Introduced to remove technical barriers to trade, the Construction Products Regulations (CPR) aims to ensure the reliability of information on the performance of products using a common technical language and uniform assessment methods. This is achieved through harmonised European standards (hENs) and new simplified European Technical Assessments (ETAs), which are replacing the previous European Technical Approvals and designed to be quicker and more straightforward for the industry.
Under the CPR, since 1 July 2013 a construction product needs to be CE marked and accompanied by a declaration of performance (DoP) if it is to be placed on the market in the European Economic Area and is covered by a hEN or an ETA. The CPR is not intended to harmonise member states’ building regulations; rather, it harmonises the methods of:
- declaration of product performance
- assessment and verification of constancy of performance (AVCP).
Harmonised technical specifications are either hENs established by CEN/CENELEC, or European Assessment Documents (EADs) produced by the European Organisation for Technical Assessment (EOTA) as the basis for issuing ETAs for products not covered by hENs. The specification defines methods of assessing and declaring all the performance characteristics required by regulations in any member state that affect the ability of construction products to meet the basic requirements for construction works.
So, what does this mean for product manufacturers, designers, builders and local building authorities?
Responsibility for ensuring that a product has the correct characteristics for a particular application rests with the designers, contractors and local building authorities. Providing local Building Regulations are met, designers, specifiers and users are free to set their own requirements on the performance of the works and, therefore, construction products. The information contained in the DoP should allow them to make comparisons between products, as the methods of assessment, test and declaration of results will be the same.
Old and new ETAs
How do the old and new ETAs differ? The European Technical Approvals published prior to July 2013 under the CPD were a technical assessment of a product’s fitness for use based on all the relevant characteristics. Under the CPR, a European Technical Assessment is based on an agreement between the manufacturer and the Technical Assessment Body (TAB) for the performance characteristics that the manufacturer chooses to express that might be relevant for the intended use. This sounds like a subtle difference but is a significant change in emphasis.
TABs are designated for defined product areas by the responsible authority in each member state – in the UK this is the Department for Communities and Local Government – and come together under EOTA.
In practice, there will not be appear to be much change on site. ETAs issued under the CPD will remain until the end of their validity period, at which time a manufacturer can have them converted. For an interim period, the established European Technical Guidelines (ETAGs) used to issue ETAs under the CPD are being used as European Assessment Documents, which replace them under the CPR. A programme of conversion of the commonly-used ETAGs is underway to a timetable agreed with the European Commission.
Finally, is there still a place for voluntary third-party product certification, such as BBA Agrément Certificates, when a product is CE marked through an hEN or ETA?
The answer is yes, provided that the additional certification adds value and does not conflict with the CE mark. Typically this added value covers fitness for a particular purpose and includes:
- characteristics and performance outside the scope of the technical specification, such as durability, installation and maintenance
- an assessment of the test characteristics and performance in the context of use for the locality, i.e. the Building Regulations in England, Wales, Scotland and Northern Ireland.
So, CE marking via an ETA provides reliable information on a product in a consistent and reliable format. However, it does not assess the suitability of that product for the specific requirements at the local building regulations level. Third-party approvals such as Agrément Certificates continue to provide that valuable link between the data, the design process, and the various UK Building Regulations requirements.
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