Guidance Note No 21/1 CE Marking Windows and doorsets to BS EN 16034 Introduction CE Marking of construction products has been a legal requirement since July 2013. It is a European requirement for all products covered in the scope of a hen (Harmonised European Standard) to be CE Marked and for the manufacturer to issue a DoP (Declaration of Performance). It is a means of declaring a construction product s performance against a European Standard. BS EN 16034 has been cited in the OJEU (Official Journal of the European Union) and will become harmonised from 1 st November 2016. It will then be voluntary to CE mark to this standard until the end of the co-existence period, 1 st November 2019. After this date it will become mandatory to CE Mark all products in scope. Given the scope of BS EN 16034, (i.e. windows and doorsets) products CE Marked to this standard will also have to be CE Marked to either: BS EN 14351-1 Doors and windows External pedestrian doorsets and windows 1 OR BS EN 13241 Industrial, commercial and garage doors and gates product standard. prbs EN 14351-2 Doors and windows Internal pedestrian doorsets (when published in the OJEU and mandatory when the co-existence period finishes) OR BS EN 16361 Power operated pedestrian doors (when published in the OJEU and mandatory when the co-existence period finishes) OR Scope of this Guidance Note This Guidance Note is intended for the manufacturers of pedestrian doorsets and openable windows with fire resisting and smoke control characteristics covered by the harmonised product standard BS EN 16034:2014 (Pedestrian doorsets, industrial, commercial, garage doors and openable windows - Product standard, performance characteristics - Fire resisting and/or smoke control characteristics). There are three main types of operation covered in this standard: opening and self-closing as a normal mode of operation normally held open but self-closing in the case of fire or smoke normally maintained locked in the closed position. 1 This Guidance Note should be read in conjunction with CGN 19/1 CE Marking windows and doorsets. Tel: 01453 828851 Fax: 01453 828861 Email: enquiries@c-a-b.org.uk Web: www.c-a-b.org.uk Page 1 of 12
This standard is not applicable to: fixed windows, glazed side panels and/or overpanels, which are not an integral part of a doorset and/or openable window door assemblies produced with components from several sources, where there is no single identified manufacturer or legal entity who will take responsibility for them doors and/or windows installed in environments where the electromagnetic disturbances are outside the range of those specified in EN 61000-6-3 radio operating devices fitted to doorsets and/or openable windows, the relevant ETSI standards should be applied in addition. What does the manufacturer need to do? The chart on the following page provides an overview of the CE marking process to BS EN 16034. The following sections of this Guidance Note provide further details on each of the eight steps highlighted. 1 Define your product ranges For the purposes of this guidance note, your products will be fire resisting and / or smoke control doorsets and / or openable windows covered by BS EN 16034 (along with one of the other product standards listed in the introduction). You should where possible group your product range, e.g. casement, tilt and turn, parallel opening. This will allow you to declare separate performance levels for each style against the required characteristics. It is the collection of characteristics and their performance values that define the product type. If you decide all your products are to be placed into a single group you will need to prepare only one Declaration of Performance (detailed in section 7 below), but this will need to state the worst properties achieved across the group. As the Declaration of Performance is a legal statement of the performance of your products, you must use only this data when referring to your products, for example in any sales literature and on websites. Hence you need to think carefully about the optimum grouping of your products. Tel: 01453 828851 Fax: 01453 828861 Email: enquiries@c-a-b.org.uk Web: www.c-a-b.org.uk Page 2 of 12
Steps for the manufacturer to CE mark products to BS EN 16034 1 Define your product ranges 2 Review Annex ZA within BS EN 16034. Note that products in scope of BS EN 16034 will also be CE marked to either BS EN 14351-1, prbs EN 14351-2, BS EN 16361 or EN 13241-1, so you must also review the Annex ZA in the relevant product standard 3 Check the essential performance characteristics in BS EN 16034. For the UK market the mandatory requirements are currently: resistance to fire, smoke control, self-closing, ability to release, durability of ability to release and durability of self-closing 4 For products in the scope of BS EN 16034, the applicable AVCP compliance system is System 1; contract with the Notified Product Certification Body that you wish to work with 5 Carry out the required Initial Type Testing (ITT). Test reports will normally be "cascaded" down from your system supplier; otherwise you will need test reports from a Notified Body 6 Set up and implement your Factory Production Control (FPC) system. The manufacturer is responsible for the FPC. The assessment, evaluation and continuous assessment of the FPC is carried out by a Notified Body 7 Obtain the Certificate of Constancy of Performance for the product from the Notified Product Certification Body. Produce and sign the Declaration of Performance 8 Apply CE marking to either the product, the packaging or the accompanying documents Tel: 01453 828851 Fax: 01453 828861 Email: enquiries@c-a-b.org.uk Web: www.c-a-b.org.uk Page 3 of 12
