With many companies unsure of their duties under the incoming Construction Products Regulation Giles Willson has some timely advice.
I hope when you read this you are thinking – what more on CE marking?
The GGF is keen that our members and the wider industry are fully aware of their responsibilities which will be mandatory from July 1. The Construction Products Regulation (CPR) replaces the Construction Products Directive (CPD) and if a product has a harmonised European Standard (a hEN) with an Annex ZA you will need to make a declaration of performance and CE mark your product.
This is to enable the European Economic Area (EEA) to operate as a single market and to allow free trade between member states. Failure to comply with the CPR if within scope from July 1 could lead to a prosecution resulting in a fine and possibly even a custodial sentence.
In 2001, the GGF ran a series of road shows across the UK to explain the requirements of the Construction Products Directive and the then-new EN 1279 for Insulating Glass Units. These events went into the background and detailed requirements for showing compliance with the standard. The speakers included members of the GGF who had been working for the previous 10 years (1991-2001) on the development of the actual standards.
In 2003, the GGF held a two-day technical seminar covering EN 14351-1 Windows and external pedestrian doorsets without resistance to fire and/or smoke leakage characteristics, when this was first published to explain how the standard works and the requirements.
In 2006, the GGF published a new leaflet, Marking of Safety Glass in time for the September 1 2006 and the commencement of CE marking for certain ‘safety glasses.
In 2010, when the Construction Products Directive was changing to the Construction Product Regulation, the GGF were actively involved in lobbying the European Commission and Parliament to ensure the changes were satisfactory for the industry. The one key success the Federation were part of was the inclusion of the use of web sites and electronic communication for providing the declaration of performance.
In 2012, to aid members, the federation launched a micro site called The Route to CE marking with exclusive flow charts mapping out the different routes to CE marking. This is fully accessible for GGF members on the GGF website www.ggf.org.uk/ce-marking but the landing page is open to all companies and has key information including frequently asked questions on CE marking, a list of harmonised European Standards and a full glossary of terms found within the CPR.
The GGF is currently preparing to run a series of seminars nationwide to fully explain the requirements. These events will continue for the rest of the year and will be available for all in the industry to attend. Details of venues and times will be publicised soon.
As you can see the GGF has been very busy on this huge issue and the Federation has now created the tools and measures to ensure GGF members and the wider industry (including every relevant small/medium sized business), are furnished with accurate and factual information.
From my experiences from meetings with many industry figures over the last year or so, there seems to be mixed feelings on CE marking; some companies are fully ready with all their evidence sorted, others appears completely unaware that they need to comply with the CPR and to CE mark their products.
I do not feel that on July 1 the world will dramatically change, but if you are not ready, what will you say if challenged by your customers, competitors or Trading Standards?
The key points
It should be noted that if a company buy in a product which is CE marked, they do not change it (including re-branding); they do not have to do anything else.
If a company buys a CE marked product in and changes it then they are responsible for the declaration of performance and CE marking.
If a company buys unglazed frames and sources the IGU separately then they are responsible for the CE marking for the window under EN 14351-1.
If a company fails to comply with the CPR they can be investigated by Trading Standards who can take the organisation to court. If found guilty there are fines (usually £5,000 per offence) and potential custodial sentences for the company directors.
Giles Willson is Deputy Chief Executive and Director of Technical Affairs at the Glass & Glazing Federation.