Q&A about CPR

Most common question about CPR. The Construction Product Regulation becomes a legal requirement for cables from the 1st July 2017

Q&A about CPR 2018-08-24T13:49:45+00:00

Tratos wants to help you better understand CPR and fill in any grey areas about the regulation, so we have designed a series of Frequently Asked Questions. See the FAQs below:

What is the Construction Products Regulation?

Regulation (EU) No 305/2011 lays down the conditions for the placing or making available on the market of construction products by establishing harmonised rules for declaring their performance in relation to their essential characteristics and for CE marking those products.

What happens after the 1st July 2017?

After this date all products manufactured, or placed on the market, will have to have a European Classification under the new standard (EN 50575:2014) Cables which don’t, cannot be legally sold in the European market. More Cables manufactured before this date and already held in stock, can however still be sold and used.

Which cables are affected by CPR?

All electric cables used for the supply of electricity and for control and communication purposes, which are intended to be used permanently in construction and civil engineering projects, subject to performance requirements for reaction to fire.

What should contractors and installers do?

Contractors and installers must always:

  • Only purchase and install cable that has been Classified under the CPR, and has been marked accordingly. (carries the CE Marking according to CPR; Strictly speaking this is not true, the cable does NOT have to be CE marked, only the packaging and labelling)
  • ensure the relevant DoP is available and has been checked.
  • You must use an appropriate class of performance according to the installation

Tratos recommends that you only use cables with classifications equal to or higher than class Cca

What is the difference between reaction to fire and resistance to fire cable?

  • Reaction to fire describes a cable’s behaviour during a fire, as well as its potential contribution to the development of fire.
  • Resistance to fire, describes a cable’s ability to continue operating as normal during a fire. (circuit integrity)

What are the changes with CPR?

The new Standard EN 50575:2014 mandates that the reaction to fire performance of cables should be assessed using 3 main criteria:

  • heat release,
  • flame spread,
  • flame propagation,

and 3 additional, optional, criteria:

  • smoke production,
  • flaming droplets,

n.b. these are also known as the “essential requirements”

The new requirements under the CPR mean that a cable’s level of performance in terms of reaction to fire must be defined using a common European Classification (Euro Classes) system.

What are ‘construction works’?

Construction works are the buildings and other civil engineering works that are subject to regulation regarding safety in the event of a fire, including limiting the generation and spread of fire and smoke.

What are the additional classification methods?

There are three further classification methods (Criteria) relating to:

  • the amount of smoke produced when a cable burns,
  • the level of acidity of the smoke,
  • flaming droplets.

Cables in Euro Class B1ca – B2ca and Cca will deliver the best results regarding the release of smoke, acidity and flaming droplets.

What does ‘placing on the market’ mean?

`Placing on the market’ means the first making available of a construction product on the European market. Typically this is typically done by the manufacturer or importer.

What does ‘making available on the market’ mean?

‘making available on the market’ means any supply of a construction product for distribution or use on the Union market in the course of a commercial activity, whether in return for payment or free of charge;

What is a Declaration of Performance?

The Declaration of Performance (DoP) is a key part of the Construction Products Regulation. It provides information on the performance of a product. A DoP requires the manufacturer, importer or distributor to assume legal responsibility for the conformity of the construction product with its declared performance.

What should a DoP include?

In a standard format a DoP must include:

  • A unique ID for the specific product’s intended uses
  • Manufacturer’s information
  • The AVCP (Assessment and Verification of Constancy of Performance) system applied
  • A dated reference of the harmonised standard
  • The Notified Body used
  • The Declared Performance (or NPD if no performance is declared)

The DoP must be published on the website for 10 years after the product was last sold.

What is a Notified Body?

A Notified Body is an independent, third-party body recognised by the European Union. CPR includes three types of notified bodies: product certification body, factory production control certification body and a testing laboratory.

What is the CE Mark?

The CE marking allows a product to be placed legally on the market in any member state. It indicates that a product is consistent with the manufacturer’s DoP. It confirms that the manufacturer takes responsibility for product conformity with performance covered by the DoP but it is not a quality mark. Only DoP-declared performance can be used in technical or commercial documentation.

When does the Construction Products Regulation start?

The critical date is the 1st July 2017

Who has responsibilities under CPR?

Under CPR there is a legal obligation placed upon cable manufacturers, distributors and importers at the point that these products are placed on the market. However, the CPR is important to everyone and has implications for the whole of the supply chain as well as the end customer or user.

What happens after the 1st July 2017?

Relevant information about a product’s reaction to fire classification must be printed on the cable packaging, which must also reference the Declaration of Performance. This information is based on the test results from a Notified Body such as BASEC.

A CE mark affixed based on a self-declaration is not sufficient evidence of compliance.

Who has responsibilities under CPR?

The Construction Product Regulation (CPR) places more emphasis on the whole of the supply chain and imposes legal obligations on manufacturers, importers and distributors and on those companies in the supply chain which either place a product on the market under their own name, or trademark or modify a construction product already placed on the market so as to change its essential characteristics.

“Economic operator” means the manufacturer, importer, distributor or authorised representative;
“Manufacturer” means any natural or legal person who manufactures a construction product or who has such a product designed or manufactured, and markets that product under his name or trademark;
“Distributor” means any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a construction product available on the market;
“Importer” means any natural or legal person established within the Union, who places a construction product from a third country on the Union market;
“Authorised representative” means any natural or legal person established within the Union who has received a written mandate from a manufacturer to act on his behalf in relation to specified tasks; However, the CPR is also important to the specifier, end customer or user.

What should manufacturers do?

Manufacturers must get their products tested and classified to ensure the relevant DoP is made available to the purchaser of the cable. The cable product label must carry the CE mark, the class of performance, unique reference number of the DoP, scheme of assessment, and the identity of the Notified Body used.

The CE marking, in accordance with the relevant harmonised standard, EN 50575, must be on the product packaging or labels.

It should be noted that the `manufacturer’ is the person who places the product on the market in the EU. This may be the actual manufacturer, or an importer. read more:

read more:

‘manufacturer’ means any natural or legal person who manufactures a construction product or who has such a product designed or manufactured, and markets that product under his name or trademark;

What should distributors and wholesalers do?

The cable you buy and sell for permanent installation in a building or construction works must be CPR compliant and where there is doubt it should be withdrawn or recalled. Cable sold must carry the CE Marking according to CPR (Again it is the packaging and labelling which must carry the CE mark, not the actual cable marking) and you should ensure the relevant DoP is available and has been checked. Suspicious cable should be brought to the attention of the National Authority, which in the UK is the Department for Communities and Local Government.

Storage and transportation of the relevant cable must not risk or compromise a cable’s conformity with DoP and when supplying an own brand product, distributors and wholesalers are subject to the same legal obligations as the manufacturer. When importing from a non-EU country, you have the same responsibilities as a manufacturer and become the person first placing the product on the market.

What should contractors and installers do?

Contractors and installers must always install cable that carries the CE Marking according to CPR (Again it is the packaging and labelling which must carry the CE mark, not the actual cable marking) and ensure the relevant DoP is available and has been checked. You must use an appropriate class of performance according to the installation – An absolute minimum of class Eca is recommended – class Fca should be avoided – and wherever possible, certainly where fire safety requirements are high or very high, it’s recommended to use cable described as low fire hazard or equivalent (LSHF, LSOH, OHLS, LSNH), with classifications higher than class Cca. Check whether low fire hazard cables above class Eca include the additional classifications for smoke emission, acidity, and where appropriate, flaming droplets and if in doubt contact the manufacturer.

What should specifiers and designers do?