2 Review Annex ZA Annex ZA forms part of each harmonised standard (hen) and this provides the checklist for CE marking that you must review. Annex ZA normally sets out: which product performance characteristics need to be determined and declared by you who is responsible for the tasks that lead to the Declaration of Performance, i.e. which are your responsibility and which are the responsibility of an independent third party (a Notified Body 2 3 the information that needs to accompany the CE marking symbol. In particular, Annex ZA of BS EN 16034 sets out: the performance characteristics that are relevant to fire resisting and / or smoke control doorsets and / or openable windows used for fire and / or smoke compartmentation and / or escape routes (Table ZA.1) see section 3 below the Assessment and Verification of Constancy of Performance or AVCP which defines the degree of involvement of independent third parties in testing the product and in the initial inspection and continuous surveillance of the Factory Production Control (FPC) in accordance with the relevant clauses within the standard and its intended use (Table ZA.2) see section 4 below how the testing and control tasks for the manufacturer and for the Notified Product Certification Body are assigned within AVCP system 1 across the essential characteristics and the FPC (Tables ZA.3) see sections 4, 5 and 6 below the contents of the Declaration of Performance (ZA.2.2) see section 7 below the requirements for CE Marking and labelling (ZA.3) see section 8 below. 3 Check required performance characteristics Table ZA.1 in BS EN 16034 identifies the relevant essential characteristics you will need to declare for your products. The essential characteristics are those which relate to the basic requirements for construction works set out in the CPR (Construction Products Regulation). All of the essential characteristics must be considered but you can only provide performance evidence for those characteristics that are applicable to your product(s). 2 The Nando (New Approach Notified and Designated Organisations) Information System is used to list all Notified Bodies http://ec.europa.eu/enterprise/newapproach/nando/index.cfm. This can be searched by country and legislation. For CE marking to EN 16034, the Notified Body must be notified for EN 16034. 3 With respect to the functions of Notified Bodies, there is a distinction between: a product certification body (a body notified to carry out constancy of performance certification AVCP 1/1+), a factory production control certification body (a body notified to carry out factory production control certification AVCP 2+) and a testing laboratory (a body notified to measure, examine, test, calculate or otherwise assess the performance of products AVCP 3). Tel: 01453 828851 Fax: 01453 828861 Email: enquiries@c-a-b.org.uk Web: www.c-a-b.org.uk Page 4 of 12
The rule is that you must determine the performance of any characteristic in the product standard that: has an identified threshold value is a requirement under UK building regulations. Hence based on these criteria, for fire resisting and / or smoke control doorsets and / or openable windows there are six high-level essential characteristics that must be determined depending on the intended use, in addition to those required by the relevant product standard listed in the Introduction: Resistance to fire (for fire compartmentation uses) Smoke control (only for applications where limitation of smoke spread is required) Ability to release (only for hold open doors) 4 Self-closing (only for self-closing fire resistant and / or smoke control doorsets and / or openable windows) Durability of ability to release Durability of self-closing (only for self-closing fire resistant and / or smoke control doorsets and / or openable windows): o Against degradation (cycle testing) o Against ageing (corrosion). Note: Empty declarations are not permitted; when an essential characteristic has not been determined, the option no performance determined (NPD) can be used in the Declaration of Performance (DoP) and accompanying information. If you have declared NPD against an essential characteristic, you cannot then claim a performance value for this product against this characteristic in any sales literature or on your website, for example. 4 Determine the compliance system & responsibilities You now need to refer to the system of Assessment and Verification of Constancy of Performance (AVCP), which sets out the tasks required and who is responsible for each task, as summarised in the table below. For doorsets and windows in the scope of BS EN 16034, there is only one AVCP system level that applies: AVCP 1. 4 There are potentially two essential characteristics referred to as Ability to release that can be applied to doorsets. In EN 14351-1, reference is made to the ability to release (to open), meaning the ability for doors on escape routes to be opened safely in the direction of escape without the need for keys. In EN 16034, reference is made to the ability to release (to close), meaning the ability for doors used for fire and smoke compartmentation to be released from a fixed open position and to close safely. Tel: 01453 828851 Fax: 01453 828861 Email: enquiries@c-a-b.org.uk Web: www.c-a-b.org.uk Page 5 of 12
