FREQUENTLY ASKED QUESTIONS

FAQs regarding EU Construction Products Regulation

From CPD to CPR:

As of July 1st 2013 construction products put on the market shall refer and be in accordance to the Construction Product Regulation N° 305/2011/UE. That regulation replaces the CPD (Construction Product Directive) over 20 years old.
For rooflights the CE marking is ruled by the following standards:

  • EN 1873 for individual rooflights
  • EN 14963 for continuous rooflights
  • EN 12101-2 for NSHEVs

CPD - The directive and CE marking had to be transposed by each member state in its national legislation.

CPR – The regulation is directly applicable in each member state. CE marking is enforced in each member state as soon as an harmonized standard has been published.

CPD - Attestation of conformity by the manufacturer

CPR – Declaration of Performance (DoP), which is a document supplied by the manufacturer to the customer including all information that the customer needs to choose the product, check its conformity and the use of it.

CPD - 6 essential requirements: 1 Mechanical resistance and stability 2 Safety in case of fire 3 Hygiene, health and the environment 4 Safety and accessibility in use 5 Protection against noise 6 Energy economy and heat retention

CPR – 7 essential requirements:
1 Mechanical resistance and stability
2 Safety in case of fire
3 Hygiene, health and the environment
4 Safety and accessibility in use
5 Protection against noise
6 Energy economy and heat retention
7 sustainable use of natural resources

CPD - The CE marking of a product was supposed to mention all the performances included in annex ZA of the harmonized standard.

CPR – A product can be CE marked minimum with only one specification of annex ZA unless it is mentioned in the standard that more than one are necessary for the product to perform.
The list of essential characteristics shall be in DOP.

Note:
The possibility of only one specification is dangerous and is not accepted by EUROLUX which already decided last year that “All essential values of performance in annex ZA” have to be declared.

CPD -The systems for evaluation (initial testing and FPC) of a product were set by the CPD depending of the product type (system 1+ to

CPR – CPR indicates that simplified methods to attest the performances could be used by small manufacturers (SME) or for products sold in very small quantities (individually manufactured or custom-made in a non-series process).
CPR also specifies that it does not apply for products concerned by system 1 or 2.

The declaration of conformity (DoP) is a document that shall include all the information needed by the client to make its choice, check the conformity of the product and for its use.

The DoP shall contain e.g.
“the intended use or uses for the construction product, in accordance with the applicable harmonised technical specification;
the list of essential characteristics, as determined in the harmonised technical specification for the declared intended use or uses and
the performance of those essential characteristics of the construction product which are related to the intended use or uses taking into consideration the provisions in relation to the intended use or uses where the manufacturer intends the product to be made available on the market”.

The document shall include all information needed to the user of the country in which the product is distributed.

FAQs regarding European Standards

Some manufacturers claim that the CE procedure to CE mark natural smoke and heat ventilators (NSHEVs) is quite simple and can be achieved by buying equipment’s which have been tested and to install them on “compatible frames”.

Is that right and how to check conformity?

  • In fact yes, it is possible for a manufacturer to use tests certificates obtained by another company in order to manufacture a NSHEV and to mark it with an own CE marking in accordance with EN 12101-2.
  • The procedure to use is well known and is defined as “cascading”.
  • The procedure needed in doing so is as follows:
    1. Obtain from the owner of the original test certificates an agreement to use the test certificate for its own uses.
    2. That the factory of the manufacturer “by delegation” be recognized as a manufacturing site by the notified body, which means:
      1. That the factory is recognized by the notified body for the manufacture of the product,
      2. That the factory manufacturing quality control system is yearly supervised by the notified body for that type of products,
      3. That the certificate issued by the notified body and presented by the manufacturer indicates the factory of the manufacturer and not the factory of the manufacturer which granted the cascading.
    3. That the product has been checked “complete” by the manufacturer before the factory and delivered as one package on the building site.
      1. The product shall not be delivered to the building site from various places (frame, infill, motors, …),
      2. The product marking shall not be done on building site by the installer.

FAQs regarding natural smoke and heat ventilation – Airflow performances of natural ventilators

Preamble: Information given by EUROLUX in that note are checked by IFI and CSTB, which are the two notified laboratories which prepared the testing procedure presented in EN 12101-2, Annex B.

Background:

Natural Smoke and Heat Ventilators (NSHEVs) are in some cases offered by several manufacturers with high airflow performance for installation on flat roofs and with much less technical equipment than most products, e. g.:

  • they shall perform well without wind deflectors,
  • they have only one flap with a low opening angle,
  • the airflow efficiency claimed is 0.60 and above.

NSHEVs types concerned :

  • Double flap ventilators with and without upstand
  • One flap ventilators, roof mounted opening angle less than 120°

Note:

  • In some cases, manufacturers even present CE certificates for such types of NSHEVs.
  • This document mostly is not concerned with NSHEVs installed on sloped roof (30° and more) or wall mounted.

What is the highest reasonable level of airflow performance which can be expected for these types of ventilators?

  • Double flaps NSHVs with upstand 300mm high minimum and without wind deflectors:
    • v is declared between 0.35 and 0.45 mostly.
  • Double flaps NSHEVs without upstand (often installed on glass roofs) and without wind deflectors:
    • v is declared between 0.15 and 0.35 mostly.
  • One flap ventilator, with or without upstand, angle of opening less than 120°:
    • v can be less than 0 (negative).

What are the risks in case of installation of such types of ventilators?

    • Double flap ventilator:
      • The efficiency for smoke evacuation of the building is reduced with the same ratio that the difference between announced performance an actual.
    • Double flaps NSHVs with upstand 300mm high minimum and without wind deflectors:
      • As an example for a claimed performance of c v = 0.65 instead of 0.40: The outflow of smoke is reduced by almost 40%.
    • Double flaps NSHEVs without upstand and without wind deflectors:
      • As an example for an announced performance of c v = 0.65 instead of 0.25: The smoke outflow is reduced by almost 70%.

Therefore the efficiency of such a system can be vastly reduced.

  • One flap ventilator, with or without upstand, angle of opening less than 120°:
    • In that case the coefficient of efficiency even can be negative. This means that there is the possibility, in case of windy conditions, for the outside wind to blow the smoke towards the floor and to increase considerably the risks due to the smoke. Using of NSHEV never should be done without considering the wind. Where the wind influence is not sufficiently covered by the products themselves, by mounting or by other systems (e.g. wind sensitive control systems) the NSHEV are not only inefficient. They are also dangerous and increase the risk for the user, the risk for the fire fighters and the risk for the real property.

What are the reasons explaining that wrong performance information?

  1. Fraud: Manufacturer uses test reports limited to wall mounting of NSHEVs also for installation on roofs.
  2. Manufacturer uses reports of tests done prior to harmonization of test procedures as defined in the EN standard:
    • Which did underestimate the effect of side wind,
    • Some CE certificates in early days of implementation of the EN standard did not specify in detail the limits for the product use. Many of these certificates have been updated. But it is possible that commercial departments of manufacturers still distribute the “older versions”, more favorable.
  3. With the introduction of the EN standard, numerous new bodies without prior experience in smoke ventilation were notified. Which led to errors in the certificates issued by some of these notified bodies, for example certificates including possibility of installation on flat roofs, when the ventilators were only tested without side wind effect.

What to do in case of uncertainty?

  • Clients should refuse such types of products.
  • Please ask for handing out not only for certificates but for the test reports to check the conditions of test, side wind effect and wind deflectors for example.
  • When help is needed, send information to your national manufacturer association as a member of EUROLUX for explanations (see Members). It will check with the laboratories in charge.