Nick Boulton, Timber Trade Federation head of technical and trade policy
The Construction Products Regulation (CPR) is designed to increase free trade and streamline the regulatory framework for construction products across Europe.
Rather than separately negotiate each individual national legislative tangle, companies now have the opportunity to ensure their products comply with the CPR and this will allow them to trade their goods freely in any member state across Europe.
It will also raise the perception of the timber industry as a whole, highlighting the fact we are not merely supplying "raw material" but selling high-performance, low-carbon construction products for a modern construction market. This is a positive step-change for the industry and our customers to note.
Under the CPR, a wide range of wood and wood-based products destined for the construction market in the UK or any EU member state are now required to declare their performance characteristics via CE marking before being placed on the market. To reflect this, Section 7 of the Building Regulations has been amended to adopt CE marking as the primary route to show fitness for purpose.
Ultimately, this is about producer responsibility. Manufacturers must produce a Declaration of Performance (DoP) document for their products to accompany the CE mark. This DoP is the principal piece of information which is required to be made available throughout the supply chain.
Importers and distributors should then ensure they request and receive a copy of the DoP and make this available to customers, along with the visible CE marking.
Importers face extra responsibility if they are bringing in products from outside the EU. They take on the legal liability for the product within the EU borders and must therefore ensure that all paperwork is in place and available for the customer before placing on the market.
Wood-based panels have been using CE marking voluntarily since 2004 so buyers are already aware of the terminology and format used.
Structural timber will now have to incorporate the CE marking along with the European system of strength classes already used, while cladding and flooring will have to declare their performance via the specific formats laid out in the relevant harmonised product standards.
The TTF has produced extensive guidance notes for members which are available free of charge from the website or on request. Our guide shows members what a typical CE mark should look like as well as which main timber-based products are affected.
We have also been running workshops and seminars for TTF members and will continue to provide updates during the year.
CE marking is an important step forward. It allows the timber industry to show it is competing as a leading construction products manufacturer and not to be sidelined as a second class "material".
Lawrence Young, UK Timber Frame Association chairman
CE marking provides a fantastic opportunity for all UKTFA members to establish their products as the go-to building material across Europe. As the CE mark effectively acts as a ‘European passport’, our members’ products can be sold right across the Continent, with their quality and manufacturing consistency guaranteed.
In the past, quality assurance has had its limitations, with the current BS 5750 and ISO 9001 standards proving insufficient in an increasingly competitive market. ISO 9001 in particular only demonstrates that a manufacturer is producing something consistently, regardless of the performance or quality of its outputs. The new CE marking of structural timber elements will go a long way to improving this system.
The CE mark ensures that any building products sold have met minimum safety and performance levels, as laid out in the harmonised European standards or a product’s European Technical Approval. This certifies that they have been manufactured to an agreed level of performance, as laid out by the EU and the European Economic Area.
Harmonising regulations like this creates a level playing field by creating a common standard for the safe, traceable manufacture of all timber-based construction products.
As of this summer, all members of the supply chain, which includes trusses, woodbased boards, joists and fasteners, will be required to adhere to the new regulations. There is also soon to be a European standard relating to the product performance declaration and resultant CE marking for timber frame wall panels, floor cassettes and prefabricated roof panels.
The UKTFA technical teams and members have been at the heart of the preparations for the codes that underpin the legislation. To assist members in the transition, the UKTFA is partnering with TRADA to launch an auditable UKAS-accredited scheme, which will be based on the future CE-marking regulations. This has resulted in the publication of a set of advice notes, which are available on our website (www.uktfa.com).
To achieve a CE mark, timber construction products will typically have an audited factory production control (FPC) system. The FPC demonstrates that the manufacturing is done in such a way that it can be repeated, and that the method can be recorded and confirmed. Once approved by a Notified Body organisation, it will lead to a Declaration of Performance certificate, resulting in the manufacturer being able to apply a CE mark.
Regardless of whether a product has been manufactured in Europe, it will have to comply with the same consistent standards before it can be CE marked and placed on the European market. The UKTFA board has therefore taken the decision to make CE marking a minimum requirement of membership, guaranteeing UKTFA members’ products are fit for market.
Although these new standards will help to ensure consistency, it is important for UKTFA companies to remember that this will not block innovation. In fact, the regulation should put our members in a better position, as it will encourage them to review their business operations. A full-scale audit and review of manufacturing procedures could result in increased efficiency and reduced errors during manufacturing.
