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OrgalimeCPRGuidefinal15 05 2013
OrgalimeCPRGuidefinal15 05 2013
OrgalimeCPRGuidefinal15 05 2013
ORGALIME
The European Engineering Industries Association
secretariat@orgalime.org / www.orgalime.org
LIST OF CONTENTS
click on the page number to see the chapter
FOREWORD! 3
INTRODUCTION! 4
CHAPTER 1 - MAIN CONCEPTS! 5
DECLARATION OF PERFORMANCE! 5
Key facts to know about the Declaration of Performance! 5
Derogations from drawing up a Declaration of Performance! 6
How to supply the Declaration of Performance?! 6
In which language should the manufacturer supply the Declaration of Performance?! 6
Which performances should the manufacturer declare on the Declaration of Performance?! 6
Declaration of Performance and Hazardous Substances! 7
Declaration of Performance, what does it look like?! 9
THE CE MARKING! 12
Key facts to know about CE marking for the CPR! 12
What does it look like?! 13
Derogations to use the CE mark! 13
BASIC REQUIREMENTS FOR CONSTRUCTION WORKS! 14
Sustainable use of natural resources! 14
Basic requirements: 7 requirements under the CPR! 14
SYSTEM OF ASSESSMENT AND CONSTANCY OF PERFORMANCE! 15
How does it work?! 15
CHAPTER 2 - THE APPLICATION OF CPR AT A GLANCE! 16
CHAPTER 3 - ECONOMIC OPERATORS! 17
MANUFACTURER! 17
DISTRIBUTOR! 18
IMPORTER! 18
AUTHORISED REPRESENTATIVE! 19
THE CONDITIONS UNDER WHICH AN IMPORTER/DISTRIBUTOR BECOMES A MANUFACTURER! 19
CHAPTER 4 - HARMONISED STANDARDS AND EUROPEAN ASSESSMENT DOCUMENTS! 20
HARMONISED STANDARDS! 20
EUROPEAN TECHNICAL ASSESSMENT! 20
CHAPTER 5 - SIMPLIFIED PROCEDURES! 21
How does it work?! 21
Who can be defined as a micro-enterprise?! 21
CHAPTER 6 - ADDITIONAL POINTS! 22
VOLUNTARY MARKS! 22
PRODUCT CONTACT POINTS! 22
SERVICE PROVIDERS TECHNICAL ASSESSMENT BODIES! 22
NOTIFIED BODIES! 23
TRANSITIONAL ARRANGEMENTS SUMMARISED! 23
GLOSSARY! 24
USEFUL LINKS! 26
ANNEX I - PRODUCT AREAS! 27
ANNEX II - ORGALIME MEMBERS! 29
ANNEX III - LIST OF EUROPEAN SECTOR ASSOCIATIONS AND OTHER CONTRIBUTORS PARTICIPATING IN THE DRAFTING OF THIS GUIDE! 33
2
FOREWORD
Regulation (EU) No 305/2011 lays down the conditions for the placing or making
available on the market of construction products (see annex I) by establishing
harmonised rules for declaring their performance in relation to their essential
characteristics and for CE marking those products.
The old Construction Products Directive (CPD) was revised because it was not applied in a
harmonised way throughout the EU (in some member states, for example, the CE marking was
not compulsory). Whereas a Regulation applies directly without need for national transpositions,
from which such discrepancies can arise. So this revision was deemed necessary to remove
remaining technical barriers to trade, and also to align with the principles of the New Legislative
Framework.
On 26 May 2008, the European Commission tabled the proposal for a new regulation and after
years of discussion between the three institutions, the Regulation was finally adopted on 9 March
2011 and published in the Official Journal of the EU on 4 April 2011. The Regulation entered into
force 20 days later, and becomes fully applicable from 1 July 2013. The purpose of this Orgalime
guide is to explain the main changes and obligations for all economic operators arising from this
Regulation, and to help Orgalime industries prepare to meet the new requirements, where
necessary.
This guide reflects the best knowledge of industry experts across Europe and the state of the art
at the time of writing. It represents our best understanding; a binding interpretation of Community
legislation, however, remains the exclusive competence of the European Court of Justice.
Orgalime, the European Engineering Industries Association, speaks for 38 trade federations
representing some 130,000 companies in the mechanical, electrical, electronic, metalworking &
metal articles industries of 23 European countries. The industry employs some 10.3 million
people in the EU and in 2012 accounted for some !1,840 billion of annual output. The industry not
only represents some 28% of the output of manufactured products but also a third of the
manufactured exports of the European Union.
3
INTRODUCTION
From 1 July 2013, the new CPR will bring changes for those Orgalime member companies who
already manufacture and place on the market products which are covered by a CPD-harmonised
European standard (hEN) or European Technical Assessment (ETA). Other Orgalime members will
be relatively unaffected. The affected members and products are predominantly in the
electromechanical sector of Orgalime, however some electrical sector products are the subject of
a CPD mandate, cables for example.
The old CPD had different scope wording but essentially the same meaning, to be within the
scope of the new CPR, a product must firstly be destined for permanent incorporation in
construction works and have some bearing on the ability of the building or works to meet the
expectations of occupants that it will not pose various risks to their safety nor be a source of
harm to others.
