Retrofit kits for Small wastewater treatment systems

CE marking, approval and voluntary manufacturer’s declaration of conformity

Retrofit kits for sewage treatment technology are key components of the industry and are preferably installed in suitable concrete tanks. As a product, they are therefore subject to various regulations that are difficult to understand:

1. European requirements for free movement of goods (CE marking, factory production control) and product safety.

2. National regulations, e.g., for operation, installation and maintenance (Wastewater Regulation, German Association for Water, Wastewater and Waste (DWA), DIN 4261-1, approval and additional documentation.)

The harmonized standard for packaged and/or site-assembled domestic wastewater treatment plants EN 12566-3, published under the European Construction Products Regulation, for example, is not completely applicable to retrofit kits. Accordingly, no CE marking in accordance with the Construction Products Regulation can take place here.

Background: the general technical approvals customary in Germany (abZ) for small wastewater treatment systems were abolished in 2017 in line with the implementation of the ECJ judgment of October 2014. In the ruling, it was prohibited to impede free movement of goods by the German abZ for products with CE marking by implementing additional national requirements. For the retrofit kits, which are not subject to the ruling, the German Institute for Construction Engineering (DIBT) has now introduced new abZs.

However, for all products in the European market the manufacturer / distributor must apply not only the Construction Products Regulation. For retrofit kits, additional European regulations must as a rule be taken into consideration for which CE marking may well be required. Due to the elimination of abZ approvals for small wastewater treatment systems, a number of effective requirements for installation, operation and maintenance, which were formerly contained in the abZ, are now lacking. This information can now be possibly obtained from the voluntary manufacturer’s Declaration of Conformity. The DWA worksheet A221 and the new Wastewater Regulation will play an important role in future documentation.


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