CPR-Guide-revised-December-2021
CPR-Guide-revised-December-2021
Practical Impact
December 2021
Glass for Europe is the trade association for Europe’s flat glass sector. Flat glass is the material that
goes into a variety of end products, primarily in windows and facades for buildings, windscreens and
windows for automotive and transport as well as solar energy equipment, furniture and appliances.
Glass for Europe brings together multinational firms and thousands of SMEs across Europe, to
represent the entire building glass value-chain. It is composed of flat glass manufacturers, AGC
Glass Europe, Guardian, NSG-Group and Saint-Gobain Glass Industry, and works in association with
Carlex and national partners gathering building glass processors all over Europe
Construction Products Regulation
Introduction
Regulation (EU) 305/2011, more commonly referred to as the Construction Products Regulation
(CPR), replaces the 1989 Construction Products Directive (CPD). This new piece of legislation sets out
the rules governing when and under which conditions, the CE marking must accompany construction
products placed on the EU market. The purpose of this guide is to explain the main changes between
the ‘old’ Construction Products Directive and the ‘new’ Construction Products Regulation.
o This new EU regulation therefore applies to most glass products for use in buildings and
their derived products.
o All glass manufacturers, processors and building glass supply chain actors need to
understand what the new legislative changes will mean for their business.
To that end, Glass for Europe has put together this practical guide to steer you through the new
terminology and concepts and highlight what the main changes will be.
✓ Part One – General information on the CE marking for building glass / page 4
✓ Part Two – Q&A on the main regulatory changes affecting CE marking as of 1 July 2013
/ page 6
The CE-marked product can therefore cross because they were heavy, lacked transparency
national borders more easily, and compliance and were not always consistently applied
with national legislations, such as building across the EU. Change has come in the form of
codes, can be conveniently demonstrated a harmonised regulation meaning that all 27
based on the declared values. EU countries must apply the same rules. The
regulation aims to clarify and simplify concepts
The existing rules and procedures underpinning and procedures and give credibility to the
the CE marking were recently overhauled system.
Since 2005, a number of building glass products implementation across the whole of Europe.
have been subject to harmonised European Under the regulation, a Declaration of
standards (see list of standards), and therefore Performance (DoP) must be drawn up before
these products must bear the CE mark, except products covered by hENs or ETAs are placed
under very special conditions. This principle on the market. By affixing the CE marking, the
remains and is in fact reinforced by the new company assumes responsibility for the
regulation, which will ensure more thorough conformity of their product with the
declared performance values. Drawing up a In addition to harmonised European standards
DoP is mandatory, except in only a few on ‘glass for use in buildings and construction
exceptional cases. If this declaration is not works’, numerous other standards exist on
drawn up then the CE marking should not be transformed and/or more complex products
affixed. such as windows. Therefore the whole supply
Firstly, it is crucial to ensure that the product of these hENs must be complied with. The
conforms to the description of the requirements of hENs for glass products
harmonised European standard. All aspects include:
Depending on the systems of Assessment and meeting the above requirements. The
Verification of Constancy of Performance applicable AVCP systems can be found in the
(AVCP), notified bodies may be involved for hENs.
2. When a construction product is covered by a • The DoP sets down the information
harmonised standard or conforms to a European that has to be declared for CE marking
Technical Assessment which has been issued for on the basis of the hEN.
it, information in any form about its performance
in relation to the essential characteristics, as
defined in the applicable harmonised technical
specification, may be provided only if included
and specified in the declaration of performance
except where, in accordance with Article 5, no
declaration of performance has been drawn up.
(a) the reference of the product-type for which the • The DoP must relate to a product type
declaration of performance has been drawn up; or a group of product types. This
product type must be identified in the
DoP. (See CPR Article 2, definition 9
for definition of product type).
• A product type may cover several
products with the same declared
performances.
(b) the system or systems of assessment and • List all relevant systems of
verification of constancy of performance of the assessment and verification of
construction product, as set out in Annex V; constancy of performance (AVCP).
