THE CONSTRUCTION PRODUCTS REGULATION CE marking is coming to the UK s builders merchants

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1 The Directive THE CONSTRUCTION PRODUCTS REGULATION CE marking is coming to the UK s builders merchants The Construction Products Directive was a European Union directive introduced in Its purpose was twofold: To create a common framework for regulations on buildings and other construction works. To ensure the free movement of benign construction products within the EU. (A construction product is any product which is sold for permanent incorporation into construction works so it doesn t apply to tools, etc.) The directive made provision for the CE marking of construction products for more about the CE and other marks see my article last month. Being a directive, it was implemented by the national governments of the EU, and most of them chose to make the CE marking of construction products compulsory. The UK, along with four other countries on the NE fringe of CE Mark Europe, chose not to do so. The Regulation However, the directive is now being replaced by the Construction Products Regulation. Being a regulation rather than a directive, this bypasses national governments and becomes law directly. As a result of the new regulation, from July 1 a construction product that is covered by a harmonised European Standard or a European Technical Assessment (see below) must have CE marking if it is to be offered for sale. So expect to see a lot more CE marking in the near future it s reckoned that about 80% of construction products will require it. (Remember that a CE mark indicates a basic level of consumer protection, rather than excellence.) Harmonised European Standards A harmonised European Standard is a European Standard that has become mandatory by way of an EU directive or regulation as distinct from the other, voluntary European Standards. There are more than 400 harmonised standards applicable to construction products. (For a list of these standards, see the European Commission website listed in Further Info. By the way, BSI, rather surprisingly, would prefer Standards to remain voluntary rather than be made mandatory.) Under the Construction Products Regulation, a product which is covered by a harmonised standard must remain fit for purpose throughout its expected economic life. In addition, it must satisfy seven basic requirements, which are concerned with: Mechanical resistance and stability. Safety in the case of fire. THE CONSTRUCTION PRODUCTS REGULATION 1 MARCH 2013.

2 Hygiene, health, and the environment. Safety and accessibility in use. Protection against noise. Energy, economy, and heat retention. Sustainable use of natural resources. (This item was not in the 1989 directive, but has been added in the new regulation.) In fact, the scope of these benign basic requirements is wider than just construction products. They apply to construction works as a whole, so national building regulations must be in accord with the seven basic requirements. A harmonised European Standard includes an Annex ZA, in which is given, amongst other information, the information that the manufacturer is required to give in a Declaration of Performance see below. European Technical Assessments An innovative construction product is unlikely to be covered by a European Standard. However, following a request from its manufacturer to an approved body (eg, the BBA), after testing and other appraisals, the product might be awarded a European Technical Assessment eg, a BBA Agrément certificate. (A necessary condition for an ETA is that the product satisfies the seven basic requirements, as listed above. As the name implies, an ETA is valid Europe-wide.) The approved bodies that can issue ETA s are given on the EOTA website. (See Further Info. Organisations such as the BBA are officially known as Notified Bodies notified to EOTA by their national governments.) Many countries have just one such body, but the UK has seven, including the BBA, BM Trada Certification, and BRE Global. (The EOTA website also shows the types of products for which a particular Notified Body is authorised to issue an ETA.) Declaration of Performance Under the Construction Products Regulation, if a product requires CE marking, then the manufacturer (or importer) must make a Declaration of Performance (DoP) for the product. Usually this accompanies the CE mark on the product or its packaging, but it can be given on a website. (The Declaration of Performance replaces the similar Declaration of Conformity of the obsolete directive.) Below is an imaginary example of a Declaration of Performance on a roll of loft insulation. From top to bottom: CE mark Identification number of certification body in this case BSI. Name and address of manufacturer (or importer). 12 Year code to have put the year itself (ie, 2012) would have been too simple! THE CONSTRUCTION PRODUCTS REGULATION 2 MARCH 2013.

3 This is the year in which the CE mark was first affixed to the product, not the year of its manufacture Kozywrap Insulation Co Ltd 99 High St, Bigtown, BI99 9ZZ CPD EN 13162:2008 Mineral wool, intended to be used as thermal insulation product in buildings Reaction to Fire Thermal Resistance Thermal Conductivity Thickness Class A1 2,5 m 2 KW 0,040 W/m K 100 mm MW EN T6 DS(T+) CS(10)70 TR15 PL(5)100 MU1 AP0,35 AP0,35 AW0,40 Declaration of Performance for imaginary Kozywrap insulation 0086 CPD This is the certificate number, issued by BSI in this case (0086). CPD shows that it is for the Construction Products Regulation, and is a number assigned in this imaginary case by BSI. EN 13162:2008 The harmonised European Standard that applies to the product. (Its title is: Thermal insulation products for buildings Factory made mineral wool (MW) products Specification) Occasionally, more than one standard may be applicable to a product. Description of the product. The values for the four properties required by this standard ( essential characteristics in the jargon of the regulation). Note that a decimal comma is used I don t suppose UKIP supporters have much time for harmonised European Standards! Note also that the K in this example stands for kelvin, ie, ºC. (Lord Kelvin was a Nineteenth century physicist.) In some DoP s, a value is replaced by NPD, standing for No Performance THE CONSTRUCTION PRODUCTS REGULATION 3 MARCH 2013.

