Disclaimer: This document is a European Commission staff working document and is for information only. It is not a statement of the Commission's current or future official position on the subject it addresses.

Commission Staff Working Paper The Environmental Technology Verification (ETV) initiative Helping Eco-Innovations to reach the Market

Europe faces a range of environmental challenges that will impact on its future prosperity. These include resource depletion, increasing water scarcity, air pollution, climate change and biodiversity loss. Europe leads on innovation and innovative environmental technologies can provide solutions while also increasing EU competitiveness. Breaking into the market with innovations can be a significant problem, because innovations by definition cannot show a successful track-record. Without credible information about innovative technologies, potential buyers are unsure whether or not to trust the claims made about their performance.

Environmental Technology Verification (ETV) addresses that problem. It is an initiative that provides for third-party verification of the performance claims made by technology manufacturers in business-to-business relations. By issuing a Statement of Verification, which is the product of a successful ETV process, ETV provides credible information on the new technology. Market access for innovative environmental technologies is significantly enhanced and the technological risk for technology purchasers (whether private or public) reduced. The information contained in the Statement of Verification summarises the actual performance of the verified technology as well as the results of the tests performed. With proof of performance credibly assured, along with information about the design of the tests, innovations can expect a larger market share.

European Commission services, together with seven Member States[1], intend to launch a pilot ETV programme covering three technology fields: (1) water treatment and monitoring, (2) energy technologies, (3) materials, waste and resources. The ETV pilot programme is to be implemented by Verification Bodies specifically accredited for this purpose by national accreditation bodies in the Member States concerned.  Verification Bodies act, effectively, as a one-stop-shop for companies using ETV.

Although supported by some EU-funded 'seed money' to set the system going, the medium- to long-term expectation is for any eventual EU ETV scheme to be completely self-standing, with little or no Commission involvement. The Verification Bodies – which are at the heart of the ETV pilot initiative – will initially be supported by the EU budget, with an annual amount of €1 million programmed from 2011 to 2013. This funding will be used to set-up the structures and activities necessary to implement ETV; and as a preliminary market support action, to facilitate the ETV access for Small and Medium-sized Enterprises.

In parallel to the ETV pre-programme, the Commission has commissioned a study to assess in detail the market potential of, and demand for, an EU ETV system. The study looks at the market potential of ETV in different technology areas (not only the three areas where the pilot programme is implemented) and in various EU markets. It examines a series of technology applications where ETV could be expected to have a significant added value and estimates the potential demand for ETV as well as the readiness of relevant actors to contribute financially.

Despite strong suggestions of the added value of an ETV scheme coming from the wide consultation and involvement of stakeholders so far, no commitment to an EU ETV scheme is implied at this stage. Results from the ETV pilot programme and the market assessment study will need to be analysed before the Commission can consider the way forward and make proposals, if appropriate, on environmental technology verification in the EU.

1. What is Environmental Technology Verification (ETV)?

The aim of ETV is to provide reliable information on the performance of new eco-technologies, to make market penetration and market awareness of the product easier.  Purchasers and investors should be credibly informed about the performance of the innovation.  ETV would reduce the risk that potentially very useful environmental innovations, which offer significant benefits in terms of EU environmental performance, will otherwise never reach the market.

Environmental technologies cover many areas. They include technologies to prevent or deal with pollution, to enable energy and resources to be used more efficiently, to provide more environmentally-friendly goods and services. The performance of these technologies is understood as the results obtained in relation to their objective – e.g. the rate at which a new water treatment technology purifies water. Their impact on the environment and health – for example, the lower emission of pollutants from a new production process – would also be assessed under ETV.

ETV would verify, through qualified third-parties and transparent procedures, that performance claims are based on complete, fair and reliable test data. This would benefit all parties:

· The technology developer can show reliable data proving the value of the innovative technology,

· Technology buyers and investors have reliable information on which to base their purchasing decisions and to better manage technological risk,

· Other stakeholders, public policy-makers or regulators have clear indications of the performance achievable by new technologies.

The ETV process would not entail repeating the tests already carried out: test data of good quality may be taken into account and help save time and cost. Key aspects under ETV are that performance parameters are completely and correctly defined and that test data are reliably established. For example, the Verification Body would ensure that operational conditions are clear, that no important impact has been missed, that parameters are verifiable and that the tests are performed under good quality systems.

