CE marking: guidance for engineers
The Construction Products Regulation (Regulation (EU) No 305/2011; the CPR) came into force on 24 April 2011 and it succeeds the provisions in the Construction Products Directive (89/106/EEC: the CPD).
CPR and CE marking - implications for designers and specifiers
The CPR lays down harmonised conditions for the marketing of construction products. As part of the CPR, CE marking of un-excepted construction products became mandatory in July 2013. This brought the UK (and a few other member states) into line with the rest of Europe (i.e. EU/EEA). CE marking then became the main legal means for placing individual mandated products on the market in the UK (and all other member states).
According to the CPR the product areas mandated to have harmonised Standards include (as under the CPD):
- Precast concrete products
- Cement, building limes and other hydraulic binders
- Reinforcing and prestressing steel (and ancillaries)
- Masonry and related products, masonry mortars and ancillaries
- Road construction products
- Products related to concrete mortar and grout
- Structural metallic products and ancillaries
- Structural timber products and ancillaries.
CE marking is really about production control. A product can only have CE marking where it is covered by a harmonised European Standard (hEN -identified by having an annex ZA) or a European Technical Approval/Assessment (ETA). Where no harmonised standard or other requirement is in place for a product by 1st July 2013 or beyond, then manufacturers will not be expected to CE mark those products. A list of the harmonised standards under the CPR are available at the European Commission website.
What do designers need to know about CE markings?
CE markings were originally designed for national market surveillance and enforcement authorities, rather than specifiers and consumers.
Professionals do need, however, to be aware of the purpose, and the limitations of CE marking in order to be able to fully safeguard the interests of their clients and to protect their own potential liability.
Some harmonised standards may make demands of the specifier. For example BS EN 1090 will from 2014 require the design to specify the Execution Class for a steel structure, component or detail. In effect this will define the level of quality control in the fabrication process and it may even define who may legally undertake the work. This is not the case with concrete products.
Which concrete products require CE marking?
Not all concrete products require CE marking. For example, concrete (as a material) is not covered by the CPR; the European Standard for concrete EN206, is not harmonised and so therefore CE marking does not apply to ready-mixed concrete. Reinforcing and prestressing steels are included in the CPR but the harmonised standards are still a long way off.
The summary of concrete related product groups that are included in the CPR and should have harmonised standards and therefore require CE marking are as follows: precast concrete products; cladding; roof tiles; cement, building limes and other hydraulic binders ; reinforcing and prestressing steel (and ancillaries); masonry and related products, masonry mortars and ancillaries; aggregates; road construction products; products related to concrete mortar and grout; screeds; fixings; structural metallic products and ancillaries; structural timber products and ancillaries.
There are exemptions to the products included on this list. These include:
- Traditionally-made products or in a manner appropriate to heritage construction
- Those manufactured on the construction site
- Bespoke products (i.e. those manufactured specifically for an identified construction project.)
The interpretation of the legislation around this last exemption is currently a matter for conjecture and is likely to be resolved over time. One interpretation is that a product that requires design input to be used or requires specific manufacture (e.g. cut to length) does not need to bear CE markings but one that has a standard design and is ready to use e.g. a fence post or a concrete block, does.