CPR – FAQ

This paper reflects the best knowledge of industry experts across Europe at the time of writing (September 2018). It represents our best understanding of the CPR. It is not a legally binding document and is not intended as a substitute for each stakeholder’s own assessment and decision making. A binding interpretation of European Union legislation remains the exclusive competence of the European Court of Justice. Europacable declines any and all liability for any measure taken or not taken on the basis of this document, which is a private non-binding information document to be possibly used and accommodated by National Associations to prepare their own national documents.
© 2018 Europacable – All rights reserved.

  • A. SCOPE

  • Q01: What is the purpose of the CPR?

    The Construction Products Regulation (CPR)1 provides harmonized conditions for the marketing of construction products in relation to their performances. 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

  • Q02: What performances of cables are covered by the CPR?

    The performances of cables included under the CPR are

    • reaction to fire
    • resistance to fire1
    • release of dangerous substances in normal operation2, dismantling and recycling.

    1 Under consideration

    2 not including performances during fire

  • Q03: Which cables are included under the CPR?

    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. 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
    2 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

  • Q04: Which is the definition of industrial processes carried out in industrial premises?

    Cables for direct connection of machines and units, without handing over to a distribution point,
    are not concerned by the Construction Products Regulation. This are for example instrumentation and thermocouple cables, drag chain or engine connection cables.

    Cables with intended use to provide power to industrial buildings and the inside placed units generally falls under the Construction Products Regulation and should be classified.

  • Q05: Do cables in prefilled conduits and pre-connected systems have to be CE marked?

    CMS and pre-connected systems are not under CPR, but it is important that any cables within pre-assembled wiring should comply:

    • if the prefilled conduits’ and pre-connected system 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.
  • Q06: Is CE marking mandatory for an outdoor cable entering a building?

    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 of what 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.

    1 EN50174-2:2018 – 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

  • Q07: Which is the max rated voltage that is considered for general applications and therefore in the scope of EN50575:2014+A1:2016?

    The CPR does not make distinctions based on rated voltage and therefore all cables installed permanently in constructions are subject to the Regulation. However, special applications are excluded from the scope of EN 50575. Therefore, in some countries, National Regulators may define a maximum rated voltage, above which an application is considered as a Special Application, not falling in the scope of EN 50575:2014+A1:2016.

  • Q08: Do fire resistant cables fall under the CPR? And, in case, is it possible to CE mark them?

    CPR covers both reaction to fire and resistance to fire performances, but so far only the harmonized standard EN 50575 for reaction to fire is available. Therefore, fire resistant cables cannot be certified under the CPR until the dedicated harmonized standard will be issued and published on the OJ of the EU. It is therefore so far forbidden to CE mark and issue a DoP for fire resistant cables.

  • B. DEFINITIONS

  • Q09: Under the CPR, who is the manufacturer?

    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.

  • Q10: What is the definition of “Construction works”?

    When referring to cables, construction works are considered as buildings and other civil engineering works subject to regulation regarding safety in case of fire, including the objective of limiting the generation and spread of fire and smoke.

  • Q11: What is a Declaration of Performance (DoP)?

    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 Standard1

    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. OBBLIGATIONS OF ECONOMIC OPERATORS

  • Q12: Which additional burdens are imposed by the CPR on the industry?
    1. 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
    1. 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 obliges to add new labels on products. DoPs have to be maintained available for 10 years after the stop of production
    2. 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
    3. 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
  • Q13: What will be common in Europe and what specific by country in the application of the CPR?

    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 and in future Resistance to Fire) 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.

  • Q14: What are the obligations of the manufacturer under the CPR?

    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, to withdraw or recall it

  • Q15: Is the wholesaler / distributor responsible of the application of the CPR?

    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 CPR2

    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

  • Q16: Are public undertaking private Operators obliged to adopt the CPR Classification in their specifications of cables for permanent installation in constructions?

    Yes. Public undertaking private Operators (e.g. rail-way 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)

  • Q17: What is the purpose of the 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

  • Q18: What is the basis of the DoP?

    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

  • Q19: How is the DoP made available?

    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

  • Q20: When CE marking of cables begins? When shall a cable bear the CE marking under the CPR?

    Since 1st July 2017 the CE marking of cables for construction works is mandatory

  • Q21: After the start of application of the CPR, is it necessary to review existing installations to reach the level required by national regulations?

