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CE Marking interview with Kevin Underwood

CE Marking is little over a month away, and joinery firms need to have everything in place if they are to legally sell windows and external doorsets from 1 July 2013.


Mighton Products spoke to the British Woodworking Federation’s Technical Manager, Kevin Underwood, to get a run-down of what the requirements are.

Which product manufacturers will be affected by CE Marking?

CE marking will affect manufacturers of windows and external doorsets from 1 July 2013.

This is because these products are covered by a harmonised European standard (hEN) and, under the Construction Product Regulation (CPR), it will become mandatory for manufacturers of such products to apply CE marking in order to demonstrate hoe their product performs.

As a rule of thumb, If your window or external doorset requires a U-value under the Building Regulations, then you will need to CE mark. Businesses need to be wary on this count because, even customers haven’t been asking for U-values, you could still be required to provide them. We recommend that companies aim to achieve a CE mark, rather than try to avoid it as the derogations or exemptions from the requirements are very limited.

Other construction products that may be in the scope of CE Marking from 1st July include wood, and laminate flooring, garage doors, shutters, gates, cladding, panelling. Manufacturers also need to be aware that work is underway on harmonised standards for internal doorsets and fire-rated doorsets, so these could soon be in scope in the future. There could also be work in the future on developing a harmonised standard for timber stairs.

Is CE Marking just a case of sticking a label on the product?

No, although you will need to label the product once the other requirements have been met.
The mandatory requirements of CE Marking include having a written Factory Production Control system. This is to ensure that procedures are put in place to allow a manufacturer to maintain consistency in quality and to keep records of non-conforming products, processes or materials.

Crucially, you will also need to produce a Declaration of Performance (DoP) for your product and retain the documents and reports referred to when completing the DoP.

What do I need to include in the DoP?

For each CE marked product or group of products, the manufacturer will need to produce a DoP document that outlines how the product performs in relation to a number of ‘essential characteristics’. There are 8 essential characteristics for windows and 11 for doorsets.
While all of these must be listed on the DoP, only three essential characteristics are required to have a value against them. These are the thermal transmittance (i.e the U-value), a declaration of dangerous substances, and the load bearing capacity of safety devices – this can include test evidence that can be cascaded down. Here at BWF we have drawn up a template DoP that manufacturers can use. Manufacturers need to be aware that if they have evidence of the other characteristics, they must include them on the DoP. Also if the business is larger than a ‘micro-enterprise’, then their essential characteristics will need to be accredited through a Notified Body such as BSI.

So how do you define a ‘micro-enterprise’?

A micro-enterprise is defined as an enterprise which both employs fewer than 10 persons and whose annual turnover and/or annual balance sheet total does not exceed 2 million euros.

After meeting the mandatory requirements, can I just CE label the product?

Yes, but you must display the CE mark on or with your product in accordance with article 9 of the Construction Products Regulation which states that:

“The CE marking shall be affixed visibly, legibly and indelibly to the construction product or to a label attached to it before the product is placed on the market.”

We have drawn up a template label including the CE Marking information. BWF members can download this, adapt it, and get it printed off.

How is CE Marking going to be enforced?

Trading standards will be enforcing the regulation, and failure to comply could result in prosecution, or manufacturers having to take their products taken off the market.

Where can I get help?

As well as enjoying the range of other business support services that we offer, BWF members are already been making use of our CE Marking resources, which include the dedicated technical helpline. We have draft DoPs, a template CE label, and a written Factory Production Control template - all resources that are free for members to download, adapt and adopt.

Anyone wanting a brief introduction to what the BWF can provide them with on CE Marking can visit www.bwf.org.uk/toolkit/ce-marking  and download the CE Marking factsheet.

If you’re interested in joining BWF you can contact us on 0844 209 2610 or e-mail my colleague Michael Lee at Michael.lee@bwf.org.uk


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