In this article we will explain how the harmonised technical specifications (hEN and EAD) become the tools to implement the requirements described in the CPR.
According to the CPR, Construction works must adhere to certain health and safety requirements throughout their life cycle, which are defined under seven Basic Requirements of Construction Works (BRCW):
1. Mechanical resistance and stability
2. Safety in case of fire
3. Hygiene, health and the environment
4. Safety and accessibility in use
5. Protection against noise
6. Energy economy and heat retention
7. Sustainable use of natural resources
‘Essential characteristics’ are the properties used for construction products covered by the Regulation when assessing the performance of construction works according to BRCW requirements. Some examples of essential characteristics are flexural strength, fire resistance, water permeability or resistance to impact.
The list of essential characteristics relevant for each product can be found in the relevant harmonised technical specification, and in the particular case of harmonised standards, in their Annexes Z.A. In addition to this list, harmonised technical specifications also include testing, calculation and other means for assessing performance in relation to these essential characteristics.
Experts work both under the CEN and the EOTA management to write the harmonised technical specification in the best way to provide a good assessment of the construction product subject to the described requirements.
The process to develop harmonised standards (hEN) is quite idiosyncratic. Standards are requested by the European Commission, which then sends the CEN Management Center (CCMC) a “standardisation mandate”. This document is developed by the EC itself, usually taking into account the demands of the industry, the construction stakeholders and the market. During the drafting of the mandate, the EC undertake a consultation stage to build informal consensus on the terms of the mandate between all interested parties within the EC, such as other General Directorates (DG), and other possible external parties, such as CEN, the Member States and the industry.
After receiving the mandate, the CCMC sends the project to the concerned Technical Committees (TC). The Committee drafts the document and the answer to the mandate then both documents are revised by a CEN Consultant. After it’s approved, the draft standard is submitted either to CEN enquiry + Formal vote or to Unique Acceptance Procedure UAP.
When the draft standard is approved (according to the CEN rules) it is ready to be formally cited in the Official Journal of the European Union and after that it is the official reference that contains the assessment and valid performance of the essential characteristics linked to the BRCW.
The process can be repeated for every product family but also in cases where the essential requirements have to be amended due to industry or market requirements, improvement or development of new test methods etc…
Usually the harmonised technical specifications are the only documents used for manufacturers, contractors, and designers of architects. The core of these documents are the essential characteristics but we should not forget that they are only the characteristics to evaluate the performance of the construction work in relation to the seven basic requirements.
We will come back to the construction works requirements in our articles, especially to BRCW number 7, Sustainable use of natural resources, because it was introduced in the Construction Products Regulation (in force since 1 July 2013) and for the time being the mandates do not cover it, therefore there are no relating essential characteristics.
One of the first questions when dealing with a regulation is to know what products are covered by it. The reply is slightly complicated but interesting: CPR covers construction products in two different ways; for some products the CPR requirements are compulsory and for others they are voluntary. We will explain both these cases in detail.
Applying CPR is compulsory for products included in the scope of a harmonised Product Specification (hEN). Manufacturers, according to the testing and calculations given in the text of the hEN, have to declare the performance of the products in the documents described in the CPR (including the CE marking and the Declaration of Performance). In particular, the declaration has to be made for the essential characteristics described in the Annex ZA of the hEN. Moreover, it is this Annex that is the tool to be used when developing the documents required by the CPR.
The standards developed by the Technical Committees of CEN become hEN when their titles are published in the Official Journal of the European Union (OJEU). The format in the OJEU is a table including the number of the hEN, the title and the dates for the co-existence period. Applying the regulation is compulsory from the end of the co-existence period and voluntary between the beginning and the end of it. The last update of the list published can be found through this link.
For the products not included in the scope of the hEN, the regulation offers an alternative through European Technical Assessments (ETA), known as Technical Approvals. In this case manufacturers can voluntarily request an assessment of the product from a Technical Assessment Body (TAB) to provide their clients with the information described in the CPR. Technical Assessment Bodies in this respect are (amongst others) the Approval Bodies known in the European Member States.
The documents containing the assessment methodology are called European Assessment Documents (EAD). TAB, using the EAD, assess the performance of the product and give the manufacturer a ETA which contains the results for the essential characteristics. Manufacturers use the information in the ETA to prepare the documents described in the CPR (including the CE marking and the Declaration of Performance).
The European Commission also publish the list of EADs in the OJEU when they are adopted by the association of TAB called EOTA. There is no co-existence period for EAD or ETA because they are issued under request from manufacturers for a specific product.
Products not included in the scope of a hEN and not assessed using a ETA cannot be CE marked according to the CPR. The most common products in this situation are innovative products for which the standards and assessment have not been developed but every year the list of products covered either in the compulsory or voluntary way grows.