Concrete in-situ barriers have traditionally been considered a construction as opposed to a product. In practice, this meant that while they can be assessed according to the same performance requirements a steel and pre-cast concrete following testing protocols defined in the EN 1317, they are not subject to the CE marking process under the Construction Products Directive 89/106/EEC and its sucessor, the Construction Products Regulation 305/2011.
More recently, this assumption has been put into doubt after in-situ concrete manufacturers attained a full CE marking status in 2011.
Upon request from the members of the Road Restraint Systems Working Group, the ERF secretariat sent a letter to Mr Vincente Argüelles-Leoz, Head of Unit for Sustainable Industrial Policy and Construction at DG Enterprise, European Commission to seek clarification on the issue.
The ERF Secretariat received a reply on 18 April from the Commission. In their letter, the Commission clarified that while in-situ concrete barriers should be tested against the same criteria as steel and pre-cast concrete barriers, they are not subject to the requirements of the CE marking as they do are not considered products but construction works.
The letter of European Commission is available here:
Update December 2014
In a letter date 2 December 2014 and addressed to the Secretariat of the ERF, the European Commission has revised its position and has now stated that in-situ barrier that are based on a prioprietary design and which are commercialised as products are covered by hEN 1317-5:2007+A2:2012 and thus can bear the 'CE Marking'.
This revised posiiton, which essentially contradicts the previous stance of the European Commission, has provoked reaction from certain Member States, e.g. France and Germany which have challanged the logic of the interprertation. The respective position are available here: