Both pieces of legislation relate to the application of the CE mark — which refers to the French Conformite Europeene. A CE mark demonstrates that a product has met the health, safety, and environmental requirements of the EU. Acting like a technical passport for cross border trade, the CE mark enables manufacturers to market and sell their products across all EU and European Free Trade Association (EFTA) countries.
When the CPD was first introduced into European law in 1988, EU member states were given a fairly free rein to implement the Directive within the realms of their own local legislation. Within the UK’s interpretation, UK manufacturers selling their products exclusively within the UK market did not require the CE mark, but if they were selling products into a country that had adopted the CPD, all of their products were required to carry it. This was also the case in Sweden, Ireland, and Portugal.
This is set to change from today, when the CPD is replaced by the CPR. Its introduction means that CE marking will be mandatory in every EU member country for all products that are to be placed on the EU market within the scope of harmonized European Standards (hENs). For products not covered, or not fully covered by a hEN, CE marking may be applied through a European Technical Assessment (ETA).
Within the CPR, certain products — including domestic and commercial fire products — must be third party tested and approved by an independent third party, known as a Notified Body. Only then will they receive the CE mark.
The fire industry has known about the 1st July deadline for some time, and many companies will have prepared by testing all of their products for compliance with the CPR’s requirements. However, there will inevitably be exceptions, and many manufacturers reading this article will have untested, uncertified products, which won’t be permitted to carry the CE mark. The legislation is very clear — as of today, these companies are acting illegally if they sell these products within the UK and wider EU.
Top tips for manufacturers
Here are the key points that manufacturers of life and safety critical products need to be aware of:
Finally, manufacturers should view CPR as an opportunity. It will go further than the CPD in helping to protect and save lives. Those manufacturers that have CE marks on their products will be able to offer their customers an added level of confidence in their fire products, so there is a commercial incentive to embrace this new piece of legislation.
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Although many aspects of the CPR may be welcome, CE marks cannot guarantee quality or anything else about the product.
As we have found from existing CE marked products in electrical and other fields, false marking and other fakes are common, especially at the of bottom end of the market.
Any product which is safety critical should be purchased via a third party product scheme, or at least from a well known UK supplier who comes under UK consumer legislation protection for clients.
The CPR constructs upon the CPD and purposes to break down technical obstacles to trade in construction equipment within the European Economic Area. To accomplish this, the CPR provides for four main elements:
• A system of consistent technical specifications• A settled system of conformity valuation for each product family• An outline of notified bodies• CE marking of equipments.
Should a customer really limit themselves to just UK manufacturers to be safe? Surely, other EU nations at least produce products we can trust?