Construction Products Regulation (CPR): An Essential Guide

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Window frame

The Construction Products Regulation sets performance requirements for construction products such as windows, doors, and wooden flooring in the European Union. It also covers labelling, documentation, and testing for construction products.

In this guide, we explain what manufacturers and importers should know about the Construction Products Regulation, and provide examples of covered products. We also explain documentation, labelling, and other requirements.


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What is the Construction Products Regulation?

The Construction Products Regulation establishes performance requirements and harmonised rules for construction products to ensure that the products adhere to relevant characteristics. Here are some examples:

1. Mechanical resistance and stability – For example, loadings should not result in a collapse

2. Safety in case of a fire – For example, to facilitate the rescue of occupants

3. Hygiene, health, and the environment – For example, the materials should not give off toxic gas

4. Safety and accessibility in use – For example, products should not present accident risks

5. Protection against noise – For example, noise levels perceived by other occupants should not be too high

6. Energy economy and heat retention – For example, materials should be energy-efficient

7. Sustainable use of natural resources – For example, construction works should be durable

The regulation also sets labelling, documentation, and other requirements, as explained below.

Which products are covered?

The Construction Products Regulation covers construction products in general:


This Regulation lays down conditions for the placing or making available on the market of construction products by establishing harmonised rules on how to express the performance of construction products in relation to their essential characteristics and on the use of CE marking on those products.


According to Article 2, construction products are defined as products that are sold to be permanently incorporated into buildings and civil engineering works:


1. ‘Construction product’ means 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;


Annex IV lists covered product areas. Here are some examples of covered products:

  • Doors
  • Widows
  • Flooring
  • Geotextiles
  • Internal partition kits
  • Space heating appliances
  • Sealants for joints
  • Gates
  • Composite insulating kits
  • Fixed firefighting equipment (e.g. fire alarm)
  • Hydraulic binders
  • Construction adhesives

Overview

This section explains key parts of the Construction Products Regulation, and how these are related.

Assessment / Document When is it needed? Issuer
Harmonised standard When harmonised standards exist for a product CEN / CENELEC
European Technical Assessment 1. When the product is not (fully) covered by harmonised standars, and

2. You want to voluntarily affix the CE marking to my product

Technical Assessment Body (TAB)*
European Assessment Document The TAB must issue the European Technical Assessment based on the relevant European Assessment Document requirements Organisation of TABs**
Assessment and verification of constancy of performance (AVCP) 1. When the construction product is covered by a harmonised standard, or

2. A European Technical Assessment has been issued for the product

Notified body
Declaration of Performance 1. When the construction product is covered by a harmonised standard, or

2. A European Technical Assessment has been issued for the product

Manufacturer
Technical Documentation 1. When the construction product is covered by a harmonised standard, or

2. A European Technical Assessment has been issued for the product

Manufacturer

*A Technical Assessment Body (TAB) is a body designated by an EU member state that is qualified to issue a European Technical Assessment.

**The organisation of TABs is responsible for drafting the European Assessment Documents, which are harmonised technical specifications necessary for issuing a European Technical Assessment

Harmonised standards

When your product complies with relevant harmonised standards, it means that it complies with the technical requirements set by the regulation. In practice, you must follow these standards to make sure that the performance of your product is in line with the requirements in the Construction Products Regulation.

In this section, we list examples of harmonised standards that cover various construction products. We organised our list by product type (e.g. windows and doors) or material (e.g. glass or wood).

Standards for windows and doors

EN 14351-1 – Windows and doors – Product standard, performance characteristics – Part 1: Windows and external pedestrian doorsets

EN 16034 – Pedestrian doorsets, industrial, commercial, garage doors and openable windows – Product standard, performance characteristics – Fire resisting and/or smoke control characteristics

EN 1155 – Building hardware – Electrically powered hold-open devices for swing doors – Requirements and test methods

EN 1158 – Building hardware – Door coordinator devices – Requirements and test methods

EN 13241 – Industrial, commercial, garage doors and gates – Product standard, performance characteristics

Standards for fire detection and fire alarm systems

EN 54-2 – Fire detection and fire alarm systems – Part 2: Control and indicating equipment

EN 54-3 – Fire detection and fire alarm systems – Part 3: Fire alarm devices – Sounders

