On a yearly frequency, ELA and EU Commission representatives meet for a fruitful exchange of information and position on lifts and escalators matters. Last meeting was held on last July and several topics were discussed.

Among these topics, the question of the link between the Date Of Withdrawal (DOW) of a harmonised standard and its replacement by the new edition of this standard has been raised with regards to EN 81-28 and EN 81-70). These two standards have been revised technically (new requirements). At the date of repealing, the old standard ceased to give presumption of conformity and this is called the Date Of Cessation Of Presumption Of Conformity Of the Superseded Standard (DOCOPOCOSS). Up to now DOW and DOCOPOCOSS were identical.

When standards are revised technically, the industry needs time to adapt the design of the lifts to the new conditions. Also, a long time can lapse between order and installation, which raises the question under which standard (old or new) should the lift be designed and installed?

In the past ELA proposed to the Commission not to consider the date of CE marking the lift and signing the EU Declaration of conformity but rather the date of order signed by the customer to fix the version of the standard for the presumption of conformity. The Commission understands the issue for the Lifts Industry as the lift exists only once it has been fully installed and its conformity checked. The Commission remains reluctant but could consider the issue in a transversal way as the issue is not only relating to the lift industry but also to other industrial sectors. Indeed, unlike many other products where the conformity is assessed when the product leaves the factory to the distribution channel, the conformity of the lift is only assessed when the installation is finished. The progress of the installation depends on the progress of the construction work. Delays due to bad weather, non-payment, legal issues, … are frequent. This could shift the assessment of the lift over some DOCOPOCOSS. Determining the standard version at the date of the signature of the order could be one solution.

ELA will continue to discuss this important issue for the lift industry together with the representatives of the EU Commission in the coming months. Separation of DOW from DOCOPOCOSS could help our industry. The DOCOPOCOSS could for instance be some years later than the DOW not jeopardizing installations in progress.