It is now six years since compliance with the Construction Products Regulations (CPR) became a legal requirement in the UK. The CPR (which replaced the Construction Products Directive) was implemented in the UK, on 1st July 2013 and requires all construction products placed on the market, which fall within the scope of a harmonised European Standard (hEN), to have a Declaration of Performance (DoP) produced by the manufacturer and be CE Marked in accordance with the requirements of the CPR.
In terms of Insulating Glass Units (IGUs), the relevant hEN (Harmonised European Norm) is EN 1279-5:2018 – Product Standard, this standard details the requirements to comply with the CPR. In turn, EN 1279-5:2018 requires IGU manufacturers to have test evidence to show compliance with:
- EN 1279-2:2018 – Long term test method and requirements for moisture penetration
- EN 1279 3:2018 – Long term test method and requirements for gas leakage rate and for gas concentration tolerances
- EN 1279-4:2018 – Methods of test for the physical attributes of edge seal components and inserts; and a system description in accordance with EN 1279-1:2018 – Generalities, system description, rules for substitution, tolerances and visual quality.
IGU manufacturers must also operate a Factory Production Control in compliance with EN 1279-6:2018 – Factory production control and periodic tests.
The CPR does allow manufacturers to refrain from drawing up a DoP and CE Marking products under certain circumstances, these are known as derogations and are detailed in Article 5 of the CPR. There are three conditions under which a derogation is allowed. These are detailed in the GGF publication, ‘Insulating Glass Units (IGUs) – Conforming to the Construction Products Regulation (CPR)’, which can be downloaded from the Members Area on the GGF website.
This publication also details the GGFs interpretation on the application of these derogations in relation to IGUs being placed on the market. The GGFs position is that the derogations do not apply to the manufacture of any IGUs and Best Practice advice to Members, is to ensure they always have their products tested to the appropriate parts of EN 1279 series, have a system description specific to all specifications of IGUs they manufacture, have an appropriate Factory Production Control in accordance with EN 1279-6:2018 and create a DoP and CE Mark for their product ranges. This is also clarified in documents on CPR 07/07/1 from the European Commission.
By following the GGFs guidance, IGU manufacturers will be able to demonstrate compliance with the product standard, EN 1279-5:2018 and comply with the legal requirements of the Construction Products Regulations.