EN 54-4 – Fire detection and fire alarm systems – Part 4: Power supply equipment

EN 54-5 – Fire detection and fire alarm systems – Part 5: Heat detectors – Point heat detectors

EN 54-7 – Fire detection and fire alarm systems – Part 7: Smoke detectors – Point smoke detectors that operate using scattered light, transmitted light or ionization

Standards for glass products and components

EN 572-9 – Glass in building – Basic soda lime silicate glass products – Part 9: Evaluation of conformity / Product standard

EN 1036-2 – Glass in building – Mirrors from silver-coated float glass for internal use – Part 2: Evaluation of conformity; product standard

EN 1051-2 – Glass in building – Glass blocks and glass pavers – Part 2: Evaluation of conformity / Product standard

EN 1096-4 – Glass in building – Coated glass – Part 4: Product standard

EN 1279-5 – Glass in building – Insulating glass units – Part 5: Product standard

Standards for wood products and components

EN 13986 – Wood-based panels for use in construction – Characteristics, evaluation of conformity and marking

EN 14229 – Structural timber – Wood poles for overhead lines

EN 14342 – Wood flooring and parquet – Characteristics, evaluation of conformity and marking

EN 14915 – Solid wood panelling and cladding – Characteristics, evaluation of conformity and marking

EN 13171 – Thermal insulation products for buildings – Factory made wood fibre (WF) products – Specification

European Technical Assessment (ETA)

The Construction Products Regulation defines a European Technical Assessment as an assessment of how a construction product performs, relative to its characteristics.

In practice, the European Technical Assessment is a method of assessing the performance of construction products that are not covered by a harmonised standard.

Such products should undergo this assessment if you decide to affix the CE marking on them, which is voluntary if the product is not fully covered by a harmonised standard.

Process

Here is how the process of obtaining a European Technical Assessment works:

1. The manufacturer requests a European Technical Assessment from a Technical Assessment Body

2. The Technical Assessment Body issues the European Technical Assessment based on a European Assessment Document adopted by the organisation of TABs (or European Organisation for Technical Assessment (EOTA)).

3. The manufacturer can now draft a Declaration of Performance, and affix the CE marking to its product.

Content

The European Technical Assessment should include:

a. The performance to be declared, by classes or levels

b. A description of the essential characteristics agreed upon by the manufacturer and the Technical Assessment Body, and

c. Necessary technical details for implementing the relevant system of assessment and verification of constancy of performance (AVCP)

European Assessment Document (EAD)

Article 2 of the regulation defines a European Assessment Document as a document that is adopted by the organisation of TABs for the goal of issuing a European Technical Assessment.

European Assessment Documents are “harmonised technical specifications”; thus, they have a role that is similar to the role of harmonised standards, and are relevant for products that are not covered by harmonised standards.

In practice, a Technical Assessment Body uses the relevant European Assessment Document to issue the European Technical Assessment, when a manufacturer requests it.

The European Assessment Document should contain at least the following information:

a. General description of the construction product

b. List of essential characteristics agreed upon by the manufacturer and the organisation of TABs

c. Methods and criteria for evaluating the product’s performance regarding the essential characteristics

d. Principles for applying factory production control

Assessment and verification of constancy of performance (AVCP)

An assessment and verification of constancy of performance is a “harmonised system defining how to assess products and control the constancy of the assessment results”. Products need to undergo an AVCP when they are:

a. Covered by harmonised standards, or

b. A European Technical Assessment has been issued for the product.

There exist five different systems of AVCP, which are listed in Annex V:

  • System 1+
  • System 1
  • System 2+
  • System 3
  • System 4

While some of these systems can be carried out by the manufacturers, in other cases it is necessary to involve a notified body.

Note that harmonised standards or European Assessment Documents should indicate which AVCP systems should be used for your product.

Declaration of Performance

According to Article 4, the manufacturer should draw up a Declaration of Performance for a construction product that is covered by harmonised standards or conforms to a European Technical Assessment.

