Policies

CECIP Vision on metrological control of the future

Several aspects within the metrological control legal framework can make the system more efficient and effective by reducing costs, limiting double tests and improving the service level for users. CECIP prepared its vision on the metrological control in the future that aims at describing the areas of metrological control where the system may be improved and it gives proposals from the European weighing industry on the best solutions in these areas.
It includes suggestions in the following areas: Harmonisation, EU database, risk based approach, remote reverifications and independent reverifications.

MUTUAL RECOGNITION REVERIFICATION AUTHORISATIONS

Authorisations are necessary to carry out private reverifications in Member States where private reverification is allowed. In each EU Member State a separate auhtorisation is necessary while the requirements are similiar. CECIP would like to see the mutual recognition of these reverification authorisations.

Set harmonised requirements for reverifications

Reverification requirements for weighing instruments are set in national legislation and differ between all EU Member States. This creates barriers to trade and an extra adminstrative burdens for businesses. Moreover, it doesn´t provide the optimal consumer protection. Harmonisation of these reverification requirements can improve both the competitiveness of the European weighing industry and consumer protection in Europe.

Set right legal framework for digitalisation

To reap the full benefits of digitalisation of the weighing industry it is crucial that the right legal framework is established and implemented. EU legislation, OIML Recommendations and WELMEC guides should to allow innovation whilst maintaining a high level of consumer protection. This is done by focussing on the core weighing instrument when establishing requirements and allow for the flexibility of the New Legislative Framework when carrying out tests.

CALL FOR CONSISTENCY IN MARKET SURVEILLANCE

Requirements to place weighing instruments on the EU market are harmonised at EU level. Still, there are sometimes different interpretations of these harmonised requirements in EU Member States. The weighing industry faces problems due to these different interpretations such as mandatory changes of products and unfair competition. CECIP calls on Member States to co-ordinate interpretations via WELMEC to ensure more consistency.

ALLOW PRIVATE REVERIFICATIONS IN WHOLE EU

In many EU Member States it is allowed for private entities such as manufacturers to carry out the periodic reverification of weighing instruments. This private reverification has benefits for users and society. Therefore, CECIP calls on the EU Member States to allow periodic reverifications of weighing instruments and reverifications after repair to be carried out by private entities.

Controls on data transmission need to be balanced

Data collection is becoming more and more important in various fields where weighing instruments are used. Consequently, it is important that this data transmission - the electronic transfer of data from one device to another - is reliable. CECIP believes that the level of legally prescribed control should be appropriate. The right balance needs to be found between risk management and the burden of the controls.

Establish dispute resolution procedure in EU

Requirements for placing weighing instruments on the EU market are harmonised and set in EU legislation. However, from time to time problems arise when different interpretations exist on certain aspects. The existing procedure to find consensus on a common interpretation take too long for the European weighing industry. CECIP calls on decision makers to develop a fast, transparent and inclusive procedure to find consensus on interpretations. CECIP developed a paper that should serve as basis for the discussion on such a dispute resolution procedure.

Revise OIML R106 on rail weighbridges

Due to a change in the use of the automatic rail weighbridges the requirements set in OIML R106 are not up-to-date. A revision is necessary according to CECIP.

CECIP view on technologies to identify overloaded

EU legislation obliges Member States to make a decision on how to identify vehicles that are likely be overloaded. Several technologies are available and CECIP believes a careful consideration of the different options is needed.

Allow all continuous totalising weighers on market

Essential requirements for continuous totalising weighers are set in MID Directive 2014/32/EU and OIML R50. These make it mandatory to make use of belt weighers. However, other reliable and accurate systems that can meet the requirements are available as well. CECIP wants to make these essential requirements technological neutral and allow other continuous totalising weighers as well.

SIMPLER METHODS OF SOFTWARE CONTROL NEEDED

Details on software requirements for weighing instruments are set in WELMEC guides. These guides include overly technical and complicated requirements and that open to different interpretations. CECIP is in favour of simpler, transparent and aligned WELMEC guides. Additionally, a risk-based approach should be further developed. Software requirements should be futureproof and consistent.

MAKE USE OF RISK ASSESSMENT MODELS

Risk assessment models in are currently discussed and used at different levels in the weighing industry. CECIP fully supports these developments and contributes where possible. Moreover, risk assessment models should be based on well-defined and consistent criteria in all areas.

CLARITY NEEDED ON NEW VS REPAIR

For reverification purposes it is important to decide if an instrument is considered new or repaird after making changes. In certain countries new instruments can be verified by manufacturers and repaired instruments only be authorities. Unfortunately, it is not clear in each country when an instrument is repaired and when considered new. CECIP calls on authorities to provide clarity and use the CECIP workflow.

IMPROVE CONSUMER PROTECTION WITH MASS INDICATIONS

Pre-packed products require an indication of mass or volume. For liquids it is required to indicate the volume of the product. CECIP is convinced that mass indications are a better indicator as temperature has a smaller impact and weighing instruments are more accurate due to mandatory reverifications. Therefore, legislation should include the indication of mass for liquids as well.

OIML R134 NEEDS TO BE REVISED

Weighing-in-motion systems are becoming increasingly important. Therefore, it is important that state of the art standards are available that are widely accepted. OIML recommendations are suitable, only the relevant recommendation OIML R134 is outdated. CECIP calls on OIML to work on the revision of OIML R134

FOR AN AMBITIOUS INDUSTRIAL STRATEGY

The Industry4Europe coalition consists of around 130 European industry associations calling on the European Commission to develop an industrial strategy. CECIP is part of this coalition and supports the call for an EU Industrial Strategy.

Allow min, max, e and d on display only

The EU NAWI Directive obliges the maximum capacity (Max), minimum capacity (Min), verification scale interval (e) and, where relevant, the scale interval (d) to be marked on the weighing instrument. In light of digital developments there are weighing instruments on the market where this information is shown exclusively on the primary display. A limited number of authorities doesn't allow this. CECIP and the majority of Member States are convinced that this is allowed according to EU legislation and in the document the rationale for this position is described.