BCF Guide to CE Marking
As part of the requirement of the Construction Products Regulation (CPR) (305/2011EC) products that comply with this regulation have to carry the CE mark either on the product and/or on the attached information that accompanies the product. To meet the requirements of the CPR the product has to conform to a ‘harmonised standard’ (hENs)*.
The CPR also requires that products that are in scope have a Declaration of Performance (DoP) that goes with the product, this will give information on the hEN that the product complies with.
Many companies have been asked why are their paints which are used in/on construction products are not CE marked. The simple answer is that there is no harmonised standard that the paint can be tested against to see if it meets any specific requirements. Without a standard it CANNOT be CE marked.
The European Commission issues Mandates which lay out ‘essential requirements’ that a product has to meet to comply with the Construction Products Regulation. The European Standards Body (CEN) then assign the work to develop appropriate standards that layout how these essential requirements will be met to the appropriate technical committees and working groups. Once a standard has been developed and agreed then the product can be tested against this standard for compliance to the essential requirements. Standards produced by this process are known as ‘harmonised standards’ (hENs) and these contain an Annex ZA (may also be an Annex ZB etc.) which lays out the criteria that have to be met for any CE marking of products.
At present paints are not considered as ‘construction products’ unlike wallcoverings, therefore the Commission does not issue Mandates for standards for paints.
The exceptions to this are intumescent coatings where industry has requested the Commission to issue a Mandate to cover these and a standard is being developed to enable criteria to be met and CE marking of products to take place. The other possible exception might arise should emissions from coatings come into scope of the CPR under ‘health, hygiene and environment’ which could cover air quality or contamination of water or soil from coatings. However at present paints are not covered under the CPR for these.
[*Note: European Technical Assessments (ETA) are another route to CE marking, being similar to Harmonised European Standards, but these are produced by a Technical Assessment Body.]
Created by the BCF, January 2014