The requirements applicable to the construction products are described in the Regulation (EU) N.º 305/2011 of The European Parliament and of the Council, commonly known by Construction Products Regulation (CPR). This document determines the conditions for the placement or availability of construction products in the market, establishing harmonised rules on how to express the performance of the construction products taking into account their essential characteristics and on the use of the CE marking on said products.

The CPR defines “Construction product” as any product or kit which is produced and placed on the market for incorporation in a permanent manner in construction works or parts thereof and the performance of which has an effect on the performance of the construction works with respect to the basic requirements for construction works - usually referred to as a system.

The CE marking procedures is obligatory when a specific product is covered by a harmonised standard that is already on the Official Journal of the European Union.

For construction products that are not covered by a harmonised standard, it is also possible to affix the CE marking through a voluntary route. In this process, the manufacturer can request to a Technical Assessment Body (TAB) to issue a European Technical Assessment (ETA). In this case, it is necessary to verify if a European Assessment Document (EAD) exists and covered the construction product. When an Assessment Document is already available. If the product does not insert itself into one of the existing European Assessment Documents, the manufacturer can request for a Technical Assessment Body to issue an ETA, based on a European Assessment Document to be developed by the TAB for the product.

Itecons - Institute for Research and Technological Development in Construction, Energy, Environment and Sustainability is one of the Portuguese Technical Assessment Bodies that can help manufacturers in this process of evaluating their products and issuing ETA.

It should be noted that a construction product that is not covered by a harmonized standard is not required to affix the CE marking. However, if the manufacturer has an ETA issued for that product, the CE marking is already mandatory. It is also safeguarded that, since the CE marking is not mandatory by the Construction Products Regulation, it may still be by national provisions at the place where the construction product is placed or made available.

As soon as the application method of the CE marking on the construction product is defined, it is necessary to understand what will be the system of AVCP (Assessment and Verification of Constancy of Performance) to apply to the product. The system of AVCP, applicable to each product and of predicted use, is defined at European Commission level and established in standardisation mandates. The base for the preparation of these mandates are the basic requirements for construction works set out in Annex I of the Regulation. The system of AVCP of the construction product allows to guarantee the precision and reliability of the Declaration of Performance. The Regulation predicts the possibility of implementation of five types of systems of AVCP (Systems 1, 1+, 2+, 3 and 4), in which the intervention of a Notified Body is required, with the exception of System 4.

The manufacturer is responsible for the implementation and maintenance of a factory production control which should fulfil the requirements of the applicable system of AVCP.

The Declaration of Performance is the document in which the manufacturers describes the performance of their products in relation to the essential characteristics in accordance with the relevant harmonised technical specifications, in this way assuming responsibility for the conformity of the product with the performance declared. Annex III of the Regulation (EU) No 305/2011, modified by the Regulation (EU) No 574/2014, presents the contents that the Declaration of Performance must contain.

After issuing the declaration of performance, the manufacturer is in conditions to affix the CE marking in their construction product and will have to create a label of the CE marking, based on the declaration of performance.

When all of the referred stages throughout the CE marking process are fulfilled, the construction product with CE marking can be placed on the market.

The Green Roofs can be CE marked by the voluntary route. The EAD 220009-00-0401, entitled “Kits for green roofs”, can be used to issue a European Technical Assessment (ETA).

Itecons, at the request of the Leca Portugal, S.A., issued an ETA for the green roof LECA® NUTROFERTIL GREEN ROOF D (https://www.itecons.uc.pt/attachments/145).

The ACCEPT platform (www.accept.uc.pt) can help the manufacturer to verify the existence of harmonized standards and European Assessment Documents, as well, to issue DoP or promote products with CE marking.