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+.