Cableways Impact Assessment Study - Final Report - saferail.nl

IA Study Concerning the Revision of the Cableways Directive
6.4 Problem Area D: Conformity Assessment of Subsystems
Consultation for this study suggests that there is a lack of clarity with regards to
existing legal requirements on conformity assessment of subsystems. However, it has
been suggested that notified bodies which account for 90% of the notification market
already use assessment modules which suggests that the impacts of Options D2 and
D3 on cableway manufacturers, notified bodies and operators would likely be
relatively limited. There is no specific evidence of impacts on passenger safety. The
main impacts would likely arise from addressing problems posed by legal uncertainty.
Due to the non-binding nature of the Application Guide, Option D2 is seen as
ineffective in terms of addressing legal uncertainty and it is therefore concluded that
benefits of Option D2 are significantly smaller than those arising from Option D3. In
conclusion, Option D3 is seen as preferable.
6.5 Problem Area E: Alignment with the NLF (Obligations of Economic
Operators)
The cableways sector is said to be transparent with no evidence of attempts to place
non-compliant products on the market and no or limited imports (perhaps with the
exception of cableway ropes). Therefore, both Option E2 and Option E3 appear to be
associated with limited benefits at the present time, although it cannot be ruled out
that increased competition from outside of the EU might mean that these Options will
deliver benefits in the future. In this respect, any potential future benefits from
Option E2 are deemed to be relatively minor and Option E3 is seen as enjoying a
comparatively higher potential in terms of its contribution to reducing or preventing
sales of non-compliant products.
These Options would be associated with a minor increase in administrative burden,
primarily for importers and distributors. Cost impacts on other stakeholders are
assumed to be negligible.
With regard to national authorities, these would incur costs arising from transposition
of these requirements and changes to existing practices but would also enjoy cost
savings from harmonising procedures applied to cableways with those used in other
sectors.
From the present-day viewpoint, relatively limited impacts appear to be associated
with either of the two options. However, should imports of non-compliant cableway
products increase in the future, due to its legally binding nature, Option E3 would
appear to be the more effective option.
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