CE Marking a products passport
The CE Mark allows manufacturers to sell their products freely anywhere within the European Union, with common requirements for product design, manufacture or assessment defined within EU directives and regulations. By attaching the CE conformity mark to a product, manufacturers are declaring that it meets the relevant requirements of the applicable CE marking directive or regulation and therefore should be granted free movement within the EU and most EFTA countries, as well as the United Kingdom (at least till the end of the transition period).
CE marking applies to numerous different product categories whereby each product type falls under one or more directives or regulations that determine the specific requirements the product must meet to be CE marked. This blog covers one regulation in particular: the EU Construction Products Regulation 305/2011 (PDF 1MB) (‘the CPR’).
The CPR seeks to remove technical barriers to trade in construction products within the European single market. It creates obligations on manufacturers, importers and distributors of construction products. The manufacturer must take responsibility for ensuring product compliance and attaching the CE mark to the product before it is placed on the market. Importers, who bring products in from outside the EU, and distributors must ensure that the CE marking information accompanies the product to its point of use.
The specific requirements for each type of product are quite detailed and are not contained in the CPR itself but in a harmonised technical specification. This is either a harmonised product standard produced by the European standards organisation CEN (so it has an EN number) or a European Assessment Document (EAD) published by the European Organisation for Technical Assessment (EOTA). In either case the technical specification must be cited by the Official Journal of the European Union (OJEU) before it can be used for CE marking. Only the dated version cited by the OJEU is valid, even if subsequent versions have been published.
The harmonized systems for product assessment in the CPR differ from systems in other directives and regulations. There are five systems in the CPR which vary with the amount of risk inherent in the performance characteristic. High risk characteristics, such as fire safety, require the involvement of third party Notified Bodies before any testing is carried out. Low risk characteristics may only require self-declaration by the manufacturer without the involvement of a Notified Body. Most structural products require the manufacturer to conduct the assessments and make an appropriate declaration of performance, but a Notified Body must check that the declaration is justified by reviewing the evidence and auditing the factory at regular intervals. The harmonized technical specification gives the allocation of tasks between the manufacturer and the Notified Body. This allocation is called the Attestation and Verification of Constancy of Performance (AVCP).
Unless a manufacturer has a comprehensive understanding of their responsibilities and how to meet them, they should seek expert advice to reduce ambiguity on CE marking requirements. BM TRADA has a long experience in construction products product marking (certification) and its experts can provide in-depth advice and support in working through the details of the AVCP systems with the manufacturer. To have a successful outcome, it is much easier if the conversation is started early in a product’s life-cycle so that any design requirements necessary to meet the applicable standard can be built into the product from day one of the design process. This will not only prevent delays but can guard against the significant costs associated with product modifications or repeat testing.
How does Brexit affect CE marking?
Since the end of the transition period, there have been two new product certification marks introduced: UK Conformity Assessed (UKCA) marking and UKNI marking for construction products being placed on the UK market that are currently CE marked. Products that are CE marked will still be accepted on the UK market after but only for a limited time. CE marking is still applicable in the European Union.
If you would like to find out more about UKCA, UKNI or CE marking or request a quote, please contact us.