    The installation of product doesn’t fall under the scope of the CPR. Normally it is not necessary to review existing installations. National Regulations can 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

  • Q22: Will the existing fire certification survive?

    Yes, but only for applications outside the scope of CPR like industrial applications or outside the EU.

  • Q23: Will the local quality mark survive?

    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.

  • Q24: Can voluntary quality marks still be used on CE marked product?

    Yes, voluntary certification marks are allowed, but they should not cover fire related performance of cables covered by the CPR.

  • Q25: Is CE marking more or less important compared with my national quality mark?

    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.

  • Q26: Which Class of Reaction-to-Fire corresponds to IEC60332 series test?

    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 max 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.

  • Q27: Is it possible to combine CPR and LVD declarations?

    No because LVD requires a Declaration of Conformity and CPR requires a Declaration of Performance, the two should be kept separate.  However, the CE mark on the CPR label would also cover LVD but not the other way

  • Q28: If a product is already CE marked under the LVD on the product itself, does this marking should be discontinued to comply with the EN 50575:2014 + A1:2016 requirement that the CE mark should be on the label?

    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 on the cable. Printing on the cable only the CE mark without the accompanying info might then be illegal.

  • Q29: How will the CE mark be applied to cables?

    In view of the specific nature of the product cable1  the fulfilment of the obligation to forward the CE mark to the end-user set by the CPR is possible exclusively through labels or accompanying documents. There is no information additional to what already present on cables that can fulfil the obligation and the spirit of the obligation

    Therefore, the Annex ZZ of the mandate Standard EN50575:2014 sets the CE marking (and all the regulatory additional information2) to be affixed visibly, legibly and indelibly to the product labels affixed to the reels, coils or drums of the power, control and communication cables. Cables forwarded in the original packaging already hold the proper CE marking.

    1 The specific nature of cables makes impossible to adopt the same criteria of marking for cables of completely different size and material, to fit a huge list of information in the normal reasonable length of repetition of information on the cables

    2 Article 9 of the CPR defines that the CE mark shall be followed by:

    • the two last digits of the year in which it was first affixed,
    • the name and the registered address of the manufacturer, or the identifying mark allowing identification of the name and address of the manufacturer easily and without any ambiguity,
    • the unique identification code of the product-type,
    • the reference number of the declaration of performance,
    • the level or class of the performance declared,
    • the reference to the harmonised technical specification applied,
    • the identification number of the notified body, if applicable, and
    • the intended use as laid down in the harmonised technical specification applied
  • Q30: What is the meaning of “year when marking first affixed”?

    This is the date when the CE mark was first affixed to a product. It is NOT the date of production of the cable.

  • Q31: How do CPR requirements affect cable imported from outside the EU?

    The CPR requirements will apply to all cables placed on the market in the EU independently from the country of production.

  • Q32: How can a customer recognize a genuine CE-marked cable?

    In case of doubts, professionals and consumers can be confirmed of the authenticity of the CE-marking:

    • 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 Point for Construction and of all Notified Bodies (NANDO; please select Product Family: Power, control and communication cables) is available on the EU website.

  • Q33: Can I use CE marked cables in non-construction applications?

    Yes, but conversely it is not allowed to use cables without the appropriate CE marking in cases where the application is regulated in the Country.

  • Q34: Can I use in my Country a cable CE marked in another Country?

    Yes, the CE marking has a EU validity.

  • Q35: How can the User know that a product is correct for applications under the CPR?

    The following elements are necessary for the user:

    • knowledge on the Euroclass requested by any national regulations for the defined building/construction works
    • CE marking with accompanying information related to the certification
    • declaration of performance from the supplier
  • Q36: How will cables change?

    Almost all cable families will require reassessment and potential adjustment because the existing levels

    of fire performances, do not match the Classes B2ca, Cca or Dca.

  • Q37: Will all European cables be harmonized?

    Now, only reaction-to-fire performances are harmonized. Cables according with national and European standards remain unchanged except the declared reaction-to-fire performances.

  • Q38: How is the declaration of performance in relation to the release of dangerous substances to be dealt with?

    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, 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.

  • Q39: Where can you obtain information on requirements for a specific product in a specific member state?

    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

  • Q40: What benefits does CPR generate for European population?

    CPR generated 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 detected a non-compliancy, 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 products 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
  • Q41: Fire performances are already available. Which added value the CPR and new rules and regulations are contributing?

    The Class of Reaction-to-Fire Table1 considers the entire behavior 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 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