Guidance note - A21. CE Marking Requirements

Transcription

1 Guidance note - A21 Issue 1. June 2013 CE Marking Requirements 1.0 WHAT IS CE MARKING? CE marking demonstrates compliance with the appropriate manufacturing standard for a product. Typically this concerns the health & safety requirements of a relevant European product directive. The mark indicates to the public, and to enforcement officers, that the product complies and may therefore be lawfully placed on the market in any EU or EFTA country. Not all products require CE marking but where they do it is a mandatory requirement. 123 Blind Company Ltd, The Street, The City, Postcode EN An example CE label for an external blind 2.0 WHICH PRODUCTS ARE AFFECTED CE marking only affects products where there is a harmonised European standard and in the blinds and shutters industry this currently affects: Products Directive Relevant Standard Enforcement Body When? All powered (motorised) products Machinery EN HSE (England, Wales and Scotland) Since Motors themselves are currently subject to other Directives Directive HSE NI (Northern Ireland) 1 January 1995 All external products Construction Products Directive Blinds EN Shutters EN Trading Standards (England, Wales and Scotland) Environmental Health Officers From 1 July 2013 (Northern Ireland)

2 The Directives provide the over-arching rules and are transposed into UK law so are a legal requirement. The product standards detail the technical requirements and compliance with these requirements means there is a presumption of conformity with the relevant Directive. 3.0 WHO IS RESPONSIBLE FOR CE MARKING? Both the Machinery Directive and the Construction Products Directive place legal obligations on manufacturers, distributors and importers. In essence the supplier (whoever places the product on the market) must CE mark the product. If manufactured in the EU the product should be CE marked by the manufacturer. If manufactured outside the EU then the responsibility for CE marking typically rests with the importer. Where machinery is assembled on site and the installation process may significantly alter the safety characteristics, the installer would be regarded as the supplier. 4.0 WHEN DO YOU HAVE TO COMPLY? All internal motorised products have had a requirement for CE marking since External products are covered by the Construction Products Directive which in the UK comes into force as the Construction Product Regulations on 1 July WHAT DO YOU NEED TO DO TO COMPLY? Compliance requirements will vary depending on the product and your position in the supply chain please see Appendix WHAT IS DUE DILIGENCE? Due diligence is detailed in most Directives and broadly it means: Knowing what is required by the Directive Declaring your product meets the relevant requirement Demonstrating compliance with applicable Directives Properly prepared able to produce a Technical File and ready to defend yourself! A Factory Production Control Process (see 9.0 below) is evidence of your due diligence in the case of the Construction Products Directive. 7.0 WHAT IS A TECHNICAL FILE? This is documented evidence to show that the products comply with the requirements of the applicable Directives. The technical file contains technical and test information relevant to the product you are putting on the market and would include items such as: General description of the product (you could refer out to the instruction leaflet/manual) Conceptual design drawings/photos Description/explanation of drawings List of standards applicable List of components a bill of materials in which you identify those that are safety critical Test reports by a competent person A copy of the Declaration of Conformity (Machinery Directive) or Declaration of Performance (Construction Products Directive)

3 It must be kept up to date. 8.0 DECLARATIONS OF CONFORMITY/PERFORMANCE The supplier must issue a Declaration of Conformity for products under the Machinery Directive. The same document is known as a Declaration of Performance under the Construction Products Directive. These declarations in themselves are not evidence of compliance; they must be supported by a full technical file. The Declaration must include: Name and address of the manufacturer Description of product serial number, model, reference etc Reference of harmonised standard where conformity is declared Signed by a responsible person and containing the identification of that signatory Last two digits of the year in which the marking was applied 9.0 WHAT IS FACTORY PRODUCTION CONTROL (FPC)? EN identifies the requirements of a FPC. The manufacturer shall establish document and maintain an FPC system to ensure that the products placed on the market conform with the stated performance characteristics. The FPC system shall consist of procedures, regular inspections and tests and use the results to control raw and other incoming materials or components, equipment, the production process and the product. The results of inspections, tests, requiring action shall be recorded, as well as any action taken. The action taken when control values or criteria are not met shall be recorded. 9.1 Equipment All weighing, measuring and testing equipment shall be calibrated and regularly inspected according to documented procedures, frequencies and criteria. 9.2 Raw material and components The specification of all incoming raw material and components shall be documents, as well as for ensuring their conformity. 9.3 Design Process The FPC system shall document the various stages in the design of products, identify the checking procedure and those individuals responsible for all stages of design. During the design process itself, a record shall be kept of all checks, their results, and any corrective actions taken. This record shall be sufficiently detailed and accurate to demonstrate that all stages of the design phase, and all checks, have been carried out satisfactorily. Accreditation to ISO 9001 will typically ensure the requirements of a FPC system. 9.4 Product Testing and Evaluation The manufacturer shall establish procedures to ensure that the characteristics of test procedures are recorded.

