Construction Products Regulation
Importance of the Construction Products Regulation
The Construction Products Regulation (CPR) is one of the main pieces of European legislation dealing with our product i.e. windows. It lays down the conditions under which a construction product can be placed on the market by putting into place harmonised rules on how the performance of a construction product should be expressed. These are to be defined and based on the essential characteristics of a product. By using the CE mark manufacturers declare compliance with these essential requirements. The CPR has fully replaced the Construction Products Directive in July 2013 and its implementation is therefore still under way. EPPA observes and steers this implementation process where necessary.
Product standard EN 14351-1
A harmonised standard for windows has been established by CEN (Comité Européen de Normalisation) and published as EN 14351-1 A1:2010. It covers windows of all frame materials (wood/aluminium/PVC) and is the standard for the determination of all essential characteristics based on the Basic Work Requirements (BWRs) lined out in the CPD. As these BWRs have changed and were extended through the CPR the standard will be need to be revised in order to accommodate these changes
EPPA‘s mission to advocate for legal certainty:
Windows are currently covered by more than one piece of European legislation. Next to the CPR window manufacturers also need to comply with requirements under REACh, Classification and Labelling of Products Directive CLP, Ecodesign and others. EPPA‘s members believe that all legal requirements relevant to their products should ideally be included in only one piece of legislation in order to decrease the administrative burden and to increase legal certainty.
Below you can find an outline of the BWRs, their meaning for PVC windows and an outlook to how these requirements may develop in the future.
As presribed in the Regulation the European Commission has to formulate an implementation report next year. In order to do so it has contracted with a consultancy that is gathering data on how well the CPR is working in the European Member States. It does so on the basis of a questionnaire that was sent to companies, organizations and national notified bodies. EPPA’s members have prepared their replies to this questionnaire which can be found here.
BWR 1 - Mechanical Resistance and Stability
No requirements for Windows
BWR2 - Safety in case of fire
This BWR is already covered by current hEN. While there haven’t been made any changes to this requirement through the CPR there still is a need to work on clarification of testing method for windows. These are currently not sufficiently described in the standard.
BWR3 - Hygiene, Health & Environment
The CPR has made changes to this requirement which need to be incorporated into the product standard. This work can be started once the relevant amendment to the mandate for this BWR has been published by the European Commission.
BWR4 - Safety and Accesibility in Use
The CPR has added new elements to this BWR which still need to be transposed into the harmonised product standard for windows. This work can be started once the European Commission has published the amendmend to the mandate for this BWR.
BWR5 - Protection against Noise
This BWR is covered by current harmonised product standard. No changes have been made to it with the adoption of the CPR.
BWR6 - Energy, Economy and Heat retention
This BWR has been amended through the adopoption of the CPR. The harmonised product standard can be adapted once the European Commission has published an amendmend to mandate for this BWR.
BWR7 - Sustainable use of Natural Resources
This BWR has only come into existence with the adoption of the CPR. The exact content of this BWR remains to be defined. The European Commission has indicated that first results will not be available before the end of 2015.