Task System 4 System 3 System 2+ System 1 System 1+ Factory Production Control (FPC) Factory sample tests Initial Type Tests (ITT) FPC & plant inspection FPC certification Audit testing Manufacturer Manufacturer Manufacturer Manufacturer Manufacturer Manufacturer Manufacturer Manufacturer Manufacturer Notified Body Manufacturer Notified Body Notified Body Notified Body Notified Body Notified Body Notified Body Notified Body Notified Body Notified Body Under AVCP 1, the Notified Product Certification Body decides on issuing (or otherwise) the certificate of constancy of performance for the product, based on its assessment of the ITT results, the initial FPC and manufacturing plant inspection and continuous surveillance, assessment and evaluation (i.e. certification) of the FPC. Please note that the implementation and maintenance of a Factory Production Control (FPC) is always to be undertaken by the manufacturer (see section 7 below). 5 Carry out product testing In BS EN 16034 the relevant test standards are listed in Section 5 of the standard. If you manufacture your products in strict compliance with your system supplier s instructions and use their specified components and system design, the system company may provide the required Notified Body ITT reports, subject to a signed, written agreement between you and the system company in a process known as cascading. Note that the responsibility for the Declaration of Performance and CE marking remains with the manufacturer. As long as the product and the manufacturing process do not change, the Initial Type Tests only need to be performed once. Testing is required for the six essential characteristics referred to in section 3 above. Under AVCP system 1 the manufacturer must also carry out factory sample testing; this will be to a schedule agreed with the Notified Product Certification Body. 6 Set up Factory Production Control (FPC) It is the manufacturer s responsibility to establish, document and maintain an FPC system to ensure that the products placed on the market conform to the stated performance characteristics. Where a manufacturer is cascading their system supplier s Notified Body ITT results under AVCP system 1, the FPC needs to provide evidence that you are manufacturing to the exact same standard as the products originally tested by your supplier. Tel: 01453 828851 Fax: 01453 828861 Email: enquiries@c-a-b.org.uk Web: www.c-a-b.org.uk Page 6 of 12
The manufacturer s FPC system needs to consist of documented procedures, regular inspections and tests which set out how you control incoming materials or components, equipment, the production process and the product. You should also keep a record of complaints, any non-conforming products and product recalls, and what you did to prevent the problems happening again. Accreditation to ISO 9001 is deemed to comply with FPC requirements. The Notified Body is responsible for FPC inspection and certification 7 Produce a Declaration of Performance After successful testing and assessment of the product and the initial inspection of the manufacturing plant and the FPC of the manufacturer, the Notified Product Certification Body may issue the certificate of constancy of performance of the construction product; this forms the basis of the manufacturer s Declaration of Performance (DoP). The manufacturer must keep the supporting paperwork in a technical file. Under AVCP system 1, this technical file should include at least: test reports verifying the declared performance levels, sample test results, authorisation to use your supplier s test reports (cascading), FPC records and FPC certificates and inspection reports. By drawing up a DoP, the manufacturer assumes the legal responsibility for the conformity of their product with the declared performance. The DoP is to be signed by the manufacturer s designated representative. An example of a DoP is given below. This is for an external doorset with intended use fire / smoke compartmentation and on escape routes. The example DoP sets out the fourteen essential characteristics that you are required to include in the declaration for this product from the two relevant standards (EN16034 and EN 14351-1). As noted above, for the UK market you must declare against six characteristics from EN 16034: (resistance to fire, smoke control, ability to release, selfclosing, durability of ability to release, durability of self-closing), and against three characteristics from EN 14351-1 (dangerous substances, load bearing capacity of safety devices (if fitted) and thermal transmittance). The remaining characteristics may be declared