What is the difference between product and technical documentaton according to the CPR?
If you are a manufacturer of construction products, you will be expected to provide information about your product to every link in the supply chain – from distributors and importers, to contractors and handymen. When it comes to legally required documents for stating conformity with a harmonised European Standard, we can distinguish between technical and product documentation.
Technical documentation issued by a Technical Assessment Body
The Construction Products Regulation (CPR) defines technical documentation as the documents which the manufactuter finds appropriate and sufficient in order to justify his way of declaring the performances of the product. The technical documentation will of course vary from one product type to another. That is why the The Construction Products Regulation (CPR) does not point out specifically which document types constitute appropriate technical documentation. In general, the technical documentation consists of third party test-reports and certificates, issued on the basis of those test reports. All technical information should be kept available in case the market surveillance or other authorities require to verify the data in them.
Technical documentation issued by a other manufacturers
In some cases one manufacturer is allowed to use the test results obtained by another. You may ask for authorisation to use another manufacturer’s test results provided that there is a correspondence between your product and another, produced by a different manufacturer. Additionally, you may do so if the product you want to place on the market is a system of products which have been assembled as per instructions given by their original manufacturer. Both scenarios require that not only the test results, but also the authorisation of the products’ provider be a part of the technical documentation, as they remain responsible for the reliablilty and accuracy of the information.
To sum up:
The technical documentation is the fundament which helps compile accurate and legally acceptable product documentation.
The product documentation is a more concise and easily comprehensible presentation of the products qualities and performances according to standardised requirements. While the technical documentation would normally be issued by a third party (Technical Assessment Body), the product documentation is normally drawn up directly by the manufacturer and should always be accompanying the product itself. Two perfect examples of product documentation are the CE-marking (affixed to the packaging or the product itself) and the Declaration of Performance (usually prodvided by the supplier online or as hardcopy). Both are based on the results stated in the technical documentation and are the manufacturers way of declaring responsiblity for the performances, conformity of the product they are placing on the European market.