CE marking construction products is crucial to ensure the safety of the spaces in which we live and work. The procedure varies slightly from other CE marking processes: it involves various assessments, drafting a Declaration of Performance, and, in some cases, working with a Notified Body. We caught up with compliance expert René Zaat to learn the ins and outs of CE marking construction products.
Thanks for taking the time, René. To start, can you tell us a bit about your background in compliance?
Sure thing. I studied law in Amsterdam and went on to teach law for one and a half years. Afterwards, I started working at Certification Experts. I have been a part of the team for more than five years now. I focus mainly on industrial product compliance, such as machinery and construction products.
What classifies a product as a construction product?
Construction products are those that are incorporated into construction works. Take, for example, any building, such as a home or an office. The products that are used to build these structures are classified as construction products. This includes materials such as pipes and cement, but also products such as wallpaper and fire detection systems.
What sets CE marking for construction products apart from other compliance procedures?
CE marking construction products involves three key elements: the Construction Products Regulation (CPR), European harmonised standards and the system of attestation. The CPR is the technical and legal framework according to which all construction products must be assessed. It requires manufacturers to take into account essential safety characteristics, such as reaction to fire and impact resistance, which must be tested and verified before products can be placed on the market.
Where CPR is the backbone for CE marking construction products, the harmonised standards indicate how products must comply with this overarching regulation. Take, for example, gypsum boards (also known as drywall). Standard EN 520 outlines the characteristics which must be tested to indicate the performance of gypsum boards. The trajectory for testing is then determined by the ‘systems of attestation’ which are outlined in the CPR.
Systems of attestation determine the criteria for assessing the safety of construction products. There are five groups, or ‘systems’: 1+, 1, 2+, 3, and 4. Products for which safety is the most critical, such as building products, are classified as System 1, and any product classified as system 1+, 1, or 2+ will require a Notified Body for CE marking. Systems 3 and 4 outline requirements for construction products with increasingly lower levels of critical safety.
What is a Declaration of Performance?
The Declaration of Performance (DoP) is perhaps the most important piece of paperwork to accompany a CE marked construction product. It identifies a product’s essential characteristics and indicates the performance of the product according to such characteristics. In the case of gypsum boards, characteristics such as sound insulation, strength, and fireproofing will be indicated in the DoP.
The performance of characteristics mentioned in the DoP are crucial indicators of product quality. Potential buyers can refer to the Declaration of Performance to compare the product to others, so it is beneficial for manufacturers to strive for the highest safety level of their construction products which they can then indicate on the DoP.
How does a Declaration of Performance differ from a Declaration of Conformity?
The Declaration of Conformity (DoC) is an official certificate which declares that a product complies with the applicable legislation. Just like a DoC, the Declaration of Performance indicates relevant standards for construction products. The difference is that a DoP also lists the characteristics which have been tested for safety.
Speaking of harmonised standards, what if a construction product doesn’t have a harmonised standard?
That’s a good question. When there are no applicable harmonised standards for construction products, the manufacturer can get a European Technical Approval (ETA). Getting an ETA involves drawing up your own product standard with the help of a Notified Body.
For example, a past project of mine involved helping a client with CE marking concrete that had been reinforced with glass fibres. Concrete itself has a harmonised standard, but since it was combined with a different material, there was no product standard for it. We guided this client through an ETA procedure. After the necessary tests were carried out and the ETA was issued, they were able to apply the CE mark to their product.
Can manufacturers assess the performance of construction products themselves?
It differs depending on the product. There are different procedures for each system of attestation. System 4 products can be self-certified, System 3 products must be tested in an accredited lab, and systems 2+, 1 and 1+ are subject to a notified body.
What are your tips for manufacturers when CE marking construction products?
Start with identifying the applicable harmonised standards. Standards often provide a certain format for drafting the Declaration of Performance, and sometimes they even list additional requirements that must be met for CE marking. If these are not taken into account, your declaration will be invalid.
The standards also indicate which characteristics are measurable for a product. Sometimes manufacturers are convinced of a characteristic, or level of characteristic, that is not measurable. For example, if you add a fire retardant to a gypsum board, it is possible to classify it as fire class A1, but this is only possible if you undergo a specific testing procedure. Referring to the standard will tell you which procedure you must undergo to list this characteristic on your DoP.
When CE marking any product, the most efficient route to compliance starts with identifying the applicable legislation and standards. The same goes for construction products. Once you know what you can and can not declare, you can refer to the CPR to determine the system of attestation and begin testing.
René Zaat is an industrial compliance expert with more than 5 years of experience CE marking construction products. If you have questions about CE marking construction products, contact us. We are happy to help you identify applicable standards and determine the route to compliance.