Document

Report
Construction Products Regulations
Presentation
for
Building Materials Federation
By
Keith Pheasey
ARC Management Systems
The objective of this presentation is to give you a practical understanding off:
•
The requirements on Distributers.
•
The requirements on Importers.
•
The requirements on Manufacturers.
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What is the difference
between a Distributors
(retailers) and an
Importer?
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An importer means “any natural or legal person established within the Union who
places a construction product from a third country on the Union market.”
Example
Product manufactured in China and brought into the Republic of Ireland (or any other
Member State) from China – IMPORTER
A ‘distributor’ means “any natural or legal person in the supply chain, other than the
manufacturer or the importer, who makes a construction product available on the
market.”
Example
Product manufactured in the UK (or any other Member State of the Union) or brought
into the Republic of Ireland from the UK (or any other Member State) - DISTRIBUTOR
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So what does this mean
to Distributors
(retailers)?
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• Architects, QS’s, Builders etc etc do not have
to specify CE marked materials when specing
or ordering from the 1st of July – because it
will be the law, they can just expect to
receive CE Marked materials from suppliers.
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So what do we as
retailers have to do in
order to be ready?
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The CPR tells us that Distributors (Retailers)
must:
1. Take due care that the product is compliant and has all documentation to
verify compliance with the CPR;
2. Ensure instructions and safety information is in the appropriate language of
the particular market;
3. Ensure the manufacturer has made the product identifiable and the
manufacturers / importers contact details are available;
4. Ensure that products are stored or moved under such conditions that don’t
alter the products compliance;
5. Take corrective measures where necessary;
6. Cooperate with requests from national authorities.
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So how do I go about this:
•
Determine what products you stock require CE Marking.
•
Contact the suppliers of the stock to inform them of their obligations relating to
CE marked product from the 1st of July.
•
Ask them to forward copies of each products Certificate of Performance and file
them.
•
Have a process in place to monitor complaints and returns relating to the
performance of products
•
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 storage and distribution
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Be Careful:
•
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.
•
Need to keep up to date with other products coming on line that will require CE
marking each year
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I am also an Importer so
what do I have to do?
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An importer must meet all the requirements of a distributor and additionally:
•Ensure their name & contact details also appears on the product, labelling or
associated documents.
•Satisfy themselves that the manufacturer has done all that is required to comply
with the CPR;
•Keep documentation for 10 years
•Monitor the products performance in the market place.
Be Careful:
If an importer places a product on the market under his trade name, or modifies
a product, then he will be treated as the manufacturer.
CE Marking does not mean a product meets Building Regs, importers still need
to be mindful of this criteria
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I am a manufacturer so
what do I have to do?
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When applying the CPR to a product, there are
a number of key steps to be followed:
Step 1
• Identify the Appropriate Standard(s) for your Product Directive(s)
Step 2
• From the appropriate Standard(s) determine the attestation level
Step 3
• Develop the Initial Type Test file
Step 4
• Implement the Factory Production Control measures
Step 5
• Involvements of Notified Body (If Required)
Step 6
• Issue Declaration of Performance
Step 7
• Monitor Product Performance
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Step 1
• Identify the Appropriate Standard(s) for your Product
Directive(s)
Identify, the standards (if any) that apply to your product, the following website
and link will provide you with a full list of the Harmonised Standards for each
product category:
www.newapproach.org
or
www.europa.ie
http://www.newapproach.org/Directives/ProductFamilies.asp?89/106/EEC
http://ec.europa.eu/enterprise/newapproach/nando/index.cfm?fuseaction=cp
d.hs
Be Careful:
•New standards are being harmonised every year, so check regularly if your
product is not yet harmonised.
•The product categorisation can be deceiving, the standard(s) that apply to
your product may not always be listed under the category you expect, so take
some time to review related categories.
