Specifically, the obligation that UK importers take on the legal responsibility for product claims made by CE marked wood products which they place on the market, but which are manufactured outside of the EU.
TTF members should already be aware of these responsibilities as member companies importing plywood have been actively encouraged to undertake technical due diligence alongside their environmental due diligence as part of the RPP process, with members importing Chinese plywood being independently audited in this regard.
These audits for Chinese plywood are currently taking place via an independent auditor.
One area where plywood importers should be particularly careful is in regard to product claims for EN 636-3S exterior plywood.
The TTF and its members advocate that such claims must be supported, not only by evidence of exterior glue bond testing, but also evidence of the durability of species used throughout the plywood. This evidence should be available to customers upon request.
For instance, a single species plywood such as elliotis pine will be able to demonstrate a strong exterior glue bond meeting the requirements of EN 314 Class 3.
However, most pine manufacturers recognise that the elliotis pine grown in Central and South America is listed in EN 350 as durability class 4 and therefore claim their products as EN 636-2 status, suitable for all internal and high humidity construction applications.
“Unfortunately, it has been brought to our attention that some elliotis pine manufacturers are claiming EN 636-3 full exterior status for their plywood,” said the TTF. “This is misleading to importers and customers alike, because durability Class 4 is less than the recommendations given in EN 1099 to claim suitability for full exterior applications.
“Remember: claims on a DOP are the legal responsibility of the importer not the overseas manufacturer and are only ever as good as the evidence available to support them. If you have no evidence to support the claim you make, then your claim is not valid.”