The added value of ETV lies in the quality, credibility and comparability of the 'Statement of Verification', which is the result of a successful verification process. The complete verification report and the 'Statement of Verification' are intended for use in business-to-business relations. This is not a product certificate in the sense that there is no control that a series of products conform to given specifications. ETV is not a label either: each Statement is specific to one technology; there are no pre-defined labelling criteria.

ETV Statements of Verification would be registered and published on a public website, allowing stakeholders to check references relating to ETV verifications and to access a reliable source of comparable data on environmental technologies. The publication of the complete verification reports would be encouraged, but the decision whether or not to publish would be left to technology manufacturers (e.g. to protect intellectual property).

Verifying the performance of a technology under ETV is just one step in a process leading from research and development to market penetration and diffusion. It is therefore essential that ETV is undertaken at the right moment in this process.

To be ready for ETV, the technology should be ready for the market, i.e. once all major developments affecting the performance have been concluded. When there is a demonstration project or test campaign planned, verification under ETV would normally add only a marginal cost in exchange for a significant benefit in terms of added credibility.

ETV is particularly advisable where there is no technical standard or certification system available to prove the performance of the technology concerned, or where the innovative features are not adequately reflected by the existing standards.

2. Why an EU ETV pilot programme?

ETV programmes have been implemented for one and half decades in North America (US and Canada) and for half a decade in East Asia (Japan, Korea, the Philippines). In Europe, several research and pilot projects have been funded by the EU Framework-Programme for Research and Technological Development, by the Nordic Innovation Council and by several Member States (Denmark, Germany, the Netherlands)[2]. The EU pilot programme builds on these different programmes and projects.

The EU pilot programme would enable a large-scale experiment of ETV in near-real conditions. The main elements of a voluntary EU ETV scheme are to be tested through the pilot programme, although the pilot programme would not be on the full scale, either geographically and regarding the technological scope, that would be expected under the definitive scheme. The aspects of the pilot programme which will be evaluated in particular are the following:

· Practicality and robustness of procedures: accreditation of Verification Bodies, co-ordination through technical working groups, solution of disputes between proposers and operators;

· Value added of the pilot programme: response to the potential demand for ETV, value added for technology developers and users, response to policy objectives;

· Cost-benefit of the pilot programme, accessibility for SMEs: capacity of the pilot programme to become self-sustainable, capacity of interested SMEs to meet the costs or to find appropriate support to use ETV.

Verification Bodies will be requested to collect the basic information necessary to enable the evaluation of the pilot programme, as part of the funding agreements to be concluded with the Commission.

Indirect benefits may also be expected from ETV in the medium- to long-term, such as the facilitation of international technology exchanges through the international recognition of ETV verifications and the progressive emerging of an eco-innovation market place, promoting competition based on performance and facilitating the greening of public procurement.

3. Scope of the pilot programme 3.1. Initial scope

The ETV pilot programme is open to all market-ready technologies that demonstrate a potential for innovation and are of benefit to the environment. The scope of the technology areas to be covered by the ETV pilot programme is initially limited to the following three areas:

(1) Water treatment and monitoring (monitoring of water quality, treatment of drinking water and of waste water)

(2) Materials, waste and resources (separation and sorting of solid waste, recycling of materials, end-of-life products and chemicals, products from biomass)

(3) Energy technologies (renewable sources of energy, energy from waste, energy efficiency technologies)

3.2. Scope for further development

The scope may be extended to cover further technology areas in the future, depending on demand, availability of testing organisations and protocols, and administrative capacity of the pilot programme itself. In addition to the three technology areas above, the following areas are to be considered for possible inclusion. For that reason, they are included within the scope of the market assessment study run in parallel to the ETV pilot programme.

(4) Soil and groundwater monitoring and remediation (monitoring of soil pollution, of groundwater, remediation in-situ, depollution of sediments and sludge)

(5) Clean production and processes (savings in material resources, energy efficiency in industry and buildings, prevention and reduction of industrial pollution and waste)

(6) Environmental technologies in agriculture (abatement of air and water pollution, including odours, re-use or recycling of nutrients and organic waste, reduction of pesticide use)

(7) Air pollution monitoring and abatement (air emissions monitoring, abatement of pollution carried out within stationary installations)

If successful, the ETV approach could also be applied to other technological fields, within or beyond the field of environmental technologies, possibly integrating other aspects than environment, for example in the health and social fields. As long as these aspects can be quantified and verified through testing, they could be verified following the same approach. This would lead to new types of technical information, alongside technical standards and labelling, for the benefit of technology developers, purchasers and policy-makers.  Better-informed choices will be more cost-beneficial. Any wider application of ETV would however need to be specifically assessed.

