CONSTRUCTION PRODUCT REGULATION – CPR UE 305/11
Introduction and Management of CPR EU 305/11 (2)
This second communication is intended to inform customers of the "state-of-the-art" of our knowledge, involvement and management of this Regulation.
CPR EU Regulation affects distributors, integrators, manufacturers, architects, contractors, engineers or anyone involved in European buildings and the materials used in their construction which must comply with CPR requirements.
By us as manufacturer, by 1.7.2017 is imminent the need to provide our communication cables Classified according to the Construction Products Regulation (CPR) 305/11 EU whose process includes the following commitments:
- Declare the performance of cables with respect to their Reaction to Fire and publishing their relevant
DoP (Declaration of Performance) assuming our responsibility for their conformity.
- Create and implement a certification system (AVCP) for the continuous surveillance of the cables.
- Point out the CE marking and the due information on cables’ jackets as well as on labels accompanying
each single cable length supplied.
- Maintain for 10 years the relevant supporting documentation.
We will not insist on describing all details and content of the CPR regulation, as well as the various permitted fire reaction Euro-classes; each European country involved in this process has already published extensive documentation, including the destination of use of the different Euro-classes. By the way, they often differ from one country to the other, unfortunately.
On the contrary, here we will simply describe and explain how to make sure that our cables have the due Certification as well as the technical documents and labels comply with all the details required by the Regulation according to the Specs. CEI EN 50575.
Samples of our products, both coaxes and LAN cables, have been entrusted to IMQ - the Institute already providing the Certification of our company’s Quality Management System ISO 9001 - which in this specific case becomes our Notified Body and the supplier of our Products’ Certifications, undergoing the necessary tests of Reaction to Fire in order to classify them according to the Directives of the CPR.
Classes of the relevant Fire Reaction in Italy and the European countries which we are involved with our communication cables can be resumed in the following list:
Classes (acc. to UE 305/2011) Reaction to Fire
B2ca s1a, d1, a1 very high performance
Cca s1b, d1, a1 high performance
Cca s3, d1, a3 high performance
Dca s2, d2, a2 good performance
Eca low performance
Fca bad performance, applies to cables for outdoor use only
At this date, our already Certified coaxes and LAN cables are listed in the attached document (CPR 1) under the denomination EFFECTIVE, while several others denominated EXPECTED have been submitted to our Certification Body and their Classification as Dca is still outstanding.
Two exceptions, already Classified Dca, as follows:
- the coaxial cable DG163ZH which has been Classified Dca s2, d2, a1;
- and the cable LAN7A1200ZHA which has been Classified Dca s1a, d0, a2.
The goal of our company is to sort by July 1st, 2017 all the cables today in the catalog up to the possible Dca Classification where applicable. Then, thanks to the forthcoming installation in the company of one burning chamber for testing the reaction to fire for single cable, we will investigate how developing new cables, able to be classified in the higher performance classes.
3. Relevant Documentation
Here is a kind of manual, whose information come from the Spec. CEI EN 50575, which are given just as a simple and practical aid for the CAVEL cable user that: → http://www.imq.it/en/).
This institution is accredited to the European Commission as a Notified Body and it is included in the NANDO (New Approach Notified and Designated Organizational Information System) (Web → http://ec.europa.eu/growth/tools-databases/nando/index.cfm ) where they are identified by nr. 0051 of the list:
(Web → http://ec.europa.eu/growth/tools-databases/nando/index.cfm?fuseaction=directive.notifiedbody&dir_id=33 ).
As you will see, the identification number of the Notified Body appears on several occasions in the documents that we will descr
- must choose the appropriate cable for the application to be put into practice;
- wants to make sure of the chain of information relevant to the CPR for the selected product;
- wants to verify the presence of distinctive signs of this process on products: cables and their packaging.
3.1 Certification Body and Fire Reaction Report
The Product Classification process starts with the choice of a Notified Body.
In most of cases we chose the IMQ – Istituto del Marchio Qualità (quality brand institute) (webibe later.
The cables provided to the Notified Body are submitted to the relevant tests and in case of positive feedback they issue the “Reaction to fire classification report for electric cable”.
For example, see the attached document (CPR 2) for coaxial cable:
CAVEL DG163ZH which obtained the Class Dca s2, d2, a1.
This document, reserved between us and the issuing body, remains filed at our company.
3.2 Issue of the DoP and updating of Technical Data Sheet
Supported by the positive feedback of the tests and the release of the Classification Report, we are in turn authorized to draw up a corresponding DoP - Declaration of Performance.
See the attached document (CPR 3), again relevant to the DG163ZH cable, which connects to the Fire Reaction Report via its Identification Number 0051-CPR-541, where we assume the responsibility to declare the Fire Reaction of Class Dca s2, d2, a1.
This document is public and it may be required at our company at any time.
For service to anyone who needs it, this document is made available on the corporate website as well.
It's easy to trace it by navigating into our web site up to the Data Sheet of each cable.
On top of the Data Sheet just on the right side of the cable code you can find the symbol which opens its relevant downloadable PDF:
(e.g. on the web site → https://www.cavel.it/en/prodotti/1/1/05/DG163ZH).
Still on the web, on the left side of the cable code, there is also the symbol that allows you to download the cable Data Sheet. This latter is now updated with a precise indication of the Fire Reaction Class according to EU 305/2011, as can be seen in the attached document (CPR 4).
Note that the printed text on the cable sheath has also been updated:
- with the additional Euroclass indication, in this specific case Euroclass Dca s2, d2, a1
- and with a modified production Lot Number, represented now by the abbreviation gggaa (n), where:
ggg represents the day of production (001-365)
aa represents the year of production (e.g. currently 17 = 2017)
(N) represents a possible progressive number, it present in some cases only.
3.3 CE marking and cable labelling, according to CEI EN 50575-2015
Once done what above, it allows us to draw up and apply for any cable packing unit a CE labelling conforming to the instructions of CEI EN 50575-2015 standard.
The CE label example is visible in the attached document (CPR 5), where a legend explains the meaning of its content. One CE label accompanies any single piece of cable, whether it is a roll or a plastic reel or a wooden drum. Completing the information we also show one of the standard label that appears on all multiple packaging cardboard boxes and any wooden drum, where the Production Lot is visible.
3.4 Lot of production and its usefulness
In accordance with the implementation of a Factory Production Control (FCP), as set out in the CEI EN 50575: 6.3 Specification, the manufacturer must establish a system for traceability and marking of any individual batches of products so that they shall be identifiable and traceable according to their production origin. The relevant documentation is kept by the manufacturer for a period of 10 years.
This allows, when deemed necessary by the user or the intermediary, to ask the manufacturer for details about the features of the supplied cable, simply providing the following details: cable code and lot number. As shown in the previous paragraphs, the cable code and production lot number are always present on all cable sheaths as well as the standard label. In future a single label is being built that integrates the two current ones and we will announce it in due time.
We have to point out that the management of CPR for communication cables, which firstly has the noble aim to minimize the risks to people and property by reducing the danger of fires, against has “another side of the coin”, as it means that an extraordinary number of dedicated professional and quite expensive activities will be performed which will reflect on the company's costs and prices to the public for classified products.
Due to the same process, in addition maybe we assume that we have to implement a kind of rationalization of the present large number of types of cables to simplify their commodity offer.
We remain at your disposal for any further request for information and insights on the approached themes.
Also we will be grateful to those who will provide us with any additional ideas and contributions suitable to achieve the intended purposes.
Sales and Marketing Director
CAVEL – Italiana Conduttori Srl