A. Scope
The Construction Product Regulation (CPR) 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 with Euro-Classifications making possible the comparison of their performances from different manufacturers in different countries.
These methods are compiled in harmonised standards (or sometimes, 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 for fixed installations.
Further information can be found at:
http://ec.europa.eu/growth/sectors/construction/product-regulation/index_en.htm
Construction Products Regulation No 305/2011 of 9 March 2011.
The performances of cables included under the CPR are:
- reaction to fire – currently active.
- resistance to fire – under consideration / in preparation.
- release of dangerous substances in normal operation, dismantling and recycling.
Notes:
Resistance to fire requirements for cables are still in the process of being developed and hence this requirement is not currently active.
The release of dangerous substances does not include the substances released during fire.
Cables for permanent installation in construction works and civil engineering structures, within the scope of the cited harmonised product standards developed under Mandate M/443 EU, 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.
Following completion of the consideration of performance requirements for resistance to fire, and the citation of a harmonised product standard, additional cable types are expected to be:
- 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 installations.
Cables for permanent installation are considered those which are not specifically designed for temporary installation only.
Certain classes of cable such as those providing control and power circuits inside machinery, lift cables or other cables specifically designed for use in industrial processes carried out in industrial premises and are not part of the Mandate M/443 EU, are excluded.
Note:
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.
Yes, indeed. All cables intended to be installed permanently in constructions must be CE marked in order to be legally supplied. National Regulators may define for particular 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 a specific construction. In such a case the length of cable should be as short as possible and connected in the fire compartment it first enters or be protected from fire.
For information technology applications the standard EN 50174-2 may apply.
EN 50174-2:2018 – 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.
Note: Classes of performance higher than Euroclass Eca may be specified in Member State regulations.
It is important that any cables used in prefilled conduits and pre-connected systems comply:
- if the prefilled conduits’ and pre-connected systems’ final application is in construction and civil engineering works subject to reaction to fire requirements; or,
- 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.
The CPR does not make distinctions based on rated voltage and therefore all cables installed permanently in constructions are subject to the Regulation, irrespective of operating voltage. Indeed, optical fibre cables are also covered.
CPR is intended to cover both reaction to fire and resistance to fire performances, but so far the harmonized standard EN 50575, covering only reaction to fire, is available and has been cited in the OJEU. Therefore, the fire resistance and reaction to fire performance of fire resistant cables cannot currently be classified under the CPR. However, individual member states may adopt and apply their own local requirements for the fire properties of fire resistant cables at the present time.
For now, only reaction to fire performances are harmonized. Cables manufactured according to national and European standards remain unchanged except for the declared reaction to fire performances.
No, cables with connectors fitted are outside of the scope of CPR.
B. Definitions
The manufacturer is any natural or legal person who manufacturers a construction product and places it on the market in the EU. It may be the actual manufacturer or an importer.
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 harmonized Product Standard.
See also these FAQs, section D. Declaration of Performance (DoP)
Construction works means buildings and civil engineering works.
Some member states have set a more precise definition in national regulations.
A non-exhaustive list is the following:
- residential, industrial, commercial and office buildings;
- hospitals, schools, recreational centres and agricultural buildings;
- roads and highways, bridges, tunnels, railways, pipeline networks;
- stadiums, swimming pools;
- piers, docks, basins, sluices, channels, dams, towers, tanks.
- relevant parts of other installations such as solar farms.
C. Obligations of economic operators
The testing / certification procedure for CPR is in addition to any current voluntary Quality Marks. The severity of this burden is greater, the higher the level of performance declared. Tests required are more sophisticated moving up from Class Eca to Dca and higher (from small size flame test to full size fire scenario). Routines of continuous surveillance to certify the conformity to the DoP of the full production of Class Cca and B2ca cables under AVCP System 1+ is particularly strict and costly. The implementation of CPR impacts many company functions including technical, manufacturing, logistics, quality management and IT.
The new marking, labelling and electronic distribution of the DoPs has required a significant investment to ensure the compliant alignment of these new documents and texts for all applicable products and to provide availability of the documents to end-users. The CPR has also obliged suppliers to apply of new labelling onto all applicable products. In addition, DoPs have to remain available for 10 years after the production or a cable has ceased.
Most cables of Classes Dca and above required a full redesign to ensure the conformity of all types to the DoP. New materials have been developed in order to meet the requirements of the CPR performance classes and the additional classification requirements such as the production of flaming droplets.
