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New rules unify building product standards

27 May 2013

From 1 July manufacturers of building products will be obliged to provide more information about their performance.

The Construction Products Regulation (CPR) is intended to harmonise standards across the EU and create a level playing field for cross-border trade.

However, experts are concerned that the regulations, which will be accompanied by mandatory CE marking, will cause confusion among specifiers and raise issues over product performance liabilities.

The CPR replaces the former Construction Products Directive and requires manufacturers and distributors of products to declare the performance of a product across a number of criteria.

They must also affix a CE mark to the product and ensure all relevant information, such as safety guides, instructions and handling and storage information, is readily available.

"For designers and specifiers it's not necessarily very clear what the implications are, particularly when the products are bespoke."

Peter Caplehorn, Scott Brownrigg

The obligations have been written into the Approved Documents of the Building Regulations which were updated earlier in the year.

Peter Caplehorn, technical director of Scott Brownrigg and member of a number of industry technical committees, said: “I think it could be a bit of a nightmare. For designers and specifiers it’s not necessarily very clear what the implications are, particularly when the products are bespoke and designed by the design team.”

Caplehorn cited doors as one area where there was lack of clarity. “In the rest of Europe they don’t specify doors in the way we do, they tend to be all off the production line. We tend to design to a general performance requirement.”

Under these circumstances, he said, it is unclear whether bespoke products would need to be tested to the full range of performance requirements set out in the new regulations, as it may not be feasible to do so for just a small number of components.

“I suspect the RIBA or CIAT will have to produce a guide for members setting out the practicalities of the CPR and the scale of the liability and practical response on a project,” added Caplehorn. “This might be as simple as ensuring the right paperwork is in place – or it might be far more complicated.”

Construction Products Association technical officer Duncan King said the introduction of the CPR was good news for designers because they would ensure that all products would have to “declare their performance” which would provide specifiers with more information. However, though the CPR states that performance should be declared across seven key areas, some of this information would not be available and would be developed in future because the specific regulations, and measurements were not in place.

One example was the area of “sustainable use of natural resources” where there were no baseline method and standards yet for measuring this. “Products have to play catch up, but that’s not unusual,” said King.

Comments

The CPR is no doubt a good thing bringing clarity to declarations, however, it should not get confused with Quality Marks or Certification.
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If you are specifying complete windows and external doorsets, that is, glazed windows, and doorsets with the leaves hung in their frame, in almost all cases, these will need to be CE marked. There will be only a few occasions where CE marking will not be required (e.g. one off bespoke work).
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Essential requirements for a product are defined in an annex of a harmonised standard (as a rule of thumb, you do not need to CE Mark if there is not a relevant harmonsied standard). In terms of joinery products, the big impact is on windows and external doorsets.
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There are levels of attestation that help a designer identify how stringent the requirements are (from 1+ down to 4). For windows and external doorsets, this is set at level 3/4, which is quite light touch.
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For each CE marked product the manufacturer will need to produce a Declaration of Performance (DoP) document that outlines how the product performs in relation to the ‘essential characteristics’ (8 for windows and 11 for doorsets). While all of these characteristics must be listed on the DoP, only three are required to have a value against them as they are either a regulated characteristic in the UK, or the Product Standard requires a threshold level of performance to be met.These characteristics are the thermal transmittance (U-value), a declaration of dangerous substances and the load bearing capacity of safety devices. Where manufacturers have evidence of the other characteristics, they will include them on the DoP. Manufacturers must make the DoP available to you – some will have them on their website, others may send you them by email, post or other means. All values declared will need to be ratified by a "Notified Body" if the manufacturer has more than 9 employees.
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The CE mark must be either on the product itself or on a label attached to the product. If on the product, this could be on the glass (but don’t confuse it with the glazing’s own CE marking), or in the close of a window or on the frame of a doorset. Any windows or doorsets that are purchased (i.e. money exchanging hands) before 1 July do not require the CE mark, but after this – regardless of the project start date – the product must be CE marked.
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Beyond the Label and the DoP, companies need to have a documented Factory Production Control in place. This does not have to be audited by anyone at Level 3/4.
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The new regulations also include other wood products including wood flooring, cladding and panelling. It does not currently include internal or fire-rated doorsets (for internal use).
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If you do have any questions regarding joinery, please do feel free to call the BWF. www.bwf.org.uk

Iain McIlwee, 10 June 2013

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