Question 1

Concerning the permitted formaldehyde emission for Fireboards, OSB, Plywood and MDF please answer to the following: 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 the use in class E1/ E2? 3. Does the requirement to E0 exists in Europe, if it does, what are the criteria for its use (certain products/areas/conditions, etc.)?

Having regard to the relevant Greek provisions, such as:

1 Common Ministerial Decision «Maximum formaldehyde limit for furniture, 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 national requirement of class E1 as maximum permitted limit. It is noted though, that the scope of the aforementioned provision excludes construction products.

2 Presidential Decree no. 90 “Exposure limit values and maximum exposure limit values of workers to certain chemical agents during their work in compliance with Commission Directives 91/322/EEC and 96/94/EC and the amendment and supplementation of the Presidential Decree 307/86 «Protection of workers 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 to formaldehyde emission is defined at 2 ppm (2.5 mg/m3).

Question 2

Concerning the content of NH3 in the fly ash for concrete that is to be used in living spaces/residential buildings (incl. schools, hospitals, etc.) please answer to the following: 1. Are there 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 maximum allowed amount of NH3 declared by the manufacturer? 3. What is the testing method for determination of the maximum declared amount of NH3 in fly ash for concrete? 4. Does the manufacturer declare the content of NH3 in the Safety data sheet 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 values of workers to certain chemical agents during their work in compliance with Commission Directives 91/322/EEC and 96/94/EC and the amendment and supplementation of the Presidential Decree 307/86 «Protection of workers 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 to ammonia (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 is compulsory, since ammonia (anhydrous) is included in the list of harmonised classification and labeling of hazardous substances (Table 3.1) of regulation (EC) 1272/2008, with index no 007-001-00-5.

Question 3

1) Which are the requirements (if any) to the required classes (levels and classes) applicable in your country for the application of sealants, covered by EN 15651 - Sealants for non-structural use in joints in buildings and pedestrian walkways? 2) Which are the requirements for adhesives for floor covered by a non-harmonized standard EN 14293?

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

  • There are no additional national requirements in force other than those derived from the harmonised standard EΛOT EN 15651 – “Sealants for non-structural use in joints in buildings and pedestrian walkways”, for the essential characteristics of non-structural sealants, when placing or/and making 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 (ΕΛΟΤ) as a national relevant standard, but it has not been transposed into Greek law, and therefore it is not compulsory.
  • In addition, some technical characteristics of sealants and parquet adhesives, when they are intended to be used in public works, may be defined either as part of the project plan/design or in the relevant Greek Technical Specifications (ETEΠ) which prescribe the rules /specifications that should be applied for the construction of a building or civil engineering public work. With the Joint Ministerial Decision «Approval of four hundred forty (440) Greek Technical Specifications (ETEΠ) with mandatory application to all Public Works», (Official Government Gazette (OGG) 2221/B/2012), the Technical Specifications have become compulsory.

Such Specifications (ETEΠ) that include the products in question are mainly the following:

EΛΟΤ ΤΠ 1501-03-04-05-00:2009 “Sealing of building joints”

EΛΟΤ ΤΠ 1501-03-08-01-00:2009 “Wooden windows and doors”

EΛΟΤ ΤΠ 1501-03-08-07-01:2009 “Single layer and laminated glass glazing”

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

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

EΛΟΤ ΤΠ 1501-03-07-01-02:2009 “Glued hardwood flooring”

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

Question 4

Which are the Greek requirements for the products of EN 14351?

The harmonized 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 3661/2010 «Measures to reduce buildings΄ energy consumption and other provisions» and b) Ministerial Decision «Approval of Regulation of the Energy Performance of Buildings» Official Government Gazette 407/B/2010 the thermal transmittance Uw for windows and or UD for doors is required to be declared at the declaration of performance for these products in Greek

Question 5

Which is the language or languages required in Greece for the declaration of performance and in which national regulation this is laid down?

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

  1. Regulation 305/2011 of the European Parliament and of the Council of 9th March 2011 «laying down harmonized conditions for the marketing of construction products and repealing Council Directive 89/106/ΕEC» and its corrigendum.
  2. Law 4072/2012 (Official Government Gazette 86/Α/11.4.2012), Chapter Ε’ «Market surveillance of industrial products and quality services», article 31, regarding market surveillance within the Regulation 765/2008/Ε
  3. Ordinance no. Γ19Γ 5008099 EΞ /2013/ 01.03.2013 of the Ministry of Finance.

The declaration of performance for construction products should be drawn up in Greek for the products available in Greek market.

Question 6

Which are the technical requirements for small wastewater treatment plants in Greece?

Having regard to the relevant Greek provisions, such as:

1 Common Ministerial Decision «Maximum formaldehyde limit for furniture, 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 national requirement of class E1 as maximum permitted limit. It is noted though, that the scope of the aforementioned provision excludes construction products.

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

Question 7

Which are the national requirements for penetration seals covered by ETAG 026-2?

Having regard to the relevant Greek provisions, such as:

1 Common Ministerial Decision «Maximum formaldehyde limit for furniture, 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 national requirement of class E1 as maximum permitted limit. It is noted though, that the scope of the aforementioned provision excludes construction products.

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

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

“stable unburnt material” (ΕΛΟΤ ΤΠ 1501-04-01-01-00 “Building piping systems under pressure with copper tubes with seam” and ΕΛΟΤ ΤΠ 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“ (EΛOT TΠ 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: [email protected]) for any further requirements regarding other national rules applying to your product.

Question 8

May a construction product bearing the Polish mark “B” – which is introduced according to Polish law- be placed on the Greek market?

Having regard to the relevant Greek provisions, such as:

1 Common Ministerial Decision «Maximum formaldehyde limit for furniture, 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 national requirement of class E1 as maximum permitted limit. It is noted though, that the scope of the aforementioned provision excludes construction products.

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