An effective system of market surveillance is another key to the success of any successful regulatory proposal. In relation to system regulation, the fact that every installed system is unique implies particular challenges for market surveillance [Brocklehurst 2021, p.4-6]:
- A much higher volume of compliance testing must be carried out to assure the same level of compliance as a mass-produced product. This requires many more market surveillance resources.
- It is a greater challenge for authorities to keep track of all the products that are placed on the market.
- Compliance verification requires on-site inspection in addition to documentation analysis and laboratory testing. The legal mandate to carry out such inspections needs to be covered.
The following solutions could address these challenges:
- Creation of an online database for installers to notify an installation of a system covered by regulation;
- Bundling of on-site market surveillance verifications for various regulations of different types, for example, ecodesign, and health & safety.
Note that the health and safety regulation for lift systems (Lifts Directive 2014-33) was found to be successful despite inadequate market surveillance arrangements [Brocklehurst 2021, p.37]. This is probably because it is a safety regulation, followed more rigorously since nobody wishes to be held responsible for an accident.
Every installed system is unique. The challenges this brings for market surveillance can be addressed.