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CPR & CE Marking

What is CE marking?

CE marking is the use of the CE symbol with supporting information which legally confirms the product conforms to the requirements of a harmonised European Standard (hEN), which includes all the designated procedures that a manufacturer has to apply from production through to supply. These include initially checking the product meets all the applicable performance requirements stated in the hEN and thereafter is monitored through routine testing to confirm continued performance and conformity thereby providing increased confidence to the purchaser and user of the product. It is important to note that the CE mark is not a quality mark and uniquely confirms conformity of the product with the essential characteristics stated in the Declaration of Performance applicable to the product.

The principles of CE marking

  1.  The Construction Products Regulation (CPR) is fully implemented from 1st July 2013 across the 27 European Member states. As a result, all construction products manufactured and supplied in conformity with a harmonised European Standard (hEN) have to be CE marked to enable them to be legally placed on the market. (Note the abbreviation ‘hEN’ is used for brevity and does not appear on European Standards).
  2.  A voluntary method of CE marking through the use a European Technical Assessment (ETA) is available for those products which are not covered by or do not comply with a hEN. This is principally intended to be a stop-gap situation until an appropriate applicable hEN is drafted and published. Construction products can only be CE marked if they are supplied in conformity with a hEN or an ETA.
  3. Some construction products are within the scope of European Standards which have not been harmonised and therefore they cannot be CE marked. Examples of this include ready mixed concrete and unbound granular mixtures e.g. Type 1 sub-base. There are also some custom-made (“bespoke”) products which are covered by derogations in the CPR and are therefore excluded from CE marking e.g. some Dimension Stone units.
  4. All other construction products not covered under a, b and c above can continue to be legally supplied from 1st July 2013. However, the long-term aim of the European Commission is to encourage manufacturers to produce and supply as many construction products as possible in conformity with a hEN.
  5. To be able to CE mark a product identified in a) or b) above, the manufacturer has to produce signed Declarations of Performance (DoP) followed by CE marking information (the CE marking) for all applicable products. The CE marking is clearly identified by the inclusion of the regulatory CE symbol ‘ ’ which is not included on the DoP. The DoPs will generally be made available electronically on the manufacturer’s website whereas the CE marking is required to be affixed to the product, the packaging, a label or supplied with the accompanying documents. Companies may also make the CE marking available on their websites to enable a wider availability of this information.
  6. In order to be able to provide DoPs and CE marking for a product, the manufacturer must be made aware of the end use of that product in order for him to be able to declare conformity with the correct hEN and therefore provide the appropriate CE marking documentation. If the end use of the product is not specified then CE marking may not be possible. For example, a supplier of aggregates may need to know if the aggregates are intended for use in concrete, asphalt or another construction product or application in order to CE mark it appropriately.

The distribution of CE marked construction products

  1. Where CE marked products are supplied by the manufacturer and are subsequently resold by a distributor without being changed in any way, the CE marking made available by the manufacturer is cascaded without change, to the customer by the distributor. However, if the product is changed in any way e.g. by blending with another product thereby changing its performance, and/or if the product is supplied solely under the distributor’s own name or trademark, the distributor then takes on the legal responsibility for CE marking the product.
  2.  Where the product supplied to the distributor is broken down into smaller units or packages without being changed as identified above, the manufacturer’s CE marking must be supplied/made available to the customer with each of the smaller units or packages. Where a loose bulk product is supplied in bags, the CE marking can be placed on the bag or other form of packaging.

Impacts on purchasers and specifiers

Specifiers and purchasers of construction products should be aware of which of the products they choose to use are covered by CE marking. In doing so, they will be able to appropriately source performance data for those products in relation to design and procurement decisions. For Public Sector Procurers there is an obligation to specify CE marked products (including ETAs) where there is a harmonised European Standard available for the product type which they wish to specify. However, there is no compulsion to specify a harmonised CE marked product type for a particular application over and above a non-Harmonised one.