The new DoP. Declaration of Performance. Construction Product Regulation. latest information on standardization. Ralf Podleschny.

Similar documents
Guidance Note on the Construction Products Regulation

Construction Products Regulation

Georgios Katsarakis Europäische Kommission

DECLARATION OF PERFORMANCE

The Danish Energy Agency will carry out inspections in October We will check the CE marking of the smoke alarms you sell or use.

Policy Briefing. Frequently Asked Questions on the Construction Products Regulation and CE marking. December Background

Your essential guide to CE Marking

Fire safety in buildings and implementation of European fire test standards

Quality Regulations for Profiles

European Technical Approval ETA 13/0526

Page 1 of European Technical Approval ETA-12/0495

Assessment Report Construction Product Regulation* * CPR - REGULATION (EU) No 305/2011

Rakennustuotedirektiivin (89/106/EEC) artiklan 10, neuvoston direktiivi 21. joulukuuta 1988, mukaisesti notifioitu tuotehyväksyntälaitos EOTAN JÄSEN

European Technical Approval ETA-12/0500

Regulation (EU) No 305/2011 (CPR) and its mechanisms and potential consequences on environmental and sustainability tools in the construction sector

European Technical Assessment ETA-10/0153 of 10/06/2015

European technical approval

Module 7. CE marking of Vehicle Restraint Systems EN Göran Fredriksson, SSBA

European Technical Assessment. ETA-02/0020 of 22 September English translation prepared by DIBt - Original version in German language

CE mark now! Mandatory CE marking of construction products 1 July 2013

Eurooppalainen tekninen hyväksyntä ETA - 13/0613 European Technical Approval

Page 1 of European Technical Approval ETA-08/0018

Rakennustuotedirektiivin (89/106/EEC) artiklan 10, neuvoston direktiivi 21. joulukuuta 1988, mukaisesti notifioitu tuotehyväksyntälaitos EOTAN JÄSEN

European Organisation for Technical Approvals

Page 1 of European Technical Approval ETA-09/0129, Issued on September 26, 2011, valid until June 3, 2014

Testing Rules for Thermal Conductivity October 2015

AVERTISSEMENT Vous trouverez ci-dessous la version française de ce Guidance Paper suivie de la version anglaise

Sealfire W1000 Compound. (2 references for the same product) Fire Stopping and Sealing Product: Penetration Seals

ETAG 016 SELF-SUPPORTING COMPOSITE LIGHTWEIGHT PANELS. (Part one : G E N E R A L)

Certification of construction products - Fire dampers. Certification Rules 032

Europeiskt Tekniskt Godkännande European Technical Approval

European Technical Assessment ETA-15/0652 of 27/10/2015

How To Write A European Technical Assessment

European technical approval

Rakennustuotedirektiivin (89/106/EEC) artiklan 10, neuvoston direktiivi 21. joulukuuta 1988, mukaisesti notifioitu tuotehyväksyntälaitos EOTAN JÄSEN

Guidance from the Group of Notified Bodies for the Construction Products Directive 89/106/EEC. GNB-CPD position paper from SG17 - EN :2009

European Technical Approval ETA-10/0153

The Danish Enterprise and Construction Authority to inspect CE marking of windows and pedestrian doors

Authorised and notified according to Article 10 of the Council Directive 89/106/EEC of 21 December 1988 on the

At Ancon, it s all part of the service

European Technical Approval ETA-06/0259

European Technical Approval ETA 13/0384

DECLARATION OF PERFORMANCES N ETCH 01A EN

CE marking of steel elements according to EN

DIRECTIVE 2014/32/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

Scheme rules for thermal insulation products for building equipment and industrial installations - VDI certification scheme

Scope of EN Clarification Document

Infrastructure Steel in Norway; Requirements and Specifications

European Technical Approval ETA-10/0124

PUBLICATIONS. Introduction

European Technical Assessment ETA-15/0028 of 23/02/2015

WORKING DOCUMENT FOR SCC CONSULTATION CONSTRUCT09/874 EUROPEAN COMMISSION ENTERPRISE AND INDUSTRY DIRECTORATE-GENERAL

EA Document on. Accreditation. For Notification Purposes

Europeiskt Tekniskt Godkännande European Technical Approval

Steel procurement in major projects: Guidance on the application of social issues. Purpose

