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Technical Information Bulletin: CE Marking to be mandatory from 1st July in the UK

The construction industry is facing the most significant change for a decade in the way in which construction products are sold in Europe. From 1 July 2013, under the Construction Products Regulation 20111 (CPR), it will become 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 is a major change as affixing of CE marking under the provisions of the existing Construction Products Directive (CPD) is currently voluntary in the UK. For those already CE marking under the CPD the transition should be straightforward.

The CPR builds upon the CPD and aims to break down technical barriers to trade in construction products within the European Economic Area (EEA). 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 NOT 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 (technical language) as used in the harmonised technical specifications.

Some elements of the CPR came into force on 24 April 2011. The first changes apply to notified bodies and technical approval bodies and the way in which they operate. The full legislation relating to manufacturers, importers and distributors comes into force on 1 July 2013, when the CPD will be replaced.

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 (a 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 and for ETAs in a section in the EAD.

By making a DoP (Declaration of Performance) the manufacturer, importer or distributor is assuming legal responsibility for the conformity of the construction product with its declared performance. The information to be contained in them is detailed in Annex ZA of a hEN or in a section of the EAD. DoPs must be publicly available.

Where minimum or maximum values have been set in the technical specifications, these need not be repeated in the DoP. Classes of performance may be declared within the DoP, with the key to the classes appearing in the technical specification. A detailed knowledge of the technical specification is therefore often needed.
Where a parameter is covered in the hEN or ETA, it is not permissible to quote any results obtained for that parameter using a different test method or different units.

Together with the technical specification, the DoP should give all the information needed by specifiers and regulators to judge whether the product meets all relevant regulations in the Member State upon whose market it is to be placed.

Provided that the manufacturer has met the requirements of at least one characteristic in the declaration of performance they are not required to determine and/or declare values relating to characteristics for which regulations do not exist in the chosen market sector (i.e. Member state/intended use). In these cases, a declaration of ’no performance determined‘ (NPD) may be made, as provided for in the hEN.

Where applicable, the declaration of performance should be accompanied by information on the content of hazardous substances in the construction product to improve the possibilities for sustainable construction and to facilitate the development of environment-friendly products. This is complicated by the fact that, for many substances, the necessary test methods have yet to be agreed. Initially it should be limited to substances referred under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH).

Advanced Insulation Offer a range of CE marked insulation products. They can be found on our e-commerce site at:


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