Mail From Teun Bokhoven 14/10 Dear Jan Erik

mail from teun bokhoven, 14/10 ============================== dear jan erik, unfortunately i am not able to attent the next keymark mee

Mail From Teun Bokhoven, 14/10
==============================
Dear Jan Erik,
Unfortunately I am not able to attent the next Keymark meeting. We had
arranged that Rob Meester could take over and represent the ASTIG
position. However, due to personal circumstances he has to cancel as
well. At the moment I try to get a replacement in the person of Gerard
van Amerongen (but he could not confirm yet). I will keep you
informed.
With regard to the ASTIG position on the Keymark Scheme Rules:
We discussed the issue at our last meeting (Sept. 26) in Lisbon.
Attached I send you the text of the minutes, which reflects our
position.
We are basically concerned about two issues:
1. The cost of the Keymark system in relation to the avoided cost of
double testing
2. The impact it will have on the EU market, as still a number of
countries (mainly France and Spain) still require totaly different
tests in order to grant for subsidies.
3. The willingness by certification bodies to accept keymark (and even
stimulate that). We observe (as we have done before) that
certification institutes are not involved in the work we do at the
moment. Therefor there is a considerable risk.
Obviously these elements link together. If Keymark is not accepted as
a basis to link subsidy schemes, it will prove to be a useless
instrument and the industry will not enter into Keymark certification.
I believe it should be pointed out to the Keymark group that the
succes of the system will depend heavily on the ability to have a
European Keymark Scheme, accepted by the national certification bodies
dealing with solar thermal and connect it to national or regional
subsidy schemes.
We are aware that the Keymark project team will not be in the position
to clear this issue, but hope that this issue will be addressed and
not underestimated. Maybe you can make this an action item for the
last part of the work. It is also important to inform the Commission
delegate on this issue. Maybe he can influence the proces from his
point. I will be happy to discuss the issue with him in Brussels
together with Piria (if he likes to).
I hope you can convene this message to the group.
I will try to call you before the meeting. If there is anything
unclear please respond.
I cc Raffaele Piria of this message as he will be present and also
took part of our ASTIG meeting.
Kind regards,
Teun Bokhoven
Mail enclosure:
Taken from the minutes of the ASTIG meeting, Lisbon September 26- 2002
Keymark
The Keymark Scheme Rules are discussed based on an outline of the
various changes made after our last meeting. The following decision
have been taken.
Art. 3.1.:
Under re B.2.3.3: There is mentioned that there will be a “uniform
price level towards all EU manufacturers and suppliers.” This clause
can be under constraint by EU competition rules. Suggest to delete
that clause in order to avoid unnecessary delays by authorities in
implementing the scheme.
Art 5.1.:
The selection of the type test sample is now described as such that
the inspector will select the type at the factory and allows the
manufacturer to send it out to a selected test lab. This formulation
is a compromise between the original ASTIG point of view and the
wishes from the labs to selected both the type sample + test lab.
Agreed.
Art 5.3.:
In case modifications are made the requirements for re-testing is
based on the EN-standards. However the cost for the certification are
still charged. Agreed.
Art 7
The certificate is given for a period of 5 years (only if the
manufacturer operates under ISO 9000) after which new type testing is
required, with inspections of the production every 2 years. In case
the manufacturer is not operating under Iso 9000, factory inspection
is required every year.
ASTIG doesn’t see any reason for a 5 year retesting frequency if the
company act under ISO 9000.
Art 7.1.:
This clause deals with the special testing in case a deviation of the
original certificate is observed. The clause now provides a set of
objective criteria + it states that in case of any unjustified
reclamation , the cost will be carried by the party who required the
re-testing procedure. This clause now takes the original ASTIG
comments into account. Agreed
General remark: there is a unanimous fear that the cost involved in
Keymark will be too high to allow a general acceptance by the
industry. In particular smaller companies might find the cost
unacceptable.
Solar Keymark Secretariat (Annex A)
The proposal to form a Keymark secretariat as an activity of ( the
merged) ASTIG and ESIF is in line with our original wishes to keep
control over this part of the international certification process. It
will require a financial contribution as indicated in the Annex B. One
should take following considerations into account:
*
The proposal estimates 200 products @ 500 Euro.to cover for the
full cost. A EU support proposal has been rejected , thus the cost
have to be covered fully by the manufacturers. With regard to the
budget proposal to carry out the work (100 Keuro), there is not
yet a good underlying cost break down. At present there are
indications (based on only a limited # of manufacturers) that
already 75 products will brought under the scheme. We need to
discuss this part as well. Can we expect xxx certificates,
contributing YYY euro / certificate, providing ZZZ euro/year to
operate the secretariat (in whatever form).
*
It should also be considered that, in due time this Solar keymark
secretariat could run with a surplus of money to promote the solar
keymark, and thus the industries delivering products under the
scheme.
*
Within the present EPD discussion it becomes clear that
certification for any technology under the EPD is very important
in order to use the full impact in the EPD. For instance: the lack
of European standards for balanced ventilation and heat-recovery
in buildings is giving that technology a drawback in the
development process of the EPD. If solar has that arranged it will
become in the benefit our solar thermal in general.
ASTIG agrees in principle with the proposed structure, however before
a final decision is made, a more detailed cost estimate must be made.
The present cost estimate is considered to high.
Unquote