The REACH Regulation has now been functioning since 2007, being an unquestionable progress of the regulation of chemicals, even if some areas may need improvements.

The Construction Products Regulation (CPR) already requires that the information under REACH Article 33 to be provided together with the Declaration of Performance for each construction product CPR Article 6(5).

By doing that, the CPR enables:

• Continuous improvements made in REACH to be automatically taken into account without the need of any change in the CPR legal text.
• The implementation of the REACH requirements (Article 33) for information on the presence of Substances of Very High Concern (SVHC) in construction product articles.

Both regulations are a solid framework to provide all the relevant actors in the construction products supply chain with information to take appropriate risk management actions. This information is also available to the competent authorities.

Construction Products Europe experts have read with interest the SABE draft roadmap for standardisation of substances in articles, and this is our position:

Construction Products Europe does not support the development of a "Standardised Material Declaration Sheet” in the frame of standardisation, and considers that this discussion should remain in the political remits: European Parliament, Council and Commission.

Construction Products Europe recommends CEN to focus the standardisation exclusively on the identification of methods to determine concentration of substances in articles and reminds that as to determining the content of certain regulated dangerous substances in construction products CEN/TC 351 has already made some progress.

Construction Products Europe urges CEN and the European Commission to support CEN/TC 351 standardisation activities. In particular the development of standardised test methods on emissions of dangerous substances and their full validation.