Construction Products Directive
The Four Main Provisions of the CPR
The CPR builds upon the CPD and aims to break down technical barriers to trade in construction products within the European Economic Area. To achieve this, the CPR provides for four main elements:
• a system of harmonised technical specifications
• an agreed system of conformity assessment for each product family
• a framework of notified bodies
• CE marking of products
The CPR harmonises the methods of assessment and test, the means of declaration of product performance and the system of conformity assessment of construction products, but this is not applicable to national building regulations. The choice of required values for the particular intended use is left to the regulators and public / private sector procurers at the national level. However, such required values must be expressed in a consistent manner as used in the harmonised technical specifications.
Harmonised Technical Specifications
Under the CPR, harmonised technical specifications are harmonised European product standards (hENs) established by CEN/CENELEC3. The harmonised technical specification for a product defines European wide methods of assessing and declaring all the performance characteristics required by regulations in any Member State which affect the ability of construction products to meet seven basic requirements for construction works. These include :
1. Mechanical resistance and stability
2. Safety in case of fire
3. Hygiene, health and environment
4. Safety and accessibility in use
5. Protection against noise
6. Energy economy and heat retention
7. Sustainable use of natural resources.
The main route to a harmonised technical specification under the CPR is for hENs to be drawn up and published by CEN/CENELEC. European product standards also address characteristics not regulated in any Member State, but which have been included for commercial reasons e.g. aesthetic characteristics. Because of this, all hENs under the CPR include an Informative Annex (termed Annex ZA), the first part of which (ZA.1) lists the regulated requirements according to a mandate issued to CEN or CENELEC by the European Commission and the clauses in the standard in which they are addressed. Some of these clauses may in turn refer to separate supporting documents such as test standards. In this way, Annex ZA.1 in the hEN becomes a checklist for CE marking from which the manufacturer can see all the mandatory requirements for their product and how they can be met.
CE marking enables a product to be placed legally on the market in any Member State. However, as explained below, this does not necessarily mean that the product will be suitable for all end uses in all Member States.
CE marking indicates that a product is consistent with its Declaration of Performance (DoP) as made by the manufacturer. The declaration varies according to the particular harmonised technical specification covering the product. In general there are three ways in which information can be presented for each relevant characteristic:
• confirmation of achievement of a minimum performance or threshold. This could be by satisfying a Pass/Fail criterion or simply by being eligible to be in the standard.
• the actual performance (declared value).
• a particular class of performance reached.
As such, decision makers (e.g. designers and specifiers) should understand the relevant performance requirements for the product.
How CE marking is approached for a specific product is set out in the harmonised technical specifications. For hENs this is set out in Annex ZA.3.