Construction Products Regulation: What You Need to Know

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.

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be in compliance with the DoP requirements, then every step should be taken to correct this, or the product should be withdrawn or recalled from the market.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 globalfire@exova.com.