You Have To Obey EU Regulations
Jim Coulson on chipboard and plywood relative to the CE Mark
I WROTE in CFJ (October 2014) about the possible impact of EUTR (European Union Timber Regulation), considering that it is now just over a year old.
Another piece of European legislation came out at almost exactly the same time in 2013: That’s when we got the CPR (Construction Products Regulation) from Europe.
I also wrote a bit about it last year; but here we are just over year on, and it seems that people are still not taking the CPR fully on board – especially where Chinese plywood seems to be concerned (although I have to say that they’re not the only culprits!).
l No opting out of a Regulation: The CPR was not really new it replaced the CPD – where the D stands for Directive – but that was not the law, and the UK opted out of it. However, the R stands for Regulation and that very definitely is the law: And the UK cannot opt out of it – so therefore it must be obeyed!
What the CPR says is that any product used in ‘permanent construction’ and which is covered by something called a Harmonised Standard (bear with me!) must then carry the CE Mark, to show that the product in question obeys the relevant European Standards.
For wood-based flooring products – such as chipboard and plywood – that means EN 13986; which is the standard for all wood-based panel products; and which applies all across the European Union.
So officially, all flooring (and roofing) plywood, as well as all chipboard (used for flooring or otherwise) that is used in a permanent structure, must have a CE Mark. But how much of it out there is not correctly marked? – I ask.
l CE Mark doesn’t guarantee perfection: Of course, as I have written in other articles in CFJ that simply having a CE Mark displayed on a product is not a cast-iron guarantee that it will be ‘perfect’. But at least it is a start, and it shows that some thought has been given to product performance.
So if you are buying any plywood (or chipboard) for use when you ply your trade (sorry about the pun!) as a flooring contractor; then 99 times out of 100 it is highly likely that it will be for some ‘permanent’ use (ie, not for a temporary floor, such as in a marquee or for a trade show, for example).
And that board product must then bear the CE Mark and it should state which aspect of EN 13986 that it complies with.
l Beware of vague certificates: However, beware of vague certificates that give you the product’s so-called Declaration of Performance (known as its DoP), but only in a very broad way: They are really no help at all.
The DoP must be available on demand by any person who buys the product; and it must accompany that product throughout its trading life, right down the chain of supply to the final use.
l Ask your stockist for a DoP (Declaration of Performance): So your stockist must be able to give you a meaningful DoP about what you are buying – in other words; what it is supposed to be used for and what basic attributes it might have (that’s the meaning of performance!).
A plywood that merely describes itself as Type 2/3 or some such wording, is not only meaningless – it is useless to you as a flooring contractor!
This is because it is supposed to be either Type 2 (for occasional wetting) or Type 3 (for exterior use or when you need it to be fully water-resistant): and it cannot be both things, in the same material.
l Proper water resistance: If you read my articles in CFJ regularly, you will know that one of my constant ‘gripes’ is the use of plywood with no proper water resistance, when used with water-based adhesives, or when laid in damp conditions: so a vague ‘is it a 2 or is it a 3?’ type of description is really no help – especially when you’re facing a claim!
l So remember: Just as much as the EUTR is the law, so is the CPR – and both will get you into trouble if they are not obeyed.
The former (EUTR) carries a possible prison sentence for the importer of illegally obtained wood goods (and the confiscation of all stock – including yours, if you were unlucky enough to buy from them!).
The latter (CPR) has potentially dire consequences for the job you are working on – and very likely an upset client as well! It’s your choice: so please make it wisely: and don’t buy cheap – or, as the saying goes, you’ll buy twice – and maybe have to pay compensation into the bargain.
Jim Coulson FIMMM FFB is the director of TFT Woodexperts
T: 01765 601010