4 9.5 FPC Documentation The FPC system documentation shall address at least the following: Definition of tasks and authorities Definition of the structure of the system documentation Specification and verification of raw materials and components Identification and traceability of products Documented procedures and instructions related top FPC Control of FPC related records Design control Identification of inspections and tests to be carried out Identification of necessary equipment for inspections and tests Treatment of non-conforming products Carrying out corrective actions 10.0 WHAT ARE THE CONSEQUENCES FOR NON-COMPLIANCE? Failure to CE mark the products detailed above is a criminal offence. The enforcement body has a number of possible remedies available to them: Remove product from sale (temporary or permanent) Product recall Fines Imprisonment 11.0 RESOURCES 11.1 Standards Product Standards EN Internal blinds - Performance requirements including safety EN External blinds - Performance requirements including safety EN Shutters - Performance requirements including safety Test Method Standards EN Shutters and blinds power operated - Safety in use - Measurement of the transmitted force EN 1932 External blinds and shutters - Resistance to wind loads - Method of testing EN Shutters, external and internal blinds misuse test methods EN 1933 Exterior blinds - resistance to load due to water accumulation test method EN Skylight and conservatory roller shutters resistance to snow load test method 11.2 Directives as implemented in UK Construction Product Regulation

5 Machinery Directive The Machinery Directive is implemented in the UK as Supply of Machinery (Safety) Regulations 2008 S.I British Blind and Shutter Association, PO Box 232, Stowmarket, Suffolk, IP14 9AR T: F: Please note the information contained in this document is intended for general guidance and should not be taken as definitive advice. You should ensure you take advice based upon your particular circumstances. The BBSA is not responsible for the content of external websites referred to in this document. BBSA 2013 V1 06/13

6 Guidance note - A21 Appendix 1 CE Marking Requirements 1.0 OVERALL SUMMARY The two tables below highlight the main product standards and test method standards to be used to ensure compliance to either the Machinery Directive (MD) for motorised products or the Construction Products Directive (CPD) for external products. See sections 2.0 and 3.0 for specific information. 1.1 Blinds Machinery Directive Construction Products Directive Product MD Test Standard MD Product Product Test Standard CPR Internal N/A EN 1932 Yes External External motorised N/A EN 1933 Yes motorised retractable blinds Yes EN Yes blinds blinds (manual EN 1932 Yes EN Yes EN Yes EN or motorised) 1.2 Shutters Machinery Directive Construction Products Directive Product MD Test Standard MD Product Product Test Standard CPR Internal N/A EN 1932 Yes External External Motorised N/A EN Yes motorised shutters shutters Yes EN Yes shutters (manual or EN 1932 Yes EN Yes EN Yes EN motorised) For motorised external products both the MD and the CPD apply. NB External Venetians are included in EN

