The Construction Products Regulation 305/2011 has been fully applicable since July 1, 2013. At that time, the Regulation replaced the previous Building Products Directive.
In Sweden, the biggest change was that the CE marking of construction products became mandatory. The Construction Products Regulation is also often called CPR.
The CE marking has been made a legal requirement by the EU, and the requirement applies to all Member States as well as non-members such as Norway. The fact that a construction product is CE marked does not in itself mean that it complies with national building regulations, but it must be CE marked and performance certified to be put on the market, regardless of whether or not the product does comply with the national standards; it is a direct offence to sell or use non CE marked products. Consequences for such an offence may include demands for the product to be replaced, or that the product is banned completely.
There remains some confusion within the industry despite clear rules on CE marking about who is actually responsible for the CE certification of the product.You, as a downstream user, can place a very simple but mandatory requirement on your supplier without much in-depth knowledge on the subject: You must always demand to take part of the product Declaration of Performance (DoP). Without a DoP, the product is prohibited from being marketed and used.
The Construction Products Regulation places mandatory requirements for downstream users to implement the DoP. This requirement extends to the manufacturing site in the form of a mandatory CE marking requirement for construction products covered by harmonized product standards, e.g. the EN14915: 2013 (solid wood) and EN 13986: 2004 (wood-based panels).
The operators within the chain are
- Downstream users include the contractor who uses the product for construction work (for which executive positions such as the purchasing department are also included). This definition further comprises wholesalers, e.g. the construction retail chain, who are not allowed to sell the product to customers if the product has not been subjected to a DoP.
- Importers are for example downstream users, such as retail companies or wholesalers, who import goods from another country. It is up to the individual operator to provide all necessary information to the end user, as importers are treated as manufacturers with the same responsibilities that that position entails regarding areas such as production control.
- Manufacturers are by definition the operators that place the product on the market. For fire-impregnated wood products, the manufacturer is covered by contractual requirements on for example production control, quality systems, factory inspections, type testing, and manufacturing processes. The requirements fall under the ZA Annex, AVCP system 1 and are mandatory legal requirements throughout the EU for operators such as manufacturers of fire-impregnated wood products.