The Danish Energy Authority to carry out inspections in June and July 2012

Transcription

1 The Danish Energy Authority to carry out inspections in June and July 2012 We check the CE marking of the insulation products of expanded polystyrene (EPS) you sell or use. And we check if you have declared the properties required by the Danish Building Regulations (BR10). Market surveillance of construction products ensures that products marketed and sold in Denmark are safe and not detrimental to health. At the same time we ensure fair market competition. During the months of June and July 2012, focus will be on CE marking of factory made EPS insulation products according to applicable standards. During May, the Danish Energy Authority will publish information material on the rules applicable in the area and of the upcoming inspections as well as the implications it may have if you do not observe the rules. The information material describes the obligations related to CE marking of insulation products. These obligations mainly lie with the manufacturer. However, dealers and contractors are also responsible for the insulation products meeting the requirements. Where will inspection of EPS insulation products be carried out? Market surveillance of EPS insulation products will be carried out at the premises of builders merchants, manufacturers and on construction sites. The Danish Energy Authority will not be able to visit all inspection points throughout the country but approximately 15 unannounced inspections will take place. The unannounced inspections will take place all over Denmark. Maybe we will come to see you! We will ask for documentation of the CE marking and that the EPS insulation products meet the requirements of BR10. Market surveillance in other countries Denmark has entered into an agreement with Austria, Finland, Latvia, Holland, Norway, Ireland, Germany, Cyprus and Sweden to carry out market surveillance of EPS insulation products at national level. The surveillance will be completed in all countries by 1 November The results of the joint collection of past experience will be used in the planning of future surveillance campaigns.

2 2/7 What is subject to the requirement for CE marking? The following harmonised standard specifies the requirement for CE marking of factory made EPS insulation products: DS/EN 13163:2009 Thermal insulation products for buildings - Factory made products of expanded polystyrene (EPS) - Specification Market surveillance will be limited to factory made EPS products. The product standard also describes how to determine the properties to be declared in connection with CE marking. What is CE marking of a construction product? The requirement for CE marking aims to facilitate the trade in construction products within the EU. CE marking implies that the construction product has been tested according to the standard in question. CE marking is a travel pass which makes it possible for a construction product to cross borders without the authorities stopping it with a requirement for further tests. Enterprises may market their construction products in all EU and EEA countries, but there is no guarantee that application of a specific product is permitted. This is stipulated in national Danish legislation, e.g. the Building Regulations (BR10). If a harmonised standard or a European Technical Approval covering the construction product exists, the product must be CE marked. CE marking of a construction product is not an approval or a quality stamp, but may be described as a labelling providing information on the properties of the construction product. A property has been determined based on the same method in all of the EU; Manufacturers are subject to the same requirements for production control; Manufacturers are subject to the same requirement for third party surveillance. CE marking makes it possible to compare construction products from different manufacturers as the products are tested in the same way and the properties are specified in the same way also. This makes it easy for consumers and workmen to select the construction product best suited for a specific building construction project.

3 3/7 The manufacturer is responsible for affixing the CE marking, but the designer, contractor, purchaser, project supervisor and client have a share in the responsibility for using CE marked construction products. What should manufacturers be aware of? CE marking is mandatory, also if a manufacturer only produces and markets for the domestic market. You have the responsibility to find the standard that covers the construction products you manufacture. If you are in doubt, you can submit a product description at and within 24 hours you will receive an answer informing you which standard is applicable to your product. CE marking is based on two main principles for attestation of conformity: 1. Initial type testing 2. Factory production control By initial type testing, ITT, the properties of the construction product are determined. The relevant standard describes how these are tested or calculated. Production control (quality management), also designated FPC, ensures that your construction product continues to meet the properties determined in connection with ITT. In Denmark, EPS insulation products are typically placed in attestation system 3. This means that a notified testing laboratory must assist at the ITT. Apart from the notified body s assistance, the manufacturer is to assume responsibility for the factory production control, prepare the EC declaration of conformity and affix the CE marking. As a minimum, the following properties should be declared for EPS insulation products to be used in Denmark: Reaction to fire Water permeability Insulation properties Compressive strength For properties for which no value has been determined at ITT, and for which the Danish Building Regulations do not lay down any requirements, the manufacturer may declare No Performance Determined (NPD).

