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CE Marking - Trying to CE the wood through the trees

 

 

Please click here to access our CE Marking Declaration of Performance Statements

As you will be aware, CE marking must be applied to all construction products that are covered by a Harmonised Standard (hEN) by July 2013. Neither spacer support systems or roofing and cladding fasteners have a harmonised standard (hEN), instead a CE mark can be obtained through a common understanding of assessment procedure (CUAP) and then European Technical Assessment (ETA), although this process exists it is actually voluntary.

Even with this process being voluntary Ash & Lacy believe that to elevate our products it is necessary to obtain the relevant CE marking for both. AshGrid™ spacer support system is already in the final stages of obtaining it’s CE mark. For roofing and cladding fasteners the correct CUAP’s have been identified and the relevant testing and protocol are being compiled. We will keep you informed of further progress as these processes continue.

At Ash & Lacy we very much welcome CE Marking, as it is aimed at eliminating products that are not fit for purpose, at a stroke reducing the risk of making a poor specification decision.

We do, however, believe that there are some significant problems with the way that the new rules will be implemented.

Firstly, defining what is to be CE marked can be confusing.  The Construction Products Directive 2011 (CPD), makes it mandatory for manufacturers to draw up a Declaration of Performance (DoP) and apply CE marking to any construction product which is covered by a Harmonised European Standard (hEN), or conforms to a European Technical Assessment (ETA) that has been issued for it. 

A construction product is defined as any product, or system, which is produced and placed on the market for incorporation in a permanent manner, in construction works (or part thereof), and the performance of such product has an effect on the performance of the construction works as a whole.  In other words, it performs a primary function within the construction works.

CE marking has been around for some time and, for construction products, displaying a CE mark has been voluntary in the UK.  However, from 1st July, that changes and manufacturers need to be aware of the implications of not complying with this legislation.

The route to obtaining a CE mark is not as simple as declaring that a product is ‘fit for purpose’.  There are five levels of assessment relating to CE marks, depending on the function of the product being considered.  These range from allowing the manufacturer to confirm that the product meets the required levels of performance and production control, to full assessment of the performance data and manufacturing processes, by an independent third party (Notified Body).

The Construction Products Directive gives guidance on the levels required for various products, but it is not until an ETA has been developed and assessed, that the correct level of assessment can be determined.

Problems arise in determining what is to be CE marked!  Only where a Harmonised European Standard exists, does a product have to be CE marked.  However, construction methods in Europe vary from those used in the UK, so there are gaps.

Where a Harmonised European Standard does not exist for a product and there is no ETA for that product, CE marking is not mandatory!  This leaves a gap for some products being used in construction, which do affect the performance of the works as a whole.  For these products a CUAP (Common Understanding of Assessment Procedure) is developed. This forms the basis for the ETA to be issued.  There will no doubt be a period of confusion over what relates to Harmonised Standards, and whether an ETA exists for certain products.

The next issue is who polices this piece of legislation? 

Responsible manufacturers have already prepared for the changes and have many products already CE marked, or in the process of achievement by 1st July.  The costs associated with this can be considerable, especially for products which fall into the highest level of assessment (1+).  This level requires that products are independently tested to confirm that manufacturer data (e.g. load/span tables) is correct. Production processes have to be inspected and assessed by an independent notified body and annual surveillance visits are required by the same notified body.  Not all manufacturers will comply; some because they do not have any knowledge of the legislation, some because they cannot afford to go through the process and some because they simply disregard it!

Policing, we are told, will be done by Trading Standards!  There will consequently be no regular checking of products used on construction sites. The only method by which they will be able to enforce this legislation is by reacting to whistle-blower reports of non-CE marked products being used.

It would seem sensible, at the very least, that Building Control should be involved in the checking process, so that any application for Building Regulation Approval can request that all products being used are correctly CE marked.  Government works will insist that products being used are CE marked but, again, who is going to check?

Manufacturers who have responsibly spent the requisite amount to CE mark their products will have to include that cost when determining their selling price.  That could put them at a commercial disadvantage against those manufacturers who have not bothered!  Furthermore, main contractors will continue to seek the cheapest option. One has to question whether they will be concerned about the use of CE marked products, when a manufacturer offers an ‘equal performance product’ that is not CE marked, at a considerably lower price.

So where does the responsibility lie?  Essentially, the manufacturer is responsible for supplying a product which is correctly CE marked, but that does not relieve a buyer of that product from any liability!  Main contractors, specifiers, etc. need to be aware of the Construction Products Directive and its implications.  If a product is not CE marked and has been used and subsequently discovered, in a construction project, serious implications will arise.  We could see roofs being stripped off, or whole areas of building being replaced.  Then lawyers will get involved (and get rich on the proceeds) in the fight to determine who was at fault.

The Metal Cladding & Roofing Manufacturers Association (MCRMA) are insisting that their members supply only CE marked products, where applicable.  For more information, the MCRMA have placed a statement on their web site (www.mcrma.co.uk) in relation to this.  Furthermore, the National Federation of Roofing Contractors (NFRC) are asking all associate members to confirm their compliance with the Construction Products Directive 2011.

In summary, the Construction Products Directive 2011 is a great piece of legislation, aimed at ensuring that only ‘fit for purpose’ products that have been properly tested and audited are used in construction.

However, very little thought appears to have been given to how the Directive is to be enforced.  In the short term, less scrupulous manufacturers will carry on supplying products and the more responsible ones will be at an even greater commercial disadvantage.

Whilst CE marking will increase the cost of manufacture, it will not necessarily increase the overall cost of a project.  Responsible ‘value engineering’ can have massive benefits, and will far outweigh the costs associated with CE marking.  The key is to involve responsible manufacturers early in a project, so that interfaces can be properly and sensibly considered and designed, making the construction process simpler, and in many cases, saving materials, wastage and time.

Ray Harriman

March 2013