4. ETV Procedure for individual verifications

Environmental technologies submitted to the ETV pilot programme for verification would undergo the following process, which is performed by a Verification Body accredited for this purpose and competent for specific groups of technologies. When further tests are needed – e.g. when the Verification Body finds that the test data in support of the claims are not sufficiently robust – a testing body is designated by the technology manufacturer to carry out further tests.

 

The organisation of the ETV pilot programme is further detailed in Annex II.

5. ETV position among other EU policies

The Environmental Technology Verification initiative was prepared under the Environmental Technologies Action Plan[3] (ETAP) and fulfils a commitment taken under the Action Plan on Sustainable Consumption and Production and Sustainable Industrial Policy (SCP-SIP)[4]. The latter sought to promote initiatives aimed at increasing the uptake of resource-efficient and eco-innovative production.

The ETV initiative is fully in line with the approach of the EU 2020 strategy for smart, sustainable and inclusive growth, in particular with the objectives of

· Developing an EU economy based on knowledge and innovation,

· Promoting a more resource efficient, greener and more competitive economy.

The ETV initiative also complements (and may facilitate or support the implementation of) several voluntary schemes and legislation at EU level:

– ETV is concerned with industrial products and processes and should provide information for use in business-to-business relations; this is complementary to eco-labels, which relate to consumer products and aim to identify greener products based on agreed criteria;

– ETV is not about defining minimum requirements, but about ensuring the credibility of performance claims put forward by a producer, going beyond minimum requirements where they exist; in particular, the Eco-Design Directive on Energy-using Products and the Energy Labelling Directive define mandatory criteria on the design of products and on the information to be provided by the producer; ETV will not overlap with the information collected under these Directives;

– Statements of Verification issued under ETV  are specific to the verified technologies; they might however be used to facilitate the definition and verification of participants' commitments under environmental management systems such as the EU Eco-Management and Audit Scheme (EMAS), which have by nature a larger scope than ETV;

– The EU Industrial Emissions Directive (IED, former IPPC) relates to permitting procedures under which Member States define the obligations of some production plants in terms of emission limits. The Best Available Techniques defined in this context refer largely to technologies already in use, for which a track record on environmental performance already exists. By addressing innovative technologies arriving on the market, ETV is complementary to this process and could add value, as verified technologies could more easily be taken into account.

6. Cost of verification and the funding of the ETV pilot programme 6.1. Cost of verification

The costs of verification under ETV can vary considerably depending on the technology concerned and the quality of existing data. The DANETV verification centre has been active in 5 technology areas since 2009 and uses procedures close to the EU pre-programme. Based on 21 verifications finalised in 2009-2010, the average cost for the testing and verification of technologies was €53,000[5], of which €28,000 was attributable to the verification procedures per se.

Feedback from public consultations and stakeholder workshops indicated that these costs may be an obstacle to participation, particularly in the case of small and medium-sized technology companies. In order to facilitate their access, the fixed costs of the pilot programme are to be indirectly supported by the EU budget, the aim being to limit the average total contribution by participating Small and Medium-size Enterprises to no more than around €20 000. This issue of SME participation will be looked at when the results of the pilot programme are evaluated.

Companies can reduce verification costs by integrating ETV early in their technology development process. Technology manufacturers typically have a full-scale demonstration or prototype roll-out undertaken before the marketing of new technologies. By organising at the same time the third-party testing of the technologies, they can collect test data in advance of the ETV procedure. To fulfil the quality requirements of ETV, a complete verification procedure under ETV could be discussed at this stage with a Verification Body. Any additional cost due to the ETV requirements on data and data quality are then likely to be minimal, and the cost of additional verification tests during the ETV process might then be avoided.

6.2. Funding of the ETV pilot programme

The costs related to the co-ordination of the pre-programme (meetings of the ETV Steering Group and technical groups, studies and external expertise, general information on the pre-programme) are to be covered by the EU budget (administrative budget and operational expenditure under LIFE+) following usual annual budget procedures.

