The Construction Products Regulation (CPR), EU No 305/2011, under System 2+, requires:
The notified production control certification body shall issue the certificate of conformity of the factory production control on the basis of:
- (i) initial inspection of the manufacturing plant and of factory production control;
- (ii) continuous surveillance, assessment and evaluation of factory production control.
This question relates specifically to EN 1090 (Requirements for conformity assessment of structural steel and aluminium components), but it could apply in other areas.
It is understood that a steel fabricator must be certified in accordance with EN 1090 in order to be able to make a declaration of performance (DoP) and apply the CE marking to the construction product.
It is further understood that such certification involves audit of the fabricator’s factory production control (FPC) system (not the construction product, not the DoP, not the CE Marking – see clause 4.2 of NB-CPR/15/568r8).
There are cases where small manufacturers might not always fabricate a construction product, and therefore might not, on the day of the audit of their FPC, have a construction product to demonstrate to the auditor.
It is noted that the Group of Notified Bodies Approved Guidance on EN 1090-1:2009+A1:2011- Certification of FPC of steel and aluminium structural components (NB-CPD/SG17/09/069r3), issued on 18 November 2016, states: “During the initial inspection and/or continuing surveillance NBs should review the scope of the portfolio of DoPs that the manufacturer has issued or plans to issue. The NB should then ensure that the processes covered by the FPC (which the NB is being asked to certify) are consistent with the scope of the portfolio of DoPs, and that the manufacturer has undertaken suitable ITT to support its DoPs.”
The notified body is not certifying the product; it is certifying that the manufacturer’s FPC is capable of producing construction products that meet defined requirements.
Therefore, the question is:
Is it acceptable for a notified body under the CPR to certify a manufacturer’s FPC system (AVCP 2+ for EN 1090) based on review of the manufacturer’s documentation and records, as well as the fabricator demonstrating the effectiveness of its FPC system by applying the same processes to a similar product that is not intended to be a construction product?
It is understood, of course, that the manufacturer cannot apply the CE marking to such a product.
September 2023
The answer is YES, provided that the producer can present the DoP and ITT register, established on the basis of the same FPC at the time of the most recent production.
It will be the task of NoBo’s auditor to compare what he/she sees on the day of the audit in terms of FPC elaboration and the values present in the register for the most recent production performed before the audit.
As a matter of fact, the objective of a system 2+ audit is to ensure that equipment is present and operated in a way that allows for conformance with the criteria certified and announced in the DoP.
As a prerequisite, that the NoBo’s auditor shall be particular cautious with the demonstrated processes at the time of the audit and shall confirm that the audited processes (applied for a similar product not intended to be marketed as a construction product) fully correspond to the processes regularly applied by the manufacturer for the delivery of the product that bears the CE marking.
This means that, where the above conditions are not fulfilled (e.g. new entrants), this is not accepted.