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European Fire Sprinkler Network

EFSN

The European Fire Sprinkler Network was set up in 2002 to bring together all those who wish to see a step improvement in European fire safety through the wider use of fire sprinkler systems.

Lobbying Activity

Meeting with Adam Jarubas (Member of the European Parliament) and European Chemical Industry Council and

15 Nov 2023 · EFSW2023: Taking stock of progress on fire safety – what should the Commission and Parliament do to improve fire safety in Europe?

Response to Review of the Construction Products Regulation

25 Jun 2020

The CPR has caused considerable confusion in the market. There is an expectation that construction products should be CE-marked and that this confirms their fitness for purpose. It does not. Instead it confirms that one test in a harmonised standard has been conducted. For most construction products all the tests in a harmonised standard need to be performed and good performance achieved in each for the product to be fit for the intended purpose. This review of the CPR needs to bring the CE-mark for construction products back into line with market expectations. It is true that Member States decide what level of performance they require in construction products and in construction works. Nevertheless the differences between them are not great so for many construction products only a few grades of quality would be needed and for a large number of construction products only one grade is needed. This is particularly true of construction products which make up parts of installed systems, such as in fire protection systems. These products are thoroughly assessed, being subjected to 40 or more tests to ensure they perform over their lifetime in the construction works. No Member State is interested in specifying the performance to be achieved in each of these 40 tests. Instead, national regulators expect experts in the technology to devise the necessary tests and set appropriate pass/fail criteria. Where the national regulators introduce differences is in whether the fire protection system is required in a building. This approach allows Member States to set the performance in construction works while basing that performance on standard products. That means, for example, that the same fire sprinkler can be sold in Finland, Ireland, Portugal and Cyprus, without barriers to market entry. If Member States were to define difference performance for a sprinkler to be achieved when subjected to an assessment, they would be specifying different sprinklers and so creating barriers to entry. Today hardly anyone in Europe understands the CPR or what CE-mark on a construction product means. This is even worse when products bearing the CE-mark are exported. Other, competing standardisation systems such as ISO or ANSI do not suffer from this issue. For the CE-mark to hold value, to support trade within the internal market and exports from it, the CE-mark must be a sufficient indicator of the quality of a construction product and its fitness for purpose. Otherwise some other mark will always be needed, as is the case today. Of the options proposed D2 looks to be closest to what is needed. However, it is unclear whether D2 is limited in scope. Would it allow a standard to specify market conventions, such as the colours used to denote different sprinkler activation temperatures? Would it allow a standard to specify that the body of a valve be made of steel or an equivalent material? This approach puts the onus on the manufacturer to show that a different material is equivalent, rather than the committee drafting the hEN having to devise a series of tests to demonstrate equivalency for unknown materials. In principle the D2 approach can work if the procedure for Delegated Acts is refined to become faster and more routine, for example with Member States given a couple of months to object and no reply taken as agreement.
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