18.04.13
CE Marking Seminar
Below text is a personal view arising out of a recent Seminar attended at the premises of the SATRA Technology Centre in Kettering, on the upcoming change to CE Marking regulations on Building Products.
Opinions and observations expressed herein are personal and where names of corporations or other entities are given it is not intended to imply that any of these entities share the views below. The new regulations come in to force in July 2013, and the personal views expressed in this document can be considered to be out of date from that time. However the reference links at the base of this document will be updated periodically.
Summary:
From July 2013 it will become a criminal offence for Construction Products to be sold in any EU country without CE marking on the product itself or, if this is impractical, then its immediate packaging.
The seminar was attended bya variety of industrybody representatives i.e. Kingfisher, B&Q Group, St. Gobain, CTD, Armatile, the Tile Association, NorcrosPlc, Johnson Tiles and others.
Under the threat of criminal sanctions the concern in the industry centred along practical considerations such as who polices the new regulations, is there a cut-off point where old unmarked stock can continue to be sold, how do you CE mark products like aggregate and natural quarried stone.
The CE mark itself has to apply to all products sold within the EU (and Croatia is due to become its 28th member when it joins the EU in July this year), and have a declaration of Performance(DOP) which attests to the products properties, i.e. for floor coverings the properties of importance may be slip resistance, fire resistance, transmission of acoustics etc. The CE mark has to be applied to all products irrespective of their origin, so CE marks have to be applied to non EU originating countries as well as EU.
From this arose an interesting discussion, as in regards to Chinese sourced materials it transpires that manufacturers use a CE mark of their own which in terms of size and font is virtually identical to the EU CE Mark and only differs very slightly in the spacing between the letters C and E. Chinese CE stands for China Export. The discussion then turned to how the new regulations are to be policed. In many EU countries – where this policy has already been in place – authorities rely on their border inspections policed by their national Customs authorities. In the UK from July the policing of these regulations will be performed by local Trading Standards Officers.
Please don’t quote me on this but the feeling round the room was that it would take time for Trading Standards to ramp up their scrutiny of these new regulations and that stock that has previously been sold (if of the same provenance) could continue to be sold until that stock was replaced with new stock. From previous experience some felt that Trading Standards would initially take a moderate view of contraventions and only use the ‘big stick’ approach if their advice and warnings were deliberately flouted, and that this approach would allow a buffer period for traders to become accustomed to the new regs.
There are several routes for certification, but again here the reality for many producers is that the manufacturers may well be able to self-certify because it is only products that have the potential to cause great harm (for example a load bearing steel girder used in construction of a high rise block, or the presence of lead and Cadmium in food preparation table tops) that will require rigorous independent testing (by accredited testing houses – New Approach Notified and Designated Organisations – NANDO - EU). So in general CE certification should be sought from the Manufacturer or Notified Body. As an aside even at this late stage in the UK there are only a handful of testing houses that have this accreditation confirmed. Although in other countries of the EU (for example Germany) where this regulation has been in force for longer there are many more such authorised bodies.
The EU have now added an additional criterion of environmental impact in the life cycle of the product from manufacture to final disposal at the products end of life. In this criteria it is felt that this new provision is rather aspirational than practical at this time, as appraisal and testing methodologies to quantify the life time environmental effects of any product are in their infancy. However over time it is expected that these aspects will gradually become mainstream.
Below are links that our Clients may find useful. This will be added to and updated over time to ensure that as a resource our Clients will be able to reference information that may be relevant to them when placing orders for manufactured product overseas.
CE Marking Overview:
NANDO EU:
Construction Products Regulation. Are you ready for July 2013?:
The Construction Products Directive , (Council Directive 89/106/EEC):
Guidelines On The Designation Of Uk Notified Bodies Under The Construction Products Regulation (305/2011):
Department forCommunities andLocal Government: