Regulations for Construction Products
The original EU Construction Products Regulation (EU-CPR) set down greater legal responsibilities for manufacturers, importers and suppliers and made it mandatory for wood-based panels to be CE marked. The UK-CPR has adopted similar principles and will continue to recognise the CE mark until January 2023, when the UKCA comes into force.
Declaration of Performance
Manufacturers now have legal responsibility for the claims about a product’s performance characteristics. They must issue an official Declaration of Performance (DoP), which distributors have to pass on to their customers. The EU has produced a Q&A to help compile a DoP. As this can now be viewed on the manufacturer’s website, the EU have also issued guidance on how to make a DOP available in this way.
The UK’s Construction Products Association have created a separate guide specifically for the UK-CPR. This was compiled in conjunction with British Board of Agrément, British Standards Institution and the Building Research Establishment.
The importer also has more responsibilities, including being required to pass all relevant product information down the supply chain as well as ensuring that the manufacturer has complied with obligations. The importer must also now be identified on the product.
Basic Requirements for Construction Works
Both regulations set down seven Basic Requirements for Construction Works (BRCW) with new rules on sustainability and the impact of a product’s life cycle.
Assessing product conformity
Both regulations set down five components for an official ‘Assessment and Verification of Constancy of Performance’ (AVCP) in line with harmonised or designated standards. There are five overall AVCP categories: 1+, 1, 2+, 3 & 4, for a full list download here.
Manufacturers are not legally required to give the AVCP categories on their panels although many do. Those relevant to APA trademarked panels are:
- CE 2+ or UKCA 2+ (for structural applications) Product marked CE 2+ or UKCA 2+ can also be used for non-structural applications, so long as buyers have checked under which Attestation of Conformity the panel has been assessed.
- CE 4 or UKCA 4 (non-structural applications only).
The AVCP also allocates specific responsibilities for manufacturers and whether an independent certification body, a Notified Body, is required. Separate notified bodies are now needed for the UK and the EU.
Panels without an official Mark of Approval can still be legally used where they are not part of any permanent construction, for example concrete formwork, crating, hoarding and non-permanent buildings.