4 Determined. The manufacturer is allowed to state this if a value for that property is not required in the UK for showing compliance with our building regulations. So a declaration of the value of an essential characteristic may not be so essential! (In some harmonised European Standards, an essential characteristic may simply be the result of a pass/fail test. In which case there is no need for the manufacturer to declare a Pass. For the DoP to be made at all, the product must have passed the test. But some manufacturers do declare a Pass because they think it looks good.) Values for other properties which are not required to be declared but are optional voluntary characteristics. This is expressed in a form that to most people will be gobbledegook. The gobbledegook You would normally have to read the standard (in the above case, EN 13162:2008) to find the explanation of this gobbledegook shorthand. The price of this Mineral Wool standard is 156. What builder, or selfbuilder even, is going to pay that money to understand some code on a Declaration of Performance? So here is a breakdown of the gobbledegook this particular standard has more than most. I give it not because it will be of much interest in itself to the typical reader, but in order to show the sort of information that is available from such a Declaration of Performance should you require it. Code Meaning MW EN Mineral Wool. The relevant standard T6 Thickness tolerance: Class 6. CS(10)70 PL(5)100 Compressive Stress: 70 kpa gives a 10% deformation. Point Load required for 5 mm deformation: 100 Newtons. CP3 Compressibility: Level 3. AP0,35 Practical sound absorption coefficient: AW0,40 Weighted sound absorption coefficient: Declarations of voluntary characteristics Who is interested, you might wonder, in this sort of obscure technical information? Well, many housebuilders could find one of the properties listed above to be significant. Studwork partition walls on the upper floor of a house are common, and to reduce sound transmission through them particularly through the walls around a WC they are often filled with mineral wool. For this purpose a housebuilder might well wish to choose the mineral wool with the highest weighted sound absorption coefficient the last property listed above, AW. ( Weighted means that the coefficient reflects the variation of perceived loudness with sound frequency.) THE CONSTRUCTION PRODUCTS REGULATION 4 MARCH 2013.

5 So the gobbledegook can be of some practical interest. Unfortunately, as things stand I think little use will be made of it how many builders pay out for any British Standards? There is a big legal edifice requiring a Declaration of Performance on a construction product, or its packaging, yet 99.99% of its users won t know what such gobbledegook means. That s absurd. In my opinion, for every mandatory standard for a construction product, BSI should publish a public webpage which explains the terminology used in a corresponding Declaration of Performance. Just to complete the account of our imaginary example, I should add that Kozywrap Insulation have chosen not to declare the values for several other properties given in the standard. These relate to: Dimensional stability, Tensile strength, Water absorption, Dynamic stiffness, Compressive creep, and Air flow resistivity all with their own symbols. The properties in a Declaration of Performance must be measured in the way prescribed, according to yet more standards. In this standard (BS EN 13162), even the way that the length of the insulation is be measured has been prescribed: BS EN 822 (Thermal insulating products for building applications. Determination of length and width). Missing properties A property not included within a particular standard can be measured howsoever the manufacturer sees fit. Its value can be published, but not as part of the Declaration of Performance. Two such properties for mineral wool would be density and specific heat values for these could be of use in some advanced building design. Who does the measuring? Can we trust a manufacturer to measure the properties of their product competently and honestly, or do we need measurement by an approved third party, a Notified Body? The answer to that question is that a bit of both are generally allowed, but the regulation for this is very complex. (For the curious: System 1+ requires the most input from an approved body, going through to System 4 which requires input only from the manufacturer.) There are two phases of measurement: Initial Type Testing This results in the figures used for the Declaration of Performance. Factory Production Control This ensures that the declared figures are maintained throughout the period of manufacture. For our Kozywrap mineral wool example, Annex ZA tells us that the Initial Type Testing of the following key properties has to be done by a third party: Reaction to Fire Thermal Resistance Compressive strength (if it is declared) THE CONSTRUCTION PRODUCTS REGULATION 5 MARCH 2013.

6 Water absorption (if it is declared). There will soon be a requirement for Initial Type Testing for the release of dangerous substances, too. As users of a construction product, selfbuilders might need to know the values of the properties of the product, but they generally don t need to know how the values are arrived at or who measured them. (Though in a future article I ll be looking at a product multifoil insulation for which they might well want to know how the figure for its insulation value is arrived at.) As a broad generalisation, important properties such as fire resistance have to be measured by a third party, and less important properties can be measured by the manufacturer. And to make the regulation less onerous for small manufacturers, in some cases they can declare values they have measured themselves, whereas a large manufacturer would have to incur the expense of obtaining values measured by a third party. Complaints Under the new regulation, a manufacturer (or importer) of construction products will have to maintain a register of complaints about their products. Exemptions Bespoke products, products made on site, and products made in a traditional manner for the renovation of listed buildings are exempt from the Regulation. Congratulations? Selfbuilders are usually more interested in practical matters than bureaucratic details. If you have read through to the end of this article congratulations! FURTHER INFO: BSI Group European Committee for Standardization (CEN) CEN is Composed of the National Standards Bodies of most European countries. It produces the European Standards. European Organisation for Technical Approvals (EOTA) EOTA is composed of those national Approved Bodies that are authorised to issue European Technical Approvals for construction products. European Commission You could waste much time searching their labyrinthine website, so here are three relevant webpages: 1. The text of the Construction Products Regulation: THE CONSTRUCTION PRODUCTS REGULATION 6 MARCH 2013.

7 2. List of harmonised European Standards for construction products: 3. Lists of Notified Bodies (approved certification bodies and testing laboratories): Should you wish to delve more deeply into the bureaucracy of the EU, you might like to know about NANDO (at the end of the above web address): NANDO = New Approach Notified and Designated Organisations. Words: Copyright article by Robert Matthews in SelfBuild & Design magazine, March, THE CONSTRUCTION PRODUCTS REGULATION 7 MARCH 2013.