Making a declaration is just not cricket

Not often heard these days, even in the hullabaloo of The Hundred, the idiom “it’s just not cricket” can refer to something that is considered unfair. ?The amount of information that a construction product manufacturer is expected to show on the Declaration of Performance (DoP) - and even accompanying the CE Marking - is arguably unfair (at least in comparison with some other goods). ?That amount is only going to increase with the new Construction Products Regulation (CPR), the legislation that initiates CE Marking. ?

(I once tried to explain cricket to a German colleague, but he couldn’t get beyond the notion that a match could last five days and still end in a draw.)

Under the current EU CPR – and the version ‘copy and pasted’ into UK legislation for UK CA Marking (but that’s another story!) – glass manufacturers and processors can display as many as 13 (unlucky!) essential characteristics (dependent upon the product and end use), from reaction to fire though pendulum body impact resistance to thermal transmittance.

The new revised CPR is expected to enter into force on the twentieth day following its citation in the Official Journal of the European Union (EU OJ), probably around the last quarter of 2024.? It will take time – and likely to be in stages - for product technical committees to revise their harmonised European Norms (product standards) in line with the requirements of the new regulation and then wait for them to be cited in the EU OJ.

As well as introducing a new Declaration of Conformity, which can be combined with the DoP, a product’s environmental sustainability performance over its life cycle will be added to the current essential characteristics.? Initially, there will be the four core climate change indicators, namely Global Warming Potential – fossil, biogenic, land transformation and total.? In later years, this list will grow to include other environmental indicators such as acidification potential and water use – as usually reported in an Environmental Product Declaration – 19 in total.

Specifically for heat treated glass, such as thermally toughened (tempered) safety glass, a new characteristic for the shatter properties of these products will be added to the DoP.? This follows the publication of EN 17635, which formally introduces a test method and classification for the shatter properties of heat treated glass, based on the traditional fragmentation test.

Some of the essential characteristics needed for security applications may also multiply, for example through splitting the resistance to manual attack classification into two, one for the ball drop test and the other for the axe test.

While a strong case can be made for expanding the current list of characteristics, particularly those related to sustainability, it will result in manufacturers issuing a larger and much busier declaration than at present.? Fortunately, recognition and acceptance of DoPs in electronic form has increased since the implementation of the current CPR, meaning as an industry we don’t create unwanted paper mountains for customers (especially as other processes in the supply chain become digitalised).

Not quite approaching the number of pages in Wisden – the book known as cricket’s bible – but manufacturers of construction products, such as glass, will need to be prepared to issue much more detailed declarations to meet forthcoming new requirements. ?

#CE #CEMarking #CPR #EU #declaration #DoP #glass #glazing #NSG #Pilkington #cricket

?

?

?