The Construction Products Regulations defines a manufacturer as “any natural or legal person who manufactures a construction product or who has such a product designed or manufactured and markets that product under his name or trademark (Article 2 (19)).” As a result, importers and distributors can also be considered a manufacturer, and are subject to all relevant legal obligations, including the need to provide a compliant Declaration of Performance.

radiators, including steel panel, multicolumn and other designer products including towel rails, are covered by the designated standard BS-EN 442. This means that manufacturers, distributors and importers are legally obliged under the Construction Products Regulation 2011 to undertake tests set out in the standard, including the measurement of the rated thermal performance output of the radiator.

The tests detailed in this standard should be carried out independently by a suitably accredited laboratory and measure the output of a radiator. The manufacturer should then state the heat output for their products at Delta T 50 and Delta T 30 in the Declaration of Performance for each radiator.

Under the UK Construction Products Regulation (CPR), which aligns with EU Regulation (EU) No 305/2011, it is a legal requirement for all radiators to be accompanied by a Declaration of Performance at the time of supply, either in paper or electronic form, for example as a website download. The Declaration of Performance must include precise outputs measured in Watts, at both Delta T 50 and Delta T 30. Delta T (?T) refers to the temperature difference between the water circulating in the central heating system and the ambient room temperature, and is crucial for accurate heat loss calculations.

Duncan Johnson, Deputy Director of Construction Products Regulation for the Office for Product Safety and Standards (OPSS), expressed support for MARC's initiative, stating: “We are delighted to be working with MARC to address the challenges being faced in the radiator industry, helping to ensure that manufacturers and suppliers are providing information that is both accurate and compliant with the standard.”

Failure to meet the legal requirements of the Construction Products Regulation 2011, particularly by declaring the heat output of radiators at Delta T 60 to provide an exaggerated perception of higher radiator output, misleads consumers and risks investigation by the Office of Product Safety and other regulatory bodies.

Such non-compliance by unscrupulous suppliers can affect the consumer because they could be buying the wrong sized radiators for their room, resulting in higher energy bills, colder homes and increased carbon emissions.

Andy Phillips, Chair of MARC, emphasised: “Complying with the Construction Products Regulation and adhering to BS-EN 442, by providing values for Delta T 50 and Delta T 30, is crucial not only for regulatory compliance but also for ensuring that consumers get the level of heating they expect. Using Delta T 60 values or higher is in breach of the Construction Products Regulation and also undermines the integrity of our industry.”

For consumers, the use by manufacturers and distributors of incorrect Delta T values on websites and in the Declaration of Performance can lead to inadequate heating, requiring them to turn up the temperature on their boiler or compromise the efficiency of their heat pump. This directly conflicts with the industry’s efforts to achieve net zero targets and places unnecessary financial burdens on households. Installers are urged to check Delta T values when carrying out radiator installations, to ensure accurate heat loss calculations and optimal heating performance.

MARC urges all stakeholders in the heating and hot water industry to ensure that the information in their product literature and advertisements is both accurate and compliant with the Construction Products Regulation 2011. By complying with BS-EN 442 and providing compliant Declarations of Performance, manufacturers and distributors will deliver the best outcome for consumers, at the same time as contributing positively to environmental goals.

For further information and guidance on compliance, visit https://www.marcuk.com/news/legal-requirements-for-radiators