Euralarm Newsletter - May 2011 - Special edition
"New Construction Products Regulation takes effect"
A new Construction Products Regulation (CPR) is being introduced to replace the familiar, outgoing CPD. Here, Christian Lais of Siemens, a member of TC Horizontal Compliance, explains what impact the move will have, the background to the CPRs introduction, and its comparative benefits.
These are interesting times for Euralarm members, as the European Parliament and Council have harmonised conditions for the marketing of construction products. In practice, this means that Council Directive 89/106/EEC (known as CPD) will be phased out by June 30th 2013, with EU Regulation no. 305/2011 (CPR) becoming mandatory without the requirement for any national implementation measures with initial effect from April 24th 2011.
CPR benefits
As part of the Better Regulation initiative, the CPRs introduction intends to simplify procedures, improve efficiency, reduce the costs incurred by enterprises (particularly SMEs), clarify the basic costs and use of CE marking, and increase the whole systems credibility through new and stricter designation criteria to bodies involved in assessing and verifying construction products constancy of performance.
The background
This process began with the so-called New Legislative Framework (NLF), the modernisation of the new approach for marketing of products, a package of measures designed to provide the following benefits:
- better rules on market surveillance, to protect consumers and professionals from unsafe products
- clearer rules on the requirements for notification of conformity assessment bodies (testing, certification and inspection laboratories)
- enhanced credibility and clarification of the meaning of CE marking
- an established common legal framework for industrial products in the form of a toolbox of measures for use in future legislation
Legal consequences
There will be national so-called Technical Assessment Bodies (TAB), Product Contact Points and more nationally organised Market Surveillance. A TAB will be active only if no harmonised standard (hEN) exists, or a manufacturer can prove their product is not, or is only partly, covered by a hEN.
Meanwhile, Product Contact Points will provide information on the provisions within its territory aimed at fulfilling basic requirements for construction works applicable, as well as providing information about the (minimum) performance of a construction product.
The CPR may have entered force on 24th April, but its main impact wont be felt until July 1st 2013. There will be no technical impact on any Construction Product at all the main effect will probably result from different interpretations and will certainly cause more paperwork!
CPR: whats new?
A Declaration of Performance (DoP) will need to be issued for each product to be able to CE mark it. Additionally, appropriate REACH information must be available. A CE Declaration of Conformity is still necessary to show compliance according to other applicable Directives, including EMC, LVD, R&TTE etc. Additionally, for System 1 products, such as fire detection and extinguishing equipment (see Mandate M/109), 3rd party testing is still necessary to allow a notified product certification body to issue the products constancy of performance certificate (c.f. CPD: former EC Certificate of Conformity).
Transitional provisions
Products reaching the market before July 1st 2013 that comply with the CPD will be deemed to also comply with the CPR. For products put on the market after this date, which were tested and complied with the CPD, only a DoP needs to be issued to comply with the CPR.
- For the full article by Christian Lais click here.
Fire Section