1. Are there any criteria to allow the use in class E1/E2 in certain areas,products, uses etc.?
2. What are the updated regulatory requirements in Greece regarding theuse in class E1/E2?
3. Does the requirement to E0 exists in Europe, if it does, what are thecriteria for its use(certain products/areas/conditions, etc.)?

Having regard to the relevant Greek provisions, such as:

i) Common Ministerial Decision “Maximum formaldehyde limit forfurniture, decorative objects and their raw materials of composite wood -Immigration of some elements from children’s furniture – Furniture Board”(Official Government Gazette 746/B/22-4-2009) and its amendment (Official Government Gazette 2650/B/09-11-2011), there is the nationalrequirement of class E1 as maximum permitted limit. It is noted though,that the scope of the aforementioned provision excludes constructionproducts.

ii) Presidential Decree no. 90 “Exposure limit values and maximumexposure limit values of workers to certain chemical agents during theirwork in compliance with Commission Directives 91/322/EEC and 96/94/ECand the amendment and supplementation of the Presidential Decree307/86 “Protection of workers health exposed to certain chemical agentsduring their work” (Official Government Gazette 135/A) as amended withthe Presidential Decree 77/93 (Official Government Gazette 34/A)” (OfficialGovernment Gazette 94/A), the exposure limit value of workers duringtheir duty to formaldehyde emission is defined at 2 ppm (2.5 mg/m3).

1. Are there any national requirements in your country for the content of NH3 in the fly ash for concrete in case the concrete is to be used for living spaces/residential buildings?

2. Which national document contains the prescriptive value of maximumallowed amount of NH3 declared by the manufacturer?

3. What is the testing method for determination of the maximum declaredamount of NH3 in fly ash for concrete?

4. Does the manufacturer declare the content of NH3 in the Safety datasheet or in some other document?

Having regard to the relevant Greek provisions, such as the Presidential Decree no. 90 “Exposure limit values and maximum exposure limit valuesof workers to certain chemical agents during their work in compliance with Commission Directives 91/322/EEC and 96/94/EC and the amendment andsupplementation of the Presidential Decree no. 307/86 “Protection ofworkers health exposed to certain chemical agents during their work”(Official Government Gazette 135/A) as amended with the Presidential Decree 77/93 (Official Government Gazette 34/A)” (Official Government Gazette 94/A), the exposure limit value of workers during their duty toammonia (for example workers in cement industry) is defined at 50 ppm(35.00 mg/m3).

Regarding point (4) of your question, we consider that the declaration of ammonia in Safety Data Sheet of the regulation (EC) 1907/2006 iscompulsory, since ammonia (anhydrous) is included in the list ofharmonised classification and labeling of hazardous substances (Table 3.1)of regulation (EC) 1272/2008, with index no 007-001-00-5.

According to the Greek Technical Specifications for public works (ETEP),we inform you the following:

• There are no additional national requirements in force other than those derived from the harmonised standard ELOT EN 15651 – “Sealants for non-structural use in joints in buildings and pedestrian walkways”, for theessential characteristics of non-structural sealants, when placing or/andmaking available these products on the market.
• The ΕΝ 14293 “Adhesives – Adhesives for bonding parquet to subfloor -Test methods and minimum requirements” has been adopted by the Greek Standardization Body (ΕLΟΤ) as a national relevant standard, but ithas not been transposed into Greek law, and therefore it is notcompulsory.
• In addition, some technical characteristics of sealants and parquetadhesives, when they are intended to be used in public works, may bedefined either as part of the project plan/design or in the relevant Greek Technical Specifications (ETEP) which prescribe the rules /specificationsthat should be applied for the construction of a building or civilengineering public work.With the Joint Ministerial Decision “Approval offour hundred forty (440) Greek Technical Specifications (ETEP) withmandatory application to all Public Works”, (Official Government Gazette(OGG) 2221/B/2012), the Technical Specifications have become compulsory. Such Specifications (ETEP) that include the products in question aremainly the following:

ELΟΤ ΤP 1501-03-04-05-00:2009 “Sealing of building joints”

ELΟΤ ΤP 1501-03-08-01-00:2009 “Wooden windows and doors”

ELΟΤ ΤP 1501-03-08-07-01:2009 “Single layer and laminated glassglazing”

ELΟΤ ΤP 1501-03-07-02-00:2009 “Ceramic tiles covering of indoor and outdoor surfaces”

ELΟΤ ΤP 1501-03-08-01-00:2009 “Paving slabs and cobblestones for pedestrian areas”

ELΟΤ ΤP 1501-03-07-01-02:2009 “Glued hardwood flooring”

Moreover we notice that the technical characteristics of the products to beused in any public work resulting from the design of the project must meet the requirements of the applicable standards in each case, depending onthe intended use, in accordance with the order of preference specified inarticles 23 and 34 of Directive 2004/18/EC and 2004/17/EC respectively.

