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Understanding the CE Construction Products Regulation

Regulation EU No. 305/2011

The first thing you may notice about the CE Construction Products Regulation (CPR) is that it is not a “Directive”. In fact, the Construction Products Regulation No. 305/2011 replaced the Construction Products Directive 89/106/EEC in March 2011. The main difference is legal – a Regulation is mandatory law as written in all EU countries and it limits the ability for individual countries to have exceptions to the Regulation. Other than that, manufacturer use of this Regulation is very similar to other Directives for product compliance purposes.

The Construction Products Regulation (CPR): The overall intent of this Regulation is to help insure the safety of “construction works” which are defined as “all building and civil engineering works”. To accomplish this, the CPR requires that all construction products offered for sale in the European Union must first comply with the Regulation. Note that the definition in the Regulation for “construction products” is very broad and includes any product or kit that is incorporated in a permanent manner in construction works or parts thereof.

The Objectives of the CPR: The overall objective of the Construction Products Regulation is to establish harmonized guidelines for expressing the performance of construction products with respect to their essential characteristics. To accomplish this, the CPR defines a consistent method for providing performance rating information to engineers and building designers throughout the EU. The CPR also provides a consistent method for construction product testing and use of calculations related to verifying performance with respect to the construction product’s essential characteristics.

The Two Compliance Paths of the CPR: As with most CE “Product Safety” Directives (LVD, MD, MDD, ATEX), the main path to compliance involves verifying that the product complies with the applicable harmonized standards listed under the Directive (or in this case, the Regulation) in order to bear the CE mark. However, unlike those other Directives, the CE Construction Products Regulation also has a defined second path to compliance known as a “European Technical Assessment” (ETA) for:

  1. Determining compliance of construction products that may not comply with all applicable harmonized standards and,
  2. Determining compliance of construction products that have any declared performance for which there is no harmonized standard.

Declaration of Performance: After verifying compliance of the construction product to the harmonized standards or alternatively, after the construction product completes the ETA process, the manufacturer prepares the Declaration of Performance (DoP) for the construction product. A DoP must be included with each construction product sold in the EU. The DoP identifies the intended use of the construction product and provides the performance ratings for a list of essential product characteristics. The DoP also indicates all standards to which the construction product complies as well as the method used to comply with the Construction Products Regulation.

No Additional Ratings: One way the CPR insures consistency in the communication of performance is by prohibiting any performance claims for a construction product that are not expressed on the Declaration of Performance. And any performance claim on the DoP must be verified to comply with the applicable harmonized standard under the CPR (or via an ETA when a harmonized standard does not exist).

Maintaining Product Quality: In addition to verifying the performance of construction products, the CPR also requires manufacturers verify consistency of performance throughout the manufacturing process and from batch to batch. This is usually demonstrated through an accredited quality certification process that could include batch testing.

Exceptions to the CPR: There are 3 exceptions to the Construction Products Regulation:

  1. Custom construction products, individually made in a non-series process.
  2. Construction products manufactured on the construction works site.
  3. Construction products for construction works that are registered as a restoration project for historical or architectural purposes.

The European Union requires that all construction products comply with the CE Construction Products Regulation before being offered for sale in the EU. Products designed and tested to harmonized standards listed under the CPR have a distinct advantage – the harmonized standards have been written specifically with the CPR in mind and provide well defined requirements that fit the expectations of the Regulation. While the European Technical Assessment process provides a method for construction products to comply with other standards, it is a much slower process and requires agreement to all non-EN harmonized performance verification methods by an accredited Technical Assessment Body (TAB).

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