By Geoff Gurney, CE marking manager at BBA
For architects and other specifiers it is pretty much business as usual. The Construction Products Regulation (CPR) sets out conditions for placing products on the market and harmonises the way in which performance is assessed and expressed.
The CPR achieves this by means of harmonised technical specifications, known as harmonised European product standards (hENs) or European Assessment Documents (EADs), which are used as the basis for issuing European Technical Assessments (ETAs) for products not covered or not fully covered by hENs.
The harmonised technical specification defines EEA-wide methods of assessing and declaring of performance characteristics required by regulations in any member state which affect the ability of construction products to meet the basic requirements for construction works. This means that separate tests are no longer needed for products being sold in more than one member state.
The CPR only covers regulated issues, and to accommodate this hENs have an Annex ZA which sets out the requirements for CE marking.
Providing local Building Regulations are met, designers, specifiers and users are free to set their own requirements on the performance of the works and, therefore, construction products. The information contained in the manufacturer’s declaration of performance (DoP), together with the product specification, will make it possible to compare products and judge whether they meet all relevant regulations.
The DoP is therefore key with the CE marking being a summary and indication that a product is consistent with its DoP. The information to accompany the CE marking is set out in the harmonised technical specification.
However, this information needs to be treated with caution. Take for example BS EN 13859 relating to roof tile underlays: BS EN 13859 Flexible sheets for waterproofing — Definitions and characteristics of underlays — Part 1: Underlays for discontinuous roofing.
Clause 18.104.22.168 Class W3 – If the product fails the test indicated in 22.214.171.124, e.g. the measured mean volume passing the specimens exceeds 100ml, it shall be classified as resistant to water penetration Class W3. Untested products shall also be classified as resistant to water penetration Class W3.
This means products within the scope of BS EN 13859 can bear the classification W3 and have failed, or not have been tested, for resistance to water penetration. It is important that users and specifiers understand the levels and classes reported in the DoP and subsequent CE marking.
The system of Assessment and Verification of Constancy of Performance (AVCP) is the term applied to define the degree of involvement of third parties in assessing the conformity of the product according to the relevant technical specification. For each product family, the system of AVCP is decided collectively by the Member States and the European Commission depending on the implications of the product on health and safety and on the particular nature and production process for the product itself. There are five systems of AVCP and levels of involvement of a third party range from full product certification and audit testing to no involvement at all, only the manufacturer’s endorsement.
Subsequently it is important that the specifier or designer checks the detail before making a decision, as the above examples clearly show.
Voluntary marks are permitted provided they fulfil a different function from that of the CE marking, are not liable to cause confusion with it, or reduce the CE marking’s legibility or its visibility. They should provide added value such as by covering a new characteristic not dealt with in the harmonised technical specification or a higher level of AVCP.
Manufacturers may use voluntary marks where they add value to the CE marking and do not cause confusion.
- to support information in respect of the ‘voluntary’ (non-harmonised) part of a hEN
- to include additional third-party involvement above that required by the prescribed system of AVCP, such as durability, installation etc., that is outside of the scope of the harmonised technical specification
- to place the test characteristics in context in the area of use, for example in relation to Building Regulation compliance.
The CPR also adds responsibilities to importers and distributors who must assure themselves that the manufacturer has undertaken all that is required.
Architects and specifiers working with public or private-bodies that are acting as a public undertaking must also consider other EU legislation affecting them and connected with standards, specifications and procurement.