In addition, to facilitate the launch of the ETV pilot programme, a call for proposals will be launched in 2011 under the EU Competitiveness and Innovation Programme (CIP) with a budget of €1 million[6]. Amounts of €1 million are also programmed under CIP for ETV in 2012 and 2013, subject to the approval procedure of annual work programmes for these years. The 2011 call should be open to Verification Bodies already accredited under ETV and it should select proposals for new activities enabling Verification Bodies to:

Ø Participate actively in the setting-up of the ETV pre-programme by implementing ETV procedures within their technical area, including by participating in relevant technical groups;

Ø Facilitate access to verification procedures under ETV for Small and Medium-sized Enterprises by providing specific technical assistance during ETV processes.

In addition, Verification Bodies are asked to set up and maintain a Quality Management System, ensuring a high level of quality and reliability for ETV procedures and products, and to report on the implementation of ETV, providing indicators that will help the evaluation of the ETV pilot programme. Only the extra costs necessary to implement verifications under the ETV pilot programme can be eligible for support in the context of this call. Furthermore, grants cannot be the source of profits for verification bodies for the duration of the grant agreement.

After evaluation of the responses to the call for proposals, Partnership Framework Agreements should be concluded with successful applicants for a duration of three years, with grant agreements being concluded on an annual basis in order for the Commission to retain the option of tailoring the level of grants to the actual conditions of implementation. The level of grants will take into account the technology scope covered by Verification Bodies, the estimated number of technologies to be verified and the number of SMEs to benefit from their assistance.

By off-setting partially the 'fixed costs' of the system, it is expected that the grant agreements with Verification Bodies will indirectly reduce the final cost for technology developers.

6.3. Possibilities of direct support

Several of the participating Member States have funds available for the promotion of innovation, having recognised the importance of supporting technologies that can help generate employment and economic growth.

Direct support to technology manufacturers, in particular SMEs, for verifications under ETV could therefore be sought through larger funding programmes, at EU and Member State level:

–  Verification under ETV could be included as part of the final stage in projects supported by research funding aimed at developing environmental technologies to the point where they are ready for the market;

–  Under EU programmes such as LIFE+ and CIP  eco-innovation, ETV procedures could be integrated into larger projects including, for example, industrial investments, industry-research partnerships or prototypes;

–  A number of SME-support schemes in Member States include support to product certification, authorisation procedures or marketing of new products and services. A study commissioned by the Commission in 2009 concluded that many of these schemes could cover support to individual verifications under ETV with little or no modification to their policies.

In the selection process of projects integrating ETV activities, under EU programmes, particular attention will be given to the risk of double-funding.

Where Member States wish to compensate manufacturers for part of the verification costs with subsidies which may constitute state aid within the meaning of Article 107(1) of the EC Treaty, they are reminded of the obligation to comply with State aid rules. In particular the provisions of the General Block Exemption Regulation (GBER) or of the de minimis rule may be applicable for such aid.

7. Conclusion

By enhancing the quality and reliability of information on the performance of new environmental technologies arriving on the market, ETV should increasingly contribute to the deployment of eco-efficient innovation, generating further investment in environment-related technologies and industries within the EU and enhancing competitive advantage. Together with the other policy measures planned in the context of eco-innovation, this should ultimately improve the cost-effectiveness of environment protection measures and generate more jobs.

ETV programmes have been in place in the US and Canada for more than a decade and are expanding elsewhere, e.g. in Asia. The Commission services participate in an informal International Working Group (IWG-ETV) aimed at preparing the ground for the harmonisation and mutual recognition of ETV programmes globally[7]. The feasibility of an ISO or ISO-CEN standard on ETV is being explored by the IWG-ETV. The experience gathered under the EU ETV pilot programme should further influence any harmonised approach on ETV.

The results of the ETV pilot programme will be evaluated by the Commission services after two to three years of actual operations. On the basis of this evaluation and the study on the market potential of ETV, the Commission will draw conclusions on the potential of ETV in Europe and on the best way to mobilise it.

 Annex I Preparatory actions

The ETV initiative is based on several studies, pilot projects and research which explored the problems encountered by new eco-technologies, as a preliminary to refining the concept of environmental technology verification. Verification protocols in specific technology fields served to test ETV in real cases. In total, some 35 technologies have been verified during this initial phase of the ETV initiative. The scene is now set to further validate and implement the concept of ETV in a wider context under fully realistic conditions, as a stepping-stone towards a potential EU-wide scheme.

