Yet again we have to focus on ever-changing legislation and find out how it affects each one of us. The current changes that are particularly relevant to the Fire Industry across the whole of the EU are the Construction Products Regulations (CPR).
What exactly is the Construction Products Regulation?
The CPR is in response to the most significant changes faced for a decade in ‘the way in which construction products are sold in Europe’.
The EU Construction Products Regulations build upon the previous Construction Products Directive and come into operation on July 1st 2013. Through a conformity assessment and the use of the CE mark, the aim is to break down technical barriers so that any products which are subject to a harmonised European standard (hEN) may be used across the European Union.
As the CPR is European law, it will overrule automatically country specific laws unless the member states need to adapt their local law to suit.
Products that have been tested under the Construction Products Directive and have achieved a certificate of conformity will not need to be re-tested and that certificate will still be valid. The CPR also states that ‘the CE marking shall be the only marking which attests the conformity of the product’ although other quality marks may be ‘affixed to the product, provided that the visibility, legibility and meaning of the CE marking is not thereby impaired’.
What are the key changes?
Manufacturers placing a product onto the market will be required to make a Declaration of Performance (DoP) and affix the CE mark. Criteria laid down in the relevant Harmonised European Standard involves inspection and test by a relevant officially Notified Body such as a Testing Laboratory, a Factory Production Control Certification Body or a Product Certification Body. The manufacturer then assumes legal responsibility for the products conformity with its declared performance.
Importers and Distributors have similar responsibilities and must ensure that the manufacturer has complied with the CPR, ensure instructions & safety information is in the appropriate language, monitor product in the market and take corrective actions where necessary.
Specifiers, Designers and Installers should refer to the Harmonised Technical Specifications when choosing products most suitable for their intended use and review the manufacturers Declaration of Conformance, i.e. they should ensure that the manufacturer has complied with the CPR.
How does this affect a system installer?
Construction products should be covered by a DoP and be labelled with the CE marking from June 1st 2013 onwards. Some products manufactured prior to that date in the UK will not need to be withdrawn from sale, but any subsequently manufactured products of the same type will be subject to the CE marking requirements of the Construction Products Regulation.
Further information may be found at www.constructionproducts.org.uk.
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