CPR - Myths, Truths and Challenges! Gordon Best, Regional Director QPANI
CPR - Myths, Truths and Challenges! Gordon Best, Regional Director QPANI
Construction Products Directive (CPD) Harmonised European Standards (hENs)
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Construction Products Directive? • A structured approach to specifying Construction Products - conformity through European Standards • Eliminating barriers to trade across member states • Common products, tests and methods of conformity • European Standards introduced from circa 2004
Construction Products Directive? • Current European Standards are CPD compliant • Directive can have national interpretation • CE marking voluntarily applied in the UK
• Agreement with Office of Deputy Prime Minister for electronic CE Marking via company websites
ACRONYM WARNING
Construction Products Regulation (CPR) 1 What is a construction product under CPR? Any product or kit (two or more products which are put together) placed on the market for incorporation in a permanent manner in construction works the performance of which affects the performance of the construction works with respect to the seven Basic Requirements for Construction Works (BRCW) identified in Annex 1 of the CPR.
Construction Products Regulation (CPR) 2 Basic Requirements for Construction Works (BRCW) 1. 2. 3. 4. 5. 6. 7.
Mechanical resistance & stability Safety in case of fire Hygiene, health & the environment Safety & accessibility in use Protection against noise Energy, economy & heat retention Sustainable use of natural resources
Construction Products Regulation (CPR) 3 •
CPR fully implemented from 1st July 2013.
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Mandatory CE marking of Construction materials supplied in conformity with hENs (harmonised European Standards).
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hENs contain an Annex ZA - products conforming with non-harmonised ENs cannot be CE marked!
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Declaration of Conformity (DoC) under CPD becomes a Declaration of Performance (DoP) under CPR
Construction Products Regulation (CPR) 4 • CE marking as defined by the DoP will be a legal requirement enabling the product to be placed on the market
• The process leading to the DoP and CE marking is: Assessment and Verification of Constancy of Performance (AVCP) currently the Attestation of Conformity (AoC) under CPD • Systems for AVCP stated in the appropriate hEN for the product defines the extent of third party assessment and involvement of Notified Bodies (NoBos)
Harmonised European Standards (hENs) hENs contain an Annex ZA Today CPD • Attestation of Conformity including Type Testing (TT) and Factory Production Control (FPC) • Declaration of Conformity (DoC) • CE marking - voluntary in UK CPR from 1st July 2013 • Assessment & Verification of Constancy of Performance (AVCP) includes: TT and FPC • Declaration of Performance (DoP) • CE marking - Legal requirement for hENs!
Supporting UK Guidance • Aggregates - PD6682 (5 Parts) (PD = Published Document) series to be amended to reflect changes in Aggregate ENs - 2013/14. • Asphalt - PD6691 to amend and publish 2014/15 with CPR compliant asphalt standards
Transition from CPD to CPR • DoC and CE marking issued under CPD is readily transferred if: • Both DoCs and CE marking have been issued before 1st July 2013 Note: If System 2+ arrange Notified Body (NoBo) assessment well prior to July deadline - Certificate number required for CE Marking
• Be ready for 1st July 2013 DoC terminology change to DoP! • Carry on CE marking as under CPD
Most hENs to be made CPR compliant from 2014
Regulated Dangerous Substances (RDS) • Covered by Basic Requirements for Construction Works (BRCW) Number 3 - hygiene, health and the environment • Test methods for product leaching are still being finalised - unlikely to be fully implemented until 2015 • Registration, Evaluation, Authorisation and restriction of Chemicals (REACH) criteria continue to apply until RDS is fully implemented.
Environmental Product Declarations (EPD) • Covered by Basic Requirements for Construction Works (BRCW) Number 7 - sustainable use of natural resources • The specifics of a declaration that will be required for construction products are still under consideration
• It is unlikely that any declarations will be required until 2018 at the very earliest!
marking 1 • Draft and issue DoCs and CE marking ahead of 1st July 2013 to allow an easy transfer to DoPs from July this year! • Paper CE marking for large volume bulk supplied Asphalt and Aggregates would involve the issue of about 7,000,000 or 35,000t of CE marking certificates per year
• Practical industry concerns - progression towards electronic Proof of Delivery - ability to print CE symbols at weighbridges - making CE marking available to the appropriate people
marking 2 • MPA letter sent to CPA (Construction Products Association) on 31st October concerning CPR requirements on affixing CE marking • Added to the agenda of the December meeting of the Standing Committee for Construction (SCC) for consideration by the European Commission
• MPA has full support from CPA, CEPMC (Council of European Producers of Materials for Construction) and UEPG (European aggregates association) for making CE marking available on company websites
marking 3 MPA letter states: “We (MPA) conclude by advising that taking due account of the principles of transitional provisions in the CPR provided under Article 66, and the delay there might be in carefully considering, and hopefully implementing, an option for 'CE marking via websites', that
the industry has no alternative pragmatic solution other than to continue to apply CPD current best practice, by providing Declarations of Performance and CE marking via company websites.”
Further Information FAQs on the CPR and CE marking: http://members.mineralproducts.org/ user/web/policy_agg_01.php
Confused by Acronyms - go to “Acronym Alley” on MPA Members website: http://members.mineralproducts.org/ user/web/res_pub01.php
