Since the 1st July 2013 CE Marking has become mandatory in the UK for all construction products, but what does this mean for the specifier? Mark Wadsworth, Operations Director of Senior Architectural Systems looks at the impact of CE marking on the industry and what specifiers need to be aware of.
The fenestration industry in the UK has had some time to evaluate and prepare for the mandatory CE marking that has been imposed by Brussels in July this year. But for what seems to be another layer of legislation, CE marking does make a lot of sense, in fact it brings together much of our current legislation to offer a single label of conformance.
It all starts with the Construction Products Regulations (CPR) EU 305/2011 which directs suppliers/installers to label their products with the CE mark (Conformité European). CE marking confirms compliance with Harmonised European standards (hEN’s), which provide methods and criteria for assessing the performance of construction products in relation to their Essential characteristics. hEN 14351-1 is applicable for doors and windows for domestic & commercial locations, and hEN 13830 for curtain walls.
Does the CE mark have to be legible and if so where?
By affixing, or having affixed, the CE marking to the product, packaging or accompanying documentation the manufacturer and/or installer is confirming that they take responsibility for the conformity of the construction product with the declared performances as well as with all the applicable requirements defined in the CPR and all other additional relevant regulations.
The mark may be permanent, but as it is mandatory there is no ‘marketing’ advantage to incurring additional costs to making it visible on the product, on the contrary, the mark could detract from the aesthetics of the supplied product.
Who is responsible to ensure conformity?
If the product is supplied and installed, such as in the case of windows, doors and curtain walls, it is the responsibility of the sub-contractor on the project. This a legal obligation and there is no need to request for CE marking or even specify compliance.
The hEN’s provide important information on the scope; normative references; terms and definitions; requirements; testing; assessment and sampling methods; assessment and verification of constancy of performance (AVCP); and, CE marking and labelling. Sub-contractors with attain much of this information from systems and product manufacturers, but it is their legal responsibility to ensure it is provided.
What’s behind the CE mark that confirms compliance?
An important CPR requirement for the manufacturer is to prepare a document called Declaration of Performance (DoP) and to supply it to the customer, in our case the main contractor, in paper or electronic means. By drawing up a DoP the sub-contractor assumes full and legal responsibility for the declared performances. It is important to qualify that the DoP only relates to the product, it can be viewed as a ‘Product Passport’ and as such it may not always relate to the projects specification or specific requirements.
The DoP must be retained by the manufacturer for a period of 10 years after the construction product is placed on the market. A CE mark cannot be affixed if a DoP has not been drawn up. A DoP is required for every product supplied on a project, it need not be provided with the product, but must be available upon request. Common products may be gathered together on a single DoP.
As a specifier what do I need to do?
Nothing… As the CE mark is a label of conformance it offers the specifier, the main contractor and ultimately the owner of the property, confidence that the product conforms to the standards. For all orders placed after the 1st of July, product supplied and/or installed will be deemed compliant. As a customer you must be given access to a DoP, should you wish to refer to it.
At Senior’s we have advised all our customers of the requirements of the CPR and their legal obligation to be in compliance. Despite some negative comments posted by some in the press, we believe the CE mark does offer the industry the ability to bring much of what our customers were already doing into a single compliance document, the DoP.
By affixing, or having affixed, the CE mark to the product, packaging or accompanying documentation, the installer or sub-contractor is confirming that they take responsibility for the conformity of the construction product with the declared performances as well as with all the applicable requirements defined in the CPR and all other additional relevant regulations.
For the specifier, the CE mark offer the assurance of conformity well after the project has been completed.