Specify cable that carries the CE Marking, according to CPR (Again it is the packaging and labelling which must carry the CE mark, not the actual cable marking) and ensure the relevant DoP is available and has been checked. In accordance with good Fire Safety Engineering practice you should specify an appropriate class of performance according to the installation – An absolute minimum of class Eca is recommended – class Fca should be avoided – and wherever possible, certainly where fire safety requirements are high or very high, it’s recommended to use cable described as low fire hazard or equivalent (LSHF, LSOH, OHLS, LSNH), with classifications higher than class Cca. Check whether low fire hazard cables above class Eca include the additional classifications for smoke emission, acidity, and where appropriate, flaming droplets and if in doubt contact the manufacturer.

Who is responsible for mandating which classification of performance must be achieved?

The EU has not instructed which classification of performance should be used in a particular application or type of building. This is the responsibility of the Regulator in each Member State – or building specifier, electrical contractor/installer or end user, providing it is a higher classification than the Regulator defines.

Who is responsible in the UK?

In the UK the Regulator is the Department for Communities and Local Government. There are, however, no official requirements so it will be down to the designer or specifier to detail which class of performance must be used, preferably using good Fire Safety Engineering principles.

Are some public-sector buildings likely to require a more stringent class of cable than others?

Public-sector buildings for different uses and occupations already have different Reaction to Fire requirements, in principle nothing will change. Local Authorities, Consultants and Insurers can specify a higher Classification than the legal minimum based upon a Fire Safety Engineering study.

How prescriptive is CPR?

CPR specifies, in terms of a common technical language:

  • the way a product is placed on the market
  • the methods of assessment and testing for fire performance requirements
  • how the fire performance of a product should be declared and the conformance system of assessment for construction products.

CPR does not say how or where a product should be used, this is left to the Regulator in the individual Country.

Can you explain the Euro Classes to me?

There are now seven Euro Classes determining the reaction to fire performance of cable: Aca, B1ca, B2ca, Cca, Dca, Eca and Fca – Aca being the highest performance (effectively non-flammable, for example bare Mineral Insulated Copper Cable) and Fca the lowest (easily flammable, for example cables having no measurable resistance to the spread of flames). Using three main criteria.

What are the additional classification methods?

There are three further classification methods (Criteria) relating to:

  • the amount of smoke produced when a cable burns,
  • the level of acidity of the smoke,
  • flaming droplets.

Cables in Euro Class B1ca – B2ca and Cca will deliver the best results regarding the release of smoke, acidity and flaming droplets.

How can cable still be installed if it was bought before the 1st July deadline?

Cable that has been legally placed on the market prior to 1st July 2017 and is in the stock of a distributor does not need to be CPR compliant. However, where importing cable from outside the EU, and it is held in stock, the distributor/wholesaler should ensure that it has a verified date as to when it was legally placed on the market.

How does CPR affect cable imported from outside the EU?

Yes – The CPR applies as soon as a cable is placed on the market in the EU.

Where else can I get guidance?

National Standards such as BS 7671 will also give guidance. However, Current Standards, Quality Marks and National Regulations  relating to reaction to fire for Construction Products will no longer apply at the end of the transition period on 30th June 2017.

I am not sure here as we say National Regulations will no longer apply but earlier we said they can be referred to – I think Peter needs to check all these again – see above this says “… and national Regulations relating to reaction to fire …” release of dangerous substances in normal operation is not a reaction to fire.

How can I specify a higher specification than the classification of performance listed?

If it is felt a higher classification is more appropriate for an application there is nothing to stop it being specified as such. The use of Fire Safety Engineering is recommended.

The rules of Member States require that construction works be designed and executed so as not to endanger the safety of persons, domestic animals or property nor damage the environment.

‘construction product’

means any product or kit which is produced and placed on the market for incorporation in a permanent manner in construction works or parts thereof and the performance of which has an effect on the performance of the construction works with respect to the basic requirements for construction works;


‘construction works’

means buildings and civil engineering works;


‘essential characteristics’

means those characteristics of the construction product which relate to the basic requirements for construction works;


‘performance of a construction product’

means the performance related to the relevant essential characteristics, expressed by level or class, or in a description;


‘level’

means the result of the assessment of the performance of a construction product in relation to its essential characteristics, expressed as a numerical value;


‘class’

means a range of levels, delimited by a minimum and a maximum value, of performance of a construction product;


