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Floor coverings and the Construction Products Regulation

Examining the requirements of this European flooring legislation.

Image © PhotoTalk

The current European legislation relating to manufacturers, Importers and distributors of construction products came into force on 1st July 2013, when the Construction Products Directive (CPD) was replaced. Since that date, all construction products must comply with the Construction Products Regulations (CPR (EU) No 305/2011) and must have CE marking. This article summarises the requirements of the regulation and how it affects the floor covering industry.

The regulation provides for four main elements:

The regulation is a general document that applies to a wide variety of products, so it is supported by product specific 'Harmonised European Standards' (often referred to as 'hENs'). All hENs under the CPR include an 'Informative Annex' (Annex ZA) that details how the standard should be applied to ensure compliance with the CPR. Some of the requirements in these standards refer to separate test procedures, so the standard effectively becomes a checklist for CE marking. The hEN enables manufacturers to see all possible requirements for a product and how those requirements should be assessed.

To apply the CE mark to a product and thus claim compliance with the CPR, the manufacturer needs to meet the requirements in Annex ZA, even though it is called an 'Informative' rather than 'Normative Annex'. To claim compliance with the hEN, a manufacturer must meet all applicable requirements of that standard – for example, resilient flooring must comply with EN 14041.

Table 1: EN 14041:2004 Annex ZA.2 systems of attestation of conformity
Product Intended use Level(s) or class(es) Attestation of conformity system
Resilient, textile and laminate floor coverings Internal and external use as flooring coverings A1fl*, A2fl*, Bfl* and Cfl* 1
A1fl, A2fl, Bfl**, Cfl, Dfl and Efl 3
(A1fl to Efl)*** and Ffl 4
*Products/materials for which a clearly identifiable stage in the production process results in an improvement of the reaction to fire classification (for example, an addition of fire retardants or a limiting of organic material). In accordance with EC decision 2001/596EC products with a different content of organic material outside the accepted limits as laid down in the factory production control documentation have to be tested separately according to table D1 in Annex D.
**Products/materials not covered by footnote *.
***Products/materials that do not require to be tested for reaction to fire (such as products/materials of Class A1 according to Commission Decision 96/603/EC, as amended). This applies also to products that are covered by a 'classified without further testing' (CWFT) decision.
System 1: See Directive 89/106/EEC (CPD) Annex 111.2.(i), without audit testing of samples.
System 3: See Directive 89/106/EEC (CPD) Annex 111.2.(ii), second possibility.
System 4: See Directive 89/106/EEC (CPD) Annex 111.2.(ii), third possibility.

The CPR uses harmonised standards in order to prove the ability of construction products to meet seven basic requirements for construction works. These cover:

Table 2: Attestation tasks for each AVCP system

Tasks for manufacturer AVCP
1+ 1 2+ 3 4
Factory production control (FPC) Yes Yes Yes Yes Yes
Further testing of samples Yes Yes Yes
Determination of the product type Yes Yes Yes Yes Yes
Assessment of products performance based on testing, calculation, tabulated values or descriptive documentation (initial type tests) Yes Yes
Tasks for Notified Body 1+ 1 2+ 3 4
Assessment of products performance based on testing, calculation, tabulated values or descriptive documentation (initial type tests) Yes Yes Yes
Initial inspection of factory and factory production control system Yes Yes Yes
Ongoing surveillance Yes Yes Yes
Certification of product conformity Yes Yes
Certification of factory production control Yes
Audit testing Yes
To issue, restrict, suspend or withdraw a certificate of constancy of performance Yes Yes Yes

Due to the range of products covered by this legislation, it can be a major task for manufacturers and importers of floor coverings to ensure that they comply with the relevant parts of the regulation. As SATRA has considerable experience with floor coverings, we are able to offer advice in relation to the CPR during the course of testing and certifying the product, to ensure that the relevant parts of the CPR are followed.

The extent to which manufacturers have to involve Notified Bodies is dependent on the product. The Notified Body may be required to undertake initial type-testing, audit the factory production control system and certify product conformity, depending on the 'Assessment and Verification of Constancy of Performance' (AVCP) system for that product. Annex ZA.2 of the appropriate harmonised standard (see table 1) specifies which AVCP system is to be used for that product type (see table 2).

All of the systems shown in table 2 require the manufacturer to set up and maintain a 'factory production control' (FPC) system, which may include the provision to undertake some product testing to check that the products continue to meet the essential safety requirements. Although not mandatory, an ISO 9001 quality management system relevant to the products concerned and certified by an accredited certification body would satisfy these requirements.

With the exception of AVCP system 4, all other systems require the input of a Notified Body. Depending upon the system, the Notified Body will produce a final document (see table 3) to confirm compliance with the system of attestation and enable the manufacturer to affix the CE mark.

Table 3: Documents required before affixing the CE mark
AVCP system Document required
1+ and 1 EC certificate of conformity
2+ Certificate of factory production control
3 Notified Body report to the harmonised standard

SATRA is a Notified Body, approved for testing in specific construction product areas, such as floorings. It is also approved as a certification body for type-examination and factory production control approval for resilient, textile and laminate floor coverings (EN 14041:2004) and also wooden flooring (EN 14342:2013). SATRA is also accredited to audit factory production control systems for system 1 of the CPR and to ISO 9001:2015.

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