as NPD but you will not be able to claim a performance value against these characteristics elsewhere (e.g. within sales literature and on the company website). You will need to make all relevant information and documents available to enforcement authorities and cooperate with them in any necessary action to eliminate risks posed by your products. You need to keep the DoP and technical files for 10 years after the final product in the range has sold. You also need to demonstrate that each product continues to confirm with the DoP; your FPC should describe how you take corrective action if any non-conformity is discovered. Products of the same batch which are supplied to a single user can be accompanied by a single DoP copy. Manufacturers can supply the customer with their copy of the DoP either in paper form or by electronic means (eg on a website). You should supply a paper copy when requested by your customer. The DoP must be supplied in the language of the country where the product is sold. Tel: 01453 828851 Fax: 01453 828861 Email: enquiries@c-a-b.org.uk Web: www.c-a-b.org.uk Page 7 of 12
Example Declaration of Performance Declaration of Performance Your DoP ref 1 2 3 4 5 6 Unique product identification code: Type, batch or serial number: Intended use: Manufacturer: Authorised representative: System or systems of assessment and verification of constancy of performance: Essential characteristics Performance Resistance to fire (for fire compartmentation uses): E: 90 EI 1 : 60 EI 2 : 90 EW: 60 Smoke control (only for applications where limitation of smoke spread is required): S 200 Ability to Self-closing (only for self-closing fire resistant and/or smoke control doorsets and/or openable windows Durability of ability to release Durability of self-closing (only for self-closing fire resistant and/or smoke control doorsets and/or openable windows) Released C Release maintained against degradation (cycle testing) 2 against ageing (corrosion) Achieved Watertightness Class 2A Dangerous substances None Resistance to wind load Class 3A Load bearing capacity of safety devices 350 N Acoustic performance NPD Thermal transmittance 1.6 W/m 2 K Radiation properties Solar gain NPD Light transmittance NPD Air permeability Class 3 9 The performance of the product identified in points 1 and 2 is in conformity with the declared performance in point 8. Name & position: Place of issue: Date of issue: Signature: Ian Somebody, Managing Director Glazeborough 01-Sep-16 Ian Somebody Harmonized technical specification EN 16034:2014 EN 14351-1:2006 +A1:2010 This declaration of prformance is issued under the sole responsibility of the manufacturer identified in point 4. Signed for and on behalf of the manufacturer by: No. 26773-2015 FD External hinged fire doorset 1234567 F XYZ 123 abc F Fire and/or smoke compartmentation A N Other Windows and Doors Ltd 23 Frame Street Glazeborough Shinyshire AB1 2CD Not applicable System 1 for EN 16034:2014 System 3 for EN 14351-1:2006 + A1:2010 7 Notified product certification body No. XXXX performed the determination of the product type on the basis of type testing (including sampling), initial inspection of the manufacturing plant and of the FPC and continuous surveillance, assessment and evaluation of the FPCand issue the certificate of constancy of performance of the product 8 Declared performance: Your product type Your product batch ref Refers to Annex ZA, Table ZA.2 (intended use) Entity legally responsible for the DoP Refers to Annex ZA, Table ZA.2 (AVCP System) EN 16034: Legally required to declare performance of these six characteristics in the UK EN 14351-1: Legally required to declare performance of these three characteristics in the UK NPD on DoP, so cannot make claims for this performance elsewhere Tel: 01453 828851 Fax: 01453 828861 Email: enquiries@c-a-b.org.uk Web: www.c-a-b.org.uk Page 8 of 12
8 Apply CE marking Once the above steps are completed, the manufacturer can CE mark their product. The CE mark is the primary means of notification that the manufacturer takes responsibility for the product s conformity with the DoP, as well as with all the applicable requirements defined in the CPR and all other additional related regulations. No DoP = no CE mark. The CE mark must be affixed before the product is placed on the market and must be the only marking which demonstrates the conformity of the product with the declared performance against the essential characteristics (refer to Article 9 of the CPR). The CE marking must be affixed visibly, legibly and indelibly in one or more of the following ways: on the product on an attached label. Where these options are not practical on account of the nature of the product (which will be unlikely for most doorsets (and windows), then alternatively it may be affixed to: the packaging accompanying documentation (e.g. delivery note). An example of a CE mark (based on the earlier DoP example) is shown below. Tel: 01453 828851 Fax: 01453 828861 Email: enquiries@c-a-b.org.uk Web: www.c-a-b.org.uk Page 9 of 12
