It obvious to most people that a CE-marked construction product has been somehow assessed according to Construction Product Regulation 305/2011 (CPR). And that is right – but what does this actually mean?
First, let’s make clear what it does NOT mean:
- the product is safe
- the product has fulfilled a list of requirements
- the product has been manufactured in EU
- the product is suitable for its intended use
If you feel puzzled, do not worry. A lot of confusing information circulates around. The main reason probably is that the rules for CE marking of construction products are different from most other product areas. This is because we take the conformity-based approach for assessment of most products (toys, machines, electrical devices, medical devices…). There the CE-marking really means conformity with requirements of a harmonized standard (mostly). But, in the area of construction products, we take the performance-based approach. The main reasons are the following:
- construction products are de facto semi-products used to produce the final product – a building
- different EU countries have different climates and other conditions
- different EU countries have different building traditions and ideas of safety level
Based on the performance-based approach, the message carried by a CE-marking on a construction product is:
“The product has been assessed according to a harmonised technical specification and some performance is declared – see below.”
In other words, the CE-symbol itself does not say much here. But it always has to be accompanied by declared performance (and other information). That is the main difference to many other product areas where a CE-marking is self-sufficient and signals conformity to European requirements – see this article.
The content of the CE-mark is clearly defined by the CPR:
- the two last digits of the year in which it was first affixed
- the name and the registered address of the manufacturer, or the identifying mark allowing identification of the name and address of the manufacturer easily and without any ambiguity
- the unique identification code of the product-type
- the reference number of the declaration of performance
- the level or class of the performance declared
- the reference to the harmonised technical specification applied
- the identification number of the notified body, if applicable
- the intended use as laid down in the harmonised technical specification applied
Basically, a CE-marking is a condensed version of a Declaration of Performance (DoP) accompanied by the CE-symbol.
Except for the CE symbol as such, the visual arrangement of CE marking is not strictly defined. There are several ways to organize the mandatory elements provided that the information is correct and legible. If other information is given on the product label, it must be clearly separated from the CE marking.
Sometimes, it is not possible or not warranted to affix the CE marking visibly to the product. In this case, it shall be affixed to the packaging or to the accompanying documents. Physical labelling is not possible for example on product which are normally not packed (e.g. aggregates) or kits where the components are not delivered together in a package.
CE marking is a mandatory mark used on construction product labels where the product falls under CPR. It must contain all mandatory information; the use of the CE symbol alone is not allowed for construction products.