Following our call on the Code for Construction Product Regulation consultation we have compiled a list of all the questions and statements raised during and since the call and reproduce them here.The Code for Construction Product Information (CCPI) is currently under consultation and will have a huge effect on how construction products are marketed in the UK. It has implications for manufacturers and specifiers alike, including marketers, PRs, technical and salespeople working in the construction product sector. 


We hosted a call on the code consultation on 26th February. You can watch the video of that call here. 

Following the call we have compiled a list of all the questions and statements raised during and since the call and reproduce them below.

This list has been shared with the Chair and Vice Chair of the Marketing Integrity Group (responsible for the Code) to help them in the consultation process. 

Here are the questions. We would be interested in your comments.

Trust Mark

1. “Show CCPI registered and numbered logo on their material.” Is this considered a quality mark? What does material refer to? Is it physically on product?

• ‘Product Information’ should be signed off by a technically competent person” Define competent person, one could be competent in specific business areas only.

• Is this going to be another compliance mark for manufacturers? How many marks do we need?

International

4. What about EU manufacturers - Importers can they register?

• A lot of building products are produced in China - how is that going to work in terms of their registration and compliance?

• A lot of clarification is needed. CE Marking refers to product marketing. "CE signify that products sold in the EEA have been assessed to meet high safety, health, and environmental protection requirements. CE marking also supports fair competition by holding all companies accountable to the same rules. There are two main benefits CE marking brings to businesses and consumers within the EEA: Businesses know that products bearing the CE marking can be traded in the EEA without restrictions. Consumers enjoy the same level of health, safety, and environmental protection throughout the entire EEA."

Code requirements/Declaration of Performance

7. How does the code relate to technical information such as Declaration of Performance? How does the process align with the DoP and CE marking process?

• “Minimum requirements” How have the CPA set minimum requirements? What is this based on?

• CE marking, data (declaration of performance) is mandatory to report - Https://www.gov.uk/guidance/construction-products-regulations-in-great-britain

• CE marking (or UK marking) is mandatory to report, isn't it? https://www.gov.uk/guidance/construction-products-regulation-in-great-britain  so how does it relate to the code?

• Having audited over 1000 manufacturer websites almost all fall short of the code’s requirements. What is the plan to educate these businesses?

• Why are there so many 'valid points' being made that are already obvious to contractors?

• How will this Code actually make a difference? Manufacturers have misled on rigorous, highly technical tests.  Will a soft code & badge increase integrity?

• Successive reports about the UK construction industry have described it as fragmented and adversarial, with a tendency to adopt a single-discipline mentality - does the code address the need for a joined up approach?

• Under the CCPI Draft it seems that the word "Insured" or "Insurance-backed" is only reserved for guarantees that have an independent insurance policy in place that a client can claim against if the manufacturer and contractor becomes insolvent. Many manufacturers in parts of construction industry currently offer long standing guarantees that are marketed as "Insured" via self-insuring themselves using third party insurance policies. Under new Draft CCPI is this still allowed so long as they are transparent what this means for clients?

• Multiple construction products are typically used in conjunction within each individual building element. This means that the performance of an individual product can’t really be considered in isolation. From what I understand of the testimony from the Grenfell Inquiry, PIR insulation had passed product testing when installed in a very specific system along with other products - but not the ones used on that project. How will product data verification for individual manufacturers manage this complexity - robust details?

Terminology

17. Will you include/improve a more detailed glossary, Terms & Definitions?

• The code doesn't mention the need for a Unique ID (single version of the truth) similar to a retail barcode, without this how will the product data be managed?

• Be careful with "up to date"! FM people will need to find info on products installed years ago - old models

• Will there be a requirement for submitting digital information about products in an open format, so it remains accessible for the lifetime of the built asset?

Survey

21. Given that the Code is largely a result of the research survey carried out in 2019, and that many issues with this research process have been raised will Adam agree that if an independent research expert reviews the survey and deems it to be unfit for purpose, and that the data is unreliable that the CPA and MIG will scrap all current plans and redo this research properly before proceeding any further?

