A guide into stress-free product compliance

Construction Products without CE marking

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

The Construction Products Regulation (CPR) requires mandatory CE marking for construction products covered by a harmonised standard.
Compliant construction products with CE marking can be placed legally on the market in any Member State.

On July 1st, 2013, the Construction Products Regulation (EU) 305/2011 entered into force.
It requires that all construction products that are covered by Harmonised standards are CE marked. Each CE marked construction product must have a Declaration of Performance (DoP), this requires more information than the previous DoConformity.

The DoP provides decision makers (e.g. building designers and specifiers) with information about relevant performance characteristics of the product. Based on this information they can judge if the construction product will be suitable for the specific end use in local construction works.

Is CE marking possible for construction products that are not covered by a harmonised standard?
Yes. For construction products that are not (fully) covered by a harmonised standard there is an alternative route to CE marking called European Technical Assessment (ETA).

The European Technical Assessment (ETA) offers an alternative way for manufacturers to draw up the Declaration of Performance and affix the CE marking. A Technical Assessment Body (TAB) issues the European Technical Assessment (ETA) document on the basis of a European Assessment Document (EAD). EAD's were previously published as Guidelines for European Technical Approval (ETAG).
These documents are produced and adopted by the European Organisation for Technical Assessment (www.eota.eu).

A list of Technical Assessment Bodies is available via the NANDO database.

How about construction products that are not covered by a harmonised standard or ETA?
For construction products that are not covered by a mandatory harmonised standard and that do also not benefit from a voluntary ETA, there is no possibility to apply CE marking based on the Construction Products Regulation. There is also no possibility or obligation to accompany these products with a DoP.
These products do not benefit from free movement of construction products in the Single EU Market. Instead these products must comply with the national technical rules of each individual member state.

Product Contact Points

The European Commission recognised the complexity of the legislation and therefore it introduced "Product Contact Points for Construction" (PCPC) in Article 10 of the CPR. These contact points shall assist companies in understanding regulatory requirements in their territory. A list of national PCPC's that are established in each EU country can be found here.

Other marks

There are many other certification marks commonly used for construction products. These marks shall not conflict with the advantages of the CPR such as the free movement of CE-marked construction products. However, some of the these quality marks are so well recognised and highly rated that they hold a very strong position in the market.
They may even be seen as barriers-to-trade because buyers demand them and companies may be unable to trade their products without these "voluntary" marks.

Mutual recognition

Although there are continuous steps to strengthen EU legislation on improving the free movement of non- harmonised goods. The reality is still "stubborn".

It is therefore recommended to use the available expertise at the product contact points and technical assessment bodies, especially for new markets and not-harmonised products.


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