For all cables of every level of performance there are severe consequences in case of non-conformity, including possible total withdrawal of the product from the market.
The CPR should be applied without differences of interpretation by each Member State. The classification of performance is the common language to define the level of fire performance of cables (reaction to fire, and in future resistance to fire) and to be used in local regulations and in user requirements.
Any decision on which class to adopt for a particular application is a Member State matter and may vary between different Member States. The wide range of combinations of the parameters for reaction to fire (Class + smoke + acidity + droplets) gives the Member States a great flexibility.
Not every Member State regulates the fire performances of cables when they are used.
The obligations of manufacturers are set out in Article 11 of the CPR as follows:
When a product is covered by a harmonised standard, the manufacturer shall draw up and keep available for 10 years the Declaration of Performance (DoP) and affix the CE marking.
Manufacturers shall ensure that their registered trade mark, contact address, elements allowing their identification and instructions and safety information are available as required on their products, packaging and/or documentation.
Manufacturers shall ensure that series production maintains the declared performance. 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, to withdraw or recall it.
Yes, indeed. The preface to the CPR describes the general obligation of distributors as follows:
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.
Moreover, distributors are subjected to obligations defined in Chapter III of the CPR.
When a distributor places on the market a product under his own name the distributor is considered a manufacturer.
Importers and Legal Representatives are also subjected to obligations defined in Chapter III of the CPR.
Yes. Public undertaking private operators (e.g. railway network operators or power and telecom network operators) should adapt their specification on cables to the CPR language, switching references from older reaction to fire test methods to the classes defined by the CPR. That requirement descends from Article 8.5 of the CPR (General principles and use of CE marking), which states that Member States 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.
Almost all cable families have required reassessment, and some receive adjustment to manufacturing processes to ensure that their fire performance will match the requirements of the new classes, particularly for classes B2ca, Cca and Dca.
Manufacturers are obliged to put in place a system to assess the ongoing conformity of their products to their declared performances.
Under AVCP 1+ for classes Cca and higher, the Notified Body undertakes periodic retesting and other checks on product performance. Should performance degrade, the Notified Body takes action with the manufacturer to bring the product back into compliance with the declared performance, or certification may be withdrawn.
For any class of performance, national market surveillance authorities are responsible for following up any cases of non-compliance.
D. Declaration of Performances (DoP)
The manufacturer, by drawing up a 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 their own responsibility, makes their decision as to whether to purchase the product if it is suitable for the application intended.
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). For reaction to fire for cables, applicable AVCP levels are 1+, 3 or 4, depending on the class of performance declared.
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 the DoP which is consequently accurate and reliable.
Further information can be found in the Delegated Regulation No 574/2014 of 21 February 2014 on the model to be used for drawing up a declaration of performance on construction products, which may be found at:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014R0574
The DoP shall be made available to users of the product (e.g., through a website) and shall be provided in the language or the languages required by the Member State where the product is made available, and on request, either in paper or in electronic form.
Based on the information on the product label and in the DoP, each product is intended to be fully traceable to the manufacturer. Market surveillance authorities in each Member State are responsible for following up on any non-compliances.
No, under CPR, the only document that the end user is entitled to a copy of is the DoP for the product, in addition to any safety or related information the manufacturer chooses to provide.
E. CE marking
Since 1st July 2017 the CE marking of cables for building and construction works has been mandatory for reaction to fire.
CE marking for resistance to fire will begin once a harmonised product standard covering this performance is published and cited in the OJEU. See section F. MEMBER STATE APPLICATION OF CPR
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 to trade among the Member States arising from the definition of fire performances, as well as the uniform modality to attest the conformity of cables.
Voluntary national or regional 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 or national quality marks is misleading because they are complementary.
Yes, indeed. A single CE mark is intended to cover all applicable directives / regulations. Under the CPR the CE mark must be accompanied, in the same place, by certain detailed information which it is not possible in practice to print directly onto the cable. Printing on the cable only the CE mark, without the necessary accompanying information, may be deemed to not legally comply with the requirements.
This is the date when the CE mark was first affixed to a product. It is NOT the date of production of the cable.
The CPR requirements apply to all cables placed on the market in the EU irrespective of the country of production.
In case of doubts, professionals and consumers can be confirmed of the authenticity of the CE-marking:
- asking their national Contact Point for Construction; or,
- asking the Notified Body whose number is stated on the DoP and on the product label.