DIRECTIVE 2006/95/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL. of 12 December 2006

A Revised EMC Directive from Europe

DECISIONS ADOPTED JOINTLY BY THE EUROPEAN PARLIAMENT AND THE COUNCIL

Fire Stopping and Sealing Product: Penetration Seals

Position paper on the CE-marking of sanitary and building valves

European Technical Approval ETA-04/0013

Mandate M/116 MASONRY AND RELATED PRODUCTS

EUROPEAN TECHNICAL APPROVAL ACCORDING TO ETAG EXPLANATIONS -

ETAG 011 LIGHT COMPOSITE WOOD-BASED BEAMS AND COLUMNS

Product Data Sheet ROCKPANEL Rockclad

Europeiskt Tekniskt Godkännande European Technical Approval

Discussion on Products under the Scope of EN and proposed CEN/TR to clarify the scope

The certification of European construction products

PIPES, TANKS and ANCILLARIES not in contact with water intended for human consumption

Understanding BS EN 771-3: Aggregate concrete masonry units

(English language translation, the original version is in Czech language) DEWALT PTB-PRO. DeWalt Black-&-Decker Str Idstein Germany

Equipment vs. Component

Safety Storage Cabinets

CERTIFICATE NAME OF PRODUCT MANUFACTURER PRODUCT DESCRIPTION CERTIFICATION PROCEDURE. No VTT C Date of issue , Updated July 1, 2011

THE CONSTRUCTION PRODUCTS DIRECTIVE (COUNCIL DIRECTIVE 89/106/EEC)

DISCUSSION PAPER ECODESIGN FOR ENERGY RELATED PRODUCTS INTEGRATED INTO OTHER ENERGY RELATED PRODUCTS

EXTENSION OF PERIODIC INSPECTION INTERVAL FOR LPG CYLINDERS

ETAG 004 EXTERNAL THERMAL INSULATION COMPOSITE SYSTEMS WITH RENDERING

Eurooppalainen tekninen hyväksyntä ETA-12/0045 European Technical Approval

General Description of The CMC- Services

(English language translation, the original version is in French language) SPIT HIT M. Société SPIT Route de Lyon F BOURG-LES-VALENCE France

Initial Type Testing Report

Rockwool Cladding Roll

The European Union s EMC Directive 2014/30/EU. Ross Carlton, Sr. EMC Engineer National Instruments

European Technical Approval ETA-10/0200

European Technical Approval ETA-08/0121

NEW AND GLOBAL + OLD APPROACH PRODUCT LEGISLATION: A. Standard questionnaire to be filled for each sector individually:

Manual for ITC's clients, Conformity assessment of ACTIVE IMPLANTABLE MEDICAL DEVICES pursuant to Council Directive 90/385/EEC

European technical approval

A Guide to the European Standard for Safety Storage Cabinets (BS EN )

DOCUMENT CAESAS/1: SCHEME DESCRIPTION AND BENEFITS

Wheatley Hall Road, Doncaster, DN2 4NB, United Kingdom

STEEL CONSTRUCTION CE Marking

Transcription:

The new DoP Declaration of Performance Construction Product Regulation and latest information on standardization Ralf Podleschny

New: Assessment and Verification of Constancy of Performance (AVCP) (old: Attestation of Performance, AoC) Clear separation between the: Certification of the product Certification of the Factory Production Control Slide 2

Systems of Assessment and Verification of Constancy of Performance Manufacturer Tasks Initial Type Testing of the product Determination of the product-type on the basis of type testing (including sampling), type calculation, tabulated values or descriptive documentation of the product Further testing of samples taken at the factory in accordance with the prescribed test plan Factory Production Control Systems 1+ 1 2+ 2 3 4 Notified Body Initial Type Testing of the product Determination of the product-type on the basis of type testing (including sampling), type calculation, tabulated values or descriptive documentation of the product Audit-testing of samples taken before placing the product on the market Initial inspection of the manufacturing plant and of factory production control Continuous surveillance, assessment and evaluation of factory production control Slide 3

General Information: Mandatory since: 01.07.2013. Immediately legally binding. Construction products placing on the European market after 01.07.2013 have to comply with the CPR 1 Superior goals: 2 3 4 5 6 Reduction of trade barriers Free market Placing construction products on the market Slide 4

