests with us before commissioning them to avoid unnecessary tests and costs.
II.4 Which testing laboratory can I use?
DIBt recognises documents from testing laboratories that are independent and possess the necessary expertise and equipment. We would be pleased to advise you in this matter.
II.5 Can tests which have already been carried out be recognised?
This can only be determined on a case-by-case basis. You are welcome to include test reports from tests already carried out with your ETA request form. In general we recommend that you discuss the tests in advance with DIBt.
II.6 Do I need to have all essential characteristics stated in the EAD assessed?
No. As the manufacturer, you can decide to not have certain characteristics assessed, e.g. if they are not relevant for a specific region or a specific intended use. 'NPD' (for 'No Performance Determined') must then be stated in the declaration of performance for these characteristics.
In our experience it is important that the ETA provides all relevant information. The ETA only offers the user and you an advantage if the user can immediately see from the ETA whether he or she can use your construction product in accordance with the national building requirements. Please do not hesitate to contact us if you have any questions related to this.
II.7 Can the EAD be extended to include additional characteristics?
Yes. Additional essential characteristics can be incorporated into the EAD upon request by the manufacturer. In this way the EAD can be tailored to your construction product. We would be pleased to advise you.
II.8 How is product performance declared in the ETA?
In accordance with the Construction Products Regulation the performance can be given as a description (e.g. in the form of a value) or in the form of performance levels or classes.
II.9 Can the EAD include several assessment methods for one essential characteristic?
Not normally. However, in justified cases, the European Commission accepts the coexistence of different methods for assessing the performance related to a single essential characteristic.
II.10 Does the EAD only contain assessment methods, or does it also include requirements?
An EAD contains methods for assessing product performance as well as information about how the performance should be declared. The performance requirements for the use of the product result from the national building provisions.
II.11 What happens if I want to modify my product? Do I also need to have the ETA amended?
Yes, in this case the ETA, and possibly the EAD, needs to be adapted.
II.12 What are the possible reasons for amending an EAD?
There are a number of form- and content-related reasons for changing an EAD: for example, amendment of the AVCP decision, revision of the referenced standards and technical rules or inclusion of a new essential characteristic at the request of a manufacturer.
II.13 How can I find out which is the current version of an EAD?
Information pertaining to the current version of a given EAD can be found on the EOTA website. The full-text document is available there.
II.14 How does a change in the EAD affect the execution of the AVCP system?
A third-party body is notified for a specific version of the EAD. As a result, the notified body must be renotified if there is a new version. As long as there are no significant changes to the requirements for the notified body, renotification will be quick and simple.
II.15 What is a kit?
The Construction Products Regulation defines a 'kit' as a construction product that is placed on the market as a set by a single manufacturer. A kit consists of at least two separate components that need to be put together to be incorporated in the construction works.
II.16 How does a 'kit' in accordance with the Construction Products Regulation differ from a 'construction technique' in accordance with the Building Codes of the federal states (Landesbauordnungen)?
A kit is a construction product made up of several components, whereas a construction technique describes the construction process, i.e. the assembly of (different) construction products to form structures or parts thereof.
III. After an ETA has been issued … The AVCP procedure
III.1 What is an AVCP system?
The acronym 'AVCP' stands for 'assessment and verification of constancy of performance'. The AVCP systems replace the attestation of conformity procedures under the Construction Products Directive.
Within the framework of the AVCP systems, the performance of the construction product is assessed and factory production is monitored to ensure precise and reliable product performance information.
III.2 Which AVCP systems exist?
The different AVCP systems are described in Annex V to the Construction Products Regulation. There are five AVCP systems. All systems at least comprise:
- the setup and application of a factory production control system by the manufacturer and
- assessment of product performance.
The systems differ according to the extent to which notified bodies (see question III.5) are to be involved in the assessment and verification of the constancy of performance.
- No notified body is necessary in system 4; all tasks are assigned to the manufacturer.
- In system 3, a notified testing laboratory assesses the product performance.
- In system 2+, a notified certification body monitors the factory production control.
- In systems 1 and 1+, a notified product certification body assesses the product performance and monitors the factory production control. In system 1+, the notified body also carries out audit-testing at regular intervals.
III.3 Can the AVCP system be selected freely? Would it be possible to define a different AVCP system in the EAD than the one specified in the harmonised standard for the same product area?
No. The AVCP system is determined by the European Commission through a delegated act. The European Commission considers the importance of the product or an individual essential characteristic with respect to the fulfilment of the basic requirements for construction works. The definition applies to all relevant harmonised technical specifications.
III.4 Can different AVCP systems be applicable for different essential characteristics in an EAD?
Yes. For example, AVCP system 1 can apply to the reaction to fire of the product and system 4 to all other essential characteristics.
III.5 What are notified bodies?
Notified bodies are bodies authorised to carry out tasks of an independent third-party in the process of assessment and verification of the constancy of performance of construction products.
The Member State notifies those bodies to the European Commission and the other Member States. The notifying authority for Germany is DIBt. Further information on the notification procedure for these bodies can be found on the DIBt website.
Whether you as the manufacturer need to contract a notified body for the assessment and verification of the constancy of performance results from the AVCP system specified in the EAD or harmonised standard (see question III.2).
III.6 How can I find a notified body to carry out the AVCP tasks for my construction product?
The notified bodies for each harmonised technical specification are listed in the European Commission's NANDO database for information purposes.
III.7 How quickly can a body be notified for a new EAD?
A body can only be notified formally via the NANDO list when the EAD has been incorporated into the NANDO list maintained by the European Commission.
Here is what you can do to contribute to more rapid notification: supply a consolidated version of the EAD to a competent body of your choice. (We are not authorised to do this ourselves.) The body can become accredited for the relevant activity based on this version. The body then submits the accreditation along with the application for notification. Within the framework of the notification procedure we verify whether the accreditation is suitable as proof of competence. It usually is so that the body can be notified quickly.
III.8 What are the consequences of not having a notified body for an EAD?
In certain cases this means that the declaration of performance cannot be drawn up and the CE marking cannot be affixed to the product. This applies if AVCP system 1+, 1 or 2+ is defined for the products covered by the EAD as these systems require an initial inspection of the manufacturing plant, continuing surveillance of the factory production control and certification by a notified body (see question III.2).
III.9 Will a body which has been notified for an EAD be capable of verifying all essential characteristics specified in an EAD?
The notified body is notified for the EAD, and in some cases for the specific intended use, and must hence be able to verify all relevant essential characteristics. It can call upon subcontractors for this.