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Urteil des EuGH stellt klar: Zusätzliche nationale Anforderungen für harmonisierte Bauprodukte sind nicht erlaubt Am 16. Oktober 2014 hat der Europäische Gerichtshof (EuGH) in Luxemburg ein Grundsatzurteil zum Bauproduktenrecht gefällt und damit das langjährige Vertragsverletzungsverfahren der Europäischen Kommission gegen Deutschland abgeschlossen (Rechtssache C-100/13). Das Deutsche Institut für vorbeugenden Brandschutz e.V. (DlvB) beschäftigt sich seit seiner Gründung im Jahr 2012 intensiv mit diesem Thema. Das Urteil bringt in wichtigen Punkten Klarheit und verpflichtet Deutschland dazu, das nationale System der Bauregellisten grundlegend zu ändern. Bund und Länder streiten seit fast zehn Jahren mit der Europäischen Kommission darüber, ob Bauprodukte, die nach europäisch harmonisierten Normen und mit CE- Kennzeichnung in Verkehr gebracht werden, in Deutschland verwendet werden dürfen, ohne zusätzliche Voraussetzungen erfüllen zu müssen. Seit dem ersten Mahnschreiben der Kommission aus dem Oktober 2005 verteidigt Deutschland die in der Bauregelliste Teil B angeführten Zusatzanforderungen im Kern mit zwei Argumenten: Erstens regele das Europäische Bauproduktenrecht nur des lnverkehrbringen von Produkten auf dem Binnenmarkt. Die Verwendung von Bauprodukten sei hiervon nicht erfasst. Diese der Sicherheit von Bauwerken zuzuordnende Materie obliege der ausschließlichen Zuständigkeit der Bundesländer. Zweitens seien ergänzende nationale Anforderungen jedenfalls in Fällen zulässig, in denen die europäische Harmonisierung von Produkteigenschaften oder Bewertungs- und Prüfverfahren aus Sicht der Mitgliedstaaten „lückenhaft" und ungenügend sei. Behinderungsverbot betrifft auch Verwendung von Bauprodukten Der EuGH hat nun beiden Argumenten den Boden entzogen. Das Gericht stellte am Beispiel von drei Produktgruppen (Elastomer-Dichtungen nach EN 681-2; Wärmedammstoffe nach EN 13162 sowie Tore nach EN 13241- 1) fest, dass die in Bauregelliste B enthaltenen zusätzlichen Anforderungen für den wirksamen Marktzugang und die Verwendung von harmonisierten Bauprodukten in Deutschland gegen Art. 4 Abs. 2 und Art. 6 Abs. 1 der Bauproduktenrichtlinie (BauPRL) verstoßen. Das in diesen Vorschriften enthaltene sog. Behinderungsverbot untersagt den Mitgliedstaaten, den "freien Verkehr, das lnverkehrbringen und die Verwendung "von richtlinienkonformen Produkten zu behindern. Wenn ein Mitgliedstaat "Lücken" in einer harmonisierten Norm findet, darf er diese nicht im Alleingang durch nationale Anforderungen schließen, sondern muss die für diesen Fall im Unionsrecht vorgesehenen besonderen Verfahren nutzen und seine Bedenken auf europäischer Ebene zur Diskussion stellen. Ergänzende nationale Regelungen sind unzulässig Formal hat der EuGH noch am Maßstab der alten BauPRL entschieden, da es aus prozessualen Gründen nicht möglich war, die zum 1. Juli 2013 wirksam gewordenen Regelungen der neuen Bauprodukt

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