General Information: Content of CPR: EU-wide harmonized product and testing standards CE-marking and Declaration of Performance (DoP) Member states have to accept CE-marked products without any hindrance, but member states are allowed to regulate the application The declaration of performance shall be supplied in the language or the languages required by the Member State where the product is made available (Art. 7,4) Slide 5

Changes: CPD CPR OLD Construction Product Directive (CPD) NEW Construction Product Regulation (CPR) 6 essential requirements 7 basic requirements Declaration Mechanical of Conformity resistance and Declaration stability of Performance (DoP) National Safety Approval in Bodies case of fire Technical Assessment Bodies (TAB) Hygiene, EOTA health and the environment Organization of TABs Safety and accessibility in use ETAG and CUAP European Assessment Documents (EAD) European Protection Technical Approval against noise European Technical Assessment (ETA) (ETA) Implementation Energy individually economy in and heat retention Immediately mandatory in member states member states Sustainable use of natural resources Slide 6

Changes because of CPR: Significance of CE-marking As of today the manufacturer has to document by the CE-Mark Manufacturer that he takes the responsibility for the conformity of the product with the declared performance (DoP) as well as the compliance with all applicable requirements laid down in the CPR and in other relevant Union harmonization legislation providing for its affixing. CE-marking has to be based on the DoP Content of DoP results from the harmonized technical specifications (hens, e. g. EN 14509, EN 14782, EN 1090-1; or ETAs) Slide 7

Changes because of CPR: Definition of economic operators Manufacturer Authorised representative Importer Distributor Slide 8

Changes because of CPR: Definition of economic operators Manufacturer: Fabricates the product, distributes it under his own brand, is reponsible for DoP and CE Manufacturer: Appoints an authorised representative and transfers some of his obligations to him Importer: places a product, manufactured outside of the European Economic Area, onto the European market (e. g. as an own trademark) Distributor: Makes a product available on the market (e. g. as an own trademark or with the manufacturers trademark) Slide 9

Changes because of CPR: An importer or distributor shall be considered a manufacturer for the purposes of the CPR and shall be subject to the obligations of a manufacturer pursuant to Article 11, where he places a product on the market under his name or trademark or modifies a construction product already placed on the market in such a way that conformity with the declaration of performance may be affected. Slide 10

Tasks for those responsible for placing the product on the market: Determination of application Determination of performance Declaration of performance e. g.: Structural application acc. to EN 1090-1 Self-supporting application acc. to EN 14782 Based on: Test reports, Test certificates or Calculation Product specific Declaration of Performance and Product labelling with the CE mark Slide 11

Tasks for those responsible for placing the product on the market: Commissioning of a notified body based on the system of Assessment and Verification of Constancy of Performance (AVCP) valid for the product If mandatory: Execution of external inspection and surveillance in each plant based on the requirements of the harmonized specification (EN or ETA) System Type of notified body Type of certificate 1+ 1 Certification body Certificate of constancy of performance 2+ Certification body for the Factory Production Control 3 Testing Laboratory --- 4 --- --- Certificate of conformity of the factory production control acc. to Annex V Slide 12

Obligations of the notified body: Notified bodies shall provide the other notified bodies with relevant information on issues relating to negative and, on request, positive results from these assessments and/or verifications (Art. 53.2) Notified bodies shall inform the notifying authority of the following (Art. 53.1) e.g.: any refusal, restriction, suspension or withdrawal of certificates any request for information on assessment and/or verification of constancy of performance activities carried out which they have received from market surveillance authorities Slide 13

Assessment and verification of constancy of performance (Art. 6): The declaration of performance shall express the performance of construction products in relation to the essential characteristics of those products Standards (e.g. EN 14782, EN 1090-1 or EN 14509) or ETAs define essential characteristics Such performances have to be declared which are mandatory in the state where the product is placed on the market national specialties The responsible for placing the product on the market has to declare the performance of at least 1 essential characteristic. Slide 14