To be required to bear the CE mark and to have the new documentation for the CPR from July
2013, such a product must also be within the scope of a CPD-standards mandate, or be the
subject of an ETA.
This guide explains the changes for Orgalime members’ products within one of the product
families for which a CPD mandate for harmonised standards is in place, or for which an ETA has
been established. For those products – most low voltage products or gas appliances for example
– which may meet the basic scope definition but for which there is no ETA nor a CPD mandate
which includes them, their position with regard to the new CPR should not change, unless
mandates do.
The Guide should therefore be read in this context. It is a living document and should mandates
change or new product family mandates be issued, the Guide will be updated accordingly.
4
CHAPTER 1 - MAIN CONCEPTS
The Construction Product Regulation (CPR) places more emphasis on the supply chain and
imposes legal obligations on manufacturers, importers and distributors and on those companies
in the supply chain which either place a product on the market under their own name, or
trademark or modify a construction product already placed on the market so as to change its
essential characteristics. A full description of the obligations placed on the supply chain is given
in chapter 3. The CPR also imposes some new changes for manufacturers who want to place a
construction product on the market.
DECLARATION OF PERFORMANCE
The previous requirement for a Declaration of Conformity (DoC) has
been replaced by a requirement for a Declaration of Performance
(DoP). The manufacturer will have to draw up a DoP when a
product, whether covered by a harmonised standard (hEN) or by a
European Technical Assessment (ETA), is placed on the market.
By drawing up a DoP, the manufacturer assumes the responsibility for the conformity of the
construction product with the declared performance.
So manufacturers must take particular care in drafting their DoP and in declaring the intended use
of the product and at least one of the relevant essential characteristics for each of the declared
intended use. For those characteristics where there is no performance declared, the term ‘No
Performance Determined’ (NPD) should be reported.
From the information provided in the DoP, the user is then able to decide which product is most
suitable for his purposes.
All the information the DoP should contain is described in Annex III of the Regulation.
The DoP should therefore include the performance of the essential characteristics of the
construction product which are related to the intended use or uses. When the manufacturer does
not assess the performance vis a vis the listed essential characteristics, he should record ‘No
Performance Determined’ (NPD).
Be careful and check first, the European Commission can also indicate essential
characteristics for which the NPD option is not allowed!
6
Declaration of Performance and Hazardous Substances
Where applicable, the DoP should be accompanied by information on hazardous substances in
the construction product. The information should initially be limited to substances referenced in
Articles 31 and 33 of the Regulation EC 1907/2006 (REACH).
What are these substances and how should this information be given?
The Safety report is to be supplied if the mixture is not dangerous according to Directive 1999/45/
EC but:
Article 33 of the REACH Regulation requires that the supplier of an article which contains a
substance in a concentration above 0,1% weight by weight shall provide sufficient information to
allow safe use of the article including, as a minimum, the name of the substance.
The substances considered in this article 33 are subject to authorisation and include:
Substances which are carcinogenic, mutagenic and toxic for reproduction (class 1A or 1B).
Substances which have endocrine disrupting properties and those substances (persistent,
bio accumulative and toxic or very persistent and very bio accumulative) which do not fully
meet the criteria above but for which there is scientific evidence of serious effects on human
health and which are identified on a case by case basis in accordance with the procedures
identified in Article 59 of REACH.
7
These substances (generally referred to as Substances of Very High Concern) are referred to in
the REACH candidate list.
Please note there is no specific model for informing on these substances in articles.
You can use the model provided in the Orgalime guide to REACH.
Be careful! Some products, some cables for instance, are required also to comply with
other directives on hazardous substances, RoHS in the case of those cables.
By 25 April 2014, the Commission will assess the specific need for information on the content of
hazardous substances in construction products and consider the possible extension of
information requirements to other substances.
Information on hazardous substances must accompany the DoP (paper electronic format, or
using website are all acceptable). This chapter will be updated as new information becomes
known.
Legally, manufacturers are not obliged to supply a DoP before that date but if they
wish to do so, they can supply a DoP with their product based on the information
reported in the declaration of conformity without additional test.
As a manufacturer, I have placed products on the market before 1 July 2013 for
which I have a certificate of conformity or a declaration of conformity with the
CPD. What shall I do with these products?
Products already on the market before 1 July 2013 in conformity with the CPD are
deemed to comply with the CPR after. A manufacturer can, if he wishes, draw up a
DoP on the basis of the pre-1 July 2013 conformity declaration.
For products made available after 1 July 2013, you should draw up a Declaration of
Performance and CE mark them in conformity with the CPR. But you do not need to
carry out further testing (you can still use the specifications of the pre 1 July
conformity document Declaration of Conformity to draw up the DoP) if nothing else
has changed.
Yes, you can still distribute them after 1 July 2013, without any change!
It is still possible that a customer might be reluctant to buy such products which do
not conform to the new Regulation and may ask you to bring them to conformity!
Make sure the DoP and CE mark follow the construction product, in whatever
unit it is sold (traceability of the DoP).
As from 1st July 2013, if you are placing your construction product on several EU
member states, you will have to translate your DoP in the language(s) required
by that member state.
8
Declaration of Performance, what does it look like?
