Strengthening the Construction Products Regulation for greater efficiency and sustainability

3. Simplify burdensome procedures with limited added value

While some improvements to the current system may be achieved thanks to improved guidance, Glass for Europe is of the opinion that a revision of the CPR would be needed to revisit certain clauses and simplify certain provisions. In this regard, Glass for Europe supports many suggestions contained under Option B ‘Repairing the CPR’ put forward in the consultation document.

Specifically, the following should be envisaged:

• A revision of article 9.2 should allow for a lighter CE label that does not duplicate the information already contained in the DoP. For certain products, duplicating all DoP information on the CE label is of no added value since this information is needed neither in shops nor on construction sites. Glass for Europe calls for a revision of article 9.2 so that the mandatory information to be given in the CE-label can be set by families of products, in collaboration with the relevant CEN technical committee. Digital tools such as QR codes can be incorporated on the label to easily retrieve the DoP.

• The simplified procedure put in place by article 37 for micro-enterprises is useless since these companies do not have the skills nor the equipment to carry the required tests themselves or to justify the use of another test method. This article should be deleted, and all standards should favour less onerous although reliable methods as well as tabulated values when relevant.

• Both articles 38 and 5a on rules applicable to ‘small series’ are ineffective in practice. Conditions are almost impossible to apply in many families of products. The CEN technical committee should be allowed to define the concept of small series for its family of products, when appropriate, and to include this definition in the relevant hEN.

• The rules for setting new classes and thresholds or for modifying them shall be clarified and the procedure simplified. If “pass/failed” cannot be used anymore, alternative terms (e.g. “confirmed”, “compliant”…) shall be agreed upon and communicated to the TCs, particularly when the declaration of a specific value is technically not grounded nor possible. The reintroduction of the concept of “conformity” may also help solving this issue.

• In annex V, notified bodies are mandated to determine the product-type based on type calculation and tabulated values, among other methods. It should be allowed that when an EN standard providing a calculation method is published, the notified body’s task is reduced to the validation of this calculation method. In the case of tabulated values provided in the standard, the notified body should not determine it again.

Apparent simplification should not indirectly contribute to market segmentation. For instance, Glass for Europe is opposed to the idea of reducing or lifting Assessment and Verification of Constancy of Performance (AVCP) obligations in case of coverage by liability insurance. Because of the inevitable danger that some producer’s commitment wanes over time, insurance companies will turn to private, national certification schemes for additional assurance. These would then multiply and suppress all benefits of the single market. 

4. Utilize the CPR as a driver of sustainability in the construction sector

Glass for Europe is a strong supporter of a massive shift in the construction sector to evolve towards greater sustainability and the achievements of the ‘New Green Deal’. The building glass sector, thanks to its recyclable products that offer massive energy and CO2 savings over their lifetimes is committed to further reducing all impacts of its activity[3].

Glass for Europe is supportive of the introduction of mandatory minimum requirements for construction products per type of product to protect consumers, to safeguard the environment and to enhance safety. Yet, a product CE mark cannot be a guarantee that the product is compliant with the national regulation of any given EU country. Regulations on the energy performance of buildings and safety for example, are of national competence. CE marking can ensure conformity with the declared performances only.

Glass for Europe calls for the EN 15804+A2 approach to be embraced as the harmonized method for assessing and communicating construction products’ environmental performance. This should be done as rapidly as possible to halt today’s multiplication of Environmental Product Declaration (EPD) methods across countries. EN 15804+A2 would offer the possibility to calculate in a harmonized way the environmental impacts of a building at all life stages. The in-use phase should be considered as it is essential to exhibit the different levels of performances and benefits of products[4].