European construction products regulations
The Construction Products Regulation (CPR)
Since 1989, Essential Requirement 3 (ER3) of the EC Construction Products Directive (CPD) has stated that “chemical emissions from products used indoors must not adversely affect the indoor environment or the health and comfort of building occupants”.
However, ER3 was not properly implemented for many years, largely due to the lack of suitable and broadly applicable (‘horizontal’) test methods. Legislative activity has been striving to rectify this situation, and has now resulted in the replacement of the CPD with the Construction Products Regulation (CPR), which came into force on 1 July 2013.
As a result of this, in order to obtain the CE mark that is compulsory before selling a product in the EU, manufacturers will in due course (depending on the industry area) need to have their products tested by accredited third-party test labs using the harmonised methods. There will also need to be in-house checks and controls to demonstrate ongoing consistency and conformity of product quality.
The requirements of the CPR have an impact upon numerous trades, including: Insulation, wood, plasterboard, varnishes, adhesives, flooring, foam, wall coverings
The development of harmonised test methods is continuing, and a final testing standard is expected in 2015 or 2016. However, a draft (prCEN/TS 16516) is already available, and this is based on the ISO 16000 series.
This mandate has been reinforced by the release and widespread adoption of German, French and Belgian national regulations. Like the CPR, these require emissions testing, but they have also established criteria for product approval or classification.
|Substances of very high concern (SVHCs) || |
Substances with the following hazard properties may be identified as SVHCs:
- Those in categories 1A or 1B of the list defined as being carcinogenic, mutagenic or toxic for reproduction (CMR substances), according to European Commission Regulation (EC) No. 1272/2008.
- Those that are persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB) according to REACH (Annex XIII).
- Those identified on a case-by-case basis, for which there is scientific evidence of probable serious effects that cause an equivalent level of concern to CMR or PBT/vPvB substances.
Key SVHCs include: 2-ethoxyethyl acetate, 2-propenamide, 1-methyl-2-pyrrolidinone, anthracene, benzyl butyl phthalate, bis(2-ethylhexyl) phthalate, dibutyl phthalate, diisoheptyl phthalate, 2-ethoxyethanol, 2-methoxyethanol and 1,2,3-trichloropropane.
National regulations for EU countries
Also currently in place are national regulations for EU countries, which require emissions testing for construction products. Note that some of these are likely to eventually be superseded by the CPR.
- Germany: The AgBB scheme is a health-related evaluation procedure for emissions of VOCs and SVOCs from building products. It lists /Administration200 compounds and their corresponding limit levels, and now includes voluntary olfactory testing.
- Germany: The ‘Ü’ mark for construction products is administered by the DIBt (Deutsches Institut für Bautechnik) and defines additional specifications for issues not covered by the European CE marking scheme.
- France: Since January 2010, it has only been permitted to sell construction products in France if the amounts of four key CMR substances (trichloroethylene, benzene, bis(2-ethylhexyl) phthalate and dibutyl phthalate) released from a construction product over 28 days are less than 1 µg/m3 each. The tests are carried out in accordance with the ISO 16000 series for a European reference room.
- France: The ‘Émissions dans l’air intérieur’ regulation requires the labelling of new and existing construction products installed indoors (including floor and wall coverings, paints and lacquers). Emissions of 10 key compounds and total VOCs (TVOC) are classified as A+, A, B or C depending on the amounts released into a 0.1–1 m3 chamber over a period of 28 days. The final label used is the one that applies to the lowest-graded individual chemical.
- Belgium: In 2012 a new draft of a regulation regarding VOC emissions from construction products into indoor air was released. The regulation, which is based on the CPR, defines maximum levels of chemicals but does not involve a labelling scheme.
For further details on the approaches, techniques and guidelines that apply to your industry, please contact our Material Emissions Specialists.