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Introduction to CE marking for construction products and how this relates to national construction regulations Dr. Adam Pinney, CPR expert Adam Pinney Consulting Ltd.
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CPR basic aims To remove technical barriers to trade. To oblige manufacturers to declare product performance. To have one single set of product assessment methods. To have defined verification of performance systems (only one system for any product/declared characteristics/reaction to fire class combination). To have CE marking to ‘guarantee’ declared product performance. Adam Pinney Consulting Ltd.
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Definition of “construction product” ‘construction product’ means: - any product or kit which is produced and placed on the market, - for incorporation in a permanent manner in construction works or parts thereof and - the performance of which has an effect on the performance of the construction works with respect to the basic requirements for construction works. Adam Pinney Consulting Ltd.
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Which products can be CE marked? Suspended ceilings Burglar alarms Ready-mixed concrete Kitchen cupboards HVAC equipment Fuel tanks of 500 litres Yes, a classic ‘kit’ with an hEN No, not subject to BWRs No, no interest from industry, no hEN No, not subject to BWRs (except fire) No, reason ???, but no hENs No, hEN limited to capacity > 1 000 litres Adam Pinney Consulting Ltd.
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Better definition A CE marked construction product: - meets the definition of the CPR, - is placed on the market in an EU/EFTA country, - is covered by a harmonised European Standard or the manufacturers makes a request (accepted) for an ETA. Adam Pinney Consulting Ltd.
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The role of technical specifications CPR Article 4.1: When a construction product is covered by a harmonised standard or conforms to a European Technical Assessment, the manufacturer shall draw up a declaration of performance. CPR Article 8.2: The CE marking shall be affixed to those products for which the manufacturer has drawn up a declaration of performance. Harmonised standards (including all test and assessment methods) are mandatory. Adam Pinney Consulting Ltd.
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Member States Construction Regulations Regulations on construction works 7 Basic Works Requirements (e.g. structural stability and fire) Regulatory provisions on construction products Product characteristics (e.g. crushing strength, reaction to fire, thermal resistance)
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Link between works and products Harmonised technical specifications form the link between works requirements and products: E.g. :works shall be mechanically stable, works shall provide adequate fire safety, works shall use energy efficiently. strength of product, reaction/resistance to fire of product, thermal conductivity of product. Adam Pinney Consulting Ltd.
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First example Product A has a crushing strength value 20.5 N/mm 2. Is it a suitable product? Answer: Yes, where works requirements require ≤ 20.5 N/mm 2 No, where works requirements require > 20.5 N/mm 2 Adam Pinney Consulting Ltd.
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Second example UK Building Regulations require that roofs have U < 0.2 W/m 2 K Adam Pinney Consulting Ltd.
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Calculation of insulation thickness U = 1 / (R si + R pb + R ins + R air + R so ) R si = 0.10 m 2 K/W, R so = 0.04 m 2 K/W, R air = 0.16 M 2 K/W R pb = d pb / λ pb = 0.012 / 0.19 = 0.06 M 2 K/W λ ins = 0.02 W/m K 0.2 = 1 / (0.10 + 0.06 + X ins / 0.02 + 0.16 + 0.04) X ins = 107 mm Adam Pinney Consulting Ltd.
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Third example A manufacturer declares No Performance Determined (NPD) against the characteristic “Reaction to fire”. Can this product be used in Germany? No, German regulations require that all products used within buildings have to be at least Reaction to fire Class E. Adam Pinney Consulting Ltd.
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The nature of European Standards Most standards are ‘complete’ standards, i.e. they contain some harmonised characteristics (linked to regulatory requirements) and some ‘voluntary’ characteristics linked to ‘quality’. Some hENs, e.g. cement and fire alarms, have only harmonised characteristics. One hEN, shower trays, has only one harmonised characteristic. Most hENs have a combination. No obligation to comply with voluntary characteristics for CE marking. Adam Pinney Consulting Ltd.
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Annex ZA All hENs contain an Annex ZA. Annex ZA establishes rules and requirements for CE marking. Manufacturers must comply fully with Annex ZA (but the annex provides a few choices). By 1 st July 2013, not all hENs were adapted to the CPR; manufacturers must therefore draw up DOP on the basis of the CPR itself and other guidance. Adam Pinney Consulting Ltd.
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Annex ZA – how it works Indicates which products are subject to CE marking. Indicates ‘harmonised’ characteristics, referring to appropriate clauses (Table ZA.1). NOTE: Not all characteristics in the standard are required for CE marking. Offers the ‘NPD’ option. Question for manufacturers: which characteristics to declare? Adam Pinney Consulting Ltd.
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Example Table ZA.1 Adam Pinney Consulting Ltd.
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Decision on characteristics The more characteristics declared, the greater the range of uses, but manufacturers can’t normally change levels of performance. Some characteristics do not apply to certain products (pentachlorophenol is for composite panels only). Some characteristics are excluded by end use (flexural tensile strength applies only for products used in suspended ceilings). Some characteristics depend on testing in end use (resistance to fire, sound insulation) and testing is expensive! National Contact Points under the CPR are supposed to advise.
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Conclusions CE marking permits products to be placed on the market, it does NOT guarantee that anyone will buy them! The CPR and its hENs provide some choices for manufacturers, and manufacturers seeking to export to the EU must know their markets. What are the implications of the CPR for Azerbaijan? Adam Pinney Consulting Ltd.
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