CE Marking – Featured Interview

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 door sets 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.

Q: Which product manufacturers will be affected by CE Marking?

CE marking will affect manufacturers of windows and external door sets 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 how their product performs.

As a rule of thumb, If your window or external door sets 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 door sets and fire-rated door sets, 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.

Q: 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.

Q: 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 door sets.

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.