‘threshold level’

means a minimum or maximum performance level of an essential characteristic of a construction product;


‘product-type’

means the set of representative performance levels or classes of a construction product, in relation to its essential characteristics, produced using a given combination of raw materials or other elements in a specific production process;


‘harmonised technical specifications’

means harmonised standards and European Assessment Documents;


‘harmonised standard’

means a standard adopted by one of the European standardisation bodies listed in Annex I to Directive 98/34/EC, on the basis of a request issued by the Commission, in accordance with Article 6 of that Directive;


‘European Assessment Document’

means a document adopted by the organisation of TABs for the purposes of issuing European Technical Assessments;


‘European Technical Assessment’

means the documented assessment of the performance of a construction product, in relation to its essential characteristics, in accordance with the respective European Assessment Document;


‘intended use’

means the intended use of the construction product as defined in the applicable harmonised technical specification;


‘Specific Technical Documentation’

means documentation demonstrating that methods within the applicable system for assessment and verification of constancy of performance have been replaced by other methods, provided that the results obtained by those other methods are equivalent to the results obtained by the test methods of the corresponding harmonised standard;


‘making available on the market’

means any supply of a construction product for distribution or use on the Union market in the course of a commercial activity, whether in return for payment or free of charge;


‘placing on the market’

means the first making available of a construction product on the Union market;


‘economic operator’

means the manufacturer, importer, distributor or authorised representative;


‘manufacturer’

means any natural or legal person who manufactures a construction product or who has such a product designed or manufactured, and markets that product under his name or trademark;


‘distributor’

means any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a construction product available on the market;


‘importer’

means any natural or legal person established within the Union, who places a construction product from a third country on the Union market;


‘authorised representative’

means any natural or legal person established within the Union who has received a written mandate from a manufacturer to act on his behalf in relation to specified tasks;


‘withdrawal’

means any measure aimed at preventing a construction product in the supply chain from being made available on the market;


‘recall’

means any measure aimed at achieving the return of a construction product that has already been made available to the end-user;


‘accreditation’

has the meaning assigned to it by Regulation (EC) No 765/2008;


‘factory production control’

means the documented, permanent and internal control of production in a factory, in accordance with the relevant harmonised technical specifications;


‘micro-enterprise’

means a micro-enterprise as defined in the Commission Recommendation of 6 May 2003 concerning the definition of micro, small and medium- sized enterprises ( 1 );


‘life cycle’

means the consecutive and interlinked stages of a construction product’s life, from raw material acquisition or generation from natural resources to final disposal.


Supply of the declaration of performance

  1. A copy of the declaration of performance of each product which is made available on the market shall be supplied either in paper form or by electronic means.

However, where a batch of the same product is supplied to a single user, it may be accompanied by a single copy of the declaration of performance either in paper form or by electronic means.

  1. A paper copy of the declaration of performance shall be supplied if the recipient requests it.

If a declaration of performance has not been drawn up by the manufacturer in accordance with Articles 4 and 6, the CE marking shall not be affixed.

By affixing or having affixed the CE marking, manufacturers indicate that they take responsibility for the conformity of the construction product with the declared performance as well as the compliance with all applicable requirements laid down in this Regulation and in other relevant Union harmonisation legislation providing for its affixing.

A Member State shall not prohibit or impede, within its territory or under its responsibility, the making available on the market or the use of construction products bearing the CE marking, when the declared performances correspond to the requirements for such use in that Member State.

A Member State shall ensure that the use of construction products bearing the CE marking shall not be impeded by rules or conditions imposed by public bodies or private bodies acting as a public undertaking, or acting as a public body on the basis of a monopoly position or under a public mandate, when the declared performances correspond to the requirements for such use in that Member State.

Ask to our expert

Peter-Waterworth-tratosPeter Waterworth
Technical & Development Director

Our Technical & Development Director at Tratos Ltd is happy to help you with any kind of questions about Construction Products Regulations. Don’t hesitate to connect with him.

cpr@tratosgroup.com

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