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THE IMPORTANCE OF CE MARKING
» » DOUGLAS MASTERSON,
technical manager at the
Guild of Architectural
Ironmongers (GAI), provides
guidance on CE marking,
what it is, why it is necessary
and whether it will still be
required post-Brexit.
WHAT IS CE MARKING?
It is a declaration by
the manufacturer that the
product meets the essential
performance aspects of a
harmonised standard that is
recognised across Europe.
This regulation is EU law
across all member states,
including the UK.
CE marking is mandatory
for certain construction
products covered by the
Construction Products
Regulation (CPR). In the case
of ironmongery, this includes
specific products which are to
be fixed to fire or escape doors
(see table below).
WHAT IS A HARMONISED
EUROPEAN
STANDARD (HEN)?
All member states of the
European Union agree the
essential characteristics that
must be CE marked before
the product is placed on the
market. These characteristics
form a harmonised
standard.
WHAT IS THE
CONSTRUCTION PRODUCTS
REGULATION (CPR)?
Under the CPR it is
mandatory for manufacturers
to draw up a Declaration of
Performance (DoP) and apply
CE marking to any of their
construction products which
are covered by a harmonised
European standard, or
conforms to a European
Technical Assessment which
has been issued for it.
WHAT ARE THE
REQUIREMENTS FOR A
EUROPEAN STANDARD?
This depends on which
products are manufactured.
The details of the requirements
are within the relevant
standards. However, there are
common tasks required for
each product standard:
• Factory Production
Control (FPC). An FPC is
basically a quality manual
to ensure the manufacturer
is accountable with
recorded and auditable
procedures for production
of the product.
• Initial type test on products
to the relevant European
standard
• Declaration of
Performance and System
Description
• CE marking/labelling
WHAT IS A DECLARATION
OF PERFORMANCE (DOP)?
The document applies
when a construction product
is covered by a harmonised
European standard or
conforms to a European
Technical Assessment (ETA).
The DoP details the product
and the standard, and
contains information about
its performance. CE marking
must be applied to a product
which has either a current
DoP or a previously issued
Declaration of Conformity
(DoC) under the Construction
Products Directive (CPD).
Through provision of a DoP,
the manufacturer assumes
legal responsibility for the
conformity of the product.
WHO ISSUES A DOP?
The organisation that is
marketing and distributing
construction products under
their own brand name within
the EU is classed as the
‘legal entity’ and will need
to produce a DoP for the
product to the relevant hEN or
ETA. The legal entity placing
branded products on the
market can be manufacturers,
importers or distributors
and all have the responsibly
under the CPR to declare the
essential characteristics of the
product within the DoP.
PRODUCT TYPE BS EN NUMBER USAGE LOCATION
Single axis hinges BS EN 1935 Doors on escape routes and fire/smoke
control doors
Door Closing Devices BS EN 1154 Fire/smoke control doors
Electrically powered hold
open devices BS EN 1155 Fire/smoke control doors
Door co-ordinators BS EN 1158 Fire/smoke control doors
Locks and latches BS EN 12209 Fire/smoke control doors
Electromechanical locks and
latches BS EN 14846 Fire/smoke control doors
Emergency Exit Hardware BS EN 179 Locked doors on escape routes
Panic Exit Hardware BS EN 1125 Locked doors on escape routes
LOCKSMITHJOURNAL.CO.UK | SEP/OCT 2018
WHAT WILL HAPPEN
WITH CE MARKING
FROM UK NOTIFIED
BODIES POST BREXIT?
It is believed to be the case
that the UK Notified Bodies
who currently have business
dealings with manufacturers
have already put things into
place to be recognised by
European Commission at the
end of March 2019. Current CE
marked certificates would be
unaffected and manufacturers
would therefore have CE
marking to continue to sell
their products after March
2019.
WILL CE MARKING STILL BE
NECESSARY IF A NO DEAL
BREXIT WERE TO OCCUR?
The UK Government has
released the technical note
‘Trading goods regulated
under the ‘New Approach’
if there’s no Brexit deal’. This
gives advice to manufacturers
in the event of a no deal
Brexit. Points relating to CE
marking including: a new UK
conformity mark (still to be
identified), the CE marking for
exports, plus approval from
an EU Notified Body, whereby
UK Approved Bodies will no
longer be legally eligible to do
this.
www.gai.org.uk