46 | Sector Focus: Preservatives & Fire Retardants
SUMMARY
■ The OPSS is reviewing how FR treated wood products are placed on the market
■ Guidance note WPA FR 9 can be downloaded from the WPA website
■ WPA presented a webinar about flame retardant treated wood for the RIAS
■Online sales of under-treated fence posts are threatening timber’s reputation
UPHOLDING THE LAW
Flame retardant treated wood: Are you meeting your legal responsibilities, asks the Wood Protection Association?
As part of its role as the UK Construction Products Regulator, the Office for Product Safety and Standards (OPSS) is now actively reviewing how flame retardant (FR) treated wood products – including timber cladding – are placed on the market.
Several timber businesses have already been contacted to verify compliance. These products are inherently safety- critical and ensuring their traceability and performance claims meet the legal requirements of the Construction Products Regulation (CPR) is now a top priority for regulators. A key issue that OPSS is focusing on relates to the Declaration of Performance (DoP) required to support flame retardant treated wood products when they are placed on the market.
As a business, if you are sending a wood product to a treatment plant for FR treatment so you can make an additional claim about its performance then, legally, you must take on the responsibilities as the manufacturer of that product – this includes producing a new DoP.
WHAT DOES THIS MEAN FOR SUPPLIERS? If you are sending wood products, such as cladding, to a third-party for fire retardant treatment and then supplying it to market with that enhanced performance claim, you are legally classed as the manufacturer of that treated product.
This comes with a set of legal obligations, including:
• Producing a new Declaration of Performance (DoP)
• Affixing the correct CE or UKCA marking
• Maintaining a certified Factory Production Control (FPC) system
Even if your operation is not a factory – for example, a warehouse or distribution hub – these responsibilities still apply.
KEY COMPLIANCE REQUIREMENTS 1. Product performance evidence Before placing FR treated wood products on the market and in partnership with the treatment provider, a valid fire test classification report must be obtained from a Notified (EU) or Approved (UK) Body. This will include all the product’s description and forms the basis of your DoP.
2. Factory Production Control (FPC) A certified FPC system must track and trace all treated products. This includes:
• Batch IDs • Staff training logs • Stock documentation • Archiving of treatment certificates
specifications
• Apply approved FR formulations in controlled plant conditions
• Maintain their own certified FPC system and undergo regular audits by an approved
(GB)/notified (EU) body.
Any inconsistencies between the product description and the fire classification test report (for example, wrong species, profile, or thickness), treatment should not proceed.
SUPPORT AND GUIDANCE To help you get this right, the Wood Protection Association (WPA) – in collaboration with TDUK– has produced a set of detailed FR guidance notes covering:
• Roles and responsibilities of the Supplier and Treater
• Procedures for non-conforming materials 3. Issuing a DoP & CE/UKCA marking Once the treatment process and traceability system are in place, and the product has a valid fire classification report, you are required to issue a DoP in compliance with Annex III of the CPR. This document supports the CE or UKCA marking, which must then be affixed to the product.
THE ROLE OF THE TREATER The FR service treater does not own the product; they are responsible for the correct application of the treatment and do play a critical subcontracting role. They must: Validate the product’s physical characteristics (for example, thickness, species, moisture content)
• Ensure alignment between the supplied material, classification report, and end-user
TTJ | November/December 2025 |
www.ttjonline.com
• When and how a new DoP must be issued • Legal obligations around traceability
Of particular importance is Guidance Note WPA FR 9, which outlines responsibilities throughout the FR treatment supply chain – including cladding - and which references other guidance notes that are relevant. WPA FR 9 and the full guidance series can be downloaded from the WPA website (www.
thewpa.org.uk)
ACT NOW TO STAY COMPLIANT Fire performance in construction is under intense scrutiny, and regulators are placing more responsibility on suppliers to uphold safety standards for all the right reasons. If you are supplying FR treated wood products, now is the time to ensure your procedures, documentation, and legal obligations are watertight. ■
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