Opening the door to CE marking
BM TRADA Senior Consultant Peter Barker reviews some frequently asked questions about the process for CE marking fire resisting doorsets
The Construction Products Regulation (CPR), which came into effect on 1st July 2013, introduced the most significant regulatory change for a decade in the way that construction products are manufactured and sold in the European Union (EU). The CPR replaced the Construction Products Directive (CPD) and made CE marking mandatory across the entire European Union (EU), for products defined by relevant harmonised European Product Standards (hEN).
In the UK and Ireland there are two main routes via which a fire-resisting doorset can be supplied and installed within a building to comply with building regulations:
- The door leaf and its component parts (door frame, hardware, seals etc.) are supplied by different companies under separate contracts for construction and installation on site (door assembly). Not CE markable.
- The doorset is supplied by one company under a single contract either fully or part assembled for installation on site. Any further works required for the door are typically carried out using basic tools in order to fit the hardware or seals (doorset). CE markable.
The CE marking requirement under the CPR only relates to doorsets that are supplied as a warranted, tested whole from one legal entity or company under a single contract. These doorsets must comply with a range of essential requirements once CE marking of fire resisting doorsets becomes mandatory.
Under the CPR, pedestrian doorsets with fire and/or smoke control characteristics are covered by a draft hEN, pr EN 16034. This has yet to be finalised and it is for this reason that it is not currently a mandatory/legal requirement for manufacturers to CE mark such doorsets in order to place them on the open market. However, when pr EN 16034 is published as a full standard and the co-existence period has finished, all manufacturers of such doorsets must comply with the product standard under the CPR, and CE mark the doorset before placing it on the open market.
Although a co-existence period has been requested, it has not been confirmed how long such a period would be or whether it will be granted. Without a co-existence period (or after it has ceased), technically it will be illegal for a manufacturer to place a fire resisting doorset on the open market without a CE mark.
Frequently asked questions
BM TRADA has compiled some frequently asked questions received from BM TRADA Q-mark certified door manufacturers and members of the Architectural Specialist Door Manufacturers Association (ASDMA). The answers provided are to the best of our knowledge at the time of going to press.
Who needs to CE mark?
Manufacturers of construction products that are covered by harmonised product standards (hENs). Fire resisting doorsets that are constructed and supplied to market by one manufacturer will need to CE mark their doorsets under the requirements of hEN 16034 when published.
When will it come into effect?
BM TRADA’s current best estimate for pr EN 16034 to become a full standard is May 2015. A co-existence period has been requested but is yet to be confirmed. Once it comes into effect and any co-existence period has expired it will be a requirement to CE mark fire resisting doorsets.
I am only supplying the door leaf; will this need to be CE marked?
No. It will be the responsibility of the doorset manufacturer to use the correct door leaf as tested for the complete doorset. It is not possible to CE mark a door leaf. The door leaf may need to be sampled at factory source prior to testing.
If a door manufacturer only supplies the leaf for others to install into a suitable and compliant door frame with appropriate hardware and intumescent seals etc, as supported by the test evidence, is the door manufacturer in contravention of the Construction Products Regulations when they come into force?
No, this is the definition of providing doorsets as a door assembly. It is BM TRADA’s understanding that it will be possible to continue to supply different door components for construction and installation on site from various manufacturers and under different contracts. However, if a CE marked doorset has been specified this route will not be acceptable. It is likely that the requirement for CE marking will be driven by market requirements.
Can I use any CE-marked hinge on fire doors or does it have to be as the tested specification?
BM TRADA’s current understanding is that alternative CE-marked hinges can be cascaded into a doorset manufacturer’s EXAP report. However, the test evidence for the hinge must be submitted to the Notified Body writing the EXAP report (a DoP on the hinge is not sufficient as the only documentation) and the evidence for the hinge must be on a door of a similar product family.
My proposed hinge blade is bigger than the permitted hinge blade in the EXAP but it is CE marked, will this be acceptable?
Only if the CE-marked hinge has been tested on a doorset of a similar product family and is subsequently included within the EXAP for the door design.
A flush CE marked doorset has been installed but now I need to fit a glazed aperture in it, is this allowed?
CE marking follows the Chain of Custody approach that those involved with third party certification of products will already be familiar with. CE marking is a declaration by the manufacturer that the products meet basic safety requirements for selling on the open market. If changes are made to the doorset after it has been manufactured and installed the Chain of Custody is broken and any assurances that the product met these performance requirements when it left the factory would be void.
I will be manufacturing a CE-marked doorset in a frame with essential hardware but not installing it as it will be painted on site, do I need to CE mark and if so, how do I do this if it is still to be painted?
If the doorset is constructed and supplied to market by one manufacturer it should be CE-marked. The doorset can then be decorated on site by others.
Will architects be required to specify the handles (levers and pulls) tested as part of the CE-marked doorset or will there be an allowance for architects to specify a CE-marked doorset supplied by one company and the handles supplied by another company?
If the specification calls for a CE-marked doorset, it will have to be provided by one doorset manufacturer who has had the handles considered suitable for use with their doorset design as part of the scope of application using the EXAP process or, if necessary, by testing.
External pedestrian doorsets must already carry a CE mark, what if these doors also need to provide fire resistance?
Until the hEN for fire-resisting doors is published as a full standard it will only be possible to CE mark external pedestrian doorsets to EN 14351-1 and then also declare the fire resistance of the door outside of the DoP.