► Example:
EN 1279-5:2005;
EN 1279-5:2005+A1:2008;
EN 1279-5:2005+A2:2010.
A1 was only a clarification of the
classification of pendulum body
impact resistance. A2 sets down rules
for shared ITT.
(a) the intended use or uses for the construction • The intended use of all glass products
product, in accordance with the applicable is stated in the applicable hEN as
harmonised technical specification; follows: "glass for use in buildings
and construction works". No other
intended use should be mentioned.
Note: for many products, the
manufacturer may not know the end
use application.
(b) the list of essential characteristics, as • See relevant hEN standards for the list
determined in the harmonised technical of essential characteristics. See also
specification for the declared intended use or the example in Annex II
uses;
(c) the performance of at least one of the • A DoP cannot be produced if the
essential characteristics of the construction manufacturer is aiming to claim NPD
product, relevant for the declared intended use or (no performance determined) for all
uses; characteristics.
(d) where applicable, the performance of the • Glass manufacturers have been
construction product, by levels or classes, or in a providing this information for years.
description, if necessary based on a calculation
in relation to its essential characteristics
determined in accordance with Article 3(3);
(g) when a European Technical Assessment has • With very few exceptions, glass
been issued for that product, the performance, by products are covered by harmonised
levels or classes, or in a description, of the European Norms rather than
construction product in relation to all essential European Technical Assessments.
characteristics contained in the corresponding
European Technical Assessment.
3. By way of derogation from paragraphs 1 and • The delegated act referred to in this
2, the copy of the declaration of performance may article was approved as Commission
be made available on a web site in accordance Delegated Regulation (EU) No
with conditions to be established by the 157/2014 on 30/10/2013.
Commission by means of delegated acts in
accordance with Article 60. Such conditions shall,
inter alia, guarantee that the declaration of
performance remains available at least for the
period referred to in Article 11(2).
Rules and conditions for the affixing of CE What you need to know
marking (Article 9)
1. The CE marking shall be affixed visibly, legibly • No change in comparison to the CPD.
and indelibly to the construction product or to a There is still a desire from some
label attached to it. Where this is not possible or authorities or voluntary certification
not warranted on account of the nature of the
schemes for the CE marking to be
product, it shall be affixed to the packaging or to
the accompanying documents. printed on the glass. However, such
requirements cannot be legally
imposed on manufacturers. As it is
not practical for the CE marking to be
applied directly to the glass, it is
common practice for the CE marking
to be affixed to the sticker, the
packaging or other accompanying
documents. The information
accompanying the CE marking may be
separated and placed in different
locations.
Rules and conditions for the affixing of CE What you need to know
marking (Article 9)
2. The CE marking shall be followed by the two • This provision refers to a product type
last digits of the year in which it was first affixed, and not to an individual glass product.
The year in which the CE marking was
first affixed for a product type can be
found here. However, a company
starting production of this product
type later must affix, the two last digits
of the year in which the production
was started.
... the name and the registered address of the • No change compared to CPD.
manufacturer, or the identifying mark allowing
identification of the name and address of the
manufacturer easily and without any ambiguity,
... the unique identification code of the product- • It can be a code, a trade name or any
type, other way to identify the product (e.g.
alphanumerical code, barcode or QR
code). The information provided
should be sufficiently complete so
that the declared characteristics can
be found without any ambiguity.
... the reference number of the declaration of • It may be the same as the unique
performance, identification code (see CPR whereas
26).
... the level or class of the performance declared, • This will be same as in the DoP.
... the identification number of the notified body, if • This is only applicable to glass
applicable, and products under AVCP system 1.
• The number of the certificate does not
need to be indicated.
... the intended use as laid down in the • The harmonised technical
harmonised technical specification applied. specification states that the intended
use is: “Glass for use in buildings and
construction works”.
3. The CE marking shall be affixed before the • No change compared to the CPD and
construction product is placed on the market. It no pictogram is necessary for glass
may be followed by a pictogram or any other products.
mark notably indicating a special risk or use.