7 2.0 MACHINERY DIRECTIVE 2.1 Internal Motorised Blinds Overview Product Category All motorised internal blinds See EN Annex ZB Scope It applies to all internal blinds, whatever their design and the nature of the materials used, such as: venetian blind: free hanging, guided, non-retractable roller blind: free hanging, side guided, with tensioned fabric vertical blind: free hanging, with top and bottom track, sloping headrail pleated and honeycomb blind: free hanging, guided, laterally moving, tensioned Roman Shades; Austrian / Festoon blinds panel blinds plantation shutters roll-up blinds Buying in ready- made product If you are buying a made-up product from an EU source it should be CE marked by your supplier. If you sell/install this product with no changes you can rely on the testing they have carried out and the CE mark. If you import ready-made product from outside the EU you satisfy yourself that it is a compliant product and then CE mark the product. If you do not want your customers to know your supply source you can CE mark the product with your details assuming that you satisfy yourself that it is a compliant product. Who CE Marks? Assembling/manufacturing If you make an internal blind using parts from supplier(s) then you are responsible for testing to prove that the product you will put on the market is compliant and CE mark the product accordingly. Compliance under the Machinery Directive is by way of a risk assessment against the specific clauses in the standard detailed in below. Note that there are test methods to guide such risk assessments. 2

8 2.1.1 Internal Motorised Blinds Specific Requirements Annex ZB states: Once this standard is cited in the Official Journal of the European Communities under that Directive and has been implemented as a national standard in at least one Member State, compliance with the normative clauses of this document except clauses 4, 5, 7, 8.2, 10, 11, 12, 13 confers, within the limits of the scope of this document, a presumption of conformity with the relevant Essential Requirements of that Directive and associated EFTA regulations. Therefore the normative clauses for compliance with the Machinery Directive are: Section Test Method (if applicable) What you need to know/do 6.0 Misuse EN Shutters, external and internal blinds misuse test methods Products will need to be tested to the methods determined in the standard opposite. 8.0 Safety in use (not 8.2) Check compliance to clause 8.1 regarding sharp and projecting edges. EN Shutters and blinds power operated - safety in use measurement of transmitted force for clause 8.3 If you produce a guided power operated product see clause 8.3 and test method opposite. NB - child safety (clause 8.2) is specifically excluded from the Machinery Directive but is mandatory under the General Product Safety Directive (GPSD). Ensure your products do not release any dangerous substances as detailed in clause Hygiene, health & environment 14.0 Handling & Storage The two requirements here are very simple Information for installation, use and maintenance There are quite detailed requirements in this clause. Again the child safety information is mandated under the GPSD. The other information needs to be included for CE marking under the Machinery Directive. Note there is a requirement to state noise levels Marking This determines the minimum labelling requirements. 3

9 2.2 Motorised External Blinds Overview Product Category All motorised external blinds See EN Annex ZB NB External Venetian Blinds are covered by EN Scope It applies to all external blinds and awnings as well as similar products whatever their design and nature of the materials used, as follows: folding arm awning trellis arm awning pivot arm awning slide arm awning vertical roller awning marquisolette façade awning skylight awning conservatory awning Pergola awning Dutch awning insect screen brise-soleil Buying in ready- made product If you are buying a made-up product from an EU source it should be CE marked by your supplier. If you sell/install this product with no changes you can rely on the testing they have carried out and the CE mark. If you import ready-made product from outside the EU you satisfy yourself that it is a compliant product and then CE mark the product. If you do not want your customers to know your supply source you can CE mark the product with your details assuming that you satisfy yourself that it is a compliant product. Who CE Marks? Assembling/manufacturing If you make an external blind using parts from supplier(s) then you are responsible for testing to prove that the product you will put on the market is compliant and CE mark the product accordingly. Compliance under the Machinery Directive is by way of a risk assessment against the specific clauses in the standard detailed in below. Note that there are test methods to guide such risk assessments. 4

