The new CE Marking regulations, which came into force in July 2013, have shone a spotlight on product testing and labelling. But what does this really mean for merchants and their customers - particularly when it comes to imported materials? Phil Beer, Head of Special Projects at Natural Paving Products (UK) Ltd, gives the lowdown on merchants' responsibilities and how to spot incorrect or even fraudulent labelling.
The introduction of the Construction Products Regulation (CPR) brings one of the most significant changes the industry has seen to the way construction products are sold in Europe. For merchants, the regulations present a new set of legal obligations that must be adhered to, so it is really essential that they get to grips with their new responsibilities quickly.
A key part of this is ensuring that the CE Marks on the products they stock are genuine. Imported products in particular can be subject to less rigorous quality checks, so it’s useful to work with suppliers that have full control over the supply process from sourcing the raw materials, to final delivery of products.
Under the new rules, it is mandatory that all products covered by a Harmonised European Standard (HEN) or European Technical Assessment (ETA) undergo rigorous testing and carry CE Marks to state their performance characteristics.
Unfortunately, the significant cost attached to becoming fully CE Marked has led some smaller players in the Indian natural stone market, who don’t belong to ethical trading memberships, to apply false labels to their pallets and products.
Investing in the correct procedure is a substantial commitment and we’ve seen at least six competitors issuing incorrect CE labels. Compliant labels should provide test results or give details of where to obtain these, such as a web address. A good test for merchants would be to request a copy of the results from their supplier, as this should be readily available if the proper procedure has been followed.
For example, at Natural Paving Products, significant time and more than £200,000 has been invested in the process of CE Marking our products, which included comprehensive testing, the introduction of factory production controls and the production of a detailed Declaration of Performance (DoP) for each product, as well as redesigning and reprinting all packaging to reflect the test results.
Tests conducted across the product ranges include: flexural strength, which tests the breaking point of the stone; freeze thaw resistance; slip resistance in both wet and dry conditions; compressive strength and abrasion testing.
Merchants’ main responsibilities under the new regulations are to ensure that all products bear the correct CE Mark and are accompanied by the correct documentation, DoP, application instructions and safety information written in English. They must also ensure that the manufacturer and importer have complied with their requirements to apply a type, batch and serial number to the product.
Merchants must pass on all necessary documentation at the point of sale and if they believe that a product does not conform to its DoP, they have a responsibility to withdraw that product from sale. Finally, merchants must maintain records for a period of 10 years so that they can provide the market surveillance authority (trading Standards in England, Wales and Scotland and the Environmental Health Authority for Northern Ireland) with the contact details of construction products suppliers and the customers that purchase them.
As with any new legislation, there will be some adjustment required in the short term but in the long run the new regulations will bring much greater clarity and confidence to both merchants and their customers. Critically, CE Marking will make detailed information about products’ real performance readily available, meaning customers can make more informed specification choices – not to mention giving merchants more opportunities to upsell and increase margin where possible.Click here to go back to the latest news.