A. Scope
The Construction Product Regulation (CPR)1 lays down harmonized conditions for the marketing of construction products in the EU. This is achieved by providing a “common technical language” offering uniform methods to assess the performance of construction products and to compare the performance of products from different manufacturers in different countries.
These methods are compiled in harmonised standards or technical specifications. This common technical language is to be applied by:
- the manufacturers when declaring the performance of their products, but also by
- the authorities of Member States when specifying requirements for them, and by
- their users (architects, engineers, constructors…) when choosing the products most suitable for their intended use in construction works.
Further information can be found at:
http://ec.europa.eu/growth/sectors/construction/product-regulation/index_en.htm
1 Construction Products Regulation No 305/2011 of 9 March 2011.
The performances of cables included under the CPR are
- reaction to fire.
- resistance to fire.1
- release of dangerous substances in normal operation2, dismantling and recycling.
1 Under consideration
2not including performances during fire
Cables for permanent installation in constructions within the scope of the two harmonised product standards i.e.:
- cables intended to be used for the supply of electricity and communications in buildings and other civil engineering works and subject to performance requirements on reaction to fire
- and cables intended to be used for the supply of electricity, communication and fire detection and alarm in buildings and other civil engineering works where it is essential to assure the continuity of power and/or signal supply of safety installations1.
Cables for permanent installation are considered those which are not specifically designed for temporary installation only. Those that are not considered lift cables or other cables specifically designed for use in industrial processes carried out in industrial premises that are not part of the Mandate M/443 EU2
1 Under consideration.
2Mandate M/443 EN to CEN and CENELEC related to power, control and communication cables – Footnote 2) of Annex 1 – FIELD OF APPLICATION. This mandate does not cover control and power circuits inside machinery (Council Directive 89/392/EEC) or lifts (European Parliament and Council Directive 95/16/EC), or other cables specifically designed for use in industrial processes carried out on industrial premises.
Yes, indeed. All cables installed permanently in constructions must be CE marked. National Regulators can define for special circumstances the maximum length of cable whose contribution to fire is considered negligible and therefore accepted with a level of performance lower than required for the specific construction. In such a case the cable must be as short as possible and connected in the fire compartment it enters or be protected. For IT (Information Technology) the EN50174-21 applies.
1EN50174-2:2018 – Information technology installation. Installation planning and practices inside buildings.
4.1.6.2.3 Outdoor cables which enter into buildings
Information technology cables that do not comply with the minimum recommended performance requirements of EN 60332-1-2 (equivalent to Euroclass Eca) shall be either:
a) terminated in an entrance facility which is outside the external fire barrier of the building;
or
b) terminated inside the building, within 2 m (unless an alternative distance is specified by local regulations) of the point of internal penetration of the external fire barrier or any length exceeding 2 m is installed within trunking or conduit that is considered as a fire barrier in accordance with local fire regulations.
NOTE This also applies where the cable should pass through a space between two external fire barriers within a building.
Cables for permanent installation are considered those which are not specifically designed for temporary installation only. Are not considered control and power circuits inside machinery, lift cables or other cables specifically designed for use in industrial processes carried out in industrial premises that are not part of the Mandate M/443 EU1
1 Mandate M/443 EN to CEN and CENELEC related to power, control and communication cables – Footnote 2) of Annex 1 – FIELD OF APPLICATION. This mandate does not cover control and power circuits inside machinery (Council Directive 89/392/EEC) or lifts (European Parliament and Council Directive 95/16/EC), or other cables specifically designed for use in industrial processes carried out on industrial premises
It is important that any cables used in prefilled conduits and pre-connected systems comply:
1) if the prefilled conduits’ and pre-connected systems’ final application is in construction and civil engineering works subject to reaction to fire requirements, or
2) if they are sold through the distribution channel and their final application can be construction and civil engineering works subject to reaction to fire requirements.
B. Definitions
The DoP is a document drawn up for every product covered by the CPR by the manufacturer following regulatory guidelines which:
- identifies the product and the manufacturer.
- its intended use.
- its essential characteristics as given by its harmonised Product Standard.1
See Chapter D.DECLARATION OF PERFORMANCES
Further information on the Delegated Act No 574/2014 of 21 February 2014 on the model to be used for drawing up a declaration of performance on construction products, can be found at:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014R0574
1 see Q02
C. Obligations of economic operators
- An additional testing/certification procedure to current Quality Marks. The severity of this burden is growing with the level of performances declared. Tests are more sophisticated moving up from Class Eca to Dca and upper (from small size flame test to full size fire scenario) and routines of continuous surveillance to certify the conformity to the DoP of the full production of Class Cca and B2ca cables under System 1+ is particularly strict and costly. The CPR implementation impacts many company functions: technical, manufacturing, logistics, quality management and IT.
