8.3.1 Affected operators
The proposed regulation covers only certain designated product groups intended for use in flooring, walls and ceilings in indoor environments. We have been unable to carry out any exact calculation as to how many operators are only involved with the relevant types of construction products. Therefore, we are relying on the analyses carried out previously by the National Board of Housing, Building and Planning147 regarding the consequences of
introducing the Construction Products Regulation (CPR), which means that we are assuming that those affected by the proposed regulation are the same operators who are affected by the Construction Products Regulation, according to the National Board of Housing, Building and Planning’s analyses. In other words, we are talking about the whole construction products industry, which includes manufacturers and their representatives, as well as the commercial side comprising importers and distributors of construction products. Other operators affected directly or indirectly are the notified bodies and European technical assessment bodies, regulators, market surveillance authority, clients, designers and all users of construction products.
The largest group directly affected by the CPR are manufacturers and retailers of construction products. According to an estimate from the National Board of Housing, Building and
Planning based on statistics provided by Statistics Sweden, 3,600 companies with a total of 55,000 of employees were involved in manufacturing construction products in Sweden in 2010. The manufacturing was carried out mainly by small and medium-sized enterprises (SME), which are a priority group in the CPR. Statistics from Byggmaterialindustrierna, an industry association for Sweden’s construction products companies, provide similar figures. According to the association there are a total of around 3,300 construction product
manufacturers operating in Sweden, which employ 59,000 workers. The industry exported goods worth SEK 63 billion, imported goods worth SEK 32 billion and had a turnover of around SEK 140 billion in 2010. The largest turnover is in the sector for sawn and planed timber. According to figures from Statistics Sweden, this industry employed around 12,000 people in 1,300 companies in Sweden in 2010 and achieved exports worth SEK 24 billion.
147 http://www.boverket.se/globalassets/publikationer/dokument/2012/anpassning-av-svensk-ratt-till-eu- forordningen-om-harmoniserade-villkor-for-saluforing-av-byggprodukter.pdf
This group includes a large number of contractors who are self-employed, which means that they have no staff.
According to a survey reported by the Swedish Competition Authority148, in 2007 there were a good 3,750 companies with around 16,000 employees operating in the wholesale sector149 for construction products. The wholesale trade turnover for construction products in 2007 was close to SEK 73 billion, with the four largest companies accounting for a fifth of the total turnover. The majority of companies are small in terms of both number of staff and turnover. Out of the 3,750 or so companies, more than 80% were sole traders or companies with a maximum of 4 staff; 15% had between 5 and 19 employees; 2% had between 20 and 49 employees, and 1% had more than 50 employees. Out of these companies, around 80% posted a turnover of less than SEK 10 million, while only slightly more than 3% had a turnover in excess of SEK 100 million. This means that the majority of wholesale companies operate in local markets, while there are a number of large wholesale companies which operate
nationally. The impact assessment from the National Board of Housing, Building and Planning150 identifies more specifically distributors involved in the commercial chain (and therefore affected by the CPR requirements), such as the distributor’s industry association “Bygg & Järnhandlarna”, which reckons, in turn, that there are around 900 sellers of
construction products, of which about 650 are members of the association. The vast majority belong to a commercial chain.
The operators identified according to the description above include more companies than those who are really expected to be affected by the proposed regulation. The construction products being focused on are those which may affect the indoor environment, and this primarily relates therefore to products used to construct flooring, walls and ceilings in an indoor environment. Furthermore, these types of products have been identified on the basis of harmonised standards (see section 8.3.2). Viewed in terms of how construction products are traditionally151 broken down, these products belong mainly to the following categories:
· Structural ancillary products (panels, insulation, glass etc.)
· Products for fittings (joinery, wallpaper, paints, varnishes, flooring products etc.) · Consumables (putty, fixing points, adhesive etc.)
These types of construction products are also included in the survey we had carried out by IVL. The net supply of construction products to the Swedish market, as illustrated in Table 8, has been calculated for a selection of CN codes152, that are found to be linked to the
construction products in focus of our investigation. A complete list of the product groups surveyed, broken down by CN code, is presented in Table B5 in Appendix 7. We believe that this list of product groups largely corresponds to the products affected by the proposed regulation, except for the Pipes and hoses group. However, it should be noted that, in some
148 Swedish Competition Authority, 2009. Åtgärder för bättre konkurrens – konkurrensen i Sverige (Measures aimed at better competition – competition in Sweden). Swedish Competition Authority report series 2009:4. 149 The wholesale trade in construction products s refers to wholesale activities involving timber, other construction products and sanitary ware (SNI 51 530). Details about turnover and the number of employees come from Statistics Sweden.
150 http://www.boverket.se/globalassets/publikationer/dokument/2012/anpassning-av-svensk-ratt-till-eu- forordningen-om-harmoniserade-villkor-for-saluforing-av-byggprodukter.pdf
151 See also the Byggkostnadsdelegationen (Construction costs committee) (2000).
152 The CN codes in this case are at 6-digit level. CN stands for “Combined Nomenclature” and comprises statistical article codes from the customs tariff. See http://www.scb.se/sv_/Hitta-statistik/Statistik-efter- amne/Handel-med-varor-och-tjanster/Utrikeshandel/Utrikeshandel-med-varor/7221/Uppgiftslamnare/Intrastat- in--och-utforsel-av-varor/Varuklassificering-KN-koder/
cases, it is difficult to make the link between product groups and the products which primarily affect the indoor environment. This applies, for instance, to ceilings, which can be made up of many different types of construction products and possibly also of those products which do not feature in the CN codes surveyed by IVL.