The Locksmith Journal May/Jun 2019 - Issue 62 | Page 20

20 • INDUSTRYNEWS What’s in a name? GAI Guidance on Rebranding » » DOUGLAS MASTERSON, TECHNICAL manager of the GAI, provides comprehensive guidance for any locksmiths or retailers who are rebranding a product under their own name… One issue which has been consistently raised with GAI over the past number of months is the rebranding of products and the requirements for the accompanying certification. This would be of particular interest to anyone in the ironmongery and security industry selling product which falls under the scope of a harmonised European Standard, including hinges, door closing devices, locking devices (mechanical and electro-mechanical), and panic and escape hardware. A guidance document was released by the Group of Notified Bodies back in November 2017 which specifically related to the rebranding of product and the certification requirements which accompany it. This document was the result of two year’s work by the GNB Advisory Group Task Group. It was released to give some basic conditions which notified bodies should be taking into consideration. Going forward, a notified body certificate covers only construction products placed on the market by the original certificate holder to who the certificate is issued and their brand, not that of the rebrand. The physical producer cannot refer to a notified body certificate for products that are supplied for the purpose of rebranding. A rebranding manufacturer cannot in their Declaration of Performance (DoP) or a CE marking make reference to the notified body that issued a certificate to the physical producer for construction products under Assessment and Verification of Constancy of Performance (AVCP) systems 1+, 1, or 2+. This means that the rebranding manufacturer will need a notified body certificate for the rebrand. In the Construction Products Regulation (CPR), the term “placing on the market” refers to individual units – not to a product type. Construction products are considered placed on the market individually, unit by unit, when supplied for distribution or use. Products supplied by a physical producer (Original Certificate holder) to a rebranding manufacturer for the purpose of rebranding are not considered “placed on the market” by the physical producer. A rebranding manufacturer cannot in a Declaration of Performance (DoP) or a CE marking make reference to a notified body that issued a certificate to the physical producer. Hence, for construction products in AVCP systems 1+, 1, or 2+, the rebranding manufacturer will need a notified body certificate of his own. Any company rebranding a construction product under its own brand name is effectively placing it on the market. This means that this company is responsible for all certification and DoPs which should now be in the name of the company who is rebranding, not the name of the original manufacturer. Anyone who has concerns on this issue should speak to their manufacturer directly and ask for assistance in obtaining this necessary certification under their rebrand. THE MAIN TASKS FOR NOTIFIED BODIES AS DEFINED BY CPR ANNEX V ARE: Certification Decision System 1+ System 1 System 2+ X X X Assessment Of Performance X X Initial Inspection X X X Continuing Surveillance X X X Audit-Testing X LOCKSMITHJOURNAL.CO.UK | MAY/JUN 2019 Sponsored by Mul-T-Lock System 3 X DEFINITIONS: • Assessment and Verification of Constancy of Performance (AVCP) This system safeguards the reliability and accuracy of the DoP. The harmonised technical specifications (harmonised European standards and European Assessment Documents) include the technical details for the implementation of the AVCP system. • Declaration of Performance (DoP) This provides information on the performance of a product. Each construction product covered by a European harmonised standard or for which a European Technical Assessment has been issued needs this Declaration and has to be CE marked. • Physical producer Any natural or legal person who manufactures a product intended to be placed on the market as a rebranded construction product under the name or trademark of a rebranding manufacturer. In case of rebranding, the physical producer is not the manufacturer as defined by CPR. • Rebranded construction product A construction product placed on the market by a rebranding manufacturer under his name or trademark. • Rebranding manufacturer A manufacturer who does not himself physically produce the rebranded construction products he places on the market under his own name or trademark. • Notified certification body These are the only recognised third party carrying out the assessment of performance of construction products. Notified bodies are designated by EU countries. These are Bodies notified in accordance with CPR Art. 48 to function in AVCP systems 1+, 1, or 2+.