How to spot a fake DOP
As a wholesaler, the CPR requires you to make sure that cables are CPR complaint. They must have a tested Euroclass, A Declaration of Performance (DOP) and be CE marked. In the first month of the CPR we have been examining DOPs supplied by other manufacturers and many of them are non-compliant.
Is the DOP valid?
In order to comply with The Construction products regulation (CPR) the cable manufacturer has a legal obligation to draw up a valid Declaration of Performance (DOP). The DOP identifies the product, its intended use and its essential characteristics and is a key part of the legal requirements.
What is becoming clear is that many manufacturers are supplying DOPs that are not valid and, as such, it means the cable should not be placed on the market or sold through the supply chain.
In light of the legal obligations on wholesalers and distributors to ensure cables they purchase are CPR compliant, it means it is essential they check that the DOP is valid. Failure to do so could make them open to legal action from the Government enforcement agencies responsible for CPR.
How can you check a DOP is valid? What to look out for
We have seen a number of instances where DOP’s are invalid and typically these are the 3 main areas to watch out for:
1. A single DOP may cover different variations of a product type (colours and conductor sizes), but a unique identification code must be given for each variant and this must be shown in the DOP. If you look at Example 1 below it refers to a product family, in this case 300/500v, 318*A, but does not give the range of products covered, or the unique identification code of each product variant. This is not a valid DOP and is not compliant to the CPR. In our view cable should not be bought or supplied against this DOP.
|Declaration of performance|
|1. Unique identification code of the product type :||300/500v,318*A|
|2. Description of the product type :||BS6004|
2. All cables must show their intended use, which must be taken from the applicable standard for reaction to fire. Many companies are instead putting in the application of the cable, as in this case Example 2: Installation in walls etc. This is not complaint with the requirements of the Regulation and therefore makes the DOP invalid.
|EC Declaration of Performance (DOP)|
|1. Unique identification code of the product type :||6242y,6243y|
|2. Intended uses :||Installation in walls, on boards and in channels or embedded in plaster|
3. It is a requirement of the CPR to identify the harmonised standard the cables have been tested to for Reaction to Fire. There are many different products covered by the CPR other than cable and it must be possible to check the product certificate back to the performance requirements for that material. In the case here, Example 3, there are two areas of noncompliance. Firstly, BS6004 is NOT a harmonised standard and secondly, it is not the harmonised standard for Reaction to Fire. This section must refer to EN50575 the harmonised Reaction to Fire standard, or again the DOP is not valid.
|4. Systems of AVCP: System 3|
|5. Harmonised standard: BS6004:2012.Table 4|
|6. Notified bodies : BASEC 2661|
During the first month after CPR “Go-Live” we have found fewer than 20% of the DOPs we have examined have been correct. This is a serious issue as it means cable is effectively being bought and sold without compliance to the regulation. We have to date been surprised how few people have requested copies of our DOP’s and feel that companies may believe that getting letters of intent to comply with the CPR from suppliers is enough to meet their legal requirements. Our examination of other manufacturers DOPs suggests this may not be the case and may leave them open to significant legal challenge.
What should you do?
You should ensure you request DOPs and check they are valid. There is a checklist attached of what to review, but the three points above are the key areas to look out for. If you find a DOP that is not valid you should not accept product from the company as they are not complying correctly with CPR legislation and you should not sell it on to your customers.
Assistance can be obtained on how to proceed by contacting the ACI.
1. DOP number
2. Unique identification of the product type
3. Individual material codes (EXAMPLE 1)
4. Intended uses - In relation to reaction to fire. (EXAMPLE2)
5. Manufacturer name and address
6. System of AVCP
7. Harmonised standard: EN50575 (EXAMPLE3)
8. Notified body: name or number
9. Level of performance declared