10 2.2.1 Motorised External Blinds Specific Requirements Annex ZB states: Once this standard is cited in the Official Journal of the European Communities under that Directive and has been implemented as a national standard in at least one Member State, compliance with the normative clauses of this standard except Clauses 7, 8, 10, 11, 14, 15, 16, 17 and 20 confers, within the limits of the scope of this standard, a presumption of conformity with the Essential Requirements of that Directive and associated EFTA regulations. Therefore the normative clauses for compliance with the Machinery Directive are: Section Test Method (if applicable) What you need to know/do 4.0 Wind resistance EN 1932 External blinds and shutters Resistance to wind loads Method of testing This test method standard will determine the wind class of your product. NB This is also a requirement for CE marking under the Construction Products Directive. 5.0 Resistance to water pocket EN Exterior blinds Resistance to load due to water accumulation Test method. This clause is only applicable to folding arm awnings, trellis arm awnings, Dutch awnings and Pergola awnings. Under the action of precipitation, the external blind may retain water forming a pocket of water. The external blind shall withstand the corresponding load as determined in the standard opposite. 6.0 Resistance to snow load Resistance to snow load is only relevant for fixed position external products. 9.0 Misuse EN Shutters, external and internal blinds misuse test methods Products will need to be tested to the methods determined in the standard opposite Safety in use EN Shutters and blinds power operated - safety in use measurement of transmitted force 13.0 Hygiene, health and environment If you produce a guided power operated product use test method opposite. Ensure your products do not release any dangerous substances as detailed in clause Handling & Storage The requirements here are straightforward Information for Use There are quite detailed requirements in this clause. Note the product marking requirements are also detailed in this clause. 5

11 2.3 Motorised Shutters Product Overview Product Category All motorised shutters inc External Venetian Blinds See EN Annex ZB Scope It applies to all shutters and external venetian blinds as well as similar products whatever their use and nature of the materials used, as follows: External venetian blind roller shutter wing shutter Venetian shutter, flat-closing concertina shutter concertina shutter or sliding panel shutter, with or without a system of projection Who CE Marks? Buying in ready- made product If you are buying a made-up product from an EU source it should be CE marked by your supplier. If you sell/install this product with no changes you can rely on the testing they have carried out and the CE mark. If you import ready-made product from outside the EU you satisfy yourself that it is a compliant product (by testing) and then CE mark the product. If you do not want your customers to know your supply source you can CE mark the product with your details assuming that you satisfy yourself that it is a compliant product. Assembling all components from one supplier If you make a motorised shutter using parts from supplier(s) then you are responsible for testing to prove that the product you will put on the market is compliant and CE mark the product accordingly. Compliance under the Machinery Directive is by way of a risk assessment against the specific clauses in the standard detailed in below. Note that there are test methods to guide such risk assessments. 6

12 2.3.1 Motorised Shutters Specific Requirements Annex ZB states: Once this standard is cited in the Official Journal of the European Communities under that Directive and has been implemented as a national standard in at least one Member State, compliance with the normative clauses of this standard except Clauses 6, 7, 10, 11, 12, 13, 14, 17, 18, 19, 20 and 23 confers, within the limits of the scope of this standard, a presumption of conformity with the Essential Requirements of that Directive and associated EFTA regulations. Therefore the normative clauses for compliance with the Machinery Directive are: Section Test Method (if applicable) What you need to know/do 4.0 Wind resistance EN 1932 External blinds and shutters Resistance to wind loads Method of testing This test method standard will determine the wind class of your product. NB This is also a requirement for CE marking under the Construction Products Directive. 5.0 Resistance to snow load EN 12833, Skylight and conservatory roller shutters - Resistance to snow load - Test method Misuse EN Shutters, external and internal blinds misuse test methods 9.0 Edge loading EN Shutters, external and internal blinds misuse test methods 15.0 Safety in use EN Shutters and blinds power operated - safety in use measurement of transmitted force Hygiene, health and environment This clause is only applicable to roller shutters for skylights and conservatories for which the inclination angle from the horizontal is less than 60. Products will need to be tested to the methods determined in the standard opposite. This clause only refers to wing shutters. Ensure your products comply with the requirements of the test method standard shown opposite. Ensure your products do not release any dangerous substances as detailed in clause Handling & storage The requirements here are straightforward Information for use There are quite detailed requirements in this clause. Note the product marking requirements are also detailed. 7

