A strong supporter of market surveillance, EPEE, representing the heating, cooling and refrigeration
industry in Europe, shares with this Advisory Note its thoughts about existing different conformity
assessment methods (self-declaration and third-party conformity assessment) related to Ecodesign
Regulation (EU) 813/2013, highlighting the following key priorities:
The importance of building on the new market surveillance regulation once it is formally
adopted in order to improve market surveillance and product compliance, independent of the
conformity assessment method chosen;
Regarding third-party conformity assessment (TPCA), there is the need to define to which type
of products it shall apply, and which conformity assessment modules shall be used, as well as
the need for sufficient time for the market to adapt. A thorough impact assessment should be
carried out in case this option is pursued.
Progress in this area must emphasize the importance of improving cooperation and mutual
trust between industry and market surveillance authorities and ensuring the same levels of
market surveillance in each Member State of the European Union.