• As the poll initial poll stands there is only 2% representation from the distributor, this speaks volumes, there buy-in is as important as that of manufacturers

CPA

23. Adam Turk has stated that he & the CPA are NOT interested in hearing that the Code is a bad idea - they're pressing on regardless of industry feedback. Does he accept this is the wrong approach, and will he retract this & agree that all options have to be on the table in terms of accepting industry feedback including scrapping this plan altogether if the consensus is that it is not the correct approach or solution?

SMEs

24. How will SMEs be engaged? They exist in their thousands, and many don’t have time/ resources to engage?

Statements

25. Think globally act locally. Clause 7 is the real driver for change IMO

• This process seems to help close the gap for where incorrect information is provided unknowingly and unintendedly. How to avoid intended misleading information?

• Saying manufacturers must have websites is a 20th century approach. important thing is accuracy of info and accessibility can be through other equivalent means.

• Websites come in all shapes & sizes, but not all are useful to support interoperability, eg. glossy PDF style pages are inadequate for information exchange

• We plan to build some of these processes into our product data management systems. This is also key when looking at what is coming down the road with Lexicon, product IDs, etc. Also, looks like overlap between Lexicon work and CCPI with the use of trade associations as "Relevant Authorities" to decide on technical requirements.

• Manufacturers' information will be captured during processes managed in common data environment (CDE) workflows, and so will form part of the asset record "golden thread". Not requiring accessible digital information seems to fall short of delivering the 'digital by default' recommendation made by Dame Judith Hackitt.

• Manufacturers has existing obligations to store the information for a minimum of 10 years

• It is going to be very hard to ensure this is all happening without open & interoperable structured data.

• Necessary? Yes 100%. Ready to launch? Not sure. I hope there is transparency about the consultation, in particular the number of organisations participating in the process and a clear roadmap on rollout and implementation for SME manufacturers and distributors who I think will be caught cold by this initiative.

• Yes, we need to get a move on. But no solution is better than a wrong solution. The wrong solution could easily lead to very dangerous complacency across the sector ("we've got our badge, all good").

• It is important that the simplicity and benefit of digitisation are explained and shared in plain language, so the manufacturers can meet all the key requirements to be clear, accurate, up to date and unambiguous. Without a single source there is no way the CCPI will deliver.

• CCPI appears to think PDF’s pushed to a webpage is sufficient! Working digitally doesn’t appear to be in their current remit.

• The intentions are noble and necessary but there still seems to be so much more to work through; I just can't see how this code can be launched effectively any time soon.

• I'd be interested to know how many manufacturers at this point are even aware of the CCPI

• I think overall the CCPi is a step in the right direction, but … it needs to be strengthened to cover the sharing of data in a BIM / project environment, especially where data is managed by a third party, such as a content provider or procurement platform. There are ways this can be addressed, but I’m sure if it isn’t covered the usual protagonists will jump in and say they have it covered regardless of whether they offer a practical solution or not. It will be good to know if the regulator will be challenging those organisations saying that they provide CCPI compliant solutions where they do not. In the end though, it’s obviously the responsibility of manufacturers to keep their information up to date, and I hope that the code will contribute to a move towards more manufacturers owning and managing their own data.

• While positive about the intentions of the Code, it feels rushed if it going to go live in the next few months.

• The primary benefit should be in terms of encouraging the adoption of processes and systems (albeit ones that are not defined, as others have pointed out) that increase transparency about product information. Even so, I've been part of other schemes in the past where having documented systems/processes, and a badge to demonstrate knowledge to end users, has had absolutely no impact on those end users who are supposedly the ones to benefit. My concern is that the same happens with this scheme. When I read the consultation report, I find myself bumping on details of it and wondering how it will work in practice. How do you properly apply it to all the different possible contexts for verbal information? Will end users of product information understand the code well enough to actually make complaints if they think a piece of information is inappropriate? And so on. Ultimately, and unfortunately, I'm unconvinced that having this badge will be a genuine demonstration of companies possessing the 'right' culture. And I mainly think it will favour large organisations who can more easily dedicate time and resource to implementing it.