(click on the number to see the explanation)
DECLARATION OF PERFORMANCE
[N]
No. 001CPR2013-07-14
1. Unique identification code of the product-type:
Positive pressure air/flue terminal with metal flue duct for C62- and C63-type gas appliances [1]
T120- P1- D-Vm-L40045- O50
2. Type, batch or serial number or any other element allowing identification of the construction product as required under Article 1(4):
Positive pressure air/flue terminal with metal flue duct for C62- and C63-type gas appliances [2]
T120- P1- D-Vm-L40045- O50
3. Intended use or uses of the construction product, in accordance with the applicable harmonised technical specification, as
foreseen by the manufacturer:
Convey air for combustion, and the products of combustion from appliances to the outside atmosphere. [3]
4. Name, registered trade name or registered trade mark and contact address of the manufacturer as required under Article 11(5):
AnyCo SA,
PO Box 21
B-1050 Brussels, Belgium
[4]
Tel. +32987654321
Fax: +32123456789
Email: anyco.sa@provider.be
5. Where applicable, name and contact address of the authorised representative whose mandate covers the tasks specified in Article 12(2):
Anyone Ltd
Flower Str. 24
West Hamfordshire [5]
UK-589645 United Kingdom
Tel. +44987654321
Fax: +44123456789
e-mail: anyone.ltd@provider.uk
6. System or systems of assessment and verification of constancy of performance of the construction product as set out in CPR,
Annex V: [6]
System 2+
7. In case of the declaration of performance concerning a construction product covered by a harmonised standard:
Notified factory production control certification body No. 5678 performed the initial inspection of the manufacturing plant
and of factory production control and the continuous surveillance, assessment and evaluation of factory production
[7]
control and issued the certificate of conformity of the factory production control.
8. Declared performance
Resistance to fire 50
Gas tightness/leakage:
• of the flue ! 0,006 l s-1 m-2
(under a positive pressure of 200 Pa)
• of the air supply duct ! 0,28 l s-1 m-2
(under a positive pressure of 40 Pa)
EN 14989-1: 2007
Flow resistance coefficient:
• of the flue 1,5 (declared)
• of the air supply duct 2,5 (declared)
9. The performance of the product identified in points 1 and 2 is in conformity with the declared performance in point 8.
This declaration of performance is issued under the sole responsibility of the manufacturer identified in point 4.
Signed for and on behalf of the manufacturer by: [9]
………………………………………………………………………………………………………………………………
(name and function)
…………………………………..……………" …………………………………..……………
(place and date of issue)# (signature)
9
[N] Number
Reference number of the DoP assigned by the manufacturer. The reference number enables
identification of the DoP in relation to a specific product-type.
Reference number assigned by the manufacturer to help identify the product for which the DoP
has been drawn up. The manufacturer can use the same number for the DoP and the unique
identification code.
[2] Type, batch or serial number or any other element allowing identification of the
construction product
The manufacturer has to give a type, batch or serial number to his product, for its identification.
This information can be the same as the unique identification code, or the manufacturer can use
another code which allows the user to technically identify the product.
The manufacturer will find this information in the Annex ZA of the harmonised standard of the
product. The technical specifications can define one or several intended uses in relation to the
relevant essential characteristics.
[4] Name, registered trade name or registered trade mark and contact address of
the manufacturer
The manufacturer has to give these details (name, address, etc…) on the DoP so all economic
operators in the supply chain know who is responsible for the conformity of the product with the
declared performances.
[5] Where applicable, name and contact address of the authorised representative
If an authorised representative is acting on behalf of the manufacturer, the name and address of
this authorised representative has to appear on the DoP.
The manufacturer has to indicate which system has been applied to the product.
It is necessary to report the name and the identification number of any notified body involved, the
tasks performed and the document(s) issued at the end of the assessment (certificate of
constancy of performance, certificate of conformity of the factory production control, tests,
calculations…) should be included on the DoP. If a European Technical Assessment (ETA) has
been issued for the product, the name of the Technical Assessment Body has to be given, also
the reference number of the ETA and the European Assessment Document.
Column 1 (essential characteristics): should include the list of essential characteristics given in the
harmonised technical specification for the declared intended use(s).
Column 2 (performance): in relation with each essential characteristic listed in the first column, the
manufacturer should declare the performance, by level or class or in a description. This
information also is found in the Annex ZA of the relevant harmonised standard. If no performance
is declared, the DoP should state ‘No Performance Determined’ (NPD).
Column 3: for each essential characteristic listed in column 1, the manufacturer should indicate
the reference number and date of issue of the harmonised standard for the product or the ETA
used for the assessment of each essential characteristic.
[9] Signature
Each original DoP is to be signed by the manufacturer or by the responsible person appointed by
the manufacturer, including name, function, place and date of issue.
If the product is not fully covered by a harmonised standard, the manufacturer may apply for a
European Technical Approval, which will assess that a particular product can be CE marked for
and placed on the market under CPR.
The CE marking symbol is to be used in accordance with the general principles set out in Article
30 of Regulation (EC) No 765/2008 and shall be affixed visibly, legibly and indelibly:
To the product.
To the accompanying documents (if not possible neither on the product or on the
packaging).
12
What does it look like?
AnyCo Ltd, PO Box 21, B-1050, Brussels, Name and the registered address of the manufacturer,
Belgium or identifying mark
intended to be used in (e.g. curtain walling, fire Intended use of the product as laid down in the
compartmentation, etc.) European standard applied
Products manufactured on the construction site for incorporation in that construction work.
