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European CPR Regulation (Construction Products Regulation)

The new Construction Products Regulation 305/2011 (called CPR) effective from 1 July 2013 cancels replaces the previous CPD Council Directive (89/106/EEC).
Each construction product and therefore also the components for walls, the precast retaining walls for horizontal silos and sealed silos, the noise barriers and in general all the products of Edil Leca Srl, needs a “Declaration of performance” (DoP) supplied in paper form or by electronic means, issued by the manufacturer.
Edil Leca Srl informs you that, as a qualified national manufacturer, each product supplied complies with the new regulation 305/2011 (CPR) and therefore the company has already the support of a own DoP document and the related certificates of external notified bodies.

What changes? What are the requirements for companies?

On 1 July 2013 the Construction Products Directive (CPD 89/106), which had introduced the CE Marking for the marketing of construction products, is repealed and replaced by the Construction Products Regulation (CPR 305/2011).
The Construction Products Regulation 305/2011, based on the principles of CPD 89/106, contains some innovation, clarifications, simplifications and requirements for the various economic operators (manufacturers, agents, distributors, importers) working in the Construction Products market.

Involved products and parties

When we talk about construction products we mean any product or kit manufactured and placed on the market to be permanently put into construction works or parts of them and whose performance affects the performance of construction works with respect to the basic requirements of works themselves.

Among the traders involved in regulatory compliance we find:

  • Manufacturers, or any person or entity that manufactures a construction product or that designs or manufactures such a product and places it on the market under its name or trademark.
  • Importers, or any person or entity established by the Union, that places a construction product from a third country on the Union market.
  • Distributors, or any person or entity in the supply chain, different as the manufacturer or importer, that makes a construction product available to the market.
  • Agents, or any person or entity established by the Union that has received a written authority from a Manufacturer authorizing him to act on his behalf in relation to certain tasks.
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The obligations introduced by the CPR Regulation for the different economic traders (manufacturers, agents, importers, distributors) are listed in the articles 11,12,13,14,15 of the Regulation.
Specially from 1 July 2013 Manufacturers will have to accompany the construction products with the DoP Declaration of Performance (articles 4,5,6,7 and Annex III of CPR) and adapt the CE marking label according to the contents of articles 8 and 9 of CPR. The technical documentation and the DoP must be kept by the Manufacturer for 10 years from the placing of the product on the market. The declaration of conformity ceases to exist.
Manufacturers must ensure that the mass production of the products maintain the declared performance through detailed procedures and make sure that the products can be identified easily by affixing a type, batch or serial number.
They shall therefore indicate on the product, on its packaging or the accompanying document their name, the registered trade name (or their trademark) and the address to be contacted.
Manufacturers must ensure that the product is accompanied by information regarding the safety of the product itself, in accordance with what is established by the member state in which they place the product.
Manufacturers must implement the necessary corrective actions if they believe that the product placed on the market does not comply with the DoP or does not meet the requirements of Regulation 305/2011. If a product carries a risk, the responsible bodies of the member state in which the product was placed, must be informed immediately, indicating the details relating to the non-conformity found and the corrective actions taken.

The manufacturer is required to provide, in the event of a reasoned request from a National Authority, all the documentation necessary to demonstrate the compliance of the product with the declared performances and with the requirements of Reg. 305/2011.

From CPD to CPR, the requirements for already CPD certified manufacturers

To support the DoP, the Manufacturer may continue to use the certificate issued before 1 July 2013 by a Notified Body in conformity of CPD up to the date of the first inspection visit scheduled after 1 July 2013. The inspection visits scheduled after 1 July 2013 must be performed exclusively by a notified body in conformity of CPR 305/2011.
Products that have been made available on the market before 1 July according to CPD can be sold by distributors without any modification to the accompanying documentation (label and declaration of conformity) even after 1 July.
A Manufacturer, even if already certified according to CPD 89/106, that places a product on the market after July 1st (art. no. 66) will have to draw up the DoP and will have to adapt the CE marking label according to the contents of art. 8 and 9 of CPR.

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