Who has to take action to comply with the CPR?
The CPR will become a legal requirement from 1st July 2017 under UK Statutory Instrument no 1387.
This puts mandatory obligations onto the entity who first places the product onto the market and subsequently, anybody in the supply chain.
This means the Manufacturer of the cable, the Importer of cable manufactured outside of the EU and any distributor or wholesaler in the supply chain must meet their legal obligations.
Here is a selection of some of the key mandatory obligations. Reference should be made to the CPR regulations to ensure full compliance.
Under the CPR the manufacturer must:
- Apply a CE mark to indicate the product is consistent with its declaration of performance
- Make a declaration of performance (DOP) with regard to reaction to fire
- Assume legal responsibility for the performance of this product to its declared performance
- Issue a DOP based on 3rd party testing from an official notified body
Any company that imports cable from outside of the EU must:
- Ensure the cable is CPR compliant and has a CE mark and a DOP
- Mark on the packaging their name, registered trade name or mark and their contact address
- Carry out sample testing of the products, keep a register of complaints, non conformance and product recalls
- Keep a copy for 10 years of the DOP for all products they supply
- Make documents available to market surveillance authorities
- In this case Compliance is the obligation of the importer not the exporting manufacturer
The Distributor or Wholesaler
A distributor is somebody in the supply chain who sells on cable already placed on the market. They must:
- Ensure cables they supply bear the correct CE marking
- Ensure the manufacturer/importer has complied with all the relevant CPR requirements
- Not supply any product they believe does not conform to its declared performance
- Ensure that if they believe a product is not in conformity withdraw or recall it