The Construction Products Regulation (CPR), which came into effect on July 1 last year, introduced the most significant regulatory change for a decade in the way that construction products are manufactured and sold in the EU.

The CPR replaced the Construction Products Directive (CPD) and made CE marking mandatory across the entire EU for products defined by relevant harmonised European Product Standards (hEN).

A CE mark on a product indicates that it has been assessed against the appropriate technical specification and that effective production controls are in place to ensure that the declared performance is maintained. The CPR emphasises that when a manufacturer CE marks a product they are taking responsibility that it conforms to a declared level or class of performance.

The product, or its packaging, may be labelled with the CE mark and all the supporting information required by the standard. However, usually only a summary of the CE marking information appears on the product and the complete information is in the accompanying documentation. Manufacturers have a responsibility to provide this documentation, but importers and distributors also have a responsibility to ensure that it accompanies the product. CE marked products should arrive at the construction site with their full documentation available.

Under the CPR, the CE mark refers to a Declaration of Performance (DoP) that is issued by the manufacturer.

Where a hEN exists, the CPR makes CE marking mandatory in all EU Member States. Most common construction products fall within the scope of a hEN, including almost all wood-based panels, whether or not they are load bearing. The harmonised European standard EN 13986: 2004: Wood-based panels for use in construction has made CE marking of wood-based panels possible since 2005, and as CE marking was mandatory in most Member States before the CPR came into force, it was widely adopted. In due course, a revision to the standard will be published with an updated section on CE marking.

The information required by both the CPR and BS EN 13986 is:

  • The CE symbol;
  • the last two digits of the year that the mark was first affixed;
  • name or logo of the manufacturer allowing unambiguous identification of the manufacturer’s name and address;
  • the identification number of the notified body, if applicable;
  • the number of the harmonised standard;
  • the levels or classes of performance, as required by the standard.

Additional information to accompany the CE mark that is required by the CPR is:

  • the reference number of the Declaration of Performance (as determined by the manufacturer);
  • a unique code for the product type (eg OSB/3 for oriented strand board, class 3 or HB.HLA2 for hardboards – heavy-duty load-bearing boards for use in humid conditions):
  • a statement of the intended use, as laid down in the standard (eg "structural wall sheathing for humid conditions").

The information about the class or performance of the product required by BS EN 13986 can be quite brief, comprising just the nominal thickness and the formaldehyde class. Most other properties are implicit in the product type, for example, OSB 1, 2, 3 or 4, which is given as a Technical Class by BS EN 13986. Declaring the Technical Class is the most convenient way of declaring the properties for the CE mark, particularly since some classes are for structural panels, others for non-structural.

The Technical Classes given by BS EN 13986 for plywood (EN 636-1, EN 636-2 or EN 636-3) are insufficient for declaring all the properties of structural plywood since the classes are not linked to individual sets of mechanical properties. Manufacturers may list the Essential Characteristics in detail instead of the Technical Class, an option that should be of benefit to specifiers.

Wood-based panels can be processed to change their properties – for instance, the panel might be treated with a fire retardant. Before the treated panel is placed on the market, the new manufacturer must obliterate the previous CE mark and apply a new one. The documentation must also be re-issued, and the manufacturer must satisfy themselves that the panel’s performance has not been changed in other ways. Sometimes the new process must be verified by a Notified Body even if they were not involved in the original process.

If the panel is modified in such a way that it can no longer be CE marked, then anyone placing it on the market should not claim compliance.

Under the CPR, the manufacturer makes a Declaration of Performance (DoP) containing the essential characteristics of the product. By affixing the CE mark to the product, the manufacturer declares that they take responsibility for the conformity of the product to the DoP. The manufacturer must affix the CE mark only to those products for which he has prepared a DOP, and this must be readily available, for instance through a website, to any recipient of the product.

While the greatest responsibilities are with the manufacturer, importers and distributors must ensure that the documentation accompanies the product and that the product’s performance is not compromised while it is in their care. If they think a product doesn’t conform to the DoP, they are obliged to take corrective action.

In the wood-based panel market, there is now greater evidence of a collaborative approach and, while there is still a lot to do, manufacturers and specifiers alike are benefiting from being part of a single harmonised market for construction products. There is now a greater onus on manufacturers to take responsibility, which means that end-users can be more confident that the products they specify will perform as expected.