CE-mark and DoP always belong together Declaration of Performance Reference number: AB-123456 (equal for DoP and CE marking) 1 Corrugated profile made of aluminium (alloy) Type: XYZ 1 0815 (number(s) of notified bodies) 2 Any Co 12345 Any City or his authorized representative in the EU 3 13 4 Reference number: AB-123456 (equal for DoP and CE marking) 5 EN 14782:2006 6 self-supporting wall covering 7 corrugated profile made of aluminium (alloy) Type: XYZ 8 Thickness x,xx mm, class 1-3 Durability Reaction to fire organic coating: Side A: XX µm, type Side B: YY µm, type Hint: At steel, details to the corrosion protection system as appropriate: corrosivity resistance class RC 2 or better A1 to F or NPD Related DoP: www.homepage.de/dop Type or Reference number: XYZ or AB-123456 2 Type or serial code or production code e.g. XYZ or IJK9876 3 e.g. Corrugated profile as wall covering acc. EN 14782:2006 4 Any Co 12345 Any City 5 or his authorized representative in the EU 6 System 3 System 4 7 The notified body NB 4711 has done the initial type testing of the product according to system 3 and issued a report to the initial type testing of the product. 8 Not relevant Manufacturer's declaration on the implementation of the initial type testing and the factory production control. 9 Declared Performance Essential requirement Performance Harmonised technical specification Thickness x,xx mm, class 1-3 acc. EN 508-2:2008 EN 14782:2006 Size tolerances complied acc. EN 508-2:2008 EN 14782:2006 Water permeability Free from holes. Visual check passed. EN 14782:2006 Dimensional change Thermal expansion coefficient: Aluminium: 24 10-6 -1 K EN 14782:2006 Dangerous substances NPD EN 14782:2006 Reaction to fire A1 to F 1 acc. EN 13501-1:2007 EN 14782:2006 Durability organic coating: Side A: XX µm Side B: YY µm Hint: At steel, details to the corrosion protection system as appropriate: corrosivity resistance class RC 2 or better acc. EN ISO 12944-2:1998 EN 14782:2006 10 The performance of the product in accordance with point 1 and 2 corresponds to the declared performance in point 9. Responsible for creating this declaration of performance is only the manufacturer referred to in point 4 (or 5). Signed on behalf of the manufacturer and in the name of the manufacturer by: (name and function) (issue place and date) (signature) Slide 15 1 Construction products according class F shall not be used in Germany; class E is at least required.

CE-mark and DoP always belong together 1 0815 (number(s) of notified bodies) 2 Any Co 12345 Any City or his authorized representative in the EU 3 13 4 Reference number: AB-123456 (equal for DoP and CE marking) 5 EN 14782:2006 Reference number the same for DoP and CE-mark 6 self-supporting wall covering 7 corrugated profile made of aluminium (alloy) Type: XYZ 8 Thickness x,xx mm, class 1-3 Durability Reaction to fire organic coating: Side A: XX µm, type Side B: YY µm, type Hint: At steel, details to the corrosion protection system as appropriate: corrosivity resistance class RC 2 or better A1 to F or NPD Related DoP: www.homepage.de/dop Type or Reference number: XYZ or AB-123456 On electronic distribution of the DoP will be decided later by the European Commission Slide 16

CE-mark and DoP always belong together Declaration of Performance Reference number: AB-123456 (equal for DoP and CE marking) 1 Corrugated profile made of aluminium (alloy) Type: XYZ 2 Type or serial code or production code e.g. XYZ or IJK9876 Reference number the same for DoP and CE-mark 3 e.g. Corrugated profile as wall covering acc. EN 14782:2006 4 Any Co 12345 Any City 5 or his authorized representative in the EU 6 System 3 System 4 7 The notified body NB 4711 has done the initial type testing of the product according to system 3 and issued a report to the initial type testing of the product. 8 Not relevant 9 Declared Performance Essential requirement Thickness Performance x,xx mm, class 1-3 acc. EN 508-2:2008 Manufacturer's declaration on the implementation of the initial type testing and the factory production control. Harmonised technical specification EN 14782:2006 Size tolerances complied acc. EN 508-2:2008 EN 14782:2006 Water permeability Dimensional change Free from holes. Visual check passed. EN 14782:2006 Thermal expansion coefficient: Aluminium: 24 10-6 -1 EN 14782:2006 K Dangerous substances NPD EN 14782:2006 Reaction to fire Durability A1 to F 1 acc. EN 13501-1:2007 organic coating: Side A: XX µm Side B: YY µm Hint: At steel, details to the corrosion protection system as appropriate: corrosivity resistance class RC 2 or better acc. EN ISO 12944-2:1998 EN 14782:2006 EN 14782:2006 10 The performance of the product in accordance with point 1 and 2 corresponds to the declared performance in point 9. Responsible for creating this declaration of performance is only the manufacturer referred to in point 4 (or 5). Signed on behalf of the manufacturer and in the name of the manufacturer by: (name and function) (issue place and date) (signature) List of essential characteristics acc. to the harmonized standard, and their declared performances Signature of the manufacturer or his authorised representative Slide 17