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Step 2
• From the appropriate Standard(s) determine the
attestation level
Once you have identified the standard, within Annex ZA at the back of the
standard you will find the attestation level. This level will determine the need
for the involvement of a notified body/Test Lab
Example:
Be Careful:
•Regardless of the attestation level you will be required to have Factory
Production Control and Determination of Product Type (ITT), the only question
is the requirement for a 3rd Party.
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Be Careful:
• The Notified Bodies and Test Labs do not cover all standards, you need to
ensure the body covers the standard and if not you need to leave time to find a
body/lab that does!
•There can be a 2/3 Month Lead Time on Factory Production Control Audits
•Expected backlogs at Product Testing Laboratories, remember Ireland is not
the only country due to adopt the CPR from the 1st of July.
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Step 3
• Develop the Initial Type Test file
Again within Annex ZA at the back of the standard you will find the testing
requirements to determine the product type. The attestation level will tell you
if a notified body is required to verify the product type testing.
In order to reduce test costs and simplify the test processes there are several
options open to companies:
Shared Test Results
A manufacture may use determination of product type results obtained by
another manufacture. However the product must have
the same design,
raw materials and
identical physical dimensions and
properties relevant to performance.
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Cascading Test Results
A manufacturer may use Determination of product type results from a component
supplier provided they were obtained from a notified body.
Conventional Series Production
Where the same product is manufactured in large volumes over periods of time and
as long as the product and manufacturing process remains unchanged there is no
need to repeat the determination of product type testing as there is generally no
limit or expiration date on ITT reports.
Series Production
Where there is series production but the finished product has potentially different
performances (i.e. due to size etc). The technical specification will state which
values may be tested as series production values to reduce the test burden and
which must be individually tested on a per product/batch level. This relates
specifically to Product Ranges etc
Individual (and non-series) Production
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Individual (and non-series) Production
Product must be completely individual and non-series.
Individual design and installed in a known works/installation
Custom made for specific order to obtain one or several end use performance
differences.
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Step 4
• Implement the Factory Production Control measures
The manufacture is responsible for organising an effective FPC system, and
nominating a delegate to:
•
Identify procedures to demonstrate conformity
•
Identify and record any instance of non conformity
•
Identify procedures to correct instances of non conformity
Be Careful:
• The above is the minimum, each harmonised standard clearly states the full extent
of the required procedures that are required for an FPC system.
•
Every harmonised standard has its own requirements, there is no one fits all. Each
standard is a set of requirements in its own right!
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Identify procedures to demonstrate conformity.
This may include procedures to cover such areas as:
 Testing of Raw Materials
 Testing of In Process Product
 Testing of Finished Product
 Standard Operating Procedures around manufacturing
Identify and record any instance of non conformity
This may include procedures to cover such areas as:
 Non Conforming Material
 Internal Auditing
 Customer Complaints
 Management Reviews
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Identify procedures to correct instances of non conformity
This may include procedures to cover such areas as:
 Corrective & Preventive Actions
 Complaint Handling
 Product Traceability
 Supplier Selection & Monitoring
Generally a well maintained management system such as ISO 9001 will cover many of
the clauses required by an FCP system, but be careful it may not cover everything.
Be Careful:
Products with an Attestation Level of 2+, 1 and 1+ will need their Factory Production
Control Systems audit by a Notified Body
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Is there anything else a manufacturer is required to do?
Yes, the manufacturer must:
• Keep documentation for 10 years;
• Monitor the product on the market;
• Ensure the product is identifiable;
• Indicate a contact point on the product;
• Provide instructions and safety information in the appropriate languages;
• Cooperate with requests from national authorities.
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So what does a CE mark
for construction
product actually look
like?
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Incorrect CE Marks
These marks have no real meaning when it comes to construction products, as
they tell us nothing about the performance of the product!!
But Be Careful:
If we are dealing with machinery or other types of products, a standard CE
mark is often all that is required!!
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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.
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GENERAL POINTS /
SUMMARY
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But please be mindful:
•
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.
•
More and more products will come “on line” in subsequent years.
•
In general Irish manufactures have left it late and are going to struggle to be
ready for the 1st of July
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QUESTIONS?
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