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The importance of CE marking

Douglas Masterson, technical manager at the Guild of Architectural Ironmongers (GAI), provides guidance on CE marking, what it is, why it is necessary and whether it will still be required post-Brexit.

What is CE marking?

It is a declaration by the manufacturer that the product meets the essential performance aspects of a harmonised standard that is recognised across Europe. This regulation is EU law across all member states, including the UK.

CE marking is mandatory for certain construction products covered by the Construction Products Regulation (CPR). In the case of ironmongery, this includes specific products which are to be fixed to fire or escape doors:

Single axis hinges BS EN 1935 Doors on escape routes and fire/smoke control doors
Door Closing Devices BS EN 1154 Fire/smoke control doors
Electrically powered hold open devices BS EN 1155 Fire/smoke control doors
Door co-ordinators BS EN 1158 Fire/smoke control doors
Locks and latches BS EN 12209 Fire/smoke control doors
Electromechanical locks and latches BS EN 14846 Fire/smoke control doors
Emergency Exit Hardware BS EN 179 Locked doors on escape routes
Panic Exit Hardware BS EN 1125 Locked doors on escape routes

What is a harmonised European standard (hEN)?

All member states of the European Union agree the essential characteristics that must be CE marked before the product is placed on the market. These characteristics form a harmonised standard.

What is the Construction Products Regulation (CPR)?

Under the CPR it is mandatory for manufacturers to draw up a Declaration of Performance (DoP) and apply CE marking to any of their construction products which are covered by a harmonised European standard, or conforms to a European Technical Assessment which has been issued for it.

What are the requirements for a European Standard?

This depends on which products are manufactured. The details of the requirements are within the relevant standards. However, there are common tasks required for each product standard:

  • Factory Production Control (FPC). An FPC is basically a quality manual to ensure the manufacturer is accountable with recorded and auditable procedures for production of the product.
  • Initial type test on products to the relevant European standard
  • Declaration of Performance and System Description
  • CE marking/labelling

What is a Declaration of Performance (DoP)?

The document applies when a construction product is covered by a harmonised European standard or conforms to a European Technical Assessment (ETA). The DoP details the product and the standard, and contains information about its performance in relation to the essential characteristics defined within the applicable harmonised technical specification.

CE marking must be applied to a product which has either a current DoP or a previously issued Declaration of Conformity (DoC) under the Construction Products Directive (CPD). Through provision of a DoP, the manufacturer assumes legal responsibility for the conformity of the product.

Who issues a DoP?

The organisation that is marketing and distributing construction products under their own brand name within the EU is classed as the ‘legal entity’ and will need to produce a DoP for the product to the relevant hEN or ETA.

The legal entity placing branded products on the market can be manufacturers, importers or distributors and all have the responsibly under the CPR to declare the essential characteristics of the product within the DoP.

What will happen with CE marking from UK notified bodies post Brexit?

It is believed to be the case that the UK Notified Bodies who currently have business dealings with manufacturers have already put things into place to be recognised by European Commission at the end of March 2019. Current CE marked certificates would be unaffected and manufacturers would therefore have CE marking to continue to sell their products after March 2019.

Will CE marking still be necessary if a no deal Brexit were to occur?

The UK Government have released the technical note ‘Trading goods regulated under the ‘New Approach’ if there’s no Brexit deal’. This gives advice to manufacturers in the event of a no deal Brexit. Points relating to CE marking include:

  • CE marking will be replaced by a new UK conformity mark (still to be identified) for use in the UK domestic market only.
  • Manufacturers will have to continue to use the CE marking for exports to the EU.
  • Export products to the EU will continue to need approval from an EU Notified Body.
  • UK Approved Bodies will no longer be legally eligible to undertake this activity for the EU market.
  • EU imports will continue to use the CE marking for a time limited period only. The duration of this period has not been set.

The UK Government have stated that these new rules will only apply if there is no deal and that they are doing their best to avoid such a scenario.