These derogations only apply in the absence of European or National provisions (i.e.
national building regulations).
Some CPR products are excluded from a CPD standards mandate where other measures
already cover the relevant requirements, because they are meeting the requirements of the
Gas Appliances Directive or the Low Voltage Directive for example, and are therefore CE
marked according to these directives.
13
BASIC REQUIREMENTS FOR CONSTRUCTION WORKS
The ‘Essential Requirements’ set out in the Construction Products Directive have been renamed
‘Basic Works Requirements’ in the Construction Products Regulation. The wording for each
requirement is unchanged with the exception of the third Basic Works Requirement for ‘Hygiene,
health and the environment’. Here a reference has been added to the effect that the construction
works should “not have an exceedingly high impact, over their entire life cycle, on the
environmental quality or on the climate during their construction, use and demolition”. However,
the most significant change is the addition of a seventh Basic Works Requirement on the
‘Sustainable use of natural resources’. This additional requirement is elaborated below:
Recyclability of the construction works, their materials and parts after demolition.
Use of environmentally compatible raw and secondary materials in the construction works.
The inclusion of this requirement will allow member states to regulate for the use of sustainable
products and for a sustainability characteristic to be included in the DoP and the CE marking.
However, for this to happen the member state will need a method for assessing the product’s
performance.
Discussions are currently taking place in order to decide how the 7th Basic Requirement will be
declared in the DoP. It seems that when Environment Product Declarations exist, these could be
used as they provide a list of characteristics representing the environmental aspects. Unless an
additional essential characteristic is included in a harmonised standard for sustainability, there is
no need to define, nothing changes for the manufacturer.
A request heard by a manufacturer in real life: you need to run a burglar resistance
performance evaluation!
Please note that burglar resistance is not part of the basic requirement on safety and accessibility in
use. Refer to Annex I, clause 4 of the Regulation, which clearly states that it is the construction works
that must be designed in such a way that they do not present unacceptable risk in case of burglaries,
and not the components. Therefore, be careful if you are asked to include such a burglar resistance
performance in relation to basic requirement no 4.
14
SYSTEM OF ASSESSMENT AND CONSTANCY OF PERFORMANCE
This is the system which the manufacturer uses to assess the performance of his construction
product in relation to its essential characteristics. Once this process is finished, the DoP can be
prepared, which is then kept with the technical file of the product. This documentation might be
supported by a certificate of constancy of performance, certificate of conformity of the factory
and production control, test laboratory reports or certificates, and/or a manufacturer’s own test
results, depending on the system of Assessment and Verification of Constancy of Performance
(AVCP) required for that product.
Product certification body carried out by a body having the competence to carry out a
product certification in accordance with given rules of procedure.
Factory production control certification body carried out by a body having the
competence and responsibility to carry out factory production certification in accordance
with given rules.
Testing laboratory carried out by a notified laboratory which examines, measures and
determines the characteristics or performance of materials or construction products.
The European Commission (through the adoption of delegated acts) could revise the
system or systems to be applied to a family of construction products taking into account
their impact on health and safety.
The table below summarises Annex V of the Regulation which describes the systems to be used,
the items to be carried out by the manufacturer and the involvement of notified bodies:
Type-testing ! !
Declaration of ! ! ! ! !
Performance
Continuous ! ! !
Surveillance
!
Type-testing ! !
Audit Testing !
15
CHAPTER 2 - THE APPLICATION OF CPR AT A GLANCE
Is my product in the
scope of the CPR? NO
YES
Is it covered by hEN or
conformed to ETA?
NO YES
No DoP necessary
Do I want ETA? DoP Derogation
No CE necessary
YES
NO
The manufacturer
prepares technical The TABs modify
file and sends it to and adjust the EAD TAB prepares an ETA
the TAB [Annex II]
16
CHAPTER 3 - ECONOMIC OPERATORS
The CPR makes it clear that obligations apply all along the supply chain, and it imposes certain
legal requirements on the manufacturer, the importer, the distributor and any manufacturer’s
authorised representative (a legal entity instructed by the manufacturer to act on his behalf). The
CPR also clarifies under what conditions a distributor/importer becomes a manufacturer. Under
those conditions the manufacturer’s responsibilities will fall on the distributor/importer. It is
therefore extremely important for all companies along the supply chain to be aware of these
conditions as failure to comply is a criminal act and subject to penalties.
The definitions given in the CPR for manufacturer, importer, distributor and authorised
representative and the legal requirements on each party are explained below.
The definitions came into force on 24 April 2011 and are now part of European law.
However, the requirements do not come into force until 1 July 2013.
MANUFACTURER
'Defined as any natural or legal person who manufactures a construction product or who has such
a product designed or manufactured and markets that product under his name or trademark'
i.e. those companies who make or design and make construction products (e.g. include a list of
products). Also, those who put products already CE marked, on the market under their own
name/trademark (e.g. include a list of products).
17
DISTRIBUTOR
'Defined as any natural or legal person in the supply chain, other than the manufacturer or the
importer, who makes a construction product available on the market'
i.e. those companies that buy and sell construction products within the EU.
