The Construction Products Regulation (CPR) comes into force throughout the European Economic Area on July 1, making CE marking compulsory for many construction products, including timber products.

All construction products placed on the EU market which fall under the scope of a harmonised technical specification – such as a harmonised European standard (hEN) or a European Technical Assessment (ETA) – must carry a CE mark and a Declaration of Performance (DOP), even those manufactured outside the EU.

Furthermore, CE marking places greater legal responsibility for compliance on agents, importers and distributors of timber products, since anyone selling a product must know its intended end use. For example, previously, a seller could simply sell ‘plywood’, but for CE marking the seller will need to declare whether the plywood is intended for structural or nonstructural, internal, humid or dry conditions, or has improved fire, thermal or acoustic properties.

The intended end use often has significant impact on the route to compliance and who takes responsibility for what. This is because each harmonised technical specification sets an Assessment and Verification of Constancy of Performance (AVCP) level, which in turn sets out the procedure for CE marking.

There are five levels of AVCP, ranging from Level 1+ (the most onerous, with major thirdparty product certification required) to Level 4, which requires only the manufacturer’s involvement. Highly safety critical products are generally allocated an AVCP of 1+ or 1, while non-safety critical products will be level 4. In simple terms the AVCP level dictates who does what to allow CE marking.

Since hENs exist for a variety of timber products, many will be required to carry a CE mark. For wood-based panels, for example, a manufacturer must make a DOP that relates to the performance characteristics of each particular panel type, as set out in EN 13986: 2004: Wood-based panels for use in construction. Characteristics, evaluation of conformity and marking.

Since wood-based panels are used in a variety of applications they may be classed at different levels of AVCP. But what does AVCP level 2+ mean in practice? To CE mark structural plywood to AVCP level 2+, the manufacturer must have conducted:

  • ITT (initial type testing)

Bending strength according to EN 310
Bending stiffness according to EN 310
Bonding quality according to EN 314 Part 1
Release of formaldehyde according to EN 717

Part 1 or Annex B of EN 13986

  • FPC (factory production control) certified by a notified body
  • Declaration of Performance
  • Twice-yearly surveillance audits of the manufacturer’s FPC system by a notified body. The manufacturer must then carry out ITT for specific end uses:

Wall sheathing:

  • Additional ITT

Strength and stiffness according to EN 789 or declare according to EN 12369
Impact resistance according to EN 596 and EN 12871
Structural flooring:

  • Additional ITT

Strength and stiffness according to EN 789 or declare according to EN 12369
Impact resistance according to EN 1195 and EN 12871
Strength and stiffness under point load according to EN 1195 and EN 12871

Roof decking:

  • Additional ITT

Strength and stiffness according to EN 789 or declare according to EN 1236
Strength and stiffness under point load according to EN 1195 and EN 12871
Impact resistance according to EN 12871

In addition, the manufacturer, importer or distributor – the person placing the structural plywood on the European market – must be able to supply a Declaration of Performance, and a Certificate of Conformity for the Factory Production Control issued by a notified body.

The CE marking process places greater responsibility for compliance on everyone in the supply chain. The manufacturer, agents, importers and distributors of timber products must all understand what is required, since it will be illegal to knowingly trade in products that require a CE mark if they do not comply.