Supporting projects and studies

In 2007, the Commission's Joint Research Centre Institute for Prospective Technological Studies ('IPTS') published a report analysing various aspects of existing ETV systems outside the EU – notably the USA and Canada. The report also looked at the feasibility of establishing ETV in Europe and it provided a basis for the preparation of a Commission ETV initiative. In 2008, another IPTS report on the costs of ETV systems, and a separate study looking at EU Member States' funding schemes for technology verification in the context of development of Small and Medium-Sized Enterprises, provided input on costing and funding aspects of ETV.

Between 2004 and 2009, four EU-funded research projects[8] developed generic testing protocols for specific technology areas: water treatment, soil and ground-water protection and rehabilitation, air emissions abatement technologies, clean production and environmental monitoring.

In addition, the pilot project TRITECH – funded under the LIFE[9] instrument in 2006-2009 – tested an operational procedure for technology verification in real conditions for 15 cases in three technology areas: water, soil and energy.

One further research project was selected under the 7th Framework Programme and began in 2009. It supports the ETV initiative by facilitating the integration of earlier research project results into the ETV pilot programme. The specific aim is to promote international harmonisation and mutual recognition between various countries' ETV systems.

Some EU Member States also implemented pilot projects on ETV: the project of the Nordic Innovation Council on Water Technology Verification Centres (NOWATECH)[10], the DanETV center on 5 different technology areas[11] and the VERA project on Verification of environmental technologies for agricultural production[12]. Some private initiatives also inspired ETV, such as the programmes of instruments evaluation run by associations of industrial users[13].

Public consultations

Two internet-based consultations (between November 2007 and March 2008), attracting 470 responses in total[14], and several expert workshops also contributed to the preparation of the ETV initiative. The main lessons drawn from the consultations were the following:

· Clear need for ETV: 83% of respondents to the general consultation and 64% of respondents to the EBTP consultation considered that there was a 'clear' or 'important' need to promote and organise third-party verification of technology performance. The first objective of the system should be to 'help technology purchasers (public or private) base their purchase decision on reliable information' (31% of respondents);

· There is overall support for having a scheme organised by EU institutions (51% of respondents), based on performance claims, on a voluntary basis and using test data provided by technology developers, with additional tests if needed (71% of respondents considered this 'appropriate' or 'very appropriate');

· The technology areas envisaged in the consultations for the beginning of the scheme (monitoring techniques, water, energy, air and clean technologies) were considered appropriate by 67% of respondents to the general consultation;

· Among the key characteristics of the scheme, two were considered very important by stakeholders: credibility and scientific soundness (78% of respondents), and the recognition of verification results in Europe (64%);

· Stakeholders were more hesitant about costing issues: 51% of respondents considered that the estimates given in the consultation paper (€20,000) could probably not be met by SMEs without external support, while 42% of respondents to the general consultation and 20% of respondents to the EBTP consultation considered that they could be met, if justified by the added value offered by the scheme.

Annex II Organisation of the pilot programme

The ETV 'General Verification Protocol'

Verification Bodies, testing bodies and analytical laboratories follow the provisions laid out in the ETV General Verification Protocol ('GVP'), which is in fact a set of general instructions for the verification of individual technologies. This includes the qualification of organisations implementing ETV procedures and the requirements regarding the quality of test data acceptable under ETV. The GVP ensures that the procedures followed and the outcomes from the pilot programme are of adequate quality and are both credible and reliable.

The GVP used under the ETV pilot programme has been elaborated by experts and stakeholders in the framework of the EU research project AdvanceETV and reviewed by the EU Member States participating in the pilot programme, represented in an ETV Steering Group.

The GVP should be the main technical reference for the implementation of ETV procedures and co-ordination at the European level. Where appropriate, it refers to relevant existing standards. It is used by the existing national accreditation bodies, in addition to the standard for inspection bodies ISO/IEC 17020, for the accreditation of Verification Bodies under the co-ordination of the over-arching body, European co-operation for Accreditation. The organisation of accreditation under ETV follows the same patterns as the "New Legal Framework" for the certification of products in the internal market[15].

The GVP includes provisions on the quality management systems that all organisations involved in verification under ETV should have in place, thus further ensuring the robustness of ETV procedures. In addition, analytical laboratory[16] should be accredited against the standard for laboratories ISO 17025.

Provisions on specific verification protocols refer to key environmental factors, to be identified in a life-cycle perspective and taken into account when defining the verification parameters. This ensures that crucial environmental aspects are not missed in individual procedures (for example energy aspects when verifying a water treatment technology).

