VOC Emissions under Construction Products Directive
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Protection of occupants, neighbours and environment
Construction Products Directive (CPD) and Construction Products Regulation (CPR) contain a chapter on hygiene, health and the environment, basically saying in very general terms that any construction work must not pose any harm to hygiene or health of occupants or neighbours, among others by giving-off of toxic gas, or by presence of dangerous particles or gases in the air.
This requirement is specifed slightly more in detail in Essential Requirement III and Interpretative document III, proposing to prevent such risk by, among others, "eliminating or limiting the use of materials which may release pollutants, and the use of which results in concentrations greater than acceptable limits". More specific proposals can be read in an Annex to Interpretative document No. 3 and a Guidance paper H, mainly meant for writers of technical specifications.
As all other elements of both laws, the purpose is not to influence the level of protection - the purpose is to harmonize technical description of products, for facilitating cross-border trade. The plan is that a CE label will be accompanied by performance classes that cover all national regulations in Europe. Then each EU member state can specify which performance classes a product shall fulfil for being accepted on that national market. The intention is that this CE marking will substitute any national law.
As Construction Products Directive (CPD) is no direct law in EU Member States, these have adopted CPD in different manners. There is available a database of national legislation related to CPD. In contrast to that, Construction Products Regulation (CPR) is binding in all EU member states without needing national adaptation.
VOC Testing in future CE marking of construction products
A summary of how VOC Testing will be integrated into CE marking is available as presentation slides in English and in German.
VOC emissions from products
VOC emissions (volatile organic compounds) are an important element of occupants protection. The plan of European Commission for handling this is:
- Product groups with major potential impact on indoor air quality shall include hygiene and health aspects, namely the emission of regulated dangerous substances, after next revision of the harmonized product performance standards for CE marking.
- This will happen on the basis of mandates issued by European Commission, first mandates are expected for 2011.
- Most probably the product performance with respect to VOC emissions into indoor air will be expressed in terms of performance classes.
- Performance classes will be specified such that each national regulation in any EU Member State (today: German and French low VOC regulations) will correspond to any of these classes.
- The testing parameters are specified on basis of existing regulation in EU Member States.
An "Expert group for Dangerous Substances" (EGDS) of the EU Commission is about to issue a list of required testing parameters. It is known to contain in any case:- Formaldehyde
- 10 VOCs and TVOC regulated in France
- VOCs with German LCI values, TVOC, TSVOC and all other parameters regulated in Germany
- In a country without regulation on VOC emissions you can then sell CE marked products with the NPD option ("no performance declared").
- In a country with existing regulation on VOC emissions you can then sell CE marked products only if they comply with the corresponding VOC emissions performance class.
- All such product standards shall make use of a harmonized VOC emissions testing method.
- This testing method has been developed in CEN TC 351 WG 2. The text is not publicly available, but here you can see a summary. The draft standard now goes through two validation steps:
- A robustness validation (showing how small changes of testing parameters will influence the test result); this will be finalized early 2012.
- In a first step existing data will be collected and analyzed for concluding on robustness of the present draft testing standard.
- In a second step remaining information will be collected by perfoming targeted testing.
- A round-robin test, planned for 2013/2014, but budget is not yet available.
- A robustness validation (showing how small changes of testing parameters will influence the test result); this will be finalized early 2012.
- Product specific harmonized performance standards may restrict testing to ony those parameters that are relevant for the involved products, as long as this is not in contradiction to national regulations in any EU Member State. These standards will also specify which verification system will be applied, and which role external surveillance will play in that procedure.
- Products with always low or even no VOC emissions into indoor air can be subject to CE marking on basis of a "without testing" (WT) option - or a "without further testing" (WFT) option if an initial testing project showed that any emissions always will be in best available VOC emissions class (possibly under certain frame conditions).
Latest News
Here you will find latest information on what is going on. You may also subscribe to one of our VOC blogs for being informed automatically if any news are reported.
09 May 2012:
The results of the robustness validation resulted in an update of the draft testing standard. It now is subject to an expert consultation within CEN TC 351 national mirror groups, and concerned CEN product TCs. With all incoming comments in mind, final version will be decided by TC 351 WG2 in early September 2012.
10 February 2012:
The validation project group delivered its reports to CEN. This will be used for small modifications of the draft horizontal testing standard. Next version is expected to go to CEN consultation in April or May 2012.
If no delays occur then the standard can be published as Technical Specification in early 2013. Next step will be publication as prEN (draft European Norm).
27 June 2011:
The validation project group had a consortium meeting and agreed on testing program for robustness validation. Work is going on now.
04 April 2011:
Eurofins Product Testing A/S received the order to organize the experimental part of above mentioned robustness validation. This will happen in a consortium formed together with two partners, German eco-institute and German BAM.
01 March 2011:
Eurofins Product Testing A/S forms part of a consortium (including German eco-institute and lead by German BAM) for performing first step of above mentioned robustness validation.
Services
Eurofins Product Testing A/S is deeply involved in the development and validation of a harmonized testing method for emissions of volatile substances into indoor air in CEN Technical Committee TC 351, Working Group WG 2. This allows to use the expertise of the world-wide largest VOC emissions testing laboratory also for CE marking as soon as the respective product standards have been released by CEN.
Eurofins Product Testing is providing services for a similar national system in Germany, the Ü mark for products relevant for indoor air quality, granted after approval by DIBt agency and followed by certification, auditing and re-testing.
The Eurofins laboratories and notified bodies can help you finding your way through conformity declaration, certification and CE marking, and support with related testing.
Important note:
CE marking is possible only for products where the European Commission has issued a mandate to CEN for establishment of a harmonized product standard.
Contact to VOC Testing Laboratories
Please see here contact information of Eurofins VOC testing laboratories in Europe, USA and China:
www.eurofins.com/voc-contacts.
Order forms and testing request forms are available for free download here.
