Bathroom and Sanitary Product Regulations in the European Union

Manufacturers of bathroom and sanitary products looking to supply their products in the European Union must follow the requirements of the Construction Products Regulation 2011 (CPR 2011) and the applicable harmonised standards that are published under the regulation.

This guide only lists requirements that are relevant for bathroom and sanitary products that are subject to harmonised standards under CPR 2011. Manufacturers of such products must comply with CE marking, declaration of performance, technical documentation, instructions, and other requirements under the CPR 2011.

Here are examples of bathroom and sanitary products that are relevant to this guide:

• Whirlpool baths
• Shower enclosures
• Wash basins
• Shower trays
• WC pans
• WC suites
• Seamless, round copper tubes for water and gas in sanitary and heating applications
• Wall-hung urinals
• Urinal flushing cisterns
• Communal washing troughs
• Baths for domestic purposes
• Bidets
• Sealants for sanitary joints

Note that we do not cover other directives and regulations that may apply to bathroom and sanitary products, such as the REACH Regulation.

Harmonised standards for bathroom products

Manufacturers of bathroom and sanitary products that are subject to harmonised standards under the CPR 2011 must draw up a declaration of performance.

The existence of a relevant harmonised standard triggers additional requirements. For instance, once the declaration exists, the manufacturer must affix the CE marking and ensure that additional labelling information, such as traceability information, accompanies the product.

Harmonised standards are also important because they state which system of assessment and verification of constancy of performance from Annex V of the CPR 2011 is required. Some systems of assessment and verification require the involvement of a notified body.

Because of the above points, manufacturers of bathroom and sanitary products must identify whether their products are subject to harmonised standards. Below we list the harmonised standards that we found that mention any of the following keywords in the title:

• WC
• Urinals
• Sanitary
• Baths
• Washing
• Wash
• Shower
• Bidet

EN 997 – WC pans and WC suites with integral trap

EN 1057 – Copper and copper alloys – Seamless, round copper tubes for water and gas in sanitary and heating applications

EN 12764 – Sanitary appliances – Specification for whirlpool baths

EN 13407 – Wall-hung urinals – Functional requirements and test methods

EN 14055 – WC and urinal flushing cisterns

EN 14296 – Sanitary appliances – Communal washing troughs

EN 14688 – Sanitary appliances – Wash basins – Functional requirements and test methods

EN 14516 – Baths for domestic purposes

EN 14428 – Shower enclosures – Functional requirements and test methods

EN 14527 – Shower trays for domestic purposes

EN 14528 – Bidets – Functional requirements and test methods

EN 15651-3 – Sealants for non-structural use in joints in buildings and pedestrian walkways – Part 3: Sealants for sanitary joints

We accessed the CEN-CENELEC site and found that they had descriptions for the above harmonised standards. By reviewing the descriptions, we found that they contain information concerning performance and functionality requirements, and other topics such as test methods and procedures for the evaluation of conformity of bathroom and sanitary products.

CE marking and other labelling

Manufacturers must draft a declaration of performance for bathroom and sanitary products subject to harmonised standards under the CPR 2011. When the declaration of performance exists, the manufacturer of the bathroom product must affix the CE marking following the placement requirements in Article 9 of the CPR 2011.

The CE marking should also be followed by the information listed in Article 9 of the CPR 2011, such as the ID number of the notified body (if any), and the reference number of the declaration of performance.

Additionally, the following information for traceability purposes should accompany bathroom and sanitary products according to Article 11 of the regulation:

• Manufacturer’s name, registered trade name or registered trade mark
• Manufacturer’s contact address
• Product’s type, batch or serial number or other product identifying information

Declaration of performance (DoP)

The manufacturer of bathroom and sanitary products must assess whether their products are subject to harmonised standards under the regulation. If they are, it must create a declaration of performance.

The declaration must follow the model set out in Annex III and the content requirements contained in Article 6 of the CPR 2011. The manufacturer must retain the declaration for 10 years. According to Article 7, the manufacturer must provide a copy of the declaration of performance when supplying their bathroom or sanitary product.

Instructions

According to Article 11 of the CPR 2011, bathroom and sanitary products should come with instructions and safety information. Additionally, the instructions should be provided in a language the consumer can understand. Thus, depending on where the manufacturer intends to supply its products, the instructions may have to feature multiple translations of the instructions.

Technical documentation

When the manufacturer has a product that is subject to a harmonised standard, it must create the declaration of performance based on technical documentation. According to Article 11 of the CPR 2011, the technical documentation must contain descriptions of all relevant elements related to the required system of assessment and verification.

The applicable harmonised standard for bathroom or sanitary products specifies the system of assessment and verification that is needed for the product. The full list of systems is found in Annex V of the CPR 2011, and each type of system specifies the tasks for the manufacturer and the notified body (if any).

Product testing

It is usually necessary to test your products to ensure that they comply with the requirements of the CPR 2011 and relevant harmonised standards.

In general, you can approach a third-party lab testing company to perform the tests. However, a harmonised standard may prescribe a system of assessment and verification that requires a notified body to perform the tests.

Here are examples of different tests for bathroom and sanitary products that are subject to harmonised standards:

• Testing of the flushing mechanism, inlet valve and overflow
• Testing for drainage
• Stability testing
• Durability testing

After the bathroom or sanitary product is tested, the manufacturer can expect to receive lab test reports from the lab testing company. These lab testing reports serve as evidence that the product complies with the requirements of the applicable harmonised standards.

FAQ

Are bathroom and sanitary products covered by the CPR 2011?

The CPR 2011 covers bathrooms and sanitary products that meet the definition of “construction product” in Article 2 of the regulation. Here are some examples of bathroom and sanitary products that are construction products and are covered by CRP 2011:

• Wash basins
• Shower trays
• WC pans
• WC suites
• Baths for domestic purposes
• Bidets

Is CE marking required for bathtubs?

We found two harmonised standards that cover bathtubs:

• EN 12764 Sanitary appliances – Specification for whirlpool baths
• EN 14516 Baths for domestic purposes

Manufacturers of covered bathtubs must draw up the declaration of performance for such products. After doing so, they must affix the CE marking.

Is CE marking required for WCs?

We found two harmonised standards that cover WCs:

• EN 997 WC pans and WC suites with integral trap
• EN 14055 WC and urinal flushing cisterns

Manufacturers of covered WCs must affix the CE marking after the declaration of performance is created for the WCs.

Is CE marking required for shower trays?

Yes, in general, manufacturers of shower trays must comply with the requirements of the following harmonised standard: EN 14527 Shower trays for domestic purposes. The manufacturer should also create the declaration of performance and affix the CE marking.

Is CE marking required for bidets?

Yes, in general, it is required. This is because bidets are subject to EN 14528 Bidets – Functional requirements and test methods, which is a harmonised standard. Manufacturers of bidets must create a declaration of performance and then affix the CE marking.