• It occurs to me that you can’t easily control what people say in a sales pitch. Unfortunately, it also seems that when a product appears to offer a significant cost saving people are more than willing to suspend belief. As such, this initiative can only work if the entire supply chain is taught to be cautious and ask for / demand proof to support verbal product claims - especially before proceeding with the ‘or similar approved’ switch. Since this initiative requires more reliable product data it should also reward those manufacturers investing in product testing - and encourage others to do likewise to create more differentiation and USP’s. From the manufacturer’s perspective, a move away from the recent culture of product homogenisation, which has allowed for easy switching, should actually be seen as a real opportunity.

• It’s been interesting watching some of the testimony at the Grenfell Inquiry … Put people with limited technical knowledge in place and add remote leadership pressure to deliver new revenue streams - what could possibly go wrong? Hopefully the inquiry will also highlight the need for adequate team training along with a culture change which places a clear line responsibility for risk assessment in the C-Suite - as much as how data is validated and presented.

• Seemed also to be an old-school view of manufacturers ... out of step with advancing MMC, DfMA, P-DfMA, etc

• Not enough consultation with the information management specialists or with digital marketing specialists

• The problems outlined here would be helped if the CCPI differentiated more clearly between “facts” and “marketing messages”. Factual claims can be substantiated (and the CCPI clearly is attempting to encourage this). Structured, verifiable secure data tracked back to source would ensure this. Marketing messages are much more difficult to control. I think the CCPI has a much bigger challenge though in the longer term; convincing manufacturers to allow their products to be genuinely compared. Ultimately pricing information changes, so it cannot easily be compared day to day. Which is why marketers use terms such as ‘competitive’.

Supply Chain

47. How are you going to engage the entire supply chain? This is a good idea, but it needs to start with the client requesting to work with only compliant companies

• Will manufacturers have a responsibility to train distribution / merchant resellers in their products to ensure their competency?

Marketing

49. Should third party marketers perhaps be able to apply to be CCPI Approved to be able to work on product information?

• As a marketing agency, would we be considered as a Supporter?

• Clients expect agencies to provide expert advice on comms including product info. Lines could be blurred as far as responsibility is concerned.

• As the marketing manager for a leading UK specialist builders merchant, I would like to know who will create the formal process to ensure that any data we show on our website is verified, checked and signed off in advance of its use by each of the manufacturers of whom we stock and sell their products? (of which there are many!) Who designs the processes for version control? And how will I know that the manufacturers have been accredited to use the CCPI logo?

• Marketing are known to‚ delete web pages‚ not knowing the page is still required to be accessed at some point because one day - someone will google it.

• All too often marketers are relatively new to an organisation, with limited technical knowledge and under pressure from sales to deliver something ‘new’ for their customers. As such marketers often act with the best of intentions but with only partial information made available to them. I’m sure that I wouldn’t be the first, last, or only, marketer asked to produce a Product Datasheet for an important customer at short notice with limited information. I’ve always refused to make unverifiable product claims but it can be a difficult conversation - especially when a potentially valuable order is on the line. If the outcome of this is a requirement for organisations to produce verifiable product data I believe it would actually help many marketers in their work.

Charter

55. Who signs the charter on behalf of the manufacturer? It needs to be the CEO. Can you confirm this?

Standards

56. BS 4940-2:1994, ‘Technical information on construction products and services. Guide to content and arrangement’ is still current. Has this been considered?

• Checking DoP communication, I would add reference to EN 15804 (or the UK version BS EN 15804:2012+A2:2019) and/or ISO 21930, as are the reference for construction products. In clause 4, certification, if the Information about the CE marking is displayed, a link to the data contained in the declaration of performance should be added. If a digital format for DoPs is to be provided, EN ISO 22057 will define the data templates (under ballot, hopefully available soon): https://www.iso.org/standard/72463.html

Audit

58. Working for a large steel manufacturer I can see a significant amount of resource is required to implement a central robust system of ‘version control’ that can be audited efficiently, a system documenting hundreds of data sheets, case studies, web pages, brochures, installation manuals, spec guides etc for creation and approval sign offs, tracking updates, mapping out the official sign off process that lists all the key personal, dates and times etc, it’s a huge undertaking when you sell thousands of different products, across several manufacturing sites involving hundreds of sales and technical personnel in different countries!!! Don't misunderstand, as responsible manufacturers many of us already have systems is place for internal track and approval - but can they be audited effectively by an external body? And what does that audit look like?