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General

Consultation Forum Sub-Groups on EPREL – Suppliers and MSA (GEN – 952.00)

18 October 2018

4 min read
European Policy
General

Consultation Forum Sub-Groups on EPREL – Suppliers and MSA (GEN – 952.00)

18 October 2018

4 min read

GEN – 952.00. The European Commission is speeding up the development of EPREL. By the end of November, most, if not all functionalities should become available. Manufacturers are recommended to test the database system.

Introduction: 1 January 2019

In response to the questions regarding article 4 of regulation 2017/1369 and the applicability of the date of 1 January 209 when data should have been entered in the public and compliance parts of the product database (EPREL) the Commission indicated that it cannot modify the text of the Regulation. The date of 1 January 2019 remains the only formal reference as it is the date published in the regulation.

The Commission is confident that EPREL, or at least a part of it, would be operational on 1 January 2019. 

The Commission expects that e-delivery will be functional by February 2019, and hopefully the System to System (S2S) uploading. A consequence will be that access to EPREL by the public and Market Surveillance Authorities will not be available on 1 January 2019. Indicatively EPREL could be accessible from around April. It will depend on the smooth development of the supporting IT tools.

The Commission expects that Member States will handle the situation sensible. Ten out 28 Member States were present at the meeting (!). Handling the situation sensibly would indicate that Member States would only start using EPREL for market surveillance when it is fully operational. Informally the Commission will update the Member States on the status of EPREL during the informal ADCO (Administrative Cooperation) meeting tentatively scheduled for 22 November 2018.

The Commission expects that meanwhile industry uploads data/tests EPREL by that date and gets experience with EPREL.

It was remarked by many associations that the many Small and Medium-sized Enterprises will encounter severe problems with entering data, not considering that many SMEs may not even be aware of the Regulation. Many SMEs are not even member of an association that can inform them.

The Commission is aware of this fact but cannot provide any help to SMEs. These companies must respect all legislation. In the case of EPREL they will have to develop their IT and XML tools. Positive is that the Commission has announced it will develop freely accessible tutorials so that companies can get acquainted with EPREL. The Commission will not set up a communication campaign, this is where Member States and associations have a role.

Registration site (see GEN – 952.01)

Using the “Registration site” presentation the Commission explained the changes that have taken place to the existing and the expected timing.

DG ENER has added the prototypes for EPREL for the following product categories:

  • Air conditioners (Label and information sheet generation not yet implemented)
  • Professional refrigerated storage cabinets (idem)
  • Residential ventilation units (idem)
  • Solid fuel boilers (idem)
  • Packages of a solid fuel boiler (idem)
  • Household refrigerating appliances (idem)

To log in the supplier must create his personal EU login. This can be done, free of charge, through the European Commission Authentication Service: https://webgate.ec.europa.eu/cas/eim/external/register.cgi?loginRequestId=ECAS_LR-560641-1CCANZhlFMI4y8zM1ROMYlzQQgruHlOpcBgNTAzkaTzuaechk0fQw3TTu3b57KpkoUnBUczOX4JuRaVrPV3zWvoG-PHslUMVSXYCPUzqqAgtuhU-T2VPzcl4fMizv6OX55aS8dL8GgLw1Gx0yJEYwxJGlvOW

You will then be able to the manufacturers that have Link to EPREL test environment: https://webgate.acceptance.ec.europa.eu/eprel/compliance/screen/product/home.

One can then create the “supplier organisation” with the role of administrator.

At present the test environment tis not yet secured!

According to the presented timing, “supplier organisations” will be able to register products from 14 December 2018 when the EPREL “production phase” goes life. In first instance this would be manual 

There are three phases/environments:

PILOT

This is a basic environment where the new functionalities can be tested. It is an unsecured testing environment and is functional at present for manual uploads.

ACCEPTANCE

This is a more robust environment that simulates the real PRODUCTION. When functionalities have been tested in PILOT, they will be deployed in ACCEPTANCE for further serious test. This environment should become operational on 30 October for 14 Product Groups and should be a secured environment so that testing with real data can take place.

PRODUCTION

This is the real environment where suppliers will enter data according to the regulatory requirements and would go life for most products on 14 December 2018 (for some others it would be February 2019).

To note is that re-registering will be necessary when moving from one phase to the next! Only manual uploads are possible but uploading System to System (S2S) would be possible from December 2018.

Implementing Act (see GEN – 592.02 &.03)

The Commission has copied ideas for this Implementing Act from those used for the Waste of Electric and Electronic Waste. It is yet incomplete and feedback from industry is welcome, also with regards as to whether such an implementing at would be needed.

Elements of note are the definition of the authorised representative and the concept of single registration in the EU.

Comments are awaited by 16 November 2018.

Recommended actions

Manufacturers concerned by EPREL should at least make sure that their IT departments are aware of it. Thea are recommended to test the prototype in the Pilot phase.

Because of the time constraints and possible bugs that could be encountered it is useful to look at the various aspects carefully. 

It may prove useful for the Product Groups to test the database in one of their meetings.

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