ARCHITECTURAL IRONMONGERY
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Chapter 6: Product Requirements – A Regulatory Approach Based on Safety Risk
• This chapter focuses heavily on how to bring all products within scope of the regulatory regime and how they will be regulated. In response to the specific questions asked within the chapter the Guild responds as follows:
• We point out that the proposed definition of‘ economic operator’ does not include product specifiers, who have significant influence on product selection, particularly in the door and ironmongery industry. We suggests including designers as defined in the Construction( Design and Management) Regulations 2015.
• We agree with the framework for regulating products not covered by designated standards or technical assessments. It emphasises the importance of manufacturers understanding and controlling safety risks. We also note the importance of independent third-party certification schemes.
• We believe that verifying product information is important and welcome measures to ensure this, despite potential slowdowns in supply.
• We acknowledge the usefulness of technical assessments, particularly in cases where harmonised / designated standards are lacking.
• We stress the need to define“ products critical to safe construction” and suggest applying risk assessments to products within systems( such as fire doors) and not just products themselves.
• We highlight the importance of correct and competent ironmongery specification for safety, security, sustainability, and accessibility. It calls for a mandatory change control document for specification changes and emphasizes the need for stringent installation requirements, especially for fire doors. We also suggest a register for fire door installers and inspectors, similar to the“ Gas Safe Register.”
• We acknowledge that implementing higher standards, including demonstration of competency and third-party certification, could increase costs but would ultimately improve quality and avoid a“ race to the bottom” in terms of quality of product.
• We agree that minimum requirements for third-party certification are necessary to ensure transparency and compliance monitoring.
• We support upfront approval from the national regulator for third-party certification schemes to help further enhance their credibility.
• We suggest legislation via the UK Construction Product Regulation or statutory guidance documents to increase the uptake of third-party certification schemes.
• We also emphasise the importance of verified marketing information, such as that provided by the CCPI. This can provide comfort that their product information is reliable and trustworthy.
• We have pointed to third-party certification schemes for installation and the ongoing work of the Industry Competence Steering Group( ICSG) as ways to address gaps in installation competence. ICSG Sector Led Group 10 is specifically involved in creation of competence frameworks on installation and maintenance.
• We also recommend that the UK government promote industry training schemes produced by Trade Associations( such as ourselves in GAI) also that they should insist on mandatory requirement for Continuing Professional Development( CPD) in all disciplines related to fire safety. The promotion of the new BS 8670 2 standard on construction product competence which is currently being created and is due for publication by Autumn 2025 would also assist in increasing levels of competency across the sector.
Chapter 7: Clear Accessible Information
• This chapter sets out Government’ s plans in relation to availability of test results, creation of a new construction products library and the way forward for Digital Product
Passports, and the future of UKCA marking.
• The GAI details manufacturers’ concerns about publishing test information data, citing the complexity of interpreting reports and the risk of misuse by nonspecialists. We also highlight legal issues related to confidentiality and GAI members’ concerns about protecting intellectual property. A potential compromise could be a summary of test reports reviewed and approved by an accredited third party.
• The Guild expresses concern about the practicality and cost of maintaining a construction library. If implemented, useful information would include product data sheets, manuals, fitting instructions, maintenance information, EPDs, certifications, contact details, and dimensional drawings.
• We see the benefits of digital labelling, ensuring product information is available throughout the supply chain. However, concerns exist regarding implementation, cost, and the need for mandatory requirements for all products.
• The GAI believes more specific guidance on minimum standards for product information is needed to improve traceability.
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JULY 2025
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