BWF members such as yourselves frequently use our Member and Technical Helplines for assistance on a wide range of Employment, Health and Safety, Contractual and Technical issues. We’re putting up a frequently asked question every Tuesday in order to help members and illustrate the type of advice we are able to provide. If you have any questions that you would like to see featured, we would be happy to assist. This question and many others like it can be found in our Question Centre. If you want further advice on any of the issues, don’t hesitate to ring the helpline or browse our extensive publications library, which includes our information on Installation, Building Regulations and Maintenance. This week: Will CE Marking affect me as a small joinery manufacturer? Work continues apace within the European Council work to amend the Construction Products Directive (CPD) to form the proposed Construction Products Regulation. There are some interesting developments which will make compliance with the CPR easier for small or specialist companies (the CPR terms these micro-enterprises). However, there will, no doubt, be further discussions and amendments before the final Regulation is published. The CPR is intended to make CE marking mandatory, but this need not necessarily be a cause of concern for the small joinery manufacturer. The intention is to accommodate these businesses and make CE marking, which is essentially a declaration that a product meets a required level of performance for certain essential characteristics, easier for them. There appear to be within the CPR various alternatives to demonstrating performance by testing or calculation in accordance with a harmonised standard, such as EN 14351-1 the harmonised standard for external windows and doorsets. Theses are detailed in Chapter VI, ‘Simplified Procedures’: Specific Technical Documentation
A manufacturer may replace type-testing or calculation to a harmonised standard with ‘specific technical documentation’ (STD) which can be used to demonstrate equivalent performance for one or several of the essential characteristics of that product. This is particularly useful for products which are individually manufactured or custom-made in a non-series process in response to a specific order.
Similar products
Where manufacturer A produces a product which corresponds to a product produced by manufacturer B, which has already been tested in accordance with a relevant harmonised standard, manufacturer A is entitled to declare performance corresponding to all or part of the test results of this other product. He can only do this after he has obtained manufacturer B’s authorisation. Manufacturer B remains responsible for the accuracy, reliability and stability of those test results. Systems or components
Where manufacturer A produces a product which is part of a system made of components which he duly assembles following precise instructions given by the provider of the system or component part, and the provider has already tested the system or component for its essential characteristics in accordance with the relevant harmonised standard, Manufacturer A is entitled to declare performance corresponding to the test results for the system or the component provided to him. One element of the CPR that appears to be unavoidable is the need for all manufacturers to have Factory Production Control procedures (FPC) in place. For products such as fire doors, the FPC system will need to be audited by a notified product certification body, but for windows or standard external doorsets, the FPC procedures need not be audited but the manufacturer is required to make a declaration that he has the FPC procedures in place. The requirements for the FPC procedures are detailed within the harmonised standards, but the BWF Technical Team can assist members to set-up their own internal systems.