What does the Construction Products Regulation mean for the purchaser of the product?


Below you will find some key points of the Construction Product Regulation (EU) No 315/2011 discussed in relation to frequently asked questions from the purchaser’s point of view.

 

What is the purpose of the CE-marking? f

The purpose of the CE-marking is to improve mobility of construction products within the European economic area.

 

What does the CE-marking stand for?

By affixing the CE-marking on the construction product the manufacturer states that the product characteristics are declared as required by harmonised European Union product legislation or European technical approval or assessment. 

The CE-marking is a consistent way of declaring product performance. When a construction product characteristics are measured, classified and declared the same way with similar products, it is easier to compare construction product properties to the requirements. Together, these characteristics form product performance.

 

What are the benefits of the CE-marking?

The CE-marking enables a uniform comparison between product characteristics values declared by the manufacturer and characteristics requirements set for a product at the construction project. Requirements set for a product come from construction site planning solutions that must fulfil the requirements of national construction legislation.

 

With the help of the CE-marking, designer and construction product purchaser find it easier to estimate the compatibility of a construction product and construction site. The marking makes comparing construction products with one another easier, as well.

 

Therefore, the CE-marking itself does not guarantee that the product complies with any national requirements.

 

What do the Declaration of Performance (DoP) and CE-marking describe?

Both the CE-marking and the DoP usually contain at least the following information:

  • Manufacturer’s name and address
  • The declared performance of product characteristics (if necessary, listed according to intended use)
  • Reference to the harmonised European standard (hEN)
  • Construction product’s intended use.

 

What does performance describe?

In different product groups the levels or classes of performance are used to describe differing aspects. See examples below.

  • If the DoP states “Compression strength - 31 MPa”, then it means that the compression strength of the product is a minimum of 31
  • MPa as defined in the standard “EN 14080:en Timber structures. Glued laminated timber. Requirements”.
  • If the DoP states “Reaction to fire - Class A1" as , then it means that the “European fire test class” of the product and the fire test classification itself are according to the classification defined in the EN 13501-1 standard, which is the standard that the “EN 13162:en Thermal insulation products for buildings. Factory made mineral wool (MW) products. Specification” requires to be used.

 

What should the buyer check before purchase of a construction product?

The buyer should verify that the product fulfils the set requirements and that the product is meant particularly for the intended use.

 

Requirements set for the construction product may be found in the building plan. In such case, checking the Declaration of Performance is an easy way to see which products fulfil those requirements.

 

If the DoP states “NPD” for some product characteristics, that means that this characteristic has not been determined for this product. In such case the product does not conform to any requirements set for this particular characteristic.

 

Which products require a CE-marking?

A construction product must be CE-marked when it belongs within the scope of application of a harmonised standard (hEN) after the transition period or when the manufacturer has applied and been granted European technical assessment (ETA) for the product. Other construction products must not be CE-marked under the Construction Products Regulation.  For harmonised standards (hEN) and their transition periods, please refer to hEN-helpdesk.

 

If the harmonised product standard does not allow CE-marking, the manufacturer has the option of acquiring the CE-marking (for declaring product characteristics for export or domestic markets, for example) after the European technical assessment (ETA). This so called ETA procedure is introduced in more detail at the Ministry of the Environment website.

 

Article 5 of the Construction Products Regulation defines specific circumstances for relaxing the responsibility to acquire the CE-marking. Naturally, this does not mean exemption from national requirements on construction products and attestation of their validity if such is demanded.

 

What does transition period mean in regard to harmonised standard?

The harmonised product standard includes the annex ZA, and information on the approval and transition period of the standard is published in the Official Journal of the European union. The hEN-helpdesk has information on each standard and transition period of each version. Usually the transition spans one year, although there are some exceptions. As long as transition is on-going, CE-marking is voluntary.

 

Even if the transition period of the newest version of the harmonised product standard was on-going, the transition may have ended for the previous version. Therefore, CE-marking is obligatory even in such cases.

 

What does article 5 of the Construction Products Regulation describe?

Exemption from obligation to CE-mark the product can be granted e.g. under article 5. However, this does not mean that the construction product would, then, be automatically released from any approval obligations. For example the building supervision authority may even then demand building site specific attestation of product validity.

 

What other ways there are besides the CE-marking for demonstrating the suitability of the product?

Some construction products currently in use cannot be CE-marked today nor over the long term.

 

The requirement to CE-mark all construction products in use is impossible to carry out as not all products are available as CE-marked. The obligation to CE-mark expands as more and more harmonised standards (hEN) are completed and they are assigned a transition period. The use of CE-marking will also expand through manufacturers acquiring the European technical assessment (ETA) for their products.

 

In Finland, there are three different legal procedures for attesting the validity of some central construction products that are without the CE-mark at present. These national procedures are voluntary, and are used to demonstrate that the product fulfils the requirements of the Land Use and Building Act or provisions laid down in the Act. In addition, procedure involving building site specific attestation of product validity can be used. The national Act on the Approval of Certain Construction Products, that lays down the three different procedures, enters into force on 1 July 2013 and also the specifying Decree is intended to be implemented on July. The procedures described in the Act will not even initially be applicable to all construction products. Because of this, other procedures besides those issued under the Act(s) will be used for declaring and attesting product characteristics. Local supervision of building will decide on the approval of these procedures on a case-specific basis.

 

Does the product certificate not replace the CE-marking?

The CE-marking cannot be replaced with any product certificate or similar arrangement. Voluntary, national markings or labelling cannot cover the characteristics within the CE-marking. Voluntary product certificates can be used instead to supplement the CE-marking if they cover something that is unrelated to the essential characteristics of the construction product.

 

What if I detect a product with inadequate CE-marking being sold?

These construction products must be reported to the market surveillance authority. There is a form available on the Tukes website for this particular use.