The list of National Product Contact Points for Construction may be found here:
Details of all Notified Bodies may be found in the NANDO database (select Product Family: Power, control and communication cables) here:
https://webgate.ec.europa.eu/single-market-compliance-space/#/notified-bodies
Yes, but conversely it is not allowed to use cables without the appropriate CE marking in cases where the application is regulated in the Member State.
Yes, the CE mark has validity across the European Union. However, the DoP and other relevant information must be supplied in a language appropriate for the country to which it is supplied.
There are presently no European harmonised provisions (prescriptions and supporting test methods) related to the release of dangerous substances applicable to cables. According with the EN 50575:2014+A1:2016, 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.
Yes, voluntary quality marks are allowed. CPR is a compliance not a quality mark and covers only the reaction to fire (and in future, resistance to fire) characteristics of cables. Voluntary national or regional quality marks (e.g., the HAR mark) will remain important as they cover performance aspects different from those covered by the CPR, for example, the electrical, mechanical, and material characteristics of the cable, and may define other cable designations (e.g., H05VV-F). Other quality marks integrate a more complete coverage of performance aspects.
In the context of the CPR, there can be no conflicting standards applied by Member States – for CE marking reference may only be made to the cited EN standards. Fire certification to IEC, CENELEC or national standards, or to other standards, will continue, but only for applications outside the scope of CPR (building and construction) or for use outside the EU.
LVD requires a Declaration of Conformity, CPR requires a Declaration of Performance. Therefore, one CE marking and two separate declarations are needed.
The Annex ZZ of the harmonised product standard (for reaction to fire, EN 50575:2014+A1:2016) sets the CE marking (and all the necessary additional regulatory information) to be affixed to the product labels.
Cables forwarded in the original packaging already carry the proper CE marking. In view of the specific nature of the product cable, the fulfilment of the obligation to forward the CE marking to the end-user is set by the CPR for manufacturers and all economic operators down to the supply chain, is possible exclusively through labels or accompanying documents such as the DoP. To print additional information on cables (e.g. the DoP code) doesn’t fulfil the obligation to forward the CE marking to end-users and it is not possible for a large set of cables.
F. Application of the CPR for cables
Each member state is required to set up a “national product contact point” where such information can be obtained. The list of contact points may be found at:
The following elements are necessary for the user:
- Knowledge on the class of performance required by any national regulations for the defined building or construction works. See Q38.
- CE marking with accompanying information related to the certification.
- Declaration of performance from the supplier.
The installation of products does not fall under the scope of the CPR. Normally it is not necessary to review existing installations. National Regulations may set rules about existing and new installations as well as special cases e.g., projects started before and completed after the date of application of the CPR.
Only Class Eca and Class Fca are defined with reference to the single cable flame propagation test (IEC) EN 60332-1-2 (respectively meeting, or not meeting, the required maximum extent of propagation).
For the other classes, particularly classes Dca to B2ca, there is not a direct relationship between existing IEC based tests and CPR performance classes due to the use of different test methods (EN 50399 for CPR). Even though the basic structure of the test rig is similar, the different mounting arrangements and the measurement of new parameters makes the test results not directly comparable.
Not for applications in building and construction works. Their use may continue for applications outside the scope of CPR.
Only Notified Bodies based in the EU may conduct work for manufacturers wishing to make declarations and CE mark product for the EU market. Declarations made on the basis of work by former Notified Bodies based in the UK are no longer valid for this purpose. The UK now has its own CPR system that is separate from the EU system.
G. Benefits of the CPR
CPR generated a higher level of safety for all European citizens because:
- Consistent levels of safety for end-users. National requirements are regulated and not just recommended.
- By creating classes of performance based on the assessment of different performances (flame/fire propagation, heat release, emission of smoke, flaming droplets, acidity) national regulators can better adapt local requirement to the fire safety risks for different applications or types of building.
- 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 legal binding document (the consequence of a non-conformity for the manufacturer can be devastating).
- The product assessment and constancy assessment are defined by the Assessment and Verification of Constancy of Performance procedures and carried out by third party bodies.
- Market surveillance is more efficient because can rely on one common information structure and on dedicated resources.
The classes of reaction to fire (see Note) considers the entire behaviour of cables in fire, dynamically measured against time on real size 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 classes of reaction to fire have become a standard feature of building regulations in Europe, though they are applied differently across Member States. Indeed, each country, under the principle of subsidiarity, decides how these classes are to be used in its mandated construction codes, 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 for cables become a point of reference as, whatever their application, they will be common to and declared with all products. The performance level of the products defined by the classes will be clearly understood by all European decision makers. 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.
Note: 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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