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CE Marking

Below is an introduction to the topic of CE Marking. You can also search for your specific topic using the Search box at the top of the page or click on any of the following keywords and phrases: .CE Marking; CPD; CPR; Harmonised standards; BS EN 1090-1

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Background

CE Marking of construction products was introduced in the Construction Products Directive (CPD) in 1988. The CPD is a European Directive that seeks to remove barriers to trade and applies to all construction products permanently incorporated in to ‘construction works’. This includes steel products such as steel sections, structural bolts, welding consumables and fabricated steel components that are used in buildings, bridges, highways and other civil engineering structures.

In the UK the CPD was enforced by  the Construction Products Regulations 1991 (CPR 1991) which described two ways of complying with the CPD. The first was by CE Marking and the second was by supplying, when asked, Trading Standards Officers in England, Wales and Scotland and Environmental Officers in Northern Ireland, all the information on the product to enable the authorities to satisfy themselves that the product complies with the regulations and the requirements of the CPD. Therefore the CPD was never seen as mandatory in the UK.

All this has now changed and on 1st July 2013 the Construction Products Directive (CPD) was replaced by another piece of EU legislation called the Construction Products Regulation (CPR). The main change is that unlike a European directive a European regulation is mandatory in all member states.

The Construction Products Regulation (CPR)

From 1st July 2013 the CPR makes CE Marking mandatory in all member states, including the UK and Republic of Ireland, for all construction products that are permanently incorporated in to building or civil engineering works and are covered by either a harmonised standard or a European Technical Assessment that is in force. The CPR also makes it clear that CE Marking has implications for the supply chain and places legal obligations on the construction supply chain including ‘manufacturers’, ‘importers’ and ‘distributors’ of construction products.

The Construction Products Regulations 2013 (CPR 2013)

The enforcing authorities and the penalties imposed for not complying with the Construction Products Regulation is a member state responsibility. On 1st July 2013 the Construction Products Regulations 1991 (CPR 1991) was repealed and replaced by the new Construction Products Regulations 2013 (CPR 2013).  Under these new regulations the enforcement authority is:

· in England Wales and Scotland is the Secretary of State or any local weights and measures authority and

· in Northern Ireland, any district council

The offences reflect the legal obligations placed on ‘manufacturers’, ‘Importers’ and ‘distributors’ of construction products described in the CPR while the penalties remain largely unchanged and include:

· Prohibition notices and notices to warn

· Suspension notices

· Fines, and

· Imprisonment

The Supply Chain

The CPR makes it clear that CE Marking applies throughout the supply chain and imposes certain legal requirements on the manufacture, the importer and the distributor. It is extremely important that companies are able to identify which part/s of the supply chain describes their activity and the legal obligations place their them – as failure to comply is a criminal act and subject to penalties including restrictions on the company’s ability to continue trading.  Companies should also be aware that their activities may fall in to one or more parts of the supply chain – e.g. a steelwork contractor who imports steel products is both a manufacturer and an importer and a bolt supplier who imports bolts is an importer and a distributor.

The definitions given in the CPR for manufacturer, importer and distributor are given below together with a brief explanation of the legal obligations imposed on each.

Manufacturer

'Means any natural or legal person who manufacturers a construction product or who has such a product designed or manufactured and markets that product under his name or trademark'

This definition applies to steelwork contractors who either fabricate or design and fabricate constructional steelwork and sell the product under their own name/trademark to their clients (usually a main contractor). It also applies to those companies that manufacture proprietary products such as purlins, decking, cellular beams, structural bolts etc and place those products on the market under their own name/trademark.

The requirements placed on the manufacturer include:

 

Manufacturer’s requirements

No.

Requirement

1.

Draw up a Declaration of Performance (DoP)

2.

Affix the CE Marking (in one of four ways: to the construction product, a label attached to it, the packaging or the accompanying documentation)

3.

Draw up technical documentation describing all relevant elements related to the required system of assessment and verification of constancy of performance

4.

Keep technical documentation and the DoP for 10 years

5.

Put in place and maintain a certified Factory Production Control system

6.

All products must bear a type, batch or serial number. This can be on the product, the packaging or the accompanying documentation

7.

All products must bear the name and address or trademark of the manufacturer. This can be on the product, the packaging or the accompanying documentation

8.

All products must to accompanied by safety instructions. These must be in the appropriate language

9.

Identify nonconforming products and either put them right or withdraw them from the market

10.

Upon a 'reasoned' request provide national authorities with all information necessary to demonstrate conformity with the DoP

 

 

The majority of the obligations placed on the manufacturer are described in the appropriate harmonised standard or ETA.

Distributor

'Means any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a construction product available on the market'

This will apply to bolt suppliers, steel stockholder and those companies that buy and put on the market construction products. The distributor must ensure.

 

Distributor’s requirements

No.

Requirement

1.

Act with due care in relation to the requirements of the CPR

2.

The products distributed bear the CE Marking, as relevant

3.

The product is accompanied by the appropriate documentation

4.

The product has the safety instructions in the appropriate language

5.

The manufacturer and importer have complied with their requirements

6.

They do not put products on the market that do not conform to the requirements

7.

Where the construction product presents a risk the distributor shall inform the manufacturer or the importer and the market surveillance authorities

8.

That storage and transportation of the product do not jeopardise the performance of the product

9.

Take corrective action and/or withdraw nonconforming products

10.

Upon a 'reasoned' request provide national authorities with all information necessary to demonstrate conformity with the DoP

 

 

A distributor may re-package certain products and/or break large batches of products into smaller batches provided that traceability to the appropriate paperwork is maintained.

Distributors must put in place a system that complies with the above requirements for construction products covered by a harmonised standard or an ETA. Note this system does not need to be certified.

Importer

'Means any natural or legal person established within the Union, who places a construction product from a third country on the Union market'

This applies to those companies that import construction products such as steel sections or structural bolts from manufacturers outside the European Union.  From 1st July 2014 it will also apply to companies that import fabricated steel complying with BS EN 1090-1.

Importer shall:

 

Importer’s requirements

No.

Requirement

1.

Only place construction products on the market that comply with the CPR

2.

Assessment and the verification of constancy of performance shall have been carried out by the manufacturer

3.

The manufacturer has drawn up the technical documentation

4.

The manufacturer has drawn up the DoP

5.

The product bears the CE Marking

6.

The product is accompanied by the required documentation in the appropriate language

7.

Not place on the market construction products that do not conform with the regulations

8.

Place the importer’s name and address on the product, the packaging or the accompanying documentation

9.

The product is accompanied by the safety instructions

10.

Storage and transportation do not jeopardise the performance of the product

11.

Take corrective action and/or withdraw non-conforming products

12.

Retain records for 10 years

13.

Upon a ‘reasoned’ request provide national authorities with all information necessary to demonstrate conformity with the DoP

 

 

Article 13.6 states that

Importers shall, when deemed appropriate with regard to ensuring the accuracy, reliability and stability of the declared performance of a construction product, carry out sample testing of construction products placed or made available on the market, investigate, and if necessary, keep a register of complaints, of non-conforming products and of product recall, and shall keep distributors informed of any such monitoring.

This requirement will apply to all those companies importing construction products from outside the European Union. The interpretation of this requirement is unclear but the intention is clear - to reduce the likelihood of non-conforming products entering the market. One view is that sample testing is only needed when non-conforming products are found. Another view is that importers must carry out sample testing on a regular basis to ensure the accuracy and reliability of the performance characteristics of the products they are putting on the market.

Importers must put in place a system that complies with the above requirements for construction products covered by a harmonised standard or an ETA.

Harmonised Standards

CE Marking is a declaration by the manufacturer that the construction product has been made correctly and meets certain public safety requirements. The factory production control system and the essential characteristics for each product are described in a set of European standards called ‘harmonised’ standards.

The main harmonised standards for constructional steelwork together with the date when CE marking is mandatory are given in the table below.

 

Standard

Title

Date in force

BS EN 1090-1

Execution of steel structures and aluminium structures – Part 1: Requirements for conformity assessment of structural components

1st July 2014

BS EN 10025-1

Hot rolled products of structural steels – Part 1: General technical delivery conditions

1st Sep 2006

BS EN 10088-4

Stainless steels – Part 4: Technical delivery conditions for sheet/plate and strip of corrosion resisting steels for construction purposes

1st Feb 2011

BS EN 10088-5

Stainless steels – Part 5: Technical delivery conditions for bars, rods, wire, sections and bright products of corrosion resisting steels for construction purposes

1st Jan 2011

BS EN 10210-1

Hot finished structural hollow sections of non-alloy and fine grain steels – Part 1: Technical delivery conditions

1st Feb 2008

BS EN 10219-1

Cold formed welded structural hollow sections of non-alloy and fine grain steels – Part 1: Technical delivery conditions

1st Feb 2008

BS EN 10340

Steel castings for structural ties

1st Jan 2011

BS EN 10343

Steels for quenching and tempering for construction purposes – technical delivery conditions

1st Jan 2011

BS EN 13479

Welding consumables – General product standard for filer metals and fluxes for fusion welding of metallic materials

1st Oct 2006

BS EN 14399-1

High-strength structural bolting assemblies for preloading – Part 1: General requirements

1st Oct 2007

BS EN 15048-1

Non-preloaded structural bolting assemblies – Part 1: General requirements

1st Oct 2009

 

 

A complete list of harmonised standards is given on the NANDO web site (http://ec.europa.eu/enterprise/newapproach/nando/index.cfm?fuseaction=cpd.hs)

 

CE marking of some of the products listed in the table becomes mandatory on 1st July 2013 while for the fabricated steelwork covered by; EN 1090-1 CE marking doesn't become mandatory until 1st July 2014.

 

European Technical Assessments

Not all construction products are covered by harmonised standards. For example construction products which are new or innovative may not be covered by a European harmonised standard. However, CE Marking can still be obtained for these products on a voluntary basis by developing a European Technical Assessment (ETA). An ETA may be developed when any of the following conditions apply:

· No relevant harmonised standards for the product exist

· No mandate for such a Standard has been given by the European Commission

· The European Commission considers that a Standard cannot be developed

· A product deviates significantly from the relevant Harmonised Standards

ETAs are voluntary and are normally applicable to the products produced by an individual manufacturer. Once the ETA is obtained the manufacturer is legally obliged to comply with it and CE Mark its products.

A complete list of ETAs is given on the EOTA web site http://www.eota.be/pages/valideta/. For some of the products listed on the EOTA web site CE Marking becomes mandatory on 1st July 2013.

To identify if a construction products is covered by an ETA search the EOTA web site. The simplest way is to search for the either the manufacturer or the product on the EOTA web site (http://www.eota.be/pages/valideta/).

Alternatively contact the product supplier who may be able to help identify which products are covered by an ETA. A list of BCSA Associate Members covering the following range of products can be found at http://www.steelconstruction.org/directories/products-and-services.html :

· Structural Components

· Steel Producers

· Protective Systems

· Steel Stockholders

· Structural Fasteners

CE Marking of Structural Steelwork

The standard for fabricated structural steelwork is ‘BS EN 1090: Execution of steel structures and aluminium structures’. BS EN 1090-1 is the CE Marking standard which comes in to force on 1st July 2014.

BS EN 1090-1

The scope of this standard is very wide ranging and covers structural steel and aluminium components and steel components for use in composite steel and concrete structures. These components can be made from hot-rolled or cold-formed constituent products or constituent products produced with other technologies. The constituent products may be sections/profiles with various shapes, flat products (plates, sheet, strip), bars, castings, forgings made of steel and aluminium materials, unprotected or protected against corrosion by coating or other surface treatment. The standard also applies to structural cold-formed members and sheeting. The standard does not cover:

· Suspended ceilings

· Rails or sleepers for use in railway systems

This harmonised standard lists the performance characteristics  (the structural characteristics  which make fabricated steel fit for its intended use), describes how steelwork contractors can demonstrate that the fabricated components they make meet the declared performance characteristics and gives the degree of their party intervention required. All fabricated steel is seen as safety critical and BS EN 1090-1 requires the steelwork contractor’s factory production control system to be assessed by a Notified Body.

BS EN 1090-2

BS EN 1090-2 is the technical requirements for steel structures and specifies the requirements for the execution (cutting, drilling, welding etc) of steel structures to ensure adequate levels of mechanical resistance and stability, serviceability and durability.

Execution Class

Informative Annex B of BS EN 1090-2 provides guidance for the determination of Execution Classes (EXC) based on reference to Consequences Classes (CC) defined in BS EN 1990, Service Categories (SC) and Production Categories (PC) defined in BS EN 1090-2.

SC relates principally to whether a component is designed for fatigue or for quasi-static actions only. BS EN 1090-2 recommends PC1 is limited to non-welded components and welded components manufactured from steel grades below S355. In practice the distinction between PC1 and PC2 makes no practical difference to most structural steelwork.

BS EN 1090-2 defines EXC as a classified set of requirements specified for the execution of the works as a whole, of an individual component or of a detail of a component. In practical terms it is expected that all the components and details in the works as a whole would generally be classified with the same EXC. Hence the National Structural Steelwork Specification (NSSS) ignores the possibility that some component r details could be EXC1 as BCSA believes that EXC2 is the best basis for ensuring consistent quality of steelwork appropriate for building construction.

In terms of wider application, the following provides a basis for determining EXC:

· EXC1 – Farm buildings

· EXC2 – Building (similar to the scope of the NSSS)

· EXC3 – Bridges

· EXC4 – Special structures (long-span bridges etc)

 

Further information on Execution Class can be found at http://www.steelconstruction.info/CE_marking#Engineer.E2.80.99s_responsibility

Certification

For a steelwork contractor to demonstrate its CE Marking capability, the CPR requires the following three documents:

· Factory Production Control Certificate – issued by a Notified Body

· Welding Certificate – issued by a Notified Body

· Declaration of Performance – issued by the Steelwork Contractor

Examples of each of these certificates can be found at http://www.steelconstruction.info/CE_marking#How_to_check_compliance_with_the_CPR_and_CE_Marking .

 

Further information

CE Marking Seminars - Implications for Engineers
CE Marking Seminars - Implications for Main Contractors
CE Marking Seminars - Legal Position
BCSA Leaflet 'Routes to CE Marking Certification for Steelwork Contractors' 
Guide to the CE Marking of Structural Steelwork, BCSA Publication No. 46/08
National Structural Steelwork Specification for Building Construction, 5th Edition (CE Marking version), BCSA Publication No. 52/10
CE Marking - Frequently Asked Questions
Steel Construction - CE Marking Supplement
www.steelconstruction.info