Construction Products Regulation (CPR) Suggestions for an SME-friendly application

The Construction Products Regulation (CPR) is one of the major pieces of legislation in the construction field, which sets the legal conditions according to which products can circulate freely within the European Union (EU). The legislative act which came into force in 2013 made CE marking (and therefore the harmonised European Standards used for this) compulsory. The CPR primarily addresses the relationship between product manufacturers and market surveillance authorities, and only indirectly covers the relationship between manufacturers and users of construction products. The requirements and provisions reflected in the regulation, however, have an impact on product specifiers/users, in particular small and medium-sized enterprises (SMEs), who represent the majority of EBC members.

Since 2016, the European Commission has been assessing the performance of the CPR with the aim of providing an evidence-based comparison of the various options for the future, as an input for the decision to revise, not to revise or to repeal the CPR. In this context, EBC published a position paper coupled with a technical note to propose some suggestions that could ease the CPR reviewing process. These can be summarised as follows:

  • The supply of performance information of construction productsminimising the effort for SMEs of producing/reading documents by having just one document providing all relevant information about the product, combined with clarifications on what information should be provided.
  • Exemptions and simplified procedures of the CPRexemptions and simplified procedures (Articles 5, 37 and 38) should be furtherly clarified in order to be fully used by small and medium-sized enterprises.
  • The content and quality of CPR standards: simplifications in harmonised European standards (hEN) should be preserved and need to be made better known to SMEs. Moreover, hENs should include less onerous but equally robust assessment methods as testing, to substantially reduce the burdens for SMEs.
  • Post-CE marking national requirementsharmonised technical standards (HTSs) should be exhaustive, so as to minimise the need for post-CE marking additional national requirements.
  • Market surveillance: market surveillance authorities should be prepared to intervene more frequently and actively to prevent instances of unfair competition.
  • Access to standardisation and standardsall stakeholders should be adequately represented in standardisation, while regulatory and financial burdens of applying standards should be reduced, where it is appropriate to do so.

Eugenio Quintieri, EBC Secretary General, stated: “The CPR is a milestone and EBC does not want, for reasons of ‘regulatory certainty’, the CPR to be repealed. Nevertheless, a considerate number of challenges with the text of the regulation itself, and with its application, exist. We have a key role to play in making sure that micro, small and medium-sized enterprises benefit from simplified rules and requirements and that they are represented in a fair and equitable manner in standardisation processes. Therefore, we recommend the European institutions to take into consideration our suggestions in the current review process.”

To read EBC position and technical note on the CPRplease click here