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A guide to conformity marking and voluntary third-party certification

The Construction Products Regulation

The EU construction products regulation, or CPR, is directly applicable in all EU member states and has applied across the United Kingdom since 2011. It seeks to remove technical barriers to the trade in construction products in the European single market. The CPR harmonises the methods of assessment and testing, the means of declaration of performance, and the system of conformity assessment of construction products.

Harmonised Standards

Harmonised European standards provide a technical basis to assess the performance of construction products. They enable manufacturers to draw up the Declaration of Performance (DOP) as defined in the Construction Products Regulation, and affix CE marking.

Non-harmonised Standards

However, although it is the intention of the EU that all construction product standards should be harmonised, some standards, such as EN 124:2015 have not been approved for harmonisation so it is not covered by the CPR and consequentially does not have legal effect. It is illegal to apply CE marking or issue a DOP under the CPR to any "Gully tops and manhole tops for vehicular and pedestrian areas" in accordance with EN124:2015.

For this reason CEN TC 165 (the overseeing CEN technical committee) ‘strongly advises that all characteristics of manhole tops and gully tops in accordance with EN 124:2015 (all parts) are assessed by an independent certification body. Based on that assessment, certificates of conformity with EN 124:2015 (all parts) or quality marks can be granted’.

Third-Party Certification

The most common independent certification body that has a scheme for EN124:2015 in the UK and the Republic of Ireland (and many other territories) is the British Standards Institution whose quality mark is the ‘Kitemark’.

Brexit and Third-Party Certification

Brexit does not affect non-harmonised standards like EN124:2015, third party certification marks like the Kitemark are ‘voluntary’ and there is no legal restriction in the EU or in the UK regarding their use.

Brexit and Conformity Marking

The EU construction products regulation, or CPR, continues to be directly applicable in all the remaining 27 EU member states and nothing changes regarding Declarations of Performance and CE marking.

From 1 Jan 2021 the UK is setting up a parallel system with its own construction products regulation with the use of the UK CA mark instead of the CE mark. Instead of standards being "harmonised" they will be "designated".

There will be three different product marks that manufacturers, and others in the supply chain, may need to apply. The rules governing these marks will depend on where the product is intended to be used. The three marks are:

  • The EU’s marking for product conformity (CE marking)
  • The United Kingdom Conformity Assessed mark (UKCA mark)
  • The United Kingdom Northern Ireland mark (UK(NI) mark), which is additional to the CE marking in some instances.

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