The Construction Products Directive
A practical guide to implementation and CE marking
by
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Applying for and using CE marking
Once a manufacturer realises that he is required to, or wishes to, apply CE marking to his products, he must go through the process of applying a European Standard. The different aspects of this process are described elsewhere in this book but, in summary, they include:
a) identifying whether the products come within the Scope of one or more harmonised European Standards and, if so, which one(s) (4.4) or, if they do not, what action is to be taken (4.4 and 4.5);
b) identifying the intended market and end uses and, therefore, which product characteristics need to be assessed (4.6.2.4 and 6.2.1);
c) passing through the evaluation of conformity procedure (Chapter 6), having identified the appropriate attestation of conformity system (Chapter 7) and, if necessary, having approached the required Notified Body(ies) (9.3).
Having successfully gone through this process, the manufacturer will be in a position to start using the CE marking symbol and providing the appropriate accompanying information. Annex ZA (usually ZA.3) states exactly what the manufacturer has to indicate, and what possibilities he has and, therefore, usually the manufacturer need only follow these instructions.
A number of principles and requirements apply to the information given with the CE marking symbol:
a) it shall include the manufacturer's name (not the name of the authorised representative, if one is used). Some standards also require that the registered address of the manufacturer be given but this is not required by the CPD itself;
b) it shall also include the unique identification number of the Certification Body (Product or FPC) for products under attestation Systems 1+, 1 and 2+; the last two digits of the year of affixing the CE marking symbol, which Guidance Paper D[9] states is the date of applying the marking to each individual product so, for many products, it is the same as the date of manufacture but may be later than this if the product is stored; and the number of the Certificate of Conformity under the same attestation systems;
c) it shall include the number of the European product standard; a description of the product (such as its generic name, materials, dimensions and intended end use(s)). But the description cannot give performance information about non-harmonised characteristics and nor can the CE marking be considered as a guarantee that the product has the dimensions stated, unless "dimensions" or "dimensional tolerances" are harmonised characteristics, in which case they would be given elsewhere; and information on the relevant essential characteristics;
d) all the information required for CE marking must appear together in one of the four locations, but a subset of the information may be given in a 'higher' location and Annex ZA will describe where this is possible;
e) all information related to the essential characteristics must be accompanied by the CE marking symbol; it is not permissible to present such information without it being with the symbol. Equally, information not associated with the essential characteristics (such as the performance against non-harmonised characteristics) cannot be presented with the CE marking symbol;
f) part or all of the CE marking information may be given in the form of a designation or symbols, but only if such a designation system or symbols are defined in the standard;
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About the Book
Compliance with the EU's Construction Products Directive is a reality for construction product manufacturers, as harmonised European Standards and European Technical Approval Guidelines come into full effect.
Purchasers, specifiers and regulatory authorities expect to see products bearing the CE marking symbol and, in most European countries, marking is already compulsory.
Many manufacturers are unclear about their obligations as regards this directive and need to be confident that they are receiving correct and unbiased advice about whether they need to obtain CE marking and if so, what they must do.
This book offers a timely and thorough explanation of the directive and its application through harmonised European Standards and European Technical Approvals (ETAs). It leads the reader through the history and background of the CPD, explaining many of the fundamental principles and provisions, and then provides an in-depth explanation of all aspects of complying with the directive through its standards and ETAs, and the process of obtaining and using the CE marking. It goes on to look at other, related issues, such as where a product comes under more than one EU directive, what the manufacturer may expect once he has obtained the CE marking and is trying to sell his product throughout the European Union, and what is likely to happen in terms of market surveillance.
The book presents each subject area logically and thoroughly and in a similar order as manufacturers will encounter them. However, some readers may prefer to concentrate only on those subjects which particularly interest them at any one time.
About the Author
The authors are eminently qualified to write about the CPD. Dr Pinney has spent 15 years working on the directive and its standards, first as head of the Standards Policy Support Section at the Building Research Establishment in the UK, then with the Construction Unit of the European Commission for three years, and most recently as one of three CEN Consultants for construction.
Stephen J. Rein joined the construction industry in 1965 and led teams on a variety of construction and civil engineering projects in both the UK and overseas. He joined the Department of the Environment to head the development of administrative mechanisms for implementing the CPD in the UK and to provide the appropriate technical and practical background knowledge, he also represented the UK on the Standing Committee for Construction. In 2002 he became a CEN Consultant for construction.
Both authors are now collaborating in a consultancy company, APSR Associates, which offers advice and help on all aspects of the CPD and its implementation, and European Standards, through a range of different services. APSR Associates can be contacted through its website, http://www.apsrconsultantsltd.com/.