Example of CE marking Last two digits of the year in which the marking was first affixed 16 A N Other Windows Ltd, 23 Frame Street, Glazeborough, Shinyshire AB1 2CD No 001 ABCD 07-2013 ANOW 012-11-001 Fire and/or smoke compartmentation and/or escape routes EN 16034:2014 12345 Resistance to fire (for fire compartmentation uses) E: 90 El 1 : 60 El 2 : 90 EW: 60 Smoke control (only for applications where limitation of smoke spread is required): S200 Name and address of manufacturer, legally responsible for CE marking Reference number of the DoP Unique identification code of the product code, given by the manufacturer Intended use of the product as laid down in the European standard No. of European Standard with year of publication Identification number of the product certification body Ability to release: Self closing (only for self-closing fire resistant and/or smoke control doorsets and/or openable windows): Durability of ability to release: Released C Release maintained Essential characteristics Level or class of the performance declared Durability of self closing (only for selfclosing fire resistant and/or smoke control doorsets and/or openable windows): against degradation (cycling testing): 2 against ageing (corrosion): EN 14351-1:2006 +A1:2010 achieved Identification number of the product certification body Watertightness 23456 Class 5A Identification number of the product certification body Dangerous substances None Resistance to wind load Test pressure Class 2 Frame deflection Class A Essential characteristics Level or class of the performance declared Load bearing capacity of safety devices Thermal transmittance 350 N 1.7 W/m 2 K Air permeability Class 3 Tel: 01453 828851 Fax: 01453 828861 Email: enquiries@c-a-b.org.uk Web: www.c-a-b.org.uk Page 10 of 12
The CE mark comprises: CE mark/logo last two digits of the year in which it was first affixed name and registered address of the manufacturer (or the identifying mark allowing identification of the name and address of the manufacturer easily and without ambiguity) unique identification code of the product type reference number of the DoP level or class of performance declared 5 reference to the harmonised technical specification/s applied identification number of the Notified Body/s (if applicable) intended use, as set out in the harmonised technical specification applied. The European Commission is considering allowing a condensed version of the CE mark to be used, which provides only some of the information listed above along with a reference to the DoP and the web address where it can be downloaded. We will update this guidance when this option is confirmed. For further information on how to reproduce the CE logo and to obtain logos to download go to: http://ec.europa.eu/enterprise/faq/ce-mark.htm Some additional elements of the CPR Manufacturers must ensure that their product is accompanied by operating instructions and safety information in the language of the country where the product is sold. Operating instructions should include all necessary information regarding routine care and maintenance, cleaning, suitable cleaning products, lubricants, the settings for moving parts and all procedures for replacing parts or coatings that are damaged or worn. The manufacturer is also required to be able to provide a list with details of the economic operators they have supplied product to or been supplied product by, should a Market Surveillance inspection be carried out (e.g. by Trading Standards). 5 Note: in the example provided, we have listed the performance against all of the essential characteristics as listed on the DoP, apart from those declared as NPD. Tel: 01453 828851 Fax: 01453 828861 Email: enquiries@c-a-b.org.uk Web: www.c-a-b.org.uk Page 11 of 12
Summary Characteristics that must be declared from EN 16034: o Resistance to fire (for fire compartmentation uses) o Smoke control (only for applications where limitation of smoke spread is required) o Ability to release (to close only for hold open doors) o Self-closing o Durability of ability to release o Durability of self-closing Against degradation (cycle testing) Against ageing (corrosion) Additional characteristics must also be declared according to the relevant product standard eg for EN 14351-1: o Dangerous substances o Load bearing capacity of safety devices (if fitted) o Thermal transmittance o Ability to release (to open for doors on escape routes) For AVCP system 1: o Notified Body to conduct Initial Type Tests o Notified Body to inspect and certificate FPC o Notified Product Certification Body to issue certificate of constancy of performance for the product o Manufacturer to implement and maintain Factory Production Control system o Manufacturer to make Declaration of Performance and CE mark product. Issue 2 November 2016 The Council for Aluminium in Building is committed to providing authoritative, impartial advice on the use of aluminium throughout the construction industry. CAB makes every effort to ensure the technical accuracy, correctness, appropriateness and completeness of its guidance publications and other information. However CAB, its members and its employees, can take no responsibility for any subsequent use of information nor for any errors or omissions in the information supplied. Tel: 01453 828851 Fax: 01453 828861 Email: enquiries@c-a-b.org.uk Web: www.c-a-b.org.uk Page 12 of 12