DOCUMENTS
 Country
Report Expertise Centre
COUNTRY REPORT 2006 - 2007
4 Closing
seminar on implementation of specific directive
4.1
Workshop I: Machinery, LVD,
EMC, Lifts
4.1.1 Introduction
At the seminar the invitation
to this workshop on Machinery, LVD, EMC and Lifts directives
specified the following questions of interest to be discussed:
What needs to been done
to make it work properly with
regards to
Ø
Implementation of Legislation
and Regulations;
Ø
TBT matters, import/export
regulations;
Ø
Testing services, availability
and capacity;
Ø
Certification services, availability
and capacity, Notified Bodies;
Ø
CE-marking, understanding and
acceptance;
Ø
Market Surveillance, implementation
and efficiency;
Ø
Consumer related issues, awareness;
Ø
Market awareness
Ø
Other possible issues.
4.1.2 Discussion
11 of the seminar participants joined this workshop, representing:
industry 3, ministries 3, UME 3, TSE 1 and Chamber of Mechanical
Engineers (also consultant) 1.
The workshop discussions raised topics on testing of imported products
from third countries, non-operational status of Notified Bodies
(NBs), problems for market surveillance caused by the law
on public procurement, low awareness
of CE-marking amongst manufacturers, unfair competition from
manufacturers not applying CE-marking, misunderstanding of
CE-marking as a quality mark, distribution of information
from market surveillance, need of access to the RAPEX system
and further matters.
The outcome from the workshop was in short presented to the seminar
and the seminar participants put further related questions,
some of which were:
Q 1: How to judge products
without CE-marking? A: Such products are not necessarily unsafe,
but they are in non-compliance with the directive and thus
illegal to put on the market. Market surveillance should take
actions towards the responsible domestic manufacturer or importer.
Q 2: It is a problem that
products without CE-marking and possibly unsafe products are
sold via Internet. A: Internet is a part of the market and
should be subject to market surveillance. In principle there
should be an authorised representative/importer in Turkey
also for those products.
Q 3: Market surveillance
is partly based on complaints on products, but Turkey is in
lack of international cooperation in market surveillance and
should have access to the full information from RAPEX system.
A: Complaints and other indications on unsafe products help
to improve the efficiency of market surveillance and so make
the exchange of information between authorities in different
countries. However, some foreign information may be difficult
to apply, when the manufacturers use different identification
of a product aimed for different markets.
Q 4: Two mandatory standards
were indicated for lifts, when would they be removed? A: They
were in the list of mandatory standards, but new information
tells that they already are removed.
Q 5: The workshop stated
that Turkey requires more capacity to test products under
the LVD and machinery directives. Did the workshop discuss
how to solve the problem? A: No, the task of the workshop
was to identify problems, not directly to solve them. However,
there is limited testing capacity besides TSE, especially
related to LVD-products. The Turkish market would benefit
from further actors to create a competitive market that adjusts
itself to market needs.
Q 6: Consumers organisation
representative expressed the opinion that at the end all products
are consumer products, including construction material. A:
That opinion was just noted.
4.1.3 Conclusions
The summary conclusions
from the workshop and the questions from the seminar are:
The following actions are
needed to make the market work properly in the area of Machinery,
LVD, EMC and Lifts directives:
Ø
Implementation of Legislation
and Regulations;
·
The Public Procurement Law
in line with the EU legislation causes problems for the Market
Surveillance Authorities which are forced to buy testing services
to meet an unforeseeable need of tests.
·
Product testing and periodical
inspection of lifts are combined in one Turkish regulation
that preferably should be split up in two.
Ø
TBT matters, import/export
regulations;
·
The implementation of Council
Decision 339/93 on Control of Conformity of Products from
Third Countries needs to be finalised.
·
Opinions like “Import increases
more than export!/One-sided issues of directives” indicate
need of information on market mechanism in the short and long
term perspectives.
·
The problem of products without
CE-marking transferred through EU-countries should be due
to Turkish discussions with the relevant EU country to reach
a bilateral agreement.
Ø
Testing services, availability
and capacity;
·
Products under the LVD and
Machinery directives require more testing capacity in Turkey,
why private initiatives should be promoted, for instance by
being engaged by MIT in market surveillance testing.
Ø
Certification services, availability
and capacity, Notified Bodies;
·
An agreement between Turkey
and the EU Commission needs to be reached to make the first
three NBs operational and to publish further directives to
their notifications.
·
Further NB applications should
be finalised and sent to the EU Commission.
·
EA’s internal assessment procedure
needs to create confidence in system certification.
·
Besides the use of the H module
for Lifts also unit verification will be needed.
Ø
CE-marking, understanding and
acceptance;
·
Further awareness campaigns
are needed to improve both manufacturers’ and consumers’ knowledge
on CE-marking, the necessity of CE-marking also within Turkey
and also to eliminate the misunderstanding of CE-marking being
a quality mark.
Ø
Market Surveillance (MS), implementation
and efficiency;
·
MS should ensure that all
·
manufacturers apply CE-marking
and thus eliminate the risk of unfair competition when manufacturers
possibly save costs or even sell unsafe products.
·
MS activities must include
the Internet market as part of the market.
·
MS activities could well be
used to help private conformity assessment bodies to grow.
·
Turkey
should enforce its attempt to reach full access to RAPEX information.
·
Information on unsafe products
should be published on Turkish Website(s).
Ø
Consumer related issues, awareness;
·
Consumers’ organisations are
weak. With financial support from the Government they could
engage more members, be more active in product safety matters
and play a more important roll in the co-operating with MIT
in consumers right matters.
·
Awareness campaigns are needed
to improve consumers’ knowledge on product safety.
Ø
Market awareness
·
The knowledge is insufficient
amongst both manufacturers and consumers on the EU principles
regarding both safety issues and CE-marking.
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