IMPORTER
'Defined as any natural or legal person established within the Union, who places a construction
product from a third country on the Union market'
i.e. those companies that import construction products e.g. steel sections, structural bolts, from
manufacturers based outside the European Union.
1. Only place construction products on the market that comply with the CPR.
2. Ensure that the assessment and the verification of constancy of performance have
been carried out by the manufacturer.
3. Ensure that the manufacturer has drawn up the technical documentation.
4. Ensure that the manufacturer has drawn up the DoP.
5. Ensure that the product bears the CE marking.
6. Ensure that the product is accompanied by the required documentation.
7. Not place on the market construction products that do not conform to the regulation.
8. Place his/her name and address on the product.
9. Ensure that the product is accompanied by the safety instructions.
10. Ensure that the storage and transportation do not jeopardise the performance of the
product.
11. Carry out sample testing.
12. Take corrective action and/or withdraw non-conforming products.
13. Retain records for 10 years.
18
AUTHORISED REPRESENTATIVE
‘Defined as any natural or legal person established within the Union who has received a written
mandate from a manufacturer to act on his behalf in relation to specific tasks’
An authorised representative can be appointed by the manufacturer to act on his behalf to carry
out some of the tasks necessary to comply with the CPR. For example affix the CE marking,
drawing up the DoP and act as a contact point for the national authorities. However, the
authorized representative cannot take responsibility for the factory production control system.
This remains the responsibility of the manufacturer. “Authorised representative” should not be
confused with a manufacturer’s commercial representative, who plays no part in ensuring the
product complies with the CPR.
An authorised representative must be established within the European Community, and work
under the authorisation of the manufacturer. There must be a written agreement between the two
parties.
Article 15 of the CPR sets out the conditions under which an importer/
distributor becomes a manufacturer.
The first of these is where a company buys a product made by another party and places it on the
market under his own name or trade mark (for example a CE Marked steel section may be placed
on the market by a steel manufacturer). In this case even though the company does nothing to the
product to change its declared characteristics, that company becomes the manufacturer and is
subject to the requirements on the manufacturer as set out above. This is sometimes called
‘badge engineering’.
The second scenario is where a company buys an already CE marked construction product (for
example a CE marked steel section), modifies that product (for example a service centre may part
fabricate the steel sections before selling it to the steelwork contractor) and places it back on the
market. Under this scenario, that company becomes the manufacturer of the modified
construction product. That company is entitled to assume that the original manufacturer has
correctly CE marked the product and can communicate onwards the un-modified performance
characteristics details without repeating the Initial Type Testing (ITT) on the basis that it has done
nothing to change those characteristics. However, that company will have to perform further ITT
for any characteristics that have been changed (for example any drilled/punched holes must
conform to the essential tolerances given in BS EN 1090-2; similarly shot-blasting and painting
the section will affect the durability and reaction to fire).
19
CHAPTER 4 - HARMONISED STANDARDS AND EUROPEAN
ASSESSMENT DOCUMENTS
HARMONISED STANDARDS
Harmonised standards are established by European Standardisation
Bodies (in practice for CPR, it is generally CEN which is responsible for
issuing a hEN) which receives a mandate from the European
Commission. It is those standards which must then be followed. There
is no “or equivalent” alternative route.
Will include the technical details necessary for the implementation of the ACVP.
The Annex ZA of the hEN contains all the harmonised provisions which have to be applied to fulfil
the obligations of the CPR.
(It is understood that the current Annex ZAs, already drafted under Commission mandates, may
have to be adapted/amended in order to meet the changed requirements of the Construction
Products Regulation.)
Harmonised standards produced under those mandates are then published by the Commission in
the Official Journal of the EU, and are added to the NANDO CPD/R list
As is the case with harmonised standards, the European Technical Assessment will be published
in the Official Journal of the EU.
Contrary to an ETA issued before 1 July 2013, ETAs issued after that date will have no time limit
on their validity.
If you have an ETA for a specific product issued before 1 July 2013, you can use it for its full
5-year validity period).
20
CHAPTER 5 - SIMPLIFIED PROCEDURES
When the manufacturer uses this simplified procedure, he should then demonstrate by means of
Specific Technical Documentation that the construction product complies with the requirement
and that the procedures used are equivalent to those described in the harmonised standard.
One or several essential characteristics or the construction product can achieve a level or
class of performance without testing or calculation in accordance with the conditions
described in the relevant harmonised standard.
The construction product placed on the market corresponds to the product-type of another
construction product already tested by another manufacturer to the relevant standard. In
this case, you can declare the performance corresponding to the test results of the other
product. But you need the authorisation of the other manufacturer!
The construction product is a system made of components and these components have
already been tested for one or several characteristics (always in accordance with the
relevant standard). In this case you can declare the performance corresponding to the test
results (all or in part) for the system. Again, you need the authorisation of the other
manufacturer!
21
CHAPTER 6 - ADDITIONAL POINTS
VOLUNTARY MARKS
It is important to repeat, as CPR is very clear on this point, that the CE marking is the only mark
required to guarantee that a construction product has been put on the market meeting the
requirements of the CPR. Nevertheless, manufacturers can use voluntary marks together with the
CE marking, provided that:
For instance, they could follow from assessing some characteristics which are not covered in the
CE marking and give a third party guarantee that the construction product complies with the
declared performance, or declare that a product is fit for a specific use, provided this is not
already included in the harmonised standard for the product.
The Commission will draw up and regularly update the list of Product contact points and publish it
in the Official Journal of the EU.
As a manufacturer, when you make a request for a European Technical Assessment (this means
that your product is not falling in the scope of a harmonised standard and/or an assessment
method is not included in the harmonised standard for at least one essential characteristic), the
European Assessment Document, under which the ETA is conducted, drawn up by the Technical
Assessment Body (TAB) should respect some main principles:
It should define appropriate mandatory time limits in order to avoid any delay.
It should take into account the protection of his commercial secrets and confidentiality.
22
Last but not least, the TAB should bear the full costs of the development and adoption of
the European Assessment Document!
Technical Assessment Bodies are designated by their member states. The name and address of
each TAB and the product areas for which it is designated should be communicated to both the
European Commission and other member states.
NOTIFIED BODIES
Notified bodies carry out third party tasks in the process of assessment and verification of
constancy of performance. They also have obligations vis-à-vis the manufacturers, for carrying
out AVCP with transparency as regards the manufacturer, and avoiding unnecessary burden for all
economic operators.
In consequence:
Guidelines for European Technical Approvals published before 1 July 2013 may be used as
EADs.
ETAs issued in accordance with the CPD before 1 July 2013 may be used as ETA
throughout the period of validity (usually 5 years from the date of issue).
Those manufacturers who are in the ETA process before 1 July 2013 should contact their
Technical Assessment Body for these specific cases.
23
GLOSSARY
Authorised representative
Any natural or legal person established within the EU who has received a
written mandate from a manufacturer to act on his behalf in relation to
specific tasks.
Construction product
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 buildings and
civil engineering works.
Distributor
Any natural or legal person in the supply chain, other than the manufacturer or the importer, who
makes a construction product available on the market.
Essential characteristics
Refer to those characteristics of the construction product which relate to the basic requirements
for building and civil engineering works.
24
European Technical Assessment
The documented assessment of the performance of a construction product, in relation to its
essential characteristics, in accordance with the respective European Assessment Document
(EAD).
Importer
Means any natural or legal person established within the Union, who placed a construction
product from a third country on the Union market.
Kit
Means a construction product placed on the market by a single manufacturer as a set of at least
two separate components that need to be put together to be incorporated in the construction
works.
Life cycle
The life cycle is the consecutive and interlined stages of a construction product’s life from raw
material acquisition or generation from natural resources to final disposal.
Manufacturer
Any natural or legal person who manufactures a construction product or who has such
construction product designed or manufactured, and markets that product under his name or
trademark.
25
Product-type
The set of representative performance levels or classes of a construction product, in relation to its
essential characteristics, produced using a given combination of raw materials or other elements
in a specific production process.
Threshold level
A minimum or maximum performance level of an essential characteristic of a construction
product.
USEFUL LINKS
26
ANNEX I - PRODUCT AREAS
ANNEX IV
PRODUCT AREAS
PRODUCT AREAS AND REQUIREMENTS FOR TABS
AREA
PRODUCT AREA
CODE
3 MEMBRANES, INCLUDING LIQUID APPLIED AND KITS (FOR WATER AND/OR WATER VAPOUR
CONTROL).
5 STRUCTURAL BEARINGS.
PINS FOR STRUCTURAL JOINTS.
7 GYPSUM PRODUCTS.
10 FIXED FIRE FIGHTING EQUIPMENT (FIRE ALARM/DETECTION, FIXED FIREFIGHTING, FIRE AND SMOKE
CONTROL AND EXPLOSION SUPPRESSION PRODUCT).
11 SANITARY APPLIANCES.
19 FLOORINGS.
21 INTERNAL & EXTERNAL WALL AND CEILING FINISHES. INTERNAL PARTITION KITS.
24 AGGREGATES.
25 CONSTRUCTION ADHESIVES.
27
L 88/40 EN Official Journal of the European Union 4.4.2011
AREA
PRODUCT AREA
CODE
28 PIPES-TANKS AND ANCILLARIES NOT IN CONTACT WITH WATER INTENDED FOR HUMAN
CONSUMPTION.
33 FIXINGS.
1. Analysing risks Identify the possible risks and benefits for the A TAB shall be established under national law
use of innovative construction products in the and have legal personality. It shall be indeä
absence of established/consolidated technical pendent from the stakeholders and from any
information regarding their performance particular interests.
when installed in construction works.
In addition, a TAB shall have staff with:
2. Setting technical Transform the outcome of the risk analysis (a) objectivity and sound technical judgement;
criteria into technical criteria for evaluating
behaviour and performance of the (b) detailed knowledge of the regulatory
construction products regarding the fulfilment provisions and other requirements in force
of applicable national requirements; in the Member States where it is designated,
concerning product areas for which it is to
provide the technical information needed by be designated;
those participating in the building process as
potential users of the construction products (c) general understanding of construction
(manufacturers, designers, contractors, practice and detailed technical knowledge,
installers). concerning product areas for which it is
to be designated;
3. Setting assessment Design and validate appropriate methods (tests
methods or calculations) to assess performance for (d) detailed knowledge of specific risks
essential characteristics of construction involved and the technical aspects of the
products, taking into account the current construction process;
state of the article. (e) detailed knowledge of the existing
harmonised standards and test methods
within the product areas for which it is to
be designated;
(f) appropriate linguistic skills.
The remuneration of the TAB personnel shall
not depend on the number of the assessments
carried out or on the results of such
assessments.
28
ANNEX II - ORGALIME MEMBERS
AUSTRIA
FEEI Fachverband der Elektro- und Elektronikindustrie Österreichs
Mariahilfer Strasse 37-39 – 1060 Vienna
Tel : (43) 1 588 39 0 – Fax : (43) 1 586 69 71
E-mail : info@feei.at - Web : www.feei.at
President: Brigitte Ederer
Director: Lothar Roitner
BELGIUM
AGORIA La fédération de l'industrie technologique –
De federatie van de technologische industrie
Diamant Building, Bd. A. Reyers 80 – 1030 Brussels
Tel : (32) 2 706 78 00 – Fax : (32) 2 706 78 01
E-mail : info@agoria.be - Web : www.agoria.be
President: Christʼl Joris
Director: Paul Soete
BULGARIA
BASSEL Bulgarian Association of Electrical Engineering and Electronics
P.O. Box 76 – 1407 Sofia
Tel: (359) 2 963 3532 or 963 3437 - Fax: (359) 2 963 0727
E-mail : eu_org@bcee-bg.org – Web : www.bcee-bg.org
President: Roumen Atanassov
Director: Boris Gotchev
DENMARK
DI Confederation of Danish Industries
H.C. Andersen Boulevard 18 – 1787 Copenhagen V
Tel : (45) 33 77 33 77 – Fax : (45) 33 77 33 00
E-mail : di@di.dk - Web : www.di.dk
President: Jesper Moeller
Deputy Director General: Thomas Bustrup
FINLAND
The Federation of Finnish Technology Industries
Eteläranta 10 – 00131 Helsinki 13
Tel : (358) 9 19231 – Fax : (358) 9 624462
Web : www.teknologiateollisuus.fi
President: Ole Johansson
Director: Jorma Turunen
FRANCE
FIEEC Fédération des Industries Electriques, Electroniques et de Communication
Rue Hamelin 11-17 – 75783 Paris Cedex 16
Tel : (33) 1 45 05 70 70 – Fax : (33) 1 45 53 03 93
E-mail : comm@fieec.fr - Web : www.fieec.fr
President: Pierre Gattaz
Director: Eric Jourde
GERMANY
VDMA Verband Deutscher Maschinen- und Anlagenbau e.V.
Lyoner Strasse 18, Postfach 71 08 64 – 60582 Frankfurt/Main
Tel: (49) 69 6603 0 – Fax : (49) 69 6603 1511
E-mail : puoe@vdma.org - Web : www.vdma.org
President: Thomas Lindner
Director: Hannes Hesse
29
ZVEI Zentralverband Elektrotechnik- und Elektronikindustrie e.V.
Lyoner Strasse 9, Postfach 70 12 61 – 60528 Frankfurt/Main
Tel: (49) 69 6302 0 – Fax : (49) 69 6302 317
E-mail: zvei@zvei.org - Web : www.zvei.de
President: Friedhelm Loh
Director: Klaus Mittelbach
HUNGARY
MAGEOSZ The Hungarian National Association of Machinery and Power Engineering Industries
1012 Budapest, Kuny Domokos u. 13-15.
Tel: +36 1 215 8868 – Fax :
E-mail: mageosz@mageosz.hu - Web : http://www.mageosz.hu/
President: László Deák
Secretary General: Gábor Vadnai
IRELAND
IEEF Irish Engineering Enterprises Federation
Confederation House, 84-86 Lower Baggot Street – Dublin 2
Tel: (353) 1 605 1676 – Fax : (353) 1 638 1676
E-mail: ieef@ibec.ie – Web : www.ibec.ie/ieef
President: Gerry Donovan
Director: Marian Byron
ITALY
ANIE Federazione Nazionale Industrie Elettrotecniche ed Elettroniche
Viale Lancetti 43, 20158 Milano
Tel : (39) 02 326 41 – Fax : (39) 02 326 4212
E-mail : info@anie.it - Web : www.anie.it
President: Claudio Andrea Gemme
Secretary General: Maria Antonietta Portaluri
ANIMA Federazione delle Associazioni Nazionali dell' Industria Meccanica varia ed affine
Via A. Scarsellini, 13 – 20161 Milano
Tel : (39) 02 4541 8500 – Fax : (39) 02 4541 8545
E-mail : anima@anima-it.com - Web : www.anima-it.com
President: Sandro Bonomi
Director: Andrea Orlando
LATVIA
Association of Mechanical Engineering and Metalworking Industries of Latvia
Ezermalas 6 - 1006 Riga
Tel : (371) 755 48 25 - Fax : (371) 708 97 76
E-mail : masoc@apollo.lv - Web : www.masoc.lv
Chairman & President: Vilnis Rantins
LITHUANIA
LINPRA The Engineering Industries Association of Lithuania
Savanoriupr 176 - 03154 Vilnius
Tel : (370) 5 231 25 20 - Fax : (370) 5 231 25 20
E-mail : info@linpra.lt - Web : www.linpra.lt
President: Vaclovas Sleinota
Director: Henrikas Mykolaitis
