What is a construction product?
Two criteria must be met for products to be defined as construction products:
1. The product is placed on the market for incorporation in a permanent manner in construction works or parts thereof.
2. The product must also influence the basic requirements of construction works, which are:
- Mechanical resistance and stability
- Fire safety
- Hygiene, health, and environment
- Safety and accessibility in use
- Protection against noise
- Energy-saving and heat insulation
Why should manufacturers document construction products?
Knowing the performances of construction products before using it in construction works
Construction products are not end-use products. They will be incorporated into construction works. It is, therefore, crucial to know the performances of construction products to ensure that construction works meet the technical requirements specified by the Building Code.
CE-marking ensures free access to the EEA market
CE-marking is proof that a construction product complies with the Construction Product Regulation. This means that the product can be sold freely throughout the entire EEA. CE-marked construction products from other EEA countries shall freely be sold in the EEA agreement, included Norway.
This does not automatically imply that the construction product can be used in Norwegian buildings. It is always necessary to check whether the performances of construction products are sufficient for the building to comply with the technical requirements in the Building Regulations.
How to document the performances of construction products
CE-marking is mandatory for all construction products for which a harmonised product standard exists.
A harmonised product standard is a standard developed by the European Standardisation Organisation (CEN/CENELEC) according to a mandate from the European Commission concerning the CE marking of construction products. These harmonised product standards set therefore requirements and test methods to assess the performances of construction products covered by the scope of these harmonised product standards.
Not all construction products have a CE-mark. This applies to construction products that are not covered by a harmonized product standard to document the product performance.
The manufacturer can then choose to CE-mark a construction product by obtaining a European Technical Approval (ETA). This is completely voluntary. The advantage is that the manufacturer can freely sell his product throughout the EU/EEA area.
If the manufacturer chooses not to CE-mark the construction product they will still have to document the relevant essential characteristics of the product.
How do I get an ETA?
- A manufacturer asks a Technical Approval Body to make a European Technical Assessment (ETA) for their product.
- An ETA is prepared based on an existing European Assessment Document (EAD). If an EAD does not already exist, the technical assessment body must prepare a new one.
- The Declaration of performance and CE-marking are prepared based on the ETA.
CE-marking and Declaration of performance
CE marking and Declaration of performance
CE marking and the declaration of performance is mandatory for all construction products covered by a harmonised product standard or by a European Technical Assessment.
What is CE-marking?
The CE marking is applied to the construction product. If the manufacturer is unable to place all the information required for the CE marking on the construction product or packaging itself, the CE marking must be applied to an accompanying document. In this case, it can be combined with the declaration of performance.
The CE marking shall always refer to the reference number of the Declaration of Performance.
There are no language requirements for the CE marking.
What is the Declaration of performance?
The Declaration of performance is a document describing the performance of the product in detail. In the harmonised standard you will find a list of their required content.
The Declaration of performance must either:
- Accompany the construction product as hard copy
- Accompany the construction product electronically (as an attachment to an email or useing documentation solutions such as NOBB or productXchange, for example)
- Be published on a website that manufacturers referred to
If the manufacturer applies a QR code to the construction product with a link to the declaration of performance, purchasers may view the declaration of performance immediately. This means that the declaration of performance is, in a way, supplied with the construction product. The manufacturer may also publish the declaration of performance on a website. The manufacturer shall then provide information on where the declaration of performance can be downloaded. Information will normally be provided on the CE label.
All construction products on the Norwegian market shall have a Declaration of performance in Norwegian, Swedish or Danish.
Requirements for non CE-marked construction products
Mutual recognition and national regulations
Products not bearing the CE-marking are not covered by the Construction Product Regulation. These products are, however, subject to the mutual recognition principle and eventually national requirements. The EEA agreement, which Norway is a part of, ensures the free movement of products throughout the entire EEA. Construction products, which are not CE marked, may be sold in Norway as long as they meet the documentation requirement for sale of such products in Norway. You can find these requirements in the Norwegian regulation on the sales and documentation of products for construction works, chapter III.
National regulation of non CE-marked construction products
Non CE-marked construction products are of the same significance to construction works as CE-marked construction products. Therefore, these construction products must also have documented characteristics and performances.
In Norway, the requirements for documentation of non CE-marked construction products are:
- The relevant essential characteristics
- The name and contact information of the manufacturer/importer/distributor
- The technical specification, which is used, e.g. a national standard or a national approval from an EU/EFTA state
- The system used for assessment and verification of the product and the name of the eventual independent assessment body
There are no specific requirements regarding the layout of such documentation. It could be appropriate to have a document comparable to a Declaration of performance.
The product documentation must be in Norwegian, Swedish or Danish.
Reports and certificates from technical control bodies and/or other accredited bodies shall be accepted on an equal footing with Norwegian reports and certificates. The technical documentation does not have to be in Norwegian.
What kind of performances should the manufacturer declare?
To allow the user to assess the performances of the construction product it is preferable to declare as many performances as possible. There is no requirement for manufacturers to specify all the performances of a construction product. Manufacturers may sell a construction product as long as at least one performance is declared.
An essential characteristic for which the manufacturer provides no performance the characteristic should be declared as "NPD" (No Performance Determined). However, manufacturers are obliged to specify the performances expressed in terms of class or threshold as defined in harmonised product standards or European assessment documents. If the Norwegian Building Regulation specifies requirements for the performances of a construction product it is also essential to declare the performance of the product.
Information about dangerous substances shall be declared
Some construction products contain dangerous substances. It is, for instance, possible to find brominated flame retardants in building boards, wall panels, and insulation materials. It is also possible to find Bisphenol A in adhesives, sealants, outdoor paint, windows, and doors.
Manufacturers must provide users with information on the content of dangerous substances if the concentration of dangerous substances in construction products exceeds a certain level, cf. the REACH Regulation and the Construction Product Regulation.
How do manufacturers provide information on dangerous substances?
It is important to differentiate between substances/mixtures of substances and other construction products.
Manufacturers have to prepare safety data sheets for substances/mixtures (such as paint, adhesive, lacquer). Manufacturers must also provide information on the content of dangerous substances for other solid construction products (windows, building boards, impregnated timber), which contain hazardous substances.
No format is specified for this, unlike substances/mixtures for which manufacturers have to draw safety data sheets. It is up to the manufacturer to determine how to specify the content of dangerous substances.
The Construction Product Regulation article 6 states that information under REACH art. 31 and 32 shall be provided together with the declaration of performance. This means that the manufacturer must inform about the content of the particularly hazardous substances that are on the candidate list according to REACH. The information must be provided in the declaration of performance or as an additional document to the declaration of performance.
Some of the harmonised standards also contain information on hazardous substances. In such cases, it is important to use the description in the standard.