The first and easiest place to start in understanding whether your product will comply is to look at its overall construction. Because we are dealing with lighting products and the carrying of electrical current over metal conducting material, or “live” current-carrying parts, you should always ensure that you’ve used a corrosion resistant metal or alloy such as silver, copper, copper alloy, plated iron or steel, or stainless steel. This may seem obvious to the product designer, but there are many products submitted each year to the major NRTLs that fail compliance on this basis alone.
EU Construction Products Regulation
By Dan Arnold, Sales Engineer
Product Safety Consulting Inc.
We hear from numerous manufacturers currently precluded from selling in the EU because their products are not CE marked. This is especially true of construction products, which are often sold under large contracts that specify CE marking. Construction products are a good example of a well-established Directive being transitioned to a Regulation, which we covered in a previous article. Construction Products Directive 89/106/EEC (CPD) was fully replaced by Construction Products Regulation 305/2011/EU (CPR) on 1 July 2013. The CPR has several interesting differences from the more common Directives and Regulations used for electrical products.
Instead of the more familiar Declaration of Conformity (DoC), the CPR requires a Declaration of Performance (DoP). Although basic information of DoC and DoP is the same, the DoP requires a declared performance level of essential characteristics. One example characteristic is compressive strength for some structural products. The essential characteristics are an important CPR concept and are in the harmonized standards for each construction product type or family. The performance levels of essential characteristics are intuitive for construction products, which must have physical integrity to function as intended over many years. Performance to at least one essential characteristic must be declared, but to be competitive and comply with the intent of harmonized standards, multiple characteristics are likely.
Another important attribute of the CPR are the Assessment and Verification of Constancy of Performance systems (AVCP systems). The AVCP is a surveillance mechanism to ensure the declared performance of essential characteristics is maintained. Each essential characteristic specified in a harmonized standard will have one of these AVCP system numbers assigned: 1+, 1, 2+, 3 or 4, from most to least comprehensive. System 1+ requires the manufacturer to maintain Factory Production Control (FPC) and periodically test samples. It also requires a Notified Body to assess product performance, initially inspect the manufacturing plant and FPC, periodically assess the FPC, and audit test the product. Conversely, AVCP system 4 only requires the manufacturer to assess performance and maintain FPC.
CE marking can be arduous for some construction products, but the legislation and compliance scheme is well established and generally intuitive, given the critical function of these products. Product Safety Consulting can help manufacturers understand the requirements and achieve CE compliance.
References:
https://ec.europa.eu/growth/sectors/construction/product-regulation_en
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Client A had been working with a NRTL for 15 months. Staff from the USA and Europe had also visited them at their facility multiple times only to be sent construction letter after construction letter. Once they heard from the engineer that the project was in for final review but nope, only to be sent another construction review letter outlining brand new items that would not be accepted.
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We reviewed the latest two construction letters, went online and ordered a Certified Wiring Harness and various components, contacted the NRTL and presented the changes and reached agreement, flew to Europe and updated the construction, help modify the NRTL draft report, submitted the revised report, photos and illustrations to NRTL and 7 days later we were scheduling the IPI inspection for this brand new client for this NRTL. Total work time was 15 business days.
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