DoP DoP does not replace the application certificate/document Member states can define own characteristics for the application e.g. compliance with special levels or classes of performance e.g. national approvals for application DoP can be helpful to judge the performance of a product DoP has to be handed over to the end user actively DoP has to be archived on the building site by the end user Slide 18

DoP Recommendation to the manufacturer: Declaration of many essential characteristics on the DoP This promotes: Comparability of the construction products Strengthening of reliability One voice Support Transparency on the market Application in all/many member states Slide 19

Notice to distributors: Acting as a distributor (trading): Take receipt of (demand) CE + DoP Passing on CE + DoP to the client Documentation for 10 years Taking CE + DoP from the manufacturer Passing on CE + DoP abc Client 1 (abc) Client 2 (abc + xyz) Passing on CE + DoP xyz Client 3 (xyz) Slide 20

Notice to distributors: Acting as a manufacturer: Purchase of the product from the manufacturer Responsibility for all necessary tests and documents Responsibility for CE-marking and DoP Documentation for 10 years Taking over of the product from the manufacturer Responsible for tests, documents, CE + DoP Passing on CE + DoP abc Client 1 (abc) Client 2 (abc + xyz) Passing on CE + DoP xyz Client 3 (xyz) Slide 21

Obligations of manufacturers (Art. 11) can be transferred to importer or distributer totally or partially Drawing up a DoP and affixing a CE-mark DoP and publications of the manufacturers must not contain any contradictory information concerning the performances of a product Manufacturers shall keep the technical documentation and the declaration of performance for a period of 10 years after the construction product has been placed on the market. (Art. 11,2) Traceability of the construction product (11,4) Product recall in case of non-conforming products (Art. 11,3) Where the product presents a risk, manufacturers shall immediately inform the competent national authorities of the Member States (Art. 11,7) Obligation to provide information to national authorities where requested (Art. 11,8) Slide 22

Obligations of manufacturers (Art. 11) can be transferred to importer or distributer totally or partially When making a construction product available on the market, manufacturers shall ensure that the product is accompanied by instructions and safety information in a language determined by the Member State concerned which can be easily understood by users. Slide 23

Obligations of Distributors (Art. 14) For CE-marked products Checking of CE marking Checking of the correct product name Checking the identity of reference number on CE marking and DoP Distribution of DoP and accompanying documents Distributor acts as a manufacturer where he places a product on the market under his name or trademark or modifies a construction product already placed on the market in such a way that conformity with the declaration of performance may be affected (Art. 15). Slide 24

Obligations of Importers (Art. 13) Tasks and obligations of an importer are a between those of a manufacturer and a distributor The importer: shall place on the market only construction products which are compliant with the applicable requirements of the CPR shall check that the manufacturer fulfils his obligations Importer acts as a manufacturer where he places a product on the market under his name or trademark or modifies a construction product already placed on the market in such a way that conformity with the declaration of performance may be affected (Art. 15). Slide 25

Recommendations to the designer / end user Early determination of the application of the product Knowledge about and definition of the product performances Communication with the person who places the products on the market Communication with the installer EN 1234 Application EN 5678 Performance 1 Performance 2 Performance 3 Slide 26

Tasks and obligations of the Designer /end user The Designer / end user: can choose the construction product on the basis of the declared performance has to compare the DoP with the performance required by the design has to collect the DoPs and CE-marks for documentation Slide 27

Recommendations to the installer Early knowledge about the application of the product Comparison of the product performances and the requirements Communication with the designer Communication with the Building owner /architect Collection of DoPs and handover to the building owner / architect Slide 28

Tasks and obligations of the installer The installer can require a DoP Comparison of the product performances and the requirements Collection of DoPs and CE marks and documentation of them Slide 29

