In a recent interview, I had the chance to sit down with Samuel Harrison, a seasoned compliance officer with over 15 years of experience in the construction industry, to discuss the intricacies of the Construction Products Regulation (CPR). Samuel has been at the forefront of ensuring that various construction products meet the stringent requirements set forth by the CPR in the European Union. His insights offer a valuable perspective on how manufacturers and importers can navigate these regulations effectively.
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What is the Construction Products Regulation?
“The Construction Products Regulation (CPR) is a critical framework that sets performance requirements for construction products within the European Union,” Samuel began. “Its primary aim is to ensure that construction products, such as windows, doors, and wooden flooring, meet specific characteristics and performance standards.”
Samuel explained that the CPR covers a wide array of essential requirements, including mechanical resistance and stability, safety in case of fire, hygiene, health and the environment, safety and accessibility in use, protection against noise, energy economy and heat retention, and the sustainable use of natural resources. “These requirements are not just bureaucratic hurdles,” he noted. “They are in place to ensure that construction products are safe, efficient, and sustainable.”
Which Products are Covered?
“One of the most frequently asked questions is about which products fall under the scope of the CPR,” Samuel continued. “Essentially, the regulation covers any product that is intended to be permanently incorporated into construction works.” This includes a broad range of items, such as:
- Doors and windows
- Flooring materials
- Geotextiles
- Internal partition kits
- Space heating appliances
- Sealants for joints
- Gates
- Composite insulating kits
- Fixed firefighting equipment
- Hydraulic binders
- Construction adhesives
“Manufacturers and importers need to understand that if their products are to be used in construction works, they likely fall under the CPR,” he emphasised.
Harmonised Standards
Samuel highlighted the importance of harmonised standards in the CPR framework. “When a product complies with harmonised standards, it means it meets the technical requirements set by the regulation,” he said. “These standards are crucial because they provide a clear, consistent benchmark for product performance.”
He provided an example, citing standards for windows and doors, such as EN 14351-1 for windows and external pedestrian doorsets, and EN 16034 for fire-resisting and smoke control characteristics. “These standards ensure that products like windows and doors not only perform well but also contribute to overall building safety and efficiency,” he explained.
European Technical Assessment (ETA)
“For products not fully covered by harmonised standards, the European Technical Assessment (ETA) comes into play,” Samuel pointed out. “The ETA is an assessment of how a construction product performs relative to its characteristics.”
He walked me through the process of obtaining an ETA. “First, the manufacturer requests an ETA from a Technical Assessment Body (TAB). The TAB then issues the ETA based on a European Assessment Document (EAD) adopted by the organisation of TABs. Once the ETA is obtained, the manufacturer can draft a Declaration of Performance and affix the CE marking to the product.”
European Assessment Document (EAD)
“The European Assessment Document (EAD) is essentially a harmonised technical specification used to issue a European Technical Assessment,” Samuel explained. “It outlines methods and criteria for evaluating a product’s performance regarding essential characteristics.”
He added that the EAD contains detailed information, including a general description of the product, a list of essential characteristics, methods and criteria for performance evaluation, and principles for factory production control. “This document is critical for ensuring that products not covered by harmonised standards are assessed rigorously and consistently,” he said.
Assessment and Verification of Constancy of Performance (AVCP)
“Another key component of the CPR is the Assessment and Verification of Constancy of Performance (AVCP),” Samuel noted. “This system defines how to assess products and control the constancy of the assessment results.”
He explained that there are five different systems of AVCP, ranging from System 1+ to System 4. “While some of these systems can be carried out by manufacturers themselves, others require the involvement of a notified body,” he said. “It’s essential to follow the AVCP system indicated in the harmonised standards or European Assessment Documents for your product.”
Documentation and Labelling Requirements
Samuel stressed the importance of proper documentation and labelling. “Manufacturers must draw up technical documentation that describes the relevant elements related to the mandated system of AVCP,” he said. “This documentation forms the basis for the Declaration of Performance.”
He also highlighted the labelling requirements, noting that products must bear the CE marking and traceability information. “The CE marking should include the manufacturer’s name, the unique product-type identification code, and other relevant details,” he explained. “This ensures that products can be easily traced back to their source, enhancing accountability and safety.”
Conclusion
As our conversation drew to a close, Samuel reiterated the critical role of the CPR in the construction industry. “The Construction Products Regulation is not just about compliance,” he said. “It’s about ensuring safety, efficiency, and sustainability in construction works. By understanding and adhering to these regulations, manufacturers and importers can not only meet legal requirements but also contribute to a safer and more reliable built environment.”
Kenneth George
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