4 4/7 If the manufacturer chooses this method, NPD must be declared. It is important that the CE marking accompanies the product and that there is conformity between the CE marking and the marketing procedures for the products. What should designers be aware of? Special attention should be paid to: specifying the right requirements for the construction product; the fact that several of the properties declared in connection with the CE marking are to be applied in the design process; the fact that the Danish requirements for the completed building are provided in the Danish Building Regulations (BR 10). What should a distributor/purchaser be aware of? If you purchase EPS insulation products you must pay special attention to the following: that insulation products are CE marked at that the CE marking is communicated to your customers; that the insulation products meet the legal requirements for the completed building, which are provided in the Danish Building Regulations (BR 10). that dealers have the same liability as manufacturers when it comes to import of producs outside the EU or marketing of a product in your own name (private label). What should workmen be aware of? As a workman you are responsible for using legitimate construction products. Consequently, special attention should be paid to the following: what the designer has stated in the project description; that you must purchase CE marked construction products, when it is mandatory to use CE marked products; that Danish requirements for the completed building are provided in the Danish Building Regulations (BR 10). that bargains must also be CE marked!

5 5/7 Therefore, it is a good idea to carry out an inspection on receipt, so that any faults and imperfections are discovered, before the product is built into the construction. Enforcement measures The Danish Energy Authority has several enforcement measures if we observe lacking CE marking or documentation during the inspection. The Authority may order: withdrawal of the product, i.e. cease of sale and marketing; recall of already sold or delivered construction products from the market; removal of the product if it has already been built into the construction. When processing the case, the Authority may: require that the enterprise provides all relevant information; have the documentation examined by an expert; have the construction product tested at an approved laboratory. Moreover, the Authority may report the enterprise to the police, and the Authority may publish the result of the completed inspection, including the name of the concerned construction products and the enterprises that breached the rules. The above enforcement measures are thoroughly described in Executive order 1075 of 10 November 2008 on marketing, sale and market surveillance of construction products. CE marking of factory made EPS products comprises 3 main elements: CE marking EC declaration of conformity Initial type testing CE marking According to the standard, the CE marking must be affixed to the product, on a label or on the package, and apart from the CE mark itself and the number of the standard it has to contain the product name, manufacturer and year. Furthermore, the CE marking must also be provided on the accompanying technical documents and should contain:

6 6/7 The CE mark; The name and address of the manufacturer; The last two digits of the year in which the CE marking is affixed; Reference to the standard (EN 13163); Description of the product; Declaration of properties in Annex ZA (values or NPD). Visit to see an example of CE marking. EC declaration of conformity It is the manufacturer who issues the EC declaration of conformity, and it is the responsible executive or a person authorised by the enterprise who by his signature confirms that the enterprise complies with the Construction Products Directive and the relevant standard. The declaration of conformity must provide information on: Name and address of the manufacturer with indication of production site; Name and position of the person who has signed the EC declaration of conformity; A description of the construction product, e.g. type, identification and application; Number and title of applicable standards; Any special conditions for the application of the construction product. The EC declaration of conformity must be in Danish, and you must be able to present it to your customer or any other person upon request. If the declaration of conformity is uploaded to the manufacturer s website, it is a good idea to keep the site updated. Visit to see an example of an EC declaration of conformity. Initial type testing Initial type testing determines the properties of the construction product and must in many cases be performed by a notified laboratory. The tests to be performed are described in the product standard EN Which information do we request at the inspection? In connection with the inspection we request the following information: CE marking CE declaration of conformity Initial type testing

7 7/7 Information on FPC (production control) The CE marking and the CE declation of conformity should be available immediately whereas information on ITT and FPC can be obtained either through the dealer or by passing on the manufacturer s contact details to the market surveillance.