This article is to bring light into processes where terms such as “certification”, “assessment”, “verification”, “evaluation”, “type-testing”, “control testing” or “audit” are used. Understanding these words is a precondition to understand the legal procedures and documents.
When a product falls under the scope of Construction Product Regulation 305/2011 (CPR), a procedure called “Assessment and Verification of Constancy of Performance of construction products” (AVCP) must be performed. Is this certification? Kind of… but not always.
AVCP consists of the following elements:
1/ Factory production control (FPC)
is “the documented, permanent and internal control of production in a factory, in accordance with the relevant harmonised technical specifications” according to the CPR. In practice, it is basically a system of written procedures leading to constancy and stable quality of production. There is a great overlap with QMS (quality management system) but they are not identical. QMS is usually too general and does not reflect all the provisions of the harmonised technical specifications (standards or EADs). But elements such as documentation system, responsibilities, monitoring, remedy etc. are the same or very similar.
FPC must always be functional regardless of whether it is audited by a Notified Body or not. If a Notified Body is not involved (under AVCP systems 3 and 4), it is the market surveillance to check it. In a nutshell, FPC must function in such a way that all products placed on the market comply with the Declaration of Performance and other relevant documents.
Monitoring of constancy of production is usually based on control testing (regular test according to a control plan). Nevertheless, “further testing of samples” is only required explicitly under AVCP systems 1+, 1, and 2+. It seems that under AVCP systems 3 and 4, the manufacturer has more freedom to choose any method to monitor the production.
2/ Assessment of the performance of the construction product
Assessment of performance is usually performed via testing but also calculation or another method can be used (when the harmonised technical specification allows for it). The manufacturer is allowed to carry out the assessment by himself under AVCP systems 2+ and 4. This means he can use his own laboratory or contract any other competent laboratory. Under AVCP systems 1+, 1 and 3, only a Notified Body/laboratory can carry out the assessment. Link to the list of Notified Bodies
This task is also commonly called “initial type-testing (ITT)”. This term is officially obsolete but well understood.
Regarding sampling for tests, the manufacturer is allowed to sample himself under AVCP systems 2+, 3 and 4 – otherwise sampling must be carried out by a Notified Body.
3/ Inspection and surveillance of factory production control
Besides product assessment, the main task for Notified Bodies is to inspect manufacturer’s system of factory production control. This has to be done under AVCP systems 1+, 1 and 2+ by audits at the factory. After the initial inspection, regular surveillance audits are done. The usual frequency is once a year but may be higher. The auditor always checks the documentation and the processes and makes a report.
4/ Audit-testing of samples
This activity only takes place under AVCP system 1+ (the most severe one). Not only does the Notified Body audits the FPC but it also samples and tests the product regularly.
5/ Certification
It may be surprising, but it is a matter of fact that not every assessment ends with a certificate. Namely, no certificate is issued under AVCP systems 3 and 4.
Summary
The following table gives a comprehensive overview of the tasks assigned to every AVCP system:
| AVCP system | + | 1 | 2+ | 3 | 4 |
| Factory production control (FPC) | M | M | M | M | M |
| Further testing of samples taken by the manufacturer | M | M | M | – | – |
| Assessment of the performance | NB | NB | M | NB | M |
| Initial inspector (plant and FPC) | NB | NB | NB | – | – |
| Continuous surveillance, assessment and evaluation of FPC | NB | NB | NB | – | – |
| Audit – testing of samples taken by the Notified Body | NB | – | – | – | – |
M = task for the manufacturer, NB = task for a Notified Body
The AVCP system is always specified in the relevant harmonised technical specification – either harmonised standard or European Assessment Document.
It is relatively common that not all characteristics of one product family are under the same AVCP system. Then, for example, some characteristics may need to be tested by the Notified Body whereas others may be tested by the manufacturer
Please, never use the following terms because they do not make sense or do not exist:
EC Certificate
CE-certificate (so commonly used! but does not exist) What is a CE-marking?
ETA-certificate (so commonly used! but does not exist ) What is an ETA?