Marley Eternit discusses the new Construction Products Regulation
The new Construction Products Regulations are instigating the most significant change in over a decade for the construction products industry. It will now become mandatory, from 1st July 2013, for manufacturers to ensure CE marking is applied to all of their products which are manufactured to a harmonised European standard, or European Technical Assessment.
Applying a CE mark sounds like quite a simple process but actually places a lot of responsibility on manufacturers. Where a harmonised standard applies, manufacturers need to take several actions, including drawing up and providing Declarations of Performance (DOP) and designing and affixing a suitable CE mark to packaging, which must include relevant references to certificates and location of DOPs. There is also the task of keeping and maintaining all of this documentation with an evolving product range.
This has resulted in a significant investment in both time and money for the construction products industry, including roofing manufacturers like ourselves, as we have had to bear the cost of the changes – in most cases to packaging and design. The DOP documentation also needs to be made available, in most cases online, which also demands further investment.
Whilst these changes do require manufacturers to produce a vast amount of documentation which arguably doesn’t actually bring any significant advantages to roofing contractors themselves, it does, however, give them the assurance that they are using a product manufactured and tested to harmonised European standards. It could also catch out less scrupulous companies if they haven’t carried out appropriate testing, as a technical file needs to be kept to confirm relevant testing has been carried out.
For Marley Eternit, nearly all of our products are affected and there is a lot of work to do, but the new regulations provide an opportunity to confirm that our products conform to the relevant standards. Our roofing customers can be assured that we have all the technical files and Declarations of Performance in place in readiness for the CPR when it takes effect at the beginning of July.
Spotlight on sustainability
There has been such an investment in the industry in preparation for mandatory CE marking that this has tended to be the main focus for discussion about the Construction Products Regulations. However, the CPR also places new focus on the sustainable use of natural resources in the design, building and demolition of construction works.
The CPR introduces a new Basic Works Requirement (BW7), which takes into account the sustainable use of natural resources, recyclability of construction works and the use of environmentally compatible raw and secondary materials. Most significantly, the regulations propose the use of Environmental Product Declarations (EPDs), where available, for the assessment of the sustainable use of resources and the impact of construction works on the environment.
An EPD provides verifiable, accurate environmental information for products and their applications. It forms part of a series of European Standards prepared by CEN TC 350, providing a system for the sustainability assessment of buildings at the building level using a life cycle approach. Although they are widely used in other parts of Europe, most UK roofing manufacturers aren’t yet using EPDs but it looks likely that this process may be accelerated as a result of the changes to the CPR.
At the moment, EPDs can vary slightly according to the rules for product assessment that are used, and as the methodology defined in the recently published BS EN 15804* standard is still under review, up until now, most manufacturers in the UK have opted to await confirmation of the rules governing product assessment before embarking on accreditation.
Marley Eternit has however already taken a significant step towards full EPDs by being the first roofing manufacturer to have the carbon footprint of our products certified, a key component of an EPD. We are also now looking at a strategy of EPD development for all of our products over the next few years, leading the way in the provision of such accreditations across the roofing industry.
* BS EN 15804 - ‘Sustainability of construction works – Environmental product declarations – Core rules for the product category of construction products’