The introduction of the Construction Products Regulation (CPR) marks a big shift in how we do business in the construction industry. The changes for manufacturers will be the most drastic because CE marking is basically a regulation of their work. From 1st July they must now apply the CE mark and produce a Declaration of Performance (DoP) for each of their products. This is a document that supplies the customer with key information about product performance. The manufacturer bears all responsibility for making sure their goods are compliant with the changes and that the corresponding DoP is accurate. The initial shift will undoubtedly be difficult. Consistent performance from 1st July and beyond will also be a challenge. And, of course, manufacturers also have the responsibility of ensuring all national regulations are also adhered to as well.
Distributors and importers will also see big changes. While they can expect a little less upheaval than manufacturers, they should still brace themselves for some significant alterations to what’s expected of them. First and foremost they will have to check that the products they receive from manufacturers are compliant with the CPR. This will involve checking for a physical CE mark on all goods as well as an accurate DoP for each product. It is worth noting that if a distributor alters a product in any way, they will then be considered as the new manufacturer according to the CPR. A distributor would also become a manufacturer if they decide to place a product for sale under their own trade name rather than the manufacturer’s name. Importers will have to make sure that all safety documentation for products is in the relevant language and that this documentation is passed onto the customer. As well as EU law, national regulations will also have to be adhered to for each country you are planning on trading in. Importers and distributors also have a regulatory role to play. If they spot any infringement of the law they will have to take the product off the market until it’s compliant.
Predictably, builders and architects are affected less by the changes. But they should still take note of how the CPR will affect the industry in general. CE marking only relates to the basic properties of a product. This refers to whether a product is fit for sale in the EU – in other words whether the product is of a high enough standard to be made available to the general public. The new rules don’t have any say in a product’s suitability for any given purpose. The EU also won’t have any authority over whether goods meet minimum requirements for a project in a certain member state. Each country is still entitled to control building regulations. So it’s the member states who define acceptable levels of performance of a product. The CPR merely informs the consumer about the basic standards of goods in a purely technical sense.
Builders and architects should always ensure they understand the manufacturer’s DoP. The information on this document forms the basis of their decision to use a product. The main thing to remember is that CE marking is purely informative. It’s not advisory in any way. As far as minimum performance is concerned, builders and architects will have to refer to things like National Annexes and Standard Recommendations. They will also have to remember that building regulations will still be governed at a national level.
The shift for those who work in the construction industry is a big one. But it is a challenge that we’re all ready for at Stanbrook & Nicholson because we know it will enhance your experience with us. Our relationship with our customers has been key to our success so far. These changes will only serve to enhance the first class service that we already provide.