Construction Products Regulations Presentation for the Hardware Association Ireland By Keith Pheasey ARC Management Systems
What Does CPR Mean? www.cemarking.ie 2
• 1 st July 2013 over 400+ Building Products must carry the CE mark. • Dozens products due to come on line in subsequent years. • The CE is a declaration of performance of the product – not product safety. www.cemarking.ie 3
So what is a CE mark for construction products? www.cemarking.ie 4
A correct CE Mark 1. The CE Mark 2. Company Contact Details 3. The Certified Bodies issue Number 4. The European standard that it has been check against. 5. The products designation (type of product) 6. The products performance criteria. www.cemarking.ie 5
Incorrect CE Marks These marks have no meaning when it comes to construction products, they tell us nothing about the performance of the product!! Be careful - if we are dealing with machinery or other types of products, a straight forward CE mark is often all that is required!! www.cemarking.ie 6
Who is responsible for placing the CE Mark on the product? www.cemarking.ie 7
• The manufactures are responsible. • It is an expensive process as they must test their products to determine the performance of the product. • It is a long process and can easily take 3 – 6 months. • In general Irish manufactures have left it late and are going to struggle to be ready www.cemarking.ie 8
Who is going to enforce this? www.cemarking.ie 9
• The Department of the Environment using officers seconded from other sections in each region. • Changes in legislation with fines in excess of € 500,000 and jail. • In the wake of the pyrite and meat scandals they are determined to enforce this rigorously!!!! www.cemarking.ie 10
So what does this mean to retailers? www.cemarking.ie 11
• Architects, QS’s, Builders etc do not have to specify CE marked materials when specing or ordering from the 1 st of July – because it will be the law, they can just expect to receive CE Marked materials from suppliers. • This means if non CE marked materials go into a building then the finger will ultimately be pointed at the supplier!!!!! www.cemarking.ie 12
Does this mean we can’t sell non CE Marked stock from the 1 st of July ? www.cemarking.ie 13
• Yes you can sell non CE marked stock. The Department of the Environment recognises that stock will have to sold before it can be replaced with CE marked stock. • However the more non CE Marked stock you move after this point, then the higher the likelihood of you running into problems with sites accepting the products. www.cemarking.ie 14
So what do we as retailers have to do in order to be ready? www.cemarking.ie 15
The Department of the Environment tells us that Distributors (Retailers) must: www.cemarking.ie 16
But what does this actually mean: • Determine what products you stock require CE Marking. • Contact the suppliers of the stock to inform them that you will only accept CE marked product from the 1 st of July. • Ask them to forward copies of each products Certificate of Performance and file them. www.cemarking.ie 17
• Have a process in place to be able to withhold a product from the market if you believe it is not in conformity • Ensure the product maintains its conformity after storagee and distribution www.cemarking.ie 18
• Train somebody in your organisation to be able to check that stock is correctly CE marked o Correct Mark & Contact Details o Ensure there are safety instructions and that they are in English o Put a procedure in place to deal with complaints or issues relating to CE marked products www.cemarking.ie 19
BE CARFULL!!! • Under the CPR, an importer or distributor is considered a manufacturer where the place a product on the market under their company name or trademark or modify a product which affects its conformity. • Distributors must ensure that the manufacturer and importer has complied with their requirements. www.cemarking.ie 20
I think my company is ready, what next? www.cemarking.ie 21
• Need to keep up to date with other products coming on line that will require CE marking each year www.cemarking.ie 22
I am also an Importer so what do I have to do? www.cemarking.ie 23
• All of the above and: o Ensure their name & contact details also appears on the product, labelling or associated documents. o Keep documentation for 10 years o Monitor the products performance in the market place. www.cemarking.ie 24
So what products are actually involved? www.cemarking.ie 25
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• Because we are dealing with 400+ product standards, it is very difficult to give a definitive list of products. • Each Standard is 50+ Pages and has exclusions for specific product types. • Do not rely on your suppliers to identify the products for you – they are struggling with this process also. www.cemarking.ie 28
Example 1 Front Door sets require CE Marking Internal Doors do not yet – Expected 2014 Fire Doors do not yet – Expect 2014 Example 2 Paint does not yet require CE Marking However fire resistant paint requires CE Marking www.cemarking.ie 29
SUMMARY www.cemarking.ie 30
1. Identify Products requiring CE mark 2. Contact suppliers 3. Gather and file ‘Certificates of Performance’ 4. Train staff member to be able to audit CE 5. Put procedures in place for complaints, returns, holding product etc. 6. Keep abreast of new standards introduced product ranges you are introducing. www.cemarking.ie 31
QUESTIONS? www.cemarking.ie 32
What CPR/CE Services ARC Provide www.cemarking.ie 33
1. Audit your product lists to identify those items requiring CE marking. 2. Review ‘Certificates of Performance’ 3. Train staff member to be able to audit CE 4. Put procedure in place for complaints, returns, holding product etc 5. On an on-going basis keep clients abreast of new standards and advise on product ranges you are introducing. www.cemarking.ie 34
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