(a) the construction product is individually • Non-series does not mean production
manufactured or custom-made in a non-series of small quantities. All the conditions
process in response to a specific order, and listed in Article 5 must be met to
installed in a single identified construction work, qualify as a non-series and to be
by a manufacturer who is responsible for the safe exempted from CE marking.
incorporation of the product into the construction
works, in compliance with the applicable national ► Example: Although bullet-resistant
rules and under the responsibility of those glass products may be produced in
responsible for the safe execution of the small quantities by a specific
construction works designated under the producer to meet a bespoke order, it
applicable national rules’. does not satisfy all the requirements
of article 5a. Therefore, the
derogation would not apply to such
products.
(b) the construction product is manufactured on • Not applicable to glass products for
the construction site for its incorporation in the buildings and construction works.
respective construction works in compliance with
the applicable national rules and under the
responsibility of those responsible for the safe
execution of the construction works designated
under the applicable national rules;
(c) the construction product is manufactured in a • May be applicable for some specific
traditional manner or in a manner appropriate to applications.
heritage conservation and in a non-industrial
process for adequately renovating construction ► Examples: traditional lead light,
works officially protected as part of a designated copper light or some types of curved
environment or because of their special glass or blown glass.
architectural or historic merit, in compliance with
the applicable national rules.
5. Distributors shall, further to a reasoned request • When (and only when) there is a
from a competent national authority, provide it request from a competent national
with all the information and documentation authority (market surveillance or
necessary to demonstrate the conformity of the relevant Ministry) the distributor shall
construction product with the declaration of pass on the request to the
performance and compliance with other manufacturer. This latter shall provide
applicable requirements in this Regulation in a the necessary document/information
language which can be easily understood by that to the distributor who will pass it to the
authority. They shall cooperate with that authority. There is no need for the
authority, at its request, on any action taken to distributor to have all documents in
eliminate the risks posed by construction advance (TT, technical files,…) in his
products which they have made available on the own files. Only the DOP and the CE
market. marking label are requested.
The CE marking should be the only marking of • The spirit of the law is that all other
conformity of the construction product with the marks that cover the same areas as
declared performance and compliance with the CE marking are banned. This is
applicable requirements relating to Union meant to ensure the free circulation of
harmonisation legislation. However, other construction products throughout the
markings may be used, provided that they help to single market.
improve the protection of users of construction
products and are not covered by existing Union • Energy labels and ecolabels are
harmonisation legislation. examples of permitted voluntary
markings.
3. For any construction product covered by a • It must be noted that the CPR not only
harmonised standard, or for which a European prohibits national restrictions on the
Technical Assessment has been issued, the CE placing on the market of CE marked
marking shall be the only marking which attests construction products, it also
conformity of the construction product with the prohibits restrictions on the use of
declared performance in relation to the essential these products.
characteristics, covered by that harmonised
standard or by the European Technical
Assessment.
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:088:0005:0043:EN:PDF
Disclaimer
This guide has been produced and researched by Glass for Europe. Whilst every effort has been
made to ensure the accuracy of all information provided, Glass for Europe does not accept
responsibility for errors or omissions.
Note that the dates mentioned in this table are the dates from which CE marking was mandatory (date
of withdrawal of the possible national standard on the same subject). CE marking was already possible
one year before (date of coexistence of this possible national standard with the new EN standard).
Therefore, some companies may have started the CE marking of their product the year before that
indicated in the table, and so can indicate that year on their CE marking label.
1EN 572-9 covers the following soda lime silicate glass products: float glass, polished wire glass, drawn sheet
glass, patterned glass, wired patterned glass, and wired and unwired channel shaped glass.
The performance of the product identified is in conformity with the declared performance
above.
This declaration of performance is issued under the sole responsibility of the manufacturer.
Signed for and on behalf of the manufacturer by:
The performance of the product identified is in conformity with the declared performance above.
This declaration of performance is issued under the sole responsibility of the manufacturer.
Signed for and on behalf of the manufacturer by: