Q: A retailer sells a products, which is not manufactured by himself/herself, using the retailer’s own name. May the retailer use thee declaration of performance(DoP) drawn up by the real manufacturer? If not, does the DoP drawn up by the retailer need to be based on certification granted by a notified body?

A：Retailers( the Construction Products Regulation(CPR) calls them distributors) making construction products available on the market on their own(trade) names are indeed considered manufacturers(cf. Article 15). Therefore, they need to draw up their own DoPs for these products.

The involvement of Notified Bodies(see Article 39 of the CPR) depends on the Assessment and Verification of Constancy of Performance(AVCP) system applicable to the product in question(see Article 28 and Annex V of the CPR). This information may be found both in the applicable harmonised standard (hEN) and in the respective Commission Decision on these systems.

Q: What are the obligations of a retailer(distributor) who sells construction products under the manufacturer’s name?

A: Retailers(the Construction Products Regulation(CPR) call them distributors shall ensure that the products, where required, bears the CE marking and is accompanied by a copy of the declaration of performance and, where applicable, safety data sheet(see Art.6(5) of the CPR)), and by instructions and safety information, in a language determined by the Member State where the products is made available.