13 3.0 CONSTRUCTION PRODUCT DIRECTIVE 3.1 External Retractable Blinds Overview Product Category All retractable external blinds See EN Annex ZA NB External Venetian Blinds are covered by EN Scope It applies to all external blinds and awnings as well as similar products whatever their design and nature of the materials used, as follows: folding arm awning trellis arm awning pivot arm awning slide arm awning vertical roller awning marquisolette façade awning skylight awning conservatory awning Pergola awning Dutch canopy insect screen Brise soleil NB: This EN standard does not cover the wind resistance of nonretractable products e.g.: Dutch canopy and Brise Soleil. These products should be evaluated according to the relevant calculation methods (such as Eurocodes) Buying in readymade product If you are buying a madeup product from an EU source it should be CE marked by your supplier. If you sell/install this product with no changes you can rely on the testing they have carried out and the CE mark. If you import ready-made product from outside the EU you satisfy yourself that it is a compliant product (by testing) and then CE mark the product. If you do not want your customers to know your supply source you can CE mark the product with your details assuming that you satisfy yourself that it is a compliant product. Who CE Marks? Assembling all components from one supplier Assuming your supplier is based in the EU and has tested their product and you are, in effect, assembling a kit of parts from an EU source to the production process laid down by that supplier then you can rely on their testing and CE mark accordingly. To prove you consistently manufacture in accordance to an agreed process you will need a documented Factory Production Control Process (FPC). Assembling/making from components from more than one supplier If you make an external shutter or external Venetian Blind using parts from a number of suppliers then you are responsible for testing to prove that the product you will put on the market is compliant by testing and CE mark the product accordingly. To prove you consistently manufacture in accordance to an agreed process you will need a documented Factory Production Control Process (FPC). 8

14 3.1.1 External Retractable Blinds Specific Requirements Annex ZA determines the requirements for CE marking under the Construction Products Directive. This details two normative clauses: Section Test Method (if applicable) What you need to do 4.0 Wind resistance EN 1932 External blinds and shutters Resistance to wind loads Method of testing This test method standard will determine the wind class of your product. NB - this is also a requirement under the Machinery Directive if the product is motorised Total Solar Energy Transmittance This is NOT currently required. Your Declaration of Performance can be marked NPD for this requirement which stands for No Performance Determined NB If the products are motorised then the Machinery Directive requirements apply as well. 9

15 3.2 External Shutters Products Overview Product Category All external shutters inc External Venetian Blinds See EN Annex ZA Scope It applies to all shutters and external venetian blinds as well as similar products whatever their use and nature of the materials used, as follows: External venetian blind roller shutter wing shutter Venetian shutter, flat-closing concertina shutter concertina shutter or sliding panel shutter, with or without a system of projection Buying in readymade product If you are buying a made-up product from an EU source it should be CE marked by your supplier. If you sell/install this product with no changes you can rely on the testing they have carried out and the CE mark. If you import readymade product from outside the EU you satisfy yourself that it is a compliant product (by testing) and then CE mark the product. Who CE Marks? Assembling all components from one supplier Assuming your supplier is based in the EU and has tested their product and you are, in effect, assembling a kit of parts from an EU source to the production process laid down by that supplier then you can rely on their testing and CE mark accordingly. To prove you consistently manufacture in accordance to an agreed process you will need a documented Factory Production Control Process (FPC). Assembling/making from components from more than one supplier If you make an external shutter or external Venetian Blind using parts from a number of suppliers then you are responsible for testing to prove that the product you will put on the market is compliant by testing and CE mark the product accordingly. To prove you consistently manufacture in accordance to an agreed process you will need a documented Factory Production Control Process (FPC). If you do not want your customers to know your supply source you can CE mark the product with your details assuming that you satisfy yourself that it is a compliant product. 10

16 3.2.1 External Shutters Specific Requirements Annex ZA determines the requirements for CE marking under the Construction Products Directive. This details three normative clauses: Section Test Method (if applicable) What you need to do 4.1 Wind resistance EN 1932 External blinds and shutters Resistance to wind loads Method of testing This test method standard will determine the wind class of your product. NB - this is also a requirement under the Machinery Directive if the product is motorised Additional thermal resistance 18.0 Total Solar Energy Transmittance NB If the products are motorised then the Machinery Directive requirements apply as well. This is NOT currently required. Your Declaration of Performance can be marked NPD for this requirