CE Marking for the CPD

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Introduction

Compliance to the CPD, which is shown by a product carrying a CE mark, indicates compliance with EU legal requirements, and allows a manufacturer to place his product on the market in any EU Member State. It is basically a device to promote free trade throughout the EU.

The products which are affected by the CPD are those products permanently incorporated into ‘the works’, whether building or civil engineering works, provided the works are subject to regulations (e.g. Building Regulations in the UK). At least one of the “essential requirements” below must apply to the product:

Essential requirements

  • mechanical resistance and stability
  • safety in case of fire
  • hygiene, health and the environment
  • safety in use
  • protection against noise
  • energy economy and heat retention

Exactly how the “essential requirement” will apply to the product will be defined in the “technical specification”, either a “harmonised” standard (hEN) (produced by the European Committee for Standardisation (CEN)) or a European Technical Approval (ETA) produced by an ETA Approval Body. The ETA can be issued with guidelines known as European Technical Approval Guidelines (ETAG’s) produced by the European Organisation for Technical Approvals (EOTA). The purpose of technical specifications is to cover all the performance characteristics required in any Member State.

Technical specifications are emerging and CE marking has arrived, but it will take several years for full coverage. CE marking will become the norm, whether the actual mark is mandatory or not and manufacturers will have to adopt it.

What does a manufacturer have to do?

Depending on the product, the technical specification will define what needs to be done in order for a product to carry the CE mark. It will also define who needs to do what, by specifying a level of “Attestation of Conformity”.

Attestation of Conformity (AoC) is basically the “who does what” to allow CE marking. Some tasks will be done by the manufacturer and some will be done by a Notified Body, e.g. test laboratory or certification body. There are basically four levels of AoC, ranging from Level 1 (most onerous) to Level 4 (least onerous), though there is also a Level 1+ and a Level 2+. As a general rule, the more safety critical products will be allocated an onerous AoC (e.g. 1 or 1+), whereas non-critical products will have a less onerous AoC (e.g. 3 or 4).

The table below summarises the requirements under each AoC Level.

1+ 1 2+ 2 3 4

Tasks for the Manufacturer

Factory production control ü ü ü ü ü ü
Further testing of samples taken at factory according to prescribed test plan ü ü ü
Initial type testing ü ü ü
Tasks for the Notified Body
Initial type testing ü ü ü
Certification of FPC ü ü ü ü
Surveillance of FPC ü ü ü
Audit testing of samples ü

Levels 1+ and 1 are essentially product certification (such as a BM TRADA Q-Mark scheme) and require considerable involvement from a “Notified Body”. On the other hand, Level 4 requires no involvement from a Notified Body. In all cases, the manufacturer is responsible for affixing the CE mark – it is not awarded by the Notified Body as a Q-Mark might be, for instance.

Route to CE Marking

Notified Bodies

BM TRADA is designated to provide Notified Body services for a very wide range of construction products as soon as the relevant technical specifications become available, and can offer its services to manufacturers both in the UK and elsewhere in the world. Companies already belonging to one of our Q-Mark product certification schemes, or holding ISO 9000 registration with us are well on their way to meeting the requirements for CE marking. And where testing is required, this can often be carried out by our sister organisations Chiltern International Fire and Chiltern Dynamics.

Contact Us

For further information please call our head office on 01494 569700 or email enquiries@bmtrada.com.