ARCHITECTURAL IRONMONGERY
• The Guild argues strongly that a final decision on UKCA marking is needed, given the significant costs already incurred by the ironmongery and door industry. CE marking is seen as a viable option, but a mutual recognition agreement is necessary to allow certification and testing by UK Bodies being equally accepted in the UK and vice versa with their European equivalents. The future of UKNI marking also needs clarification.
• GAI supports voluntary product marks to demonstrate higher standards but cautions against further markings that could confuse the market.
Chapter 8: Assurance and Oversight of Testing and Conformity Assessment
• The proposals in this chapter aim to ensure strong accountability across the testing and certification landscape, and sufficient oversight.
• The GAI believes that oversight of Conformity Assessment Bodies through the National Construction Product Regulator would be beneficial but calls for clarification on the role of UKAS.
• We also support the government’ s ability to recognize conformity assessment activity undertaken by CABs established outside the UK, provided there is a robust framework to ensure equivalent standards and proper oversight. We recommend succession planning and that broadening out of skills for UK CABs should be implemented.
• The Guild highlights the strengths of the standards development process as used by BSI, CEN and ISO( consensus, public comment, industry expert involvement). It details the pride GAI has in its strong representation on standards at national and international level. It also acknowledges weaknesses within the system including time taken due to reliance on volunteers. We also welcome increased government involvement in BSI committees.
• GAI believes that harmonized / designated standards should be freely available due to their legal status and suggests government subsidies could be used to help with funding of these
• We acknowledge a gap in the provision of fire testing as well as the provision of test reports as demand continues to be huge.
Chapter 9: The National Regulator
• This chapter outlines our proposals to strengthen the enforcement regime
• The GAI strongly agrees with the proposed functions of a national regulator, emphasising the necessity of a single point of contact for effective reporting, triage, oversight, and enforcement. They highlight the shortcomings of past experiences with Local Authority Trading Standards due to a lack of sector expertise and centralised coordination. The GAI stresses that while Trading Standards and other authorities should provide support, they should not lead the regulatory function. Significant investment in staffing levels, expertise, and competence within the national regulator is deemed crucial.
• The Guild firmly supports a stronger role for the national regulator in enforcing misleading marketing. We believe that visible involvement in such cases will act as a deterrent. We notes examples of the Office for Product Safety and Standards( OPSS) already engaging in product recalls which is a welcome development in the sector.
Chapter 10: Environment and Sustainability
• This chapter sets out how the sector can have a role in improving the sustainability and circularity of construction products, supporting sustainable growth without undermining product safety
• The GAI agrees that environmental aspects, as outlined in the revised EU-CPR, should cover products subject to designated standards or technical assessments. They support the use of Life Cycle Assessment( LCA) to measure a product’ s environmental impact across its lifecycle, aligning with the EN standard BS EN 15804 and supplemented by product-specific standards like BS EN 17610 for building hardware.
• The Guild also suggests that for products brought into the regulatory regime through a general safety requirement, the principle of market-driven LCA / EPD should apply. If a manufacturer makes an environmental performance claim, it should be substantiated by an LCA to BS EN 15804. While not advocating for mandatory LCAs / EPDs due to the potential burden, the GAI insists that any environmental claims must be evidenced by a preferably ENstandard compliant LCA / EPD.
Chapter 11: Further Evidence Requirements not featured in the Green Paper
• The GAI continues to express ongoing concern regarding the omission of BS 476 standards from Approved Document B from September 2029. We are concerned that a move solely to EN 1634-1 with its more rigid Extended Application( EXAP) rules without assessment would significantly restrict the scope of hardware and fire doors. The GAI offers its willingness to collaborate with the government to find solutions to bridge this potential gap.
Conclusion
GAI acknowledges the need for radical reform and supports the creation of a robust, transparent framework that enforces compliance and ensures products perform as claimed throughout their lifecycle. The Guild argues that the status quo is insufficient, especially regarding safety-critical items like door hardware, which must meet stringent standards not only at the point of sale but also in operation. The GAI urges the government to adopt its recommendations to avoid future tragedies and help to build a credible, transparent regulatory regime that protects building occupants and restores trust in the construction products sector.
www. gai. org. uk
JULY 2025
45
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