SECTOR INSIGHT
Entry into force of the new EU-CPR
January 2024 |
12 months after entry into force |
24 months after entry into force |
15 years after entry into force |
New EU-CPR articles and paragraphs relevant for the development of standardisation requests and EADs apply . |
Remaining new EU-CPR articles apply
Parts of the current EU-CPR are repealed .
|
New EU-CPR Article 92 on penalties applies . |
The whole of the current CPR is repealed . |
• The CE marking may be subsequently followed by a pictogram or other mark indicating a special risk or use .
• There will be a number of new obligations for manufacturers , some of which are laid out as below :
• The manufacturer shall ensure that the product ’ s performance is assessed in relation to its essential characteristics laid down in harmonised European Standards ( hENs ) or European Assessment Documents plus any additional requirements set under delegated and implementing acts .
• Manufacturers , where deemed appropriate , are to carry out sample testing of products to ensure the accuracy , reliability and stability of the declared performance and of the conformity of the product , investigate and if necessary keep a register of complaints of non-conforming products and product recalls and shall keep importers and distributors so informed .
• 3D-printing – manufacturers using 3D-printing need to satisfy obligations incumbent on manufacturers when placing product on the market .
• Where applicable , manufacturers to ensure availability of spare parts not commonly available in the market .
• If a manufacturer considers or has reason to believe that a product they placed on the market is not in conformity with its declared performance or in compliance with the Regulation , they shall immediately take corrective measures to bring the product into conformity or withdraw or recall it .
UK Market impact In terms of how these changes may impact the UK market it should be noted that the existing UK Construction Product Regulation entitled “ Construction Products ( Amendment etc .) ( EU Exit ) Regulations 2020 ” is based upon the existing European CPR . Should the UK CPR continue to be used , or be replaced with a revised version then this would mean a divergence from the EU as both jurisdictions would have differing regulations .
To complicate matters further the original Northern Ireland Protocol ( and now the Windsor Framework ) gives Northern Ireland access to the EU single market through continuous alignment with relevant EU regulation ( primarily on goods ). There is therefore a potential for ‘ internal divergence ’ with the rest of the UK if the new European CPR is adopted in NI .
‘ The previously stated deadline of 30 June 2025 for CE marking recognition in Great Britain has now been revoked and once a new date has been published , a further two year co-existence period will also apply ’
There also remains the issue of UKCA and CE marking in Great Britain . On 2 September 2024 the Minister for Building Safety and Homelessness issued a Written Ministerial Statement regarding recognition of CE marking for construction products . The previously stated deadline of 30 June 2025 for CE marking recognition in Great Britain has now been revoked and once a new date has been published , a further two year co-existence period will also apply . This means that UKCA marking will not be mandatory until after CE marking has been removed in GB , therefore CE marking continues to be the only mandatory conformity marking for the entire UK market .
www . gai . org . uk
JANUARY 2025
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