Product Contact Points (Art. 10) To improve the free movement of goods within the European Union, Product Contact Points have been set up in the Member States. The purpose of these Product Contact Points is to facilitate access to the national market for economic operators of other Member States (EU 764/2008). Member States shall designate Product Contact Points for Construction: Finland: France: Ministry of the Employment and the Economy Ministère du redressement productif Direction Générale de la compétitivité, de l industrie et des services (DGCIS) Germany: BAM Federal Institute for Materials Research and Testing UK: Department for Communities & Local Government Building Regulations & Standards Division Slide 30

Market Surveillance The member states have to set up market surveillance authorities. Cooperation with the customs Random inspections at the distributor or at the manufacturer Physical control and testing of products Formal control of marking and documentation Imposition of fines Slide 31

Future changes of the CPR (by delegated acts) Delegated Act in preparation: Annex III (form and content of DoP) Annex V (Assessment and Verification of Constancy of Performance) at the moment no bodies notified Art. 7.3 (electronic provision of DoP in the internet) If the EC will allow electronic provision, high performances regarding safety of IT will be required (prevention of changing a DoP once placed on the website) Slide 32

Further information Slide 33

Latest information on standardization Profiled sheets and liner cross sections Sandwich panels Slide 34

Profiled sheets and linear profiles Mandat e 120 STRUCTURAL METALLIC PRODUCTS Mandate 121 Mandate 122 INTERNAL and EXTERNAL WALL ROOF COVERINGS, and CEILING FINISHES ROOFLIGHTS, ROOF WINDOWS and ANCILLARY PRODUCTS Enquiry and Formal Vote EN 1090-1 EN 14782 EN 14783 5 year review UAP Procedure EN 1090-2 EN 1090-3 EN 1090-4* EN 1090-5* Steel Structures Aluminium Structures Profiled Sheets - Steel Profiled Sheets Alu * in preparation, publication 2015 Execution of steel structures and aluminium structures Requirements for conformity assessment of structural components CE-Mark based on AVCP For all characteristics: System 2+ Coexistence period until 01.07.2014 with national regulations EN 506 EN 508-1 EN 508-2 EN 508-3 Copper, Zinc Steel Aluminium Stainless Steel Self-supporting metal sheet for roofing, external cladding and internal lining EN 501 EN 502 EN 504 EN 505 EN 507 EN 12588 Zinc Stainless Steel Copper Steel Aluminium Lead Fully supported metal sheet and strip for roofing, external cladding and internal lining CE-Mark based on AVCP: Fire : System 3 oder 4 Dangerous Substances: System 3 Mechanical etc.: System 4 Mandatory Slide 35

Profiled sheets and linear profiles EN 1090 Execution of steel structures and aluminium structures EN 1090-1 CE-Marking (harmonized part) EN 1090-2 Technical requirements for steel structures EN 1090-3 Technical requirements for aluminium structures Since 01.07.2012 Eurocodes mandatory Coexistence period between 01.07.2012 and 01.07.2014 2 alternatives Design of the structure based on Eurocodes National regulations Design of metal profiles based on Eurocodes National marking Execution acc. to EN 1090-2 or EN 1090-3 National regulation for external quality control CE-marking acc. to EN 1090-1 Surveillance interval (in years): EXC 1 and 2: 1-2-3-3- EXC 3 and 4: 1-1-2-3-3- Slide 36

Sandwich Panels Sandwich Panels Self-supporting double skin metal faced insulating panels EN 14509 New revision finalized, available in 2014 CE-Mark based on AVCP: Fire resistance : System 3 Reaction to fire: System 1 Hazardous Substances: System 3 Mechanical char.: System 4 CE Today Slide 37

Sandwich Panels Sandwich Panels Self-supporting double skin metal faced insulating panels Double skin metal faced insulating panels for structural applications EN 14509-1 EN 14509-2 EN 14509-3 Structural Class III: Construction where cold-formed sheeting is used as an element that only transfers loads to the structure Structural Class II: Construction where coldformed members and sheeting are designed to contribute to the strength and stability of individual structural elements Structural Class I: Construction where coldformed members and sheeting are designed to contribute to the overall strength and stability of a structure CE-Mark based on AVCP: Fire resistance : System 3 Reaction to fire: System 1 Dangerous Substances: System 3 Mechanical char.: System 4 CE-Mark based on AVCP: General: System 2+ (at least) CE Future Slide 38

Thank you for your attention! Slide 39