Construction products

The EU Construction Products Regulation (EU CPR) of 9 March 2011 sets out harmonized conditions for the distribution of construction products in the EU. The Regulation is now to be thoroughly revised and adapted better to the current needs of the market. An important step with respect to occupational safety and health is that the draft regulation now also makes provision in annex I B/C/D for requirements regarding product safety, the circular economy and the information to be provided by product manufacturers.

However, the technical requirements stated in the Regulation take effect only once the European Commission has adopted delegated acts. These specify requirements for individual product families and categories together with the corresponding test procedures, and form the basis for standardization mandates.

The occupational safety and health lobby regards delegated acts as an unsuitable legal instrument for determining whether or not product safety should be considered; consequently, where no delegated act is adopted, it follows that product safety requirements are not set out. Based upon the practice followed with other regulations, use of the delegated act is more appropriate for supplementing and adjusting certain requirements.

To increase the binding force of these requirements, it is crucial that a directly applicable general requirement for product safety (making reference to Annex I) be added to the draft. This would enable standards development to respond swiftly and without the separate coordination process associated with a delegated act.

KAN has formulated a common position on the draft Construction Products Regulation and will present it during further negotiations at European level. This position particularly addresses the function of delegated acts and calls for product safety requirements to be enshrined in the Regulation in such a way that they can be transposed directly in standardization mandates and standards. 

KAN Position on the legislative proposal of the European Commission for the construction products regulation

KAN argumentation paper concerning product safety of construction products 

Do you have any questions on this topic, or need support? If so, please contact Michael Robert.