The Construction Products Regulation requires that once a construction product is placed on the market it is accompanied by the following documents:
-Declaration of Performance (DoP)
And in some cases:
-Instructions and safety information
This article will explain the first document (DoP) as it was not required by the Construction Products Directive but now it is the core of the legal declaration.
Manufacturers must develop a new document called Declaration of Performance (DoP) for products covered by the CPR. This document shall be based on existing information (initial type testing, tests, certificates…) for products already in the market and on new assessments for new products. The document contains a lot of information, including the performance of the product expressed as the declared values for the essential characteristics described in the hEN or ETA. In particular the document contains the following:
–The reference of the product-type, meaning the code to identify the product in relation to its performance according to the essential characteristics. Every set of performances for each manufacturing process and raw materials must be encoded with a single product-type
–System or systems of assessment and verification of constancy of performance (AVCP system). This defines the activities and processes that the product must go through (e.g. testing, assessments, factory production control…) and who would be in charge of this (manufacturer, notified body or notified laboratory).
–The reference number and date of issue of the hEN or ETA used. These documents contain the list of essential characteristics applicable to the product
–The reference number of the Specific Technical Documentation when manufacturers use simplified procedures. This case will be explained in detail in another article but only a limited number of products can benefit from the simplified procedures.
–The intended use or uses for the construction product, in accordance with the applicable hEN or ETA. The harmonised technical documentation covers only some intended uses and the essential characteristics applicable to each intended use are described in this document. This reference allows recipients of the document to check that the right information is included.
–The full list of essential characteristics and performances. From the full list, at least one of the relevant essential characteristics with the intended use or uses must be declared. Manufacturers can declare ‘NPD’ (No Performance Determined) for those essential characteristics for which no performance is declared.
The Declaration of Performance has to follow the model included in the Annex III of the Construction Products Regulation but this Annex is currently under revision by the European Commission and a new version is expected in 2014. The reason of the revision is the lack of flexibility of the document; in fact it is difficult fill it in for some products.
According to the Construction Products Directive manufacturers must issue a Certificate of conformity or declaration of conformity but this requirement is no longer demanded. Declaration of Performance DoP substitutes this document.
DoP has to be provided in the language or the languages required by the Member State where the product is made available (sometimes more than one).
The Regulation distinguishes the actions “make available on the market” and “place on the market” (see diagram below). A product is made available on the market when it is supplied by an economic operator to another i.e. the ownership of the product changes. The first time manufacturers or importers make the product available on the European market it is said that the product is “placed on the market”. This can only happen one time.