Monday, 5 August 2013

So what did YOU do to meet the new CE marking regulations?

CE Marking Regulations have now changed
One month has now passed since under the Construction Products Regulation 2011 (CPR), it has been mandatory for manufacturers to apply CE marking to any of their products which are covered by a harmonised European standard (hEN) or European Technical Assessment (ETA). This change has also had implications for distributors and their responsibilities.

However, much of the industry is still confused: Do you really know what you should have done or should be doing? Pin Board is delighted to help make it 'EC' to comply with your CEs!

What has changed since 1st July 2013?
The CPR is a major change for the whole industry with regards to CE marking, as the Construction Products Directive (CPD) it replaces was voluntary, the new Construction Products Regulation (CPR) is mandatory and has now been adopted by the European Commission and UK Government.

What is CE marking?
CE marking indicates that a product is consistent with its Declaration of Performance (DoP). By issuing a DoP the manufacturer, importer or distributor is assuming legal responsibility for the conformity of the construction product with its declared performance.

The CE Mark provides proof of this “fitness for purpose” and the manufacturer affixing the CE mark shows that the construction product will enable the finished construction works to comply with the Construction Products Regulation requirements (called Basic Works Requirements) of:
  • Mechanical resistance and stability
  • Safety in case of fire
  • Hygiene, health and environment
  • Safety and accessibility in use
  • Protection against noise
  • Energy economy and heat retention
  • Sustainable use of natural resources
The CE mark is a claim that a particular construction product can be legally placed on the market of member states of the European Economic Area (EEA).

What does the change mean?
As a result of this change, manufacturers’ and importers' construction products must now meet the CE requirements of the new Regulation.

According to the Regulation, the requirement for CE marking will apply to:

"Any product or kit which is produced and placed on the market for incorporation in a permanent manner in construction works or parts thereof and the performance of which has an effect on the performance of the construction works with respect to the basic requirements for construction works."

So any products that fall under this definition that were placed on the market from July 2013 and are covered by a harmonised standard, will have to be accompanied by a Declaration of Performance and will need to display the CE mark.

How does CPR affect you?
If you manufacture or import products that are within the scope of the Regulation, you will be required to declare that the product complies with the Regulation and display the CE mark, before they can be sold in the UK and Europe.

The responsibility for ensuring that a product has the correct characteristics for a particular application rests with the building designers, contractors and local building authorities, and manufacturers and importers will be required to provide the necessary testing evidence.

Manufacturers' responsibilities:
  • Drawing up declarations of performance for their products
  • Affixing the CE marking
  • Keeping documentation for 10 years
  • Ensuring series production maintains the declared performance – QA system, works instructions etc.
  • Ensuring products (or packaging) bear identification marks and a contact address
  • Providing instructions and safety information with their products
  • Taking corrective action where products are not in conformity with declarations of performance
Distributors' responsibilities:
  • Ensuring that, where required, products bear the CE marking and are accompanied by the necessary documents
  • Ensuring that storage or transport conditions do not jeopardise the conformity of products with declarations of performance
  • Taking corrective action where products are not in conformity with declarations of performance
It is important for distributors of construction products to ask their suppliers: a) if their products require CE marking under the CPR, yes or no. b) if yes, ask them to supply a certificate of performance and details of the CE marking. If you can prove to your customers that you are prepared and know what you're doing, then you should have no issues.

Are ALL products affected?
No, as mentioned earlier, only products covered by a harmonised European standard are eligible – if there is no harmonised standard, there is no legal requirement to CE mark the product

Harmonised standards can be either an EN or an ETAG (European Technical Approval Guidance). A quick way to tell whether an EN is harmonised is to see if it has an appendix ZA and ZZ; ZA will provide the ‘essential requirements’ of the product and ZZ will provide details of the content of the CE marking – it’s not just the letters CE.

The following links takes you to the official list of harmonised standards:

For ENs

You should check periodically for updates which may affect you.

What happens to all our stock on our shelf/stores?
Don't panic too much - products that will comply but were manufactured before 1st July will not need to be withdrawn from sale.

Why has this changed happened?
The aim of the CPR is to remove technical barriers (i.e. the multitude of national standards existing within individual European countries each of which references different test methods) to make trade between European Member States for all construction products intended for “permanent incorporation in buildings and civil engineering works” easier to measure. Under the CPR new European test methods and the means of measuring these, have been developed and accepted by all countries in the EEA.

In summary, CE marking is a passport that enables a construction product, irrespective of its origin, to be legally placed on the market of EEA member states. It means that a construction product meets certain minimum standards for health, safety and economy of energy. It is NOT a quality mark. The difference between a quality mark and the CE mark is that the certification system upon which quality marks operate is determined by the legal owner of that quality mark e.g. BSI, whereas the CE mark represents a common approach to conformity that is recognised in all countries making up the EEA.

Who is going to police the change?
The CPR is to be policed by Trading Standards.

For more information on the new CE regulations click here

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