- The new marking, labelling and electronic distribution of the DoPs required a huge investment to warrant the perfect alignment of all these new documents and texts and to warrant the full availability for end-users. In many cases it obliges them to add new labels on products. DoPs have to be maintained and available for 10 years after stopping production.
- Most of cables of Classes Dca and above required a full redesign to warrant the conformity of all types to the DoP. New materials have been developed on purpose to fulfil the new Euroclasses and the additional requirements like flaming droplets.
- For all cables of every level of performance much severe consequences in case of non-conformity up to the total withdrawal of the product from the market.
The CPR should be applied without differences of interpretation by each Member State. The Classification is the common language to define the level of fire performances of cables (Reaction to Fire at the moment) and to be used in local Regulations and in Users requirements.
Any decision on which Class to adopt for a particular application is a National matter and could vary between different Member States. The wide range of combinations of the parameters (Class + smoke + acidity + droplets) gives the Member States a great flexibility.
Not every Member State regulates the fire performances of cables.
The obligations are set out in Art.11 of the CPR as follows.
When a product is covered by a harmonised standard, the manufacturer shall draw up and keep for 10 years the Declaration of Performance (DoP) and affix the CE marking.
Manufacturers shall ensure that series production maintains the declared performance. That their products bear their registered trade mark and contact address and elements allowing their identification and instructions and safety information
Manufacturers who consider that a product, which they have placed on the market, is not in conformity with the Declaration of Performance, shall immediately take the necessary corrective measures to bring that construction product into conformity, or, if appropriate, withdraw or recall it.
Yes, indeed. The CPR describes as follows the general obligation of distributors. “(omissis) distributors of construction products should be aware of the essential characteristics for which there are provisions on the Union market, and of the specific requirements in Member States in relation to the basic requirements for construction works, and should use this knowledge in their commercial transactions”1.
Moreover distributors are subjected to obligations defined in Chapter III of the CPR.2
When a distributor places on the market a product under his own name the distributor is considered a manufacturer.
Importers and Legal Representatives are subjected to obligations defined in Chapter III of the CPR9.
1 Preface (41) of the Construction Products Regulation No 305/2011.
2 Construction Products Regulation No 305/2011 – Chapter III – OBLIGATIONS OF ECONOMIC OPERATORS.
Yes. Public undertaking private Operators (e.g. Railway Networks Operators or Power and Telecom Networks Operators) should adapt their specification on cables to the CPR language switching references from reaction-to-fire test methods to Euroclasses. That descends from Article 8.5 of the CPR (General principles and use of CE marking) which states what follows:
"Member State shall ensure that the use of construction products bearing the CE marking shall not be impeded by rules or conditions imposed by public bodies or private bodies acting as a public undertaking, or acting as a public body on the basis of a monopoly position or under a public mandate, when the declared performances correspond to the requirements for such use in that Member State”.
D. Declaration of Performances (DoP)
The manufacturer, by drawing up his DoP, assumes the responsibility for the conformity of the construction product with the declared performance.
Based on the information contained in the DoP, the User, under its own responsibility, decides to purchase the product, which is fit for its application.
All the information supplied in the DoP is obtained by strictly applying the methods and criteria provided in the relevant harmonised standard.
The correct application of these methods and criteria are guaranteed by the manufacturer himself and by the appropriate involvement of a Notified Body, following the applicable system of Assessment and Verification of Constancy of Performance (AVCP).
The affixing of CE marking follows the drawing up of the DoP and indicates that the manufacturer has strictly followed all the applicable procedures for drawing up his DoP which is consequently accurate and reliable.
Further information can be found at:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014R0574
The DoP shall be publicly available (e.g. through a website) and shall be provided language or the languages required by the Member State where the product is made available, on request either in paper or electronic form1.
1 Delegated Act No 574/2014 of 21 February 2014 on the model to be used for drawing up a Declaration of Performance on construction products.
E. CE marking
They will remain important as Voluntary National Quality Marks cover performances different from the CPR, for example, electrical, mechanical, and material characteristics of the cable. They will integrate in a more complete coverage of performances.