The Declaration of Performance should contain items such as:

  • The product-type unique identification code
  • Intended use/uses
  • Manufacturer name
  • Systems of assessment and verification of constancy of performance (AVCP)
  • A “Signed for and on behalf of the manufacturer by” statement
  • The manufacturer name and signature
  • The location where, and date when, the declaration was issued
  • Technical documentation

Technical Documentation

In general, the manufacturer of the construction products must draw up the technical documentation, which describes the relevant elements that are related to the mandated system of AVCP and is the basis for the Declaration of Performance.

The Construction Products Regulation mentions two types of technical documentation regarding construction products: “specific technical documentation” and “appropriate technical documentation”.

User Instructions

Importers and manufacturers should provide user instructions with their construction products in the language of the member state in which they are selling said products.

Labelling Requirements

The Construction Products Regulation requires you to affix the CE marking and traceability information on the construction product, its packaging, or an accompanying document.

CE Marking

CE Mark

Manufacturers should affix the CE marking to construction products in the following cases:

a. The construction product is fully covered by a harmonised standard

b. The construction product is not fully covered by harmonised standards, but an ETA has been obtained for the product

If your construction product is neither fully covered by harmonised standards and an ETA has not been issued, you should not affix a CE marking.

The CE marking should be followed by the following items:

  • Last two digits of the year the CE marking was first affixed
  • Manufacturer’s name and registered address (or an identifying mark indicating this)
  • Unique product-type identification code
  • Declaration of Performance reference number
  • Class or level of performance declared
  • Reference to applied harmonised technical specification
  • The notified body’s identification number (if applicable)
  • The intended use, as established in the applied technical specification

It should be affixed to the product or its label. If that is not possible, for example, because the product is too small, it should be affixed to the packaging or the documents that are provided with the product.

Product Traceability

Manufacturers should provide the following traceability information on the construction product, its packaging, or an accompanying document:

  • The construction product type, batch, or serial number
  • Their name, registered trade name, or registered trademark
  • Their contact address

Product testing

Articles 11 of the regulation require manufacturers of construction products to carry out sample testing of their products before selling them, when appropriate. In general, you should have your products lab-tested. If your products pass lab testing, you receive a test report that proves the product’s compliance with the requirements of relevant harmonised standards or the European Technical Assessment.

On the other hand, in some cases, the regulation also requires relevant notified body personnel to carry out the assessments and verifications of constancy of performance on the construction products and draw up reports, records, and certificates demonstrating that they have conducted these assessments.

Testing companies

Here we list a few companies that claim to provide testing for the Construction Products Regulation:

  • Intertek
  • SGS
  • BSI Group
  • TÜV SÜD

Compliance risks

Construction materials and building products manufactured outside the European Union are often non-compliant with the requirements outlined in the Construction Products Regulation.

The EU is stricter when it comes to, for example, flammability and insulation than most other markets. As such, construction materials and building products primarily intended for domestic usage or export to other markets in the world may be non-compliant.

It’s therefore critical to arrange third-party lab testing before you import and sell insulation materials, windows, and other products falling in the scope of the Construction Products Regulation.

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    Disclaimer: The Site cannot and does not contain legal advice. The legal information is provided for general informational and educational purposes only and is not a substitute for professional advice. Accordingly, before taking any actions based upon such information, we encourage you to consult with the appropriate professionals. We do not provide any kind of legal advice. THE USE OR RELIANCE OF ANY INFORMATION CONTAINED ON THE SITE IS SOLELY AT YOUR OWN RISK.

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    Sources: Our articles are written in part based on publicly available information, and our own practical experience relating to product compliance. These are some of the primary sources we use:

    • ec.europa.eu
    • echa.europa.eu
    • ecfr.gov
    • cpsc.gov
    • ftc.gov
    • fcc.gov
  • 3 Responses to “Construction Products Regulation (CPR): An Essential Guide

    1. Petre Barbu at 5:02 am

      hi,
      what is an AEC ?

    2. PJ at 7:47 pm

      As an importer of construction products (manufactured outside of the EU) sold in e-commerce, are we required to hire/have an authorized representative?

    3. Fluix at 7:07 pm

      The Construction Products Regulation is one of the most important acts of European legislation in the field of construction, so thank you for explaining the important conditions for manufacturers. In general, tracking the working environment at every stage of the project is necessary, including regulations and standards, it is easier to do with special checklists and task assignments

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