Top among the obligations are traceability of the product back to the manufacturer. "Many distributors may not be aware of their obligations," said CPA industry affairs director John Tebbit. "That is why we have listed the most important issues for our members."
The definition of a distributor is "any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a construction product available on the market", Mr Tebbit explained.
"The CPR is law as written and is already in force. The CE marking section comes into force on 1 July 2013 and that date is hard-wired into the regulation at European level," he admonished. "There is no flexibility on this date or duties at national level."
The main changes for merchants are:
* Distributors are specifically identified and given specific legal duties. (This is still in draft.)
* One major consequence of these duties is that distributors will not be able to sell unbranded goods, eg 100mm concrete blocks from multiple suppliers under one stock code. Either the distributor takes on the duties of a manufacturer and sells under their own name or the distributor sells each brand separately with its own stock record number, so that traceability is achieved.
"Many merchants will need only minor tweaks to systems, others may need more extensive changes but the CPA is working with Peter Matthews at the Builders' Merchants Federation to set up workshops for members so that we get everyone up to speed by July," Mr Tebbit pledged.
* Ensure the product bears the CE marking where required.
* The CE marking is accompanied by the relevant information: Declaration of performance; accompanying information, eg content of hazardous substances; application instructions; safety information.
* The relevant information must be provided in the language of the Member State in which the product is being placed on the market.
* Ensure that the manufacturer has complied with the requirements that the construction product bears a type, batch, serial number or some other mark by which the product can be identified, and its name, registered trade name or registered trade mark - or where the size or nature of the product does not allow this - that the required information be provided on the packaging or in the documents accompanying the product.
* The importer's name, registered trade name or registered trade mark and contact address must appear on the product, or where that is not possible, on its packaging or in a document accompanying the product.
* For a period of 10 years, the distributor must be able to provide the market surveillance authority with: the name, address and contact details of the economic operator who supplied them with the construction product; the name, address and contact details of the economic operator to whom they supplied the product.
* The construction product must maintain its conformity with the Declaration of Performance throughout its period of storage and transportation to site.
* Only place on the market construction products which are compliant with the CPR.
* Distributors should not to make the product available on the market if they have reason to believe that it is not in compliance with the requirements of the Declaration of Performance.
* If a construction product the distributor has supplied on the market and which is subsequently found not to be in conformity with the Declaration of Performance, the distributor shall make sure that the corrective measures necessary to bring that product in to conformity, to withdraw it or recall it, as appropriate, are taken.
* If such a product presents a risk, they shall immediately inform the competent authority of the Member State into which the non-compliant product was placed, giving details of the non-compliance and any corrective measures taken.
* The distributor shall co-operate with a competent national authority's request for information on any construction product, to demonstrate the product's conformity with the Declaration of Performance.