CE-marking will be a pre-condition to place cable for construction works on the market. The relevance of the CE marking under the CPR is the elimination of technical barriers among the Member States arising from the definition of fire performances as well as the uniform modality to attest the conformity of cables.
Quality Marks cover other aspects of the product such as mechanical and electrical performances and dimensions and are unique tools to monitor the compliance with voluntary standards. Therefore, a comparison between the CE marking and voluntary National Quality Marks is misleading because they are complementary.
Only Class Eca and Class Fca are defined with reference to the Flame propagation test IEC/EN 60332-1-2 (respectively meeting or not meeting the required maximum threshold of propagation).
For the other classes, there is not a direct relationship between existing IEC based test and CPR performances due to the different test methods. Even though the basic structure of the test rig is the same, the different mounting and the use of new parameters makes the test results not comparable.
In case of doubts, professionals and consumers can be confident of the authenticity of the CE-marking by:
- asking to their national Contact Point for Construction.
- asking to the Notified Body, which is declared on the DoP and on the product label.
The list of national Product Contact Points for Construction is available to this link. Please check the NANDO database on the EU website for the updated list of Notified Bodies. Instructions are provided in the Chapter 5 of the Check-list
The following elements are necessary for the user:
- knowledge on the Euroclass requested by any national regulations for the defined building/construction works.
- Label which shows the CE marking with accompanying information related to the certification.
- Declaration of Performance from the supplier.
Almost all cable families will require reassessment and potential adjustment because of the existing levels of fire performances do not match the Classes B2ca, Cca or Dca.
Now, only reaction-to-fire performances are harmonized. Cables according with national and European standards remain unchanged except the declared reaction-to-fire performances.
There are presently no European harmonised provisions (prescriptions and supporting test methods) related to the release of dangerous substances applicable to cables. According to the EN 50575:2014, reference should be made to relevant national regulations, if any.
In countries where no national regulations (relevant for cables) exist, the mention of “No Performance Determined (NPD)” should be made in the DoP and no mention is then required on the CE Marking label.
Independently, the CPR requires that the information about the potential content of hazardous substances as may be declared in the framework of the Regulation (EC) No 1907/2006 (REACH) shall be provided together with the Declaration of Performance.
Each member state is required to set up a “contact point” where such information can be obtained.
The updated list of established contact points can be found at:
http://ec.europa.eu/DocsRoom/documents/10006/attachments/1/translations/en/renditions/native
F. Benefits of the CPR
CPR generates a higher level of safety for all European citizens because:
- Same level of safety for all end-users. National requirements are regulated and not just recommended.
- Safer solution for critical applications. National Regulators can rely on a sophisticated classification of performances to regulate the level of performance.
- Withdrawal of unsafe cables. Once a non-compliance is detected, National Authorities can impose the withdrawal of unsafe cables from the market.
Users of construction products can better define their performance demands because:
- the manufacturer takes full responsibility of the performance in the Declaration of Performance, which is a legally binding document - the consequence of non-conformity for the manufacturer can be devastating.
- the product's assessment and constancy assessment are defined by the Assessment and Verification of Constancy of Performance procedures and carried out by third parties.
- market surveillance is more efficient because you rely on one common information structure and on dedicated resources.
The Class of Reaction-to-Fire Table1 considers the entire behaviour of cables in fire, dynamically measured against time on real sized samples. This is an important step forward in fire safety and allows National Authorities to treat cables in a similar manner to other construction products already covered by the CPR.
The Class of Reaction-to-Fire table will become a standard feature of building regulations in Europe, though they are likely to be applied differently across the EU. Indeed, each country, under the principle of subsidiarity, will decide how these classes are to be used in its construction standards and/or regulations. It should be noted that it is not mandatory for classification to be introduced into National regulations and some countries may take the decision to address this issue in other ways.
These Classes will, however, certainly become a point of reference as, whatever their application, they will be common to all products. The performance level of the products defined by the classes will be clearly understood by all European decision-makers. The products brought to market will comply with strenuous testing requirements, and continue to ensure that the safety of persons, animals and goods in fire hazards can be protected.
1 COMMISSION DELEGATED REGULATION (EU) 2016/364 of 1 July 2015 on the classification of the reaction to fire performance of construction products pursuant to Regulation (EU) No 305/2011 of the European Parliament and of the Council – Table 4 – Classes of reaction to fire performance for electric cables.
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