What requirements should pipes and process equipment comply with to be allowed on the European market?

If you want to export pipes or process equipment to Europe, you will have to comply with various requirements. Most importantly, you need to comply with legislative requirements, mostly related to product safety. Voluntary commitment to quality standards is also increasingly common on the European market.

1. What legal and non-legal requirements should your product comply with?

The following ‘musts’ apply to the products and uses listed here:

1. Product safety – applicable to all products,
2. Technical requirements for specific applications – standards for when products are used in specific applications including transport pressure equipment,
3. Ecodesign for energy-related products – for energy-using or energy-saving products,
4. Energy labelling – for energy-related products,
5. Chemicals – for products that contain chemical substances,
6. Harmful gases and substances – applicable to a wide variety of products such as refrigerators, air-conditioners, fire extinguishers and electronic equipment,
7. Food contact materials – for materials coming into contact with food.

Product safety

The obligation of complying with product safety requirements will firstly be the responsibility of the European company that places the finished product on the market. However, they will often ask their suppliers to comply with the requirements as well. For suppliers of parts, this can translate into demand for more information, test reports or compliance with standards.

CE marking

In addition to the general product safety requirements, there are also several product-specific standards. This shows that the product complies with harmonised safety, health and environmental requirements. Examples of CE marking and the corresponding European Union directives are:

• ATEX – applicable to equipment used in potentially explosive atmospheres,
• EMC – electromagnetic compatibility for equipment with electromagnetic emissions,
• LVD – low voltage directive applicable to electrical equipment with a voltage between 50 and 1000 V for alternating current and between 75 and 1500 V for direct current,
• PED – applicable to pressure equipment.

For parts of products that fall under CE Directives, CE marking is not legally required. Your buyer will take care of the CE marking for the complete product. However, he will expect you to comply with certain standards to ensure that his final product will also be compliant. Buyers of parts can also ask for voluntary CE marking.

Technical requirements for specific applications

Besides CE marking, additional technical requirements can apply to pipes and process equipment used in specific applications, such as aircrafts and motor vehicles. These concern the essential requirements related to product integrity (such as structure and materials, propulsion, system and equipment), product operation and the organisation’s structure.

Ecodesign for energy-related products

The Energy-related Products Framework Directive is a CE Directive specifically for energy‑using and energy-saving products. It deals with the environmental impact of products, including their energy consumption throughout their entire life cycle. The general requirements of the Framework Directive are supplemented by specific requirements laid down in implementing regulations for various products. Relevant products include heaters and water heaters and refrigerating appliances.

Energy labelling

Energy-using products destined for the consumer market must bear specific energy labels when put on the European market. These energy labels communicate information on the energy consumption of the product. Although it is your European buyer who has the responsibility to ensure that products are properly labelled, it is important to familiarise yourself with the necessary requirements. You can be asked to provide your buyer with technical documentation to make up the label.

Chemicals

To avoid environmental damage, the European Union has restricted the use of certain chemicals in the REACH regulation. REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. For example, REACH states that most measuring devices (such as thermometers and barometers) cannot contain mercury.

Food contact materials

Specific health control provisions apply to pipes and process equipment that come into contact with food,. These rules have been laid down by Commission Regulation (EC) No 2023/2006 on good manufacturing practice (GMP) for groups of materials and articles that are designed to come into contact with food (including metals and alloys). Food contact materials must be manufactured so that they do not transfer constituents to food in quantities that could endanger human health, change the composition of the food in an unacceptable way or deteriorate the taste and odour of foodstuffs.

General requirements on packaging and liability

Note that there is also non-product specific legislation on packaging and liability that apply to all goods marketed in Europe.

2. What additional requirements do buyers often have?

Quality management is crucial

ISO 9001 is a very common quality management system. If you have not done so already, you will need to implement this quality management system and get your certification.

Implement Six Sigma and lean production to keep up

Six Sigma and lean production are now crucial requirements that European buyers ask for. Both are production management strategies:

• Six Sigma seeks to improve the quality and the results of business processes by reducing the standard deviation and increasing process predictability.
• Lean production seeks to avoid sending money and resources for any other goal than creating value for the consumer.

Implementing Six Sigma and lean production is not only about complying with requirements. It also helps to improve performance on cost, speed, delivery times and reliability.

Compliance with technical product standards to guarantee quality and safety

Buyers often ask their suppliers to deliver products according to voluntary standards. The large number of different standards makes it hard to determine which ones are applicable and relevant. The standards are often harmonised and may overlap or complement each other. Which standard is the best to follow depends on your specific situation (for instance product and market(s) that you want to target). In Europe, the following standards are used most:

• ISO standards: these are recognised worldwide and cover a wide variety of products.
• EN standards: these are developed by the European Committee for Standardization and are harmonised throughout the European Union. ISO standards are often harmonised with, and published as, EN standards.
• National standards: developed by standardisations bodies in European Union Member States and only asked for and relevant in the specific European Union Member State. ISO and EN standards are more common but some (and a reducing number of) buyers will still work with national product standards.
• Foreign standards: can also be asked by companies that operate in Europe. For example, American standards will mainly be asked in the European Union by American-based multinationals operating in the oil and gas industry that follow these standards. An important difference with American standards is the technical specifications (such as inches instead of centimetres). Examples of American standards agencies are the American Petroleum Institute (API), American National Standards Institute (ANSI) and American Society for Testing and Materials (ASTM).

Environmental performance

Environmental performance and energy efficiency are part of the issues that (potential) European buyers increasingly pay attention to. Buyers are looking for green and energy-efficient products and manufacturing methods. They stay away from polluting products and processes wherever possible.

The extent to which buyers include environmental performance and energy efficiency in their sourcing criteria varies greatly. Most companies that consider this, have set up definitions that are made available to potential suppliers.

The environmental management system ISO 14001 is also becoming increasingly common. You may therefore consider it in order to keep up with your competitors. However, ISO 14001 alone will not give you a competitive edge as many players have already implemented it.

Corporate Social Responsibility (CSR)

EU companies are increasingly looking at corporate social responsibility (CSR). CSR looks at the 3 Ps: Planet (for instance, environmental performance), People, and Profit. EU companies will have varying degrees and ambition levels in terms of CSR implementation.

Some companies will (initially) strictly focus on their own operations. Others also look at the CSR performance of their direct suppliers and in some cases (especially with important issues) the entire supply chain. In those cases, suppliers can be as asked to comply with suppliers’ code of conducts.

Some companies will even audit their suppliers on CSR and base their selection on this score. The weighting may even be as high as 30% of the audit score. On the other hand, there are companies who have not (yet) included CSR in their weighting at all.

Important CSR issues in the metal parts sector relate to the sourcing of raw materials, respecting human rights and land rights, healthy and safe working conditions and environmental performance. Other CSR issues that can be of importance will depend on the specific issues that are in play in your specific sector, country or region.

EU buyers will aim to show due diligence, meaning that they will take the necessary steps to avoid implication in CSR violations. Part of this can be to make a risk assessment when buying from regions where CSR issues are likely to occur.

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