The new CE-marking certifications, alongside our second edition Design Guidance to Separating Distances during Construction and the latest health and safety training, ensure that UKTFA members’ products and services are of the highest standard. This ensures that the UKTFA logo is a tangible reassurance to both customers and the construction industry as a whole.
Kevin Underwood, British Woodworking Federation technical director
The Construction Products Regulation is one giant leap for industry, but realistically one small step for company-kind. Nonetheless, it has certainly been keeping us busy with unprecedented calls to the BWF’s technical helpline.
Within the Regulation is the extension of CE marking to some joinery products. The idea behind CE marking is simple – a framework to allow customers to compare products. It is not a mark of quality, but a legal obligation. The robustness and quality or otherwise of this information is not determined. The client, through the accompanying documentation, must assess this for themselves.
It is different from certification in so far as there are little or no company assessment or audit requirements (unless at the highest attestation level, which impacts few timber products). It doesn’t make products better, it simply makes information more available, which should be helpful and may help to improve the credibility and reliability of the European construction products market as a whole.
If your product is covered by a harmonised European standard and you are not yet compliant, get on to it straight away. If you don’t know, check – the BWF has a list available on its website. CE marking will be policed in the UK by the Trading Standards Institute and non-compliance can result in hefty fines and even custodial sentences.
While you may recoil at the thought of further regulation and paperwork, it should not be too big a burden. You need a factory production control system (FPC) in place, a Declaration of Performance (DoP) for your products, and labels to go on or accompany your products.
An FPC is a formalised series of procedures that, together, ensure the consistency of quality and performance of products made in a workshop or factory. It is the method used to demonstrate that the products made available for sale on an ongoing basis consistently perform to the levels stated in the manufacturer’s DoP.
DoPs will be required for each product range, outlining how the product performs in relation to the ‘essential characteristics’. These essential characteristics are listed in the harmonised standard. But there is no obligation to declare anything significant that you don’t already for Building Control purposes. For example, in the case of windows, it is only for U-values or load-bearing capacity of safety devices where a value is actually required. We are issuing templates to our members, so it’s just a case of filling in your product-specific information.
CE marking is now a fact of life. We are even seeing in some sectors the concept being embraced and, where a harmonised standard is not available to CE mark against, companies are using a European Technical Assessment (ETA).
CE marking also gives you an opportunity to shout about your products’ performance. You’ve gone to all the effort of pulling this stuff together, so make sure you’re highlighting the benefits of your product in your marketing. It also gives you a chance to compare your products with others. With manufacturers on the Continent having been CE marking for years, it’s crucial that UK businesses don’t miss their cue and are able to meet their obligations and remain competitive.
Products such as windows and external doorsets, trussed rafters and flooring were just part of the first tranche of wood products that are now subject to CE marking. The next wave likely to come into force may include stairs, internal doorsets and fire doors – although there is much to unpick before we get there.
For more guidance visit www.bwf.org.uk/toolkit/ce-marking
Metsä wood creates DoP Online library
Metsä Wood has created an online database (www.metsawood.com/dop) to host Declaration of Performance (DoP) certificates for the products it manufactures and supplies that are covered by new CE marking legislation.
The database was created to make it easier for customers to comply with the Construction Products Regulation (CPR).
Metsä Wood has a programme of communications to keep customers informed of CE marking developments. Customers must register in order to access the online library.
The new facility will be complemented by notifications placed on invoices and delivery notes to flag up which products are covered by the regulation.
"With compliance to the CPR being mandatory for certain timber products manufactured after July 1, 2013, there are clear obligations throughout the supply chain for compliance," said Samantha Bamforth, Metsä Wood’s new product development project manager. "One of these obligations is for each operator in the supply chain to make available the relevant product DoP to its customers.
"Metsä Wood has invested in building a customer-focused, multi-lingual website making all Metsä Wood product DoPs available in a single destination."
Metsä Wood also details which products are CPR relevant on customer order documents. CPR governed products are flagged ‘CE marked’ along with the corresponding technical specification. "Customers will then be able to use this information to help identify which products are CPR relevant when logging in to the online library," said Ms Bamforth. "They will be able to find the current product DoP by product SAP code or unique DoP reference.
"We want to help make compliance to the CPR as trouble-free as possible for our customers and will ensure information is always kept up-to-date. It is a complicated subject and there has been some confusion within the sector – but this one-stop library provides an ideal resource for our customers to access all the relevant compliance information