The characteristics of the ETV pilot programme – both its organisation and quality requirements – have been designed to ensure a satisfactory balance between:

· credibility, quality and robustness of ETV procedures,

· flexibility, with maximum choice left to the proposer, notably as to the choice of test body, bearing in mind variation in test costs and the possibility of selecting a test body located close to the proposer, for practical and/or linguistic reasons.

Technical groups

Verification bodies are represented in technical groups, which are co-ordinated at EU level and are responsible for harmonising the specific procedures followed for each technology area, ensuring coherence and comparability of results within the ETV system overall. The technical groups issue guidance to Verification Bodies for this purpose. They have a role in refining the technology scope of ETV within their technology area (i.e. the range of actual technologies to be covered). Technical groups will need to take account of the opinion of technology users and other stakeholders with regard to ETV procedures, and they can give an opinion in case of conflict between a Verification Body and a proposer.

Annex III Indicative implementation calendar

Starting from the release of this Staff Working Paper, the following steps are planned for the implementation of the ETV initiative:

· In the first month: diffusion of technical documents underpinning the ETV pilot programme (General Verification Protocol), beginning of accreditation of Verification Bodies under ETV;

· In the second or third month: publication of a call for proposals for Verification Bodies, under the Competitiveness and Innovation Programme, to support the launch of the ETV pre-programme;

· In the first six months: setting-up of thematic technical groups;

· In the first year: conclusion of Framework Partnership Agreements with Verification Bodies, ETV pre-programme becoming operational;

· After 2 to 3 years of operations: evaluation of the results of the ETV pre-programme and decision on the way forward, preparation of related proposals if appropriate, including ex-ante impact assessment.

[1]       As of October 2010, participating Member States are: Belgium, the Czech Republic, Denmark, Finland, France, Poland and the United Kingdom.

[2] See Annex I for more details.

[3]       Communication from the Commission to the Council and the European Parliament on 'Stimulating Technologies for Sustainable Development: An Environmental Technologies Action Plan for the European Union', COM(2004) 38 final, 28.1.2004

[4]       Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions on the Sustainable Consumption and Production and Sustainable Industrial Policy Action Plan, COM(2008) 397/3, 16.7.2008

[5] Costs for testing and verification ranged between €22,000 and €94,000.

[6]       2011 Work Programme for CIP – Entrepreneurship and Innovation sub-Programme – adopted on 18 January 2011 by Commission Decision C(2011) 91.

[7] The Statement of Intent setting up the International Working Group on ETV, its objectives and modes of operation, was approved by the Commission by written procedure PE/2008/2354 on 23 May 2008. The members of the IWG are currently the Canadian, EU, Philippine and US programmes.

[8]    Under the 6th Framework-Programme for Research and Technological Development (FP6). The results of all ETV related projects are accessible through the common website: http://www.eu-etv-strategy.eu/

[9]       L'Instrument Financier pour l'Environnement – the environmental funding facility managed by DG Environment.

[10] See http://www.nordicinnovation.net/

[11] See http://www.etv-denmark.com/danetv/

[12] See http://www.ecoinnovation.dk/English/Topics/Verification_of_ecoefficient_agro_technologies/

[13] See http://www.exera.com/, http://www.evaluation-international.com/ and http://www.wib.nl/

[14]     The first public consultation, using the Interactive Policy-Making tool, attracted 139 responses. The second one used the European Business Test Panel (EBTP), which is a tool allowing the European Commission to obtain direct feedback from businesses on Commission legislative proposals or initiatives likely to have an impact on businesses. The EBTP is composed of around 3 600 companies of different sizes and sectors located in all EU Member States. The EBTP consultation on ETV attracted 371 replies, of which 331 complete responses.

[15]     See Decision 768/2008/EC of the European Parliament and of the Council of 9 July 2008 on a common framework for the marketing of products and Regulation (EC) 765/2008 setting out the requirements for accreditation and market surveillance relating to the marketing of products. In particular, the requirements of the ETV General Verification Protocol on the qualifications of Verification Bodies build on the requirements relating to notified bodies under Decision 768/2008/EC, Article R17.

[16]     Analytical laboratories are distinguished from other test bodies when they implement analytical work, for example to measure chemical compounds in water or air samples, because such activities follows highly standardised and quality-controlled procedures, independent from the products or processes at the origin of the analysed samples, whereas technology tests are by nature dependent on the technologies tested.