EAPFP offers CE Marking advice
The European Association for Passive Fire Protection (EAPFP) has released a simple guide to CE-Marking for passive fire protection products. The Introduction to the Construction Products Regulation (CPR) provides advice for manufacturers and distributors on what they need to do to meet the requirements of the CPR, which came into effect on 1 July 2013.
The Guide explains that there are two routes to evaluating products on the market. These take the form of harmonised European product standards (hENs), prepared in CEN; or European Technical Assessments (ETAs), which are prepared by an Approval Body against European Technical Assessment Guidelines (ETAGs), known as a European Assessment Documents (EADs)under the CPR.
CE marking is mandatory for any product which is covered by a published hEN but remains voluntary if the product is only covered by a published EAD. Since hENs do not yet exist for a variety of passive fire protection products, the number for which a CE mark is mandatory is currently limited. But, according to the EAPFP, many manufacturers will voluntarily CE mark their products to obtain market advantage.
The guide provides a useful list of passive fire protection products for which a hEN exists and thus CE marking is mandatory. These are fire resisting dampers; fire door ironmongery and gypsum boards. It also lists those products for which voluntary CE marking is possible due to the existence of appropriate ETAGs and estimates the likely schedule for the development of suitable hENS.
Offering guidance for product manufacturers, the guide explains that each hEN and ETAG outlines performance requirements for the product in support of the relevant Basic Works Requirements of the CPD/CPR. These include: mechanical resistance and stability; safety in case of fire; hygiene, health and environment; safety in use; protection against noise; energy economy and heat retention; environmental product declarations; and sustainable use of natural resources.
The level of proof of compliance for a product against a technical specification depends upon the essential requirements, the product and its end use. There are five systems of Assessment and Verification of Constancy of Performance (AVCP), but only two are used for fire products.
System 1 is the highest level, used for safety critical products. This requires a Notified (third party) certification body to select samples for testing; check factory production control system and undertake surveillance visits.
Meanwhile System 3, used for less critical products, requires that a Notified Body (independent test laboratory) undertakes fire testing and classification. But it requires no checks of the manufacturing line or consistency of product so no need for a Notified certification body.
The Guide outlines a number of steps manufacturers must undertake to comply with the CPR, providing a flowchart to explain the process. Manufacturers should first determine if their product is covered by a harmonised product standard (hEN) or European Technical Assessment Guideline (ETAG) and identify the status of the hEN or ETAG. They should then group their products together into families to reduce the amount of testing required, before approaching a Notified Body (for products covered by a hEN) or an ETA Issuing Body (for products covered by an ETAG/hEN).”
If the product is AVCP system 1, then a Notified Certification Body (for hEN products) or an ETA issuing Body must undertake the testing and issue a Certificate of Conformity before providing a Declaration of Performance and a CE mark for the product. If the product is AVCP system 3 then the manufacturer can organise the testing with a Notified Body (test laboratory) and make a Declaration of Performance and CE mark the product itself.
”Whichever system is followed, it is recommended that manufacturers choose a Notified Test/Certification Body or ETA issuing body that is a member of EGOLF (European Organisation for fire testing, inspection and certification) and find out if they regularly participate in the Group of Notified Bodies Fire Sector Group. This will ensure that the tests are conducted correctly and the documentation provided is appropriate,” says EAPFP technical officer Niall Rowan.
“Distributors should also carefully examine products before they are placed on the market. CPR obligations are not just for manufacturers, distributors must ensure that products bear CE marking and are accompanied by all the necessary documentation.”
The EAPFP is leading a campaign to increase the number of passive fire protection products that are subject to mandatory CE marking on the European market.
The Association has been calling for voluntary European Technical Approval Guidelines (ETAGs) for a range of passive fire protection products to be converted to mandatory harmonised European product standards (hENs).