The objective of the European Construction Products Directive CPR is to ensure that reliable information is presented in relation to their performance – and all this in a harmonized manner across Europe, to facilitate cross-border trade within the European Union.
The concerned construction product shall be followed by a Declaration of Performance with a common technical language, as specified in the corresponding harmonized European product performance standards. The actual requirements still are specified by each EU Member State on its own.
CE marking in this context is the key tool and means just and only that a Declaration of Performance (DoP) following the product was drawn up in accordance with the specifications that are laid out in the corresponding harmonized European standard.
Please note that the European Construction Products Directive CPR does not define the safety of construction products or any other properties. This remains the responsibility of the national governments within the EU Member States.
All this is perceived by many actors in the industry as pretty complicated. Now you can see the intentions and the interpretation by the EU Commission in a summary report on purpose and status of the CPR (see some language versions: en – fr – de – nl – …). The report can be searched with the keywords “COM(2016) 445 final” for other languages. This report is quite clear and can help to clarify many questions.
Eurofins is listed as notified testing lab for use with CE marking, with reference to the VOC emissions testing standard CEN/TS 16516. The Danish accreditation body DANAK accredited the VOC emissions test methods of Eurofins Product Testing A/S in Galten / Denmark, in line with ISO/IEC 17025. Then DANAK informed (“notified”) the European database NANDO, operated by the European Commission, that Eurofins is qualified to perform VOC emission testing according to CEN/TS 16516 (that will be converted into EN 16516 in 2017).
This qualification is needed by industry customers of the testing lab
- for documentation of VOC emissions within a Declaration of Perfomance within CE marking,
- if a harmonized EN product standard is published as basis of CE marking,
- and if it contains a section on VOC or formaldehyde emissions with reference to CEN/TS 16516, or
- if existing test results shall be used for such purpose later, after publication of such a product standard, or
- for the new German VOC regulation that requires testing labs to be both ISO/IEC 17025 accredited and notified.
You can see the entry in the database, and you can see further explanation of what this entry means.
This additional proof of performance and quality supports the ambition of Eurofins to offer high level service to its customers, if they need to show compliance with VOC emissions requirements in Europe.
Contact persons for VOC testing services are listed here: www.eurofins.com/voc-contacts.
As reported earlier, the EU ecolabel for paints and varnishes contained requirements on SVOC content testing that confused the testing labs because it required use of ISO 11890-2 for that purpose. But that standard was not made for that purpose, for SVOC testing, omly for VOC testing.
The ISO 11890-2 standard can be expanded to include SVOC testing as well, but this is not yet specified in a harmonized manner. Each concerned testing lab tried to solve that challenge in its own manner, but differently from each other. This resulted in significantly different test results obtained from different testing labs.
Industry initiatives tried to remediate that unsatisfactory solution by publishing an interpretative guidance on how the scope of ISO 11890-2 could be expanded, to allow determination of SVOCs within the same analytical procedure as ISO 11890-2 – see our recent post in this blog.
A 2015 revision of the EU ecolabel criteria document allowed to make such changes in a way that ensures more uniform test results on a specific paint formulation than the first published version of the EU ecolabel criteria did. Earlier, two different analytical procedures had been specified – now only one of these remains. The so-called “polar system” was cancelled in the criteria document.
The updated User Manual (version 1.2) of the EU ecolabel for paints and varnishes contains a more stringent guidance on SVOC testing. ISO/TC 35 WG1 started work on an amendment or revision of ISO 11890-2. Several analytical challenges still need to be solved. This work will continue in 2017. A publication of the draft revised ISO 11890-2 standard may occur late 2017 or 2018.
Until then, the testing labs should follow the above mentioned guidance. The VOC testing lab of Eurofins Product Testing A/S in Denmark is ISO 17025 accredited for ISO 11890-2 testing. The most recent progress of standardization work at ISO will be taken on board continuously. This ensures that test results of Eurofins sill be valid also in the future.
For more information please see also http://www.eurofins.com/eu-ecolabel-svoc.
VOC = Volatile Organic Compounds
SVOC = Semi-Volatile Organic Compounds
Germany wants to regulate VOC emissions from construction products into indoor air, as small part of a pretty complex national amendment of the Construction Products Regulation.
CE marked products will not face additional regulation. Earlier additional Ü marking must not occur for CE marked products since 16 October 2016, see our explanation of the transition phase.
A number of products that cannot be CE marked will need to fulfill the AgBB limits for their emissions, and some more national requirements, by obtaining the Ü mark, as before.
Such a national regulation needs to be “notified” to the EU Commission that makes it available for comments by the EU Member States during 3 months. Germany must not implement the planned regulation before these 3 months have gone – or 6 months in the case of severe comments or opposition.
The planned German regulation was notified under the notification number 2016/0376/D since July 2016 (in German language). If that regulation is set into force, then proof of compliance with the draft regulation needs to be shown by a CE mark (if available), or by an Ü mark.
If the Declaration of Performance behind the CE mark does not include a statement on VOC emissions, because the related harmonized EN standard does not (yet) foresee this, then other ways of showing compliance can be used. The Eurofins operated Indoor Air Comfort certification program can be a good choice for that purpose.
See also our recent post on this issue with more details and more links.
Germany asked for public comments on their revised drafts concerning national amendments to construction products regulation in May 2016. While the commenting period has gone, you can see the comments that were sent in on a special German webpage (in German only).
The draft documents concerning the regulations are available in German language only. But we explained their main content regarding VOC emissions from construction products into indoor air in English, we are about to edit this in French, and we wrote a summary in German.
The specifications and limits have not been changed, compared to earlier drafts. But the manner how these shall be documented, and compliance be proven, was specified in some more detail, with textile floorings as the first example.
Many aspects of assessment and monitoring of VOC emissions from construction products remain unclear. Nevertheless, the Eurofins operated product certification Indoor Air Comfort will be a good way to show compliance with the German rules in the future. For sure, other tools will be available as well.
Please find your new information on the following pages.
BREEAM International, the UK originated and globally used sustainable buildings certification system, not only published new criteria in March 2016, see an earlier blog. Now the list of recognised emissions rating schemes was updated, to reflect the recent changes.
Please note: The criteria for low emitting products are not compulsory; you can raise a BREEAM certified building without low-emitting products. But you can earn additional points for your building project by using low-emitting products.
Regarding indoor air quality, use of low emitting products inside the building can be helpful to achieve one or two points if the BREEAM specifications have been proved by testing, or if the product fulfils the specifications of any recognised schemes and programs (differentiated in one list for compliance with the recent BREEAM standards and one list for compliance with the BREEAM standards from 2016 onwards). This document is not yet available for direct download from the BREEAM webpages, except from BREEAM Sweden.
Eurofins labels Indoor Air Comfort and Indoor Air Comfort Gold are on that list. Indoor Air Comfort Gold will be accepted now both for BREEAM and for LEED, see an earlier blog.
That list makes it easy to identify BREEAM compatible low emitting products on the market.
BREEAM Norway goes a separate way and did not yet publish that document.
BREEAM International, the UK originated and globally used sustainable buildings certification system, published new criteria in March 2016.
These criteria include a basic change of its criteria for low-emitting interior products. Now the BREEAM criteria for low-emitting interior products are the same, or at least similar, for all products. They include limit values for formaldehyde, TVOC, TSVOC and carcinogens.
The new criteria, while being more stringent than before, allow to use existing standard testing for other purposes also to show compliance with the new BREEAM criteria.
To read more: www.eurofins.com/breeam-uk-emissions-2016.