The harmonised European Standard EN 14351 identifies material independent performance characteristics that are applicable to windows and doors.

According to the relevant Greek provisions, such as the Regulation on the Energy Performance of Buildings: a) Law 4122/2013 “Energy Performanceof Buildings – Harmonization with Directive 2010/31/EU of the European Parliament and of the Council and other provisions”(Official GovernmentGazette 42/A) and b) Ministerial Decision no. DEPEA/ οικ.178581/30.06.2017 “Approval of Regulation of the Energy Performance ofBuildings” (Official Government Gazette 2367/B), the thermaltransmittance Uw for windows and or UD for doors is required to bedeclared at the declaration of performance for these products in Greek.

We inform you that according the following existing legislative framework concerning construction products:

a)Regulation 305/2011 of the European Parliament and of the Council of9th March 2011 «laying down harmonised conditions for the marketing ofconstruction products and repealing Council Directive 89/106/ΕEC» and itscorrigendum.b)Ministerial Decision no. 27421/05.03.2019 (Official GovernmentGazette958/

b) «Additional measures necessary for the implementation ofRegulation (EU) no. 305/2011 of the European Parliament and of theCouncil of 9 March 2011 laying down harmonised conditions for themarketing of construction products and repealing Council Directive89/106/EEC».

c)Ordinance no. DΤDG 1111251 ΕΞ 2018/2018/19.07.2019 of theIndependent Authority for Public Revenue.The declaration of performance for construction products should be drawnup in Greek for the products available on the Greek market.

Having regard to the relevant Greek Technical Specifications (ETEP) which prescribe the rules /specifications that should be applied for the construction of a building or civil engineering public work, there are no anyspecific national requirements that have to be fulfilled for small waste water treatment plants in Greece, except of the fact that they are covered by the ELΟΤ EN 12566 harmonised standard.

There is no reference at the Greek Technical Specifications (ETEP) for theuse of penetration seals covered by the ETAG 026-2.

However, some Greek Technical Specifications (ETEP) include requirements for materials used as sealants, such as:

“stable unburnt material” (ΕLΟΤΤP 1501-04-01-01-00 “Building piping systems under pressure with copper tubes with seam” and ΕLΟΤΤP 1501-0103-00 “Building piping systems under pressure with copper tubes”, or

“sealants should have the specific fire resistance rating of the relevant structural element of the building in which they are incorporated“ (ELOTTP 1501-04-20-01-02 “Plastic tubes of electrical installations”) etc.

Furthermore, you may contact the Ministry of Environment and Energy,General Secretariat for Regional planning and Urban Development (email:gramchora@ypen.gr) for any further requirements regarding othernational rules applying to your product.

When your construction product is subject to the requirements of the (EU) No 305/11 Construction Product Regulation (CPR), it is not allowed tointroduce other than CE marking attesting its conformity, with thedeclared performance in relation to the essential characteristics covered by that harmonised standard or by the European Technical Assessment,(art. 8 (3) of the CPR). Thus, that product cannot be placed on the EUmarket as well as on the Greek market.

Following your question, we inform you the following:

1) The issue of the production of construction products on behalf of another manufacturer (rebranding and subcontract manufacturer) falls under the provisions of paragraph 19 of Article 2 and Articles 11, 15 and36 of Regulation (EU) 305/2011. According to these provisions, the final manufacturer (rebranding manufacturer), who does not manufacture the construction product himself, should draw up a declaration of performanceand affix the CE marking, when such a product is placed on the market under his name or trademark.

2)If its construction product is subject to systems of assessment and verification of constancy of performance (AVCPs) 1+, 1 or 2+, a relevant certificate is required to be issued by a notified body on behalf of the final manufacturer, given that the physical manufacturer could not authorise the final manufacturer to use his certificate.

