The new Construction Products Regulation (CPR) will directly affect all manufacturers, distributors, end users, specifiers, and architects in the supply chain. This will be the most significant change in a long time in the way construction products are sold in Europe, including their CE marking.
Starting July 1, it will be mandatory for manufacturers or other legal entities placing a product on the market to apply CE marking to any products that are covered by a harmonised European standard (hEN). And hardware products — including door closers, hinges, panic and emergency exit devices, and locks — will be required to have the new Declaration of Performance (DoP) for declaring the essential characteristics.
CPR at a glance:
Importers, distributors, and manufacturers shall ensure products bear the CE mark and have the required accompanying documents, including DoP, before placing them on the market.
A product that does not conform with the DoP must be withdrawn or recalled.
In severe cases, there is a clear duty on importers, manufacturers, and distributors to inform the national authority of member states — in the UK, the Trading Standards.
Each importer, manufacturer, and distributor must establish National Product Contact Points to foster traceability.
European technical assessment
Where a manufacturer chooses to test fire-stopping products (ablative coated boards, putty, fire stop pillows, etc.) to a European technical assessment (ETA), which has a clause allowing for CE marking, the manufacturer will also have to apply a CE mark and produce a DoP for the product — the same rule that applies for a hEN.
DoPs are replacing Manufacturers Declarations, which are currently produced when declaring the performance of a product for ENs or ETAs.
Under the current Construction Products Dircetive (CPD), affixing the CE mark is voluntary in the UK (as it is in some other member countries), so this will be a major change for some areas of the UK construction industry.
The CE marking should be affixed to all construction products for which the manufacturer is declaring compliance with the regulations. From this, a DoP will be produced that will reflect the CE marking requirements.
Traceability of products
One of the priorities is making all products traceable back to the legal entity — the person placing a product legally on the market.
Distributors and importers become crucial in this respect. They can become the legal entity if they sell products under their own name and brand. If they don’t, then they have to sell each brand separately with its own stock record number, so that traceability is achieved back to the legal entity.
If a product is found not to be in compliance with the DoP requirements, then every step should be taken to correct this, or the product should be withdrawn or recalled from the market.
If a product presents a risk, then the competent authority of the member state should be informed immediately. Details of the noncompliance will be needed, and any corrective measures should be taken. For the UK, Trading Standards will be the main organisation responsible for enforcement.
Construction products placed on the market in accordance with Directive 89/106/EEC before 1 July 2013 shall be deemed to comply with the CPR. Manufacturers or legal entities may draw up a DoP now on the basis of a certificate or declaration of conformity, which has been issued by a notified body before 1 July 2013 in accordance with Directive 89/106/EEC.
The changes to the CPR will not have a great effect on those already CE marking products, member states currently mandating CE marking, or manufacturers whose products are subject to an ETA or to European Assessment Documents. The main change will be producing the new DoP.
Do ask to see the DoP (or view it on the relevant website), because not all products are acceptable for the application just because they carry the CE mark. Check if the product has the correct fire and/or smoke characteristics if it is going in an area where fire and smoke barriers are needed.
The CPR will have a significant effect on those who may have been sheltering under the CPD. There is no flexibility on the start date or the duties involved.
For further advice on the Construction Products Regulation, visit www.warringtonfire.net or email [email protected].
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Paul, what an eye opening article. And extremely indepth. While a lot of the specifics are a little over my head, I’m sure there’s a helluva lot of people reading this that will find it extremely hepful.
The bit that really caught my eye was ‘There is no flexibility on the start date or the duties involved.’ I take it this means potential repercusions for non-compliance from soon after Day 1?
Robert, thank you for your reply
The Construction Products Regulation has been published in Europe since April 2011, so there has been a transition period, the final parts will now become mandatory on the 1st July 2013 and the CE marking section is one of these.
We at Exova Warringtonfire have been working with clients, trade associations, etc to help support this change and we have ongoing work in this area.
we are working on DoP’s, which can start to be used now, but will be so important on the 1st july.
Hi Paul. Timely and detailed blog on a topic of major interest for the security and fire sectors. You’ll be interested to learn that our UBM colleagues working on the Ecobuild event hosted a webinar this morning between 11.00 and 12 noon under the banner ‘The Essential Guide to Door Opening Solutions’. The Construction Products Regulation formed part of the dicusssion. I listened to the entire webcast and joined in with the Q&A as well as the chat. I referenced your article on our site as part of the Twitter debate. If any readers would like to view the Ecobuild webinar retrospectively they can do… Read more »
Brian, thanks for your reply
it is an important subject, as it is a change to the way the UK will operate in the construction industry.
I’ve also attended various CPR seminars in Europe and it’s good to see that mostly they are all giving the same informaiton to industry, which can only be good and prevent confusion
there are still areas that need to be clearer, the end user, specifiers and architects will need support and education and we are working on this within Exova Warringtonfire and Warrington Certification as they are important in the supply chain.
Vital of course, Paul. Hopefully discussions such as this and this very article will help get the word out for end users and specifiers etc.