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What is CPR – in general?
Started as a Directive in 1989 (“CPD”) and turned into a Regulation in 2011 (“CPR”) which became applicable from 1st July 2013, the CPR was brought to life by the European Commission to enforce that construction works be designed and executed so as not to endanger the safety of persons, domestic animals or property nor damage the environment.
What is the scope of CPR – in general?
Products placed on the market for incorporation in a permanent manner inconstruction works.
What are “construction works”?
Buildings or other civil works including tunnels, bridges, metro stations, etc. (no ships, trains, buses, etc.)
What are the goals of CPR?
To define harmonised rules for marketing of construction products within the EU.
To provide a common technical language to assess performance of construction products.
To ensure availability of reliable information to allow comparison of construction products from different manufacturers in different countries.
What are the benefits of CPR?
It allows free circulation of construction products in the EU.
It enables national authorities to set performance requirements using a harmonised European standard so that users of construction products can better define their performance demands.
Market surveillance can rely on one common information structure.
How does CPR affect cables?
EN 50575 is the harmonised European standard, issued in 2014 and published in the Official Journal of the European Union (OJEU) on 10th July 2015, which specifies requirements for cables used in permanent constructions with regard to their reaction to fire.
What is the scope of CPR – for cables?
All cables permanently installed in buildings or other civil works.
Which type of cables?
All cables, including data and telecommunication cables.
All type of conductors, copper and optical fibre.
What is “permanently”?
All horizontal and backbone cables are in scope.
Cable assemblies and patch cords are out of scope.
Are ships, trains, buses, etc. in the scope of CPR?
No, these are not civil works.
What does “reaction to fire” mean for cables in CPR?
The fire performance of cables is classified based on a number of criteria:
Flame spread and heat release
Smoke production, acidity and flaming droplets
These criteria and test methods are specified in existing standards IEC/EN 60332-1, IEC/EN 61034-2, IEC/EN 60754-2 and in a new harmonised European standard EN 50399.
How are the cable performance classes defined?
7 Euroclasses for flame spread and heat release: A, B1, B2, C, D, E and F (A being the most severe i.e. non-combustible and F having no criteria specified)
5 classifications for smoke production: s1, s1a, s1b, s2, s3 (s1a being the most severe and s3 no criteria specified or failing any of the other four classifications)
3 classifications for acidity: a1, a2, a3 (a1 being the most severe and a3 no criteria specified or failing any of the other two classifications)
3 classifications for flaming droplets: d0, d1, d2 (d0 being the most severe and d2 no criteria specified or failing any of the other two classifications)
How are cables assessed and certified to be CPR compliant?
There are 2 different procedures:
System 1+: to assess Euroclasses B1, B2 and C
A Notified Body issues an Attestation of Conformity after an initial type test and a factory audit including regular production inspections (2x/year) and audit tests on samples taken from the warehouse (1x/year).
System 3: to assess Euroclasses D and E
Notified Body issues an Attestation of Conformity after an initial type test.
What is a Notified Body?
It is an independent organisation which has been designated by a Member State to carry out conformity assessment according to a directive. It is the obligation of the Member State to notify the European Commission and the other Member States of the designation.
Which are the Notified Bodies for CPR?
For the moment there are none. Test labs which are accredited as Notified Body will be listed on the NANDO Information System of the EC website. (Nando = New Approach Notified and Designated Organisations)
Which performance classes need to be used in which buildings/construction works?
The requirements will depend on various parameters such as the type of building, the level of occupation, the difficulty of evacuation, etc.
These requirements are not harmonised and therefore may vary from country to country.
It is the legal obligation of each EU Member State’s government to adopt CPR in national regulation and to guarantee effective surveillance of its market.
Who needs to ensure that cables sold in the EU are compliant with CPR?
The one who places the product on the market in the EU is responsible to comply with the CPR obligations. This is either the actual manufacturer or the importer.
How can I know whether a cable complies with CPR?
The product needs to have a Declaration of Performance (DoP):
This is a document drawn up by the manufacturer (or importer) in the language(s) required by the EU country where the product is made available and containing defined information such as product identification, its intended use, its declared performance according to CPR and the identification of the Notified Body. The DoP needs to be made publicly available, either on paper or in electronic format. It does not need to accompany the product itself.
The product packaging needs to have defined labelling including CE marking:
Labels on cable drums and boxes need to contain the same data as on the DoP, the reference number of the DoP, the CE mark and the year in which the CE marking was first affixed. The language of the label information can be chosen by the manufacturer (or importer). The cable itself does not need to bear the CE marking nor contain any other of the CPR requirements for labelling.
Is the manufacturer solely responsible for CPR compliance?
No, also Distributors, Specifiers and Building Owners bear responsibilities.
Distributors should not resell cables for which there is no DoP and which do not bear the appropriate labelling.
Specifiers must reference appropriate Euroclasses and s/a/d criteria according to national CPR regulations.
Building owners need to ensure that the infrastructure on their building plans is in line with national CPR regulations.
When does CPR become mandatory?
As per the publication of EN 50575 in the Official Journal of the European Union (OJEU) on 10th July 2015, the date of application was fixed on 01st December 2015, with a transition period of 12 months. However, due to some minor amendments to EN 50575, the date of application had been postponed to 1st July 2016. Following publication of Amendment 1 to EN 50575 in the OJEU on 10th June 2016 the coexistence period has officially started and will end on 01st July 2017, date when CE marking for CPR becomes mandatory.
Can cables already be CE marked for CPR today?
With the publication of EN50575:2014+A1:2016 on 10th June 2016 the coexistence period has officially started, meaning that cables can be CE marked since that date.
Are PVC cables doomed to disappear after CPR implementation?
CPR does not forbid the use of PVC cables.
What is the CPR requirement for importers (Caleb's customers) in EU and UK?
If the importer markets the cable under his own name and brand, he will per definition be the manufacturer (in relation to CE marking and EU directives/regulations) and will therefore also have the same responsibilities as the original manufacturer. Therefore, the importer needs to make sure the products are CPR complaint and with correct CE labeling and also with a DoP Declaration.
Do the importers need to get a parallel classification reports/certificates for the products marketed under their own brands?
a. If the cable is type tested under AVCP system 3 (Eca and Dca products), it is no problem that importers do not have the documents under their own name – as long as they can document that the cable has been tested by notified testing laboratory, and have ensured that the manufacturer has an FPC system in accordance with EN 50575 so that the essential characteristics are maintained (constancy of performance).
If the importer has multiple suppliers for the given type of cable, he has to add some kind of marking/code to be able to identify the actual manufacturer and to link it to the right classification report. There is no requirement for the syntax/type of code to use – it is up to the importer to decide and to manage (it is under his full responsibility that the applicable assessment procedure has been followed and completed, and that the required technical documentation /technical file is available.
b.If the product is to be marketed as Class Cca and B2ca, he must follow AVCP system 1+, and in this case he shall have a product certificate (Certificate of Constancy of Performance) issued by a notified body in his own name.
This CCP further shall include information about the manufacturing plant.
What will be the requirement for CE marking/labeling and cable marking?
a.The CE marking shall include information about Class, manufacturer, number of notified body etc. and shall be affixed visibly, legibly and indelibly to the construction product or to a label attached to it. Where this is not possible or not warranted on account of the nature of the product, it shall be affixed to the packaging or to the accompanying documents
b.There is no marking requirement for cable. However, it may be good to include the Euroclass for fire reaction for easier reference