3)If its construction product is subject to system of assessment and verification of constancy of performance (AVCP) 3, the rebranding manufacturer could base the declaration of performance on test results obtained by the physical manufacturer only after having obtained an authorisation of that manufacturer, provided that the conditions laid down in Article 36 for reliability and stability of the test results are met.

4)Additionally, it is required a contract with the physical manufacturerthat will allow the rebranding manufacturer to ful fill its obligations as legal manufacturer regarding factory production control. E.g. for applicablesystem of assessment and verification of constancy of performance(AVCP) 2+, the certificate of conformity of the factory production controlissued by a notifying body in the name of the final manufacturer, shouldtake into account the rebranding and subcontract manufacture.

Following your question, we inform you the following:

1)According to paragraphs 2 and 3 of article 28 of regulation (ΕU)305/2011 «By means of delegated acts in accordance with Article 60, the Commission shall establish and may revise, taking into account in particular the effect on the health and safety of people, and on the environment, which system or systems are applicable to a givenconstruction product or family of construction products or a given essential characteristic» and «The system or systems thus determinedshall be indicated in the mandates for harmonised standards and in the harmonised technical specifications».

2)Delegated acts no. 95/204/EC, 1999/91/EC and 2001/596/ΕC have beenissued and are in force for thermal insulation products.

3)Thermal insulation products of extruded and expanded polystyrene (EPSand XPS), which fall into class E of reaction to fire, should be assessedaccording to system of assessment and verification of constancy ofperformance (AVCP) 3 (Table ZA.2 of Annex ZA of harmonised standardsELOT EN 13163 and ELOT EN 13164).

4)Thermal insulation products, having other reaction to fire performancee.g. classes A1, A2, B, C and intended for uses subject to regulations onreaction to fire, should be assessed by system 1, as specified in relevant harmonised standards.

5)Therefore, manufacturers should not apply different system of assessment and verification of constancy of performance (AVCP) thanstandards define. Systems are determined for all Member States by the Commission acts, which are directly applicable, delegated by Regulation(EU) 305/2011 or Directive 89/106/EC. In that way, harmonisation
framework and the common technical language of the EU Member Statesare ensured.

For systems (kits), such as External Thermal Insulation Composite Systems(ETICS), their performance could be optionally assessed as a whole on thebasis of European Assessment Documents (EAD), if any. The European Technical Assessment (ETA) of this system, issued by a TAB, is anassessment element of the specific final product performance, and not of its individual components performance from which this system is constituted. The manufacturer then shall draw up a declaration of performance and shall affix the CE marking for the system, for placing thesystem on the market.

In order to place on the market the individual components of the system,which are covered by harmonised standards of Regulation (EU) 305/2011,these should bear their CE marking and get accompanied by their declaration of performance, after the assessment of their performance inthe basis of relevant harmonised standards solely.

According to presidential decree no. 41/ 04.04.2018 “Fire protectionRegulation” (Official Government Gazette 80/A), there are minimum requirements of fire resistance and reaction to fire for several construction products.

For example, table no. 7 (p. 22) includes minimum requirements of fireresistance index depending on the building use. Table no. 8 (p. 23) includes minimum required criteria of performances of fire resistance indexes for various construction elements. Especially for your products,roof openings, requirements for integrity and resistance to heat passage criteria exist. Table no. 13 (p. 3) includes minimum requirements of reaction to fire depending on the building use. Especially for your products, roof openings, exist the requirements of the 5th column of the table, where for residencies there is the requirement of C-s1,d0, etc.

Furthermore, we inform you that the competent Greek authority for the aforementioned “Fire protection Regulation” is the Ministry ofEnvironment and Energy, General Secretariat for regional planning an durban development, email: gramchora@ypen.gr

Following your question, we inform you the following:

1)Distributors or importers are considered as manufacturers according to article 15 of the Regulation (EU) 305/2011, when they repackage bulk products in small packages of e.g. 4-5 kg and place them on the market,either under their own name or nameless.

2)Furthermore, manufacturers should ensure that construction products,which they have placed on the market, are in conformity with theirdeclaration of performance or in compliance with other applicable requirements in this Regulation. Otherwise they should ensure theirwithdrawal or their recall according to paragraph 7 of Article 11 ofRegulation (EU) 305/2011.

3)Therefore, repackaged products should be CE marked and accompaniedby the relevant declaration of performance under the name of the economic operators concerned, as well as any other element required bythe applicable system of assessment and verification of constancy ofperformance (AVCP), depending on the product.