CE Marking

Meeting your obligations

As leaders in sustainable, high quality and trusted timber products, the Timber Trade Federation supports our members to meet the regulatory requirements of trading in timber. One important piece of legislation all timber traders in the UK and the EU need to understand is the EU Construction Products Regulation (CPR).

 

This legislation requires timber and wood-based products to declare their performance characteristics via CE Marking and a Manufacturer’s Declaration of Performance (DoP). These marks break down trade barriers between the EU and UK, and supports the trade of construction products by showing compliance to shared standards.

Important notice: How CPR will change from 1 January 2021 with Brexit

Great Britain is leaving the European Union at the end of a transition period which finishes on 31 December 2020. It has therefore developed its own system to replace CE marking. The technical requirements are the same:

 

  • EU wide common product standards
  • Initial Type Testing
  • Declaration of Performance
  • Development of Factory Production Control (FPC)
  • In-house factory testing
  • Involvement of a 3rd party body to oversee FPC
  • Product marking

 

The three differences are that the CE mark on products will be replaced by a new UK mark, 3rd party bodies to oversee the new UK mark will be called approved bodies rather than notified bodies, and the common product standards used by the UK mark will be called designated standards rather than harmonised standards.

 

Businesses must prepare for the end of recognition of the CE mark in Great Britain and affix the UK marking using a UK-recognised ‘approved body’ on 1 January 2022.

 

Until then, in Great Britain both the UK marking, and the CE marking will be recognised. Manufacturers will either need to either;

 

Option 1: Affix the UK marking using a UK-recognised ‘approved body’, or

Option 2: Affix the CE marking using an EU-recognised ‘notified body’.

 

Where no third-party conformity assessment is required (AVCP system 4) the manufacturer can choose whether to affix the UK marking or the CE marking, provided that the underlying requirements are met.

 

  • Manufacturers who want to supply the UK ONLY, should follow Option 1 before 31 December 2020.
  • Manufacturers already registered with a European based Notified Body will see no immediate change under Option 2.
  • Manufacturers registered with a UK based Notified Body must make a change before 31 December 2020 but can take either Option 1 or Option 2.
  • Manufacturers who want to supply the UK from 1 January 2022 must by this date follow Option 1.

 

More information, including answers to Frequently Asked Questions, can be found on the UK Government website. 

Construction Products Regulation

The CPR is designed to harmonize construction product technical standards across EU member states to ensure that construction products sold within the EU meet certain safety and technical standards.

 

Harmonizing these standards allows trade barriers between the manufacture and sale of construction products between member states to be reduced, enabling greater inter-country trade.

 

The CPR harmonises the methods of assessment and test, the means of declaration of product performance, and the system of conformity assessment of construction products – but does not extend to national building regulations.

 

The TTF is closely monitoring any potential changes to these regulations as a result of Brexit, or via the EU, so please do ensure you are subscribed to our newsletter and check out our trade hub.

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CE Marking

The data and information on CE Marked timber products indicates that the manufacturer takes responsibility for the conformity of that product to its declared performance in the standards.

 

Additionally, because CPR breaks down technical barriers affecting the trade of construction products within the EU, and means that similar products can be compared with each other and freely traded.

 

Once a product is CE Marked, a product cannot be excluded from sale in any EU member state and only one set of data is required.

 

What wood products are covered by CE marking

 

The CPR categorically states that ‘Structural Timber Products/Elements and Ancillaries’ and ‘Wood Based Panels and Elements’ must meet the requirements of the regulation.

 

Structural timber has used the European wide system of Strength Classes since the 1990s with each piece showing the Strength Class such as C16 or C24 for Softwoods and D50 or D75 for Hardwoods. Such marks will now also incorporate the letters CE where they do not do so already.

 

Wood-based panels have been voluntarily declaring their performance characteristics via CE Marking since 2004 so most buyers will be familiar with the terminology and format used.

 

Exemptions from CE Marking

 

If the product and intended use are not included in the scope of a harmonised standard, then there is no obligation to CE mark the product.

 

Wood-based products such as skirting, architraves and other wood trim are not covered by a harmonised standard and therefore do not require CE marking. Wood-based panels specifically designed for furniture are not construction products and therefore are not covered by the CPR.

 

Examples of important wood products which should NOT need CE marking would be general sawn or machined goods (unless they are Structural or Flooring). Equally, treated fencing will not require CE marking but treated structural timber will.

 

Decking should also, on the whole, be exempt but may count as Structural if it is used as a balcony or raised up on columns.

Declaration of Performance (DoP)

CPR recognises it is not always possible or convenient to include all the information required in a physical CE mark so manufacturers are also required to produce a Declaration of Performance (DoP) document for their product.

 

This is the principle document which is required to be made available throughout the supply chain. To reflect the new CPR, section 7 of UK Building Regulations has also been amended to adopt CE marking as the primary route to show fitness for purpose in the UK.

 

As part of the CPR, manufacturers are required to provide a Declaration of Performance (DoP) when placing a construction product on the market which contains technical information to demonstrate the product’s fitness for purpose.

 

Note: CE marking cannot be affixed on a product until a Declaration of Performance has been drawn up.

 

What should a Declaration of Performance (DoP) contain?

 

1. The declaration of performance shall express the performance of construction products in relation to the essential characteristics of those products in accordance with the relevant harmonised technical specifications.

 

2. The declaration of performance shall contain, in particular, the following information:

 

(a) the reference of the product-type for which the declaration of performance has been drawn up;

 

(b) the system or systems of assessment and verification of constancy of performance of the construction product, as set out in Annex V;

 

(c) the reference number and date of issue of the harmonised standard or the European Technical Assessment which has been used for the assessment of each essential characteristic;

 

(d) where applicable, the reference number of the Specific Technical Documentation used and the requirements with which the manufacturer claims the product complies.

 

Specific Technical Documentation – Documentation demonstrating that methods within the applicable system for assessment and verification of constancy of performance have been replaced by other methods, provided that the results obtained by those other methods are equivalent to the results obtained by the test methods of the corresponding harmonised standard;

 

3. The declaration of performance shall in addition contain:

 

(a) the intended use or uses for the construction product, in accordance with the applicable harmonised technical specification;

 

(b) the list of essential characteristics, as determined in the harmonised technical specification for the declared intended use or uses; CE Marking and DoPs: Importer’s and Distributor’s Guide

(c) the performance of at least one of the essential characteristics of the construction product, relevant for the declared intended use or uses;

 

(d) where applicable, the performance of the construction product, by levels or classes, or in a description, if necessary based on a calculation in relation to its essential characteristics…

 

(e) the performance of those essential characteristics of the construction product which are related to the intended use or uses, taking into consideration the provisions in relation to the intended use or uses where the manufacturer intends the product to be made available on the market;

 

(f) for the listed essential characteristics for which no performance is declared, the letters ‘NPD’ (No Performance Determined);

 

(g) when a European Technical Assessment has been issued for that product, the performance, by levels or classes, or in a description, of the construction product in relation to all essential characteristics contained in the corresponding European Technical Assessment.

 

4. The declaration of performance shall be drawn up using the model set out in Annex III.

 

5. The information referred to in Article 31 or, as the case may be, in Article 33 of Regulation (EC) No 1907/2006, shall be provided together with the declaration of performance. [This refers to information regarding the TAB or Technical Assessment Body used in country to issue European Technical Assessments]