LUXEMBOURG
ILTM Industrie Luxembourgeoise de la Technologie du Métal
B.P. 1304 – 1013 Luxembourg
Tel : (352) 43 53 661 – Fax (352) 43 23 28
E-mail : fedil@fedil.lu - Web : www.fedil.lu
President: Jacques Lanners
Director: Nicolas Soisson
THE NETHERLANDS
FME-CWM Association of Enterprises in the Technological Industrial Sector
Boerhaavelaan 40, Postbus 190 – 2713 AD Zoetermeer
Tel : (31) 79 353 1100 – Fax : (31) 79 353 1365
E-mail : alg@fme.nl – Web : www.fme-cwm.nl
President: Ineke Dezentjé Hamming Bluemink
Director: Peter Bongaerts
NORWAY
30
Norsk Industri
P.O. Box 7072 Majorstua – 0306 Oslo 3
Tel : (47) 22 59 0000 – Fax : (47) 22 59 0001
E-mail : post@norskindustri.no – Web : www.norskindustri.no
President: Rassmus Sunde
Director: Knut Sunde
POLAND
Polish Economic Chamber of Electrotechnics
ul.Szubińska 17, 85-312 Bydgoszcz
Tel/Fax : (48) 52 375 45 71
E-mail : biuro@elektrotechnika.org.pl - Web : www.elektrotechnika.org.pl
President: Janusz Nowak
Managing Director: Janusz Nowastowski
PORTUGAL
AIMMAP Associação dos Industriais Metalurgicos, Metalomecanicos e Afins de Portugal
Rua dos Platanos 197 - 4100 Porto
Tel : (351) 22 616 68 60 - Fax : (351) 22 610 74 73
E-mail : aimmap@aimmap.pt - Web : www.aimmap.pt
Vice-President: Anibal José da Costa Campos
General Manager: Rafael Campos Pereira
SLOVENIA
GZS-MPIA Metal Processing Industry Association
C/o Chamber of Commerce and Industry of Slovenia
Dimiceva 13 - 1504 Ljubljana
Tel : (386) 1 58 98 000 – Fax : (386) 1 58 98 100
E-mail : info@gzs.si - Web : www.gzs.si
President: Blaž Nardin
Director: Janja Petkovšek (Mechanical and Metalworking)
Director: Janez Renko (Electronics and Electrical)
SPAIN
CONFEMETAL Confederación Española de Organizaciones Empresariales del Metal
Principe de Vergara 74 – 28006 Madrid
Tel : (34) 91 562 5590 - Fax : (34) 91 562 8477
E-mail : confemetal@confemetal.es - Web : www.confemetal.es
President: Javier Ferrer Dufol
Director: Andres Sánchez de Apellaniz
SWEDEN
TEKNIKFÖRETAGEN The Association of Swedish Engineering Industries
P.O. Box 5510 – 114 85 Stockholm
Tel: (46)8 782 0800 – Fax : (46) 8 782 0900
E-mail: info@teknikforetagen.se - Web: www.teknikforetagen.se
President: Leif Östling
Director: Åke Svensson
Communications: Jonas Cohen jonas.cohen@teknikforetagen.se
SWITZERLAND
SWISSMEM Schweizer Maschinen-, Elektro- und Metallindustrie
Kirchenweg 4 – 8032 Zürich
Tel : (41) 44 384 4111 – Fax : (41) 44 384 4242
E-mail : info@swissmem.ch - Web : www.swissmem.ch
President: Hans Hess
Director: Peter Dietrich
UNITED KINGDOM
BEAMA Federation of British Electrotechnical and Allied Manufacturers – Associations Ltd
Westminster Tower, 3 Albert Embankment – London SE1 7SL
Tel : (44) 207 793 3000 – Fax : (44) 207 793 3003
E-mail : info@beama.org.uk - Web : www.beama.org.uk
President: Les Woolner
Chief Operating Officer: Howard Porter
31
EAMA Engineering and Machinery Alliance
62, Bayswater Road - London W2 3PS
Tel: (44) 20 7298 6450 – Fax: (44) 20 7298 6434
E-mail: eama@mta.org.uk or eamasec@dsl.pipex.com Web: www.eama.info
Chairman: Martin Walder
Alliance Secretary: Rupert Hodges
ASSOCIATE MEMBERS
CROATIA
CEA Croatian Employers Association
Ulica Pavla Hatza 12 – 10000 Zagreb, Hrvatska
Tel: (385) 1 48 97 571 – Fax : (385) 1 48 97 581
E-mail: ana.falak@hup.hr - Web : www.hup.hr
Director: Ana Falak
32
ANNEX III - LIST OF EUROPEAN SECTOR ASSOCIATIONS AND
OTHER CONTRIBUTORS PARTICIPATING IN THE DRAFTING
OF THIS GUIDE
BCSA - The British Constructional Steelwork Association
EURALARM - Association of European Manufacturers and Installers of Fire and Security Systems
EUROPACABLE E.E.I.G. - European Confederation of National Associations of Manufacturers of Insulated Wire and Cable
EWRIS - European Federation of Wire Rope Industries Industrieverband Schneid- und Haushaltswaren e.V.
33