Understanding the CPR

In a recent article in Fastener+Fixing Magazine, Barbara Sorgato, Secretary of the European Consortium of Anchor Producers, gives her thoughts on the latest CPR regulations.

“To read the CPR is crucially important, both to understand how to grasp this opportunity towards a free European internal market, and to confute misleading information of the CPR…”

Here is a list of some of the key areas of confusion and her related comments, based on the CPR.

CPR says all construction products must bear the CE marking
No! CE marking is mandatory only for those construction products for which the manufacturer has drawn up a declaration of performance (DoP) [Art. 8.2]

CPR says all construction products must have a DoP
No! A DoP is compulsory in just two cases: when a product is covered by a harmonised standard (a hEN) or when a product conforms to a European Technical Assessment/ Approval (ETA) that has been issued for it. That means: no standard, no DoP and no CE. No ETA, no DoP and no CE. [Art. 4.1]

CPR says ETAs are mandatory
No! As is true today, it is a choice by the manufacturer to apply for an ETA. However, when the ETA on their product is issued, then the CE marking is mandatory. [Art. 19.1]

CPR says ETAs will disappear
European Technical Approvals will be changed into European Technical Assessments. Whilst Approvals expire in 5 years, Assessments will have no expiring date, and will be issued in a new format, where performances are grouped in one table, to be copied and pasted in the DoP. [Art. 19.3 and Art. 26.3 – implementing act of a new ETA]

Existing ETAs will not be valid after 1^st July 2013
No! Existing ETAs are valid until their expiring date. After that, if a manufacturer wishese, they can apply for a “new ETA”. [CPR Art. 66.4]

National Certifications can substitute, coexist or be considered as an alternative to the CE marking in certain EU member states
No! Certifications on product performances as declared in the DoP are not allowed after 1^st July. The CE marking shall be the only marking. Member States shall withdraw national references and shall not prohibit or impede within their territories the circulation of products bearing the CE marking. [Art. 8.3]

Is there a transitional period between the Construction Products Regulation (CPR) and the Construction Products Directive (CPD)?
No! The CPR enters into full force for all European Member States on 1^st July 2013. The original legislation came into force in March 2011 with Specific articles applying from 1^st July 2013 to permit all stakeholders time to conform to the CPR by the time it comes into full effect. [Art. 66 and 68]

All products placed on the market before 1^st July 2013 must have a DoP
No! Construction products placed on the market in accordance with the provisions of the CPD before 1^st July 2013 are deemed to comply with the CPR. [Art. 66.1]

Note: The CPR does not make specific provision for the situation in the UK, where CE marking has previously been voluntary under the CPD. UK enforcement authorities are understood to be advising companies that inventory of products subject to the CPR placed on the UK market prior to 1^st July 2013 (e.g. available for sale from importers or exporters warehouses) need not be withdrawn and can continue to be supplied into the UK market. It is, however, important that UK suppliers recognise they will need to demonstrate conformity to the CPR before attempting to supply any of this inventory to other EU member countries.

Only European manufactured products can be CE marked
No! The European market is open to products coming from the global market, provided that these are CE marked according to the CPR.

Source: http://content.yudu.com/A2649b/FFM81/resources/index.htm?referrerUrl=http%3A%2F%2Fwww.fastenerandfixing.com%2Ffastenerandfixing
%2F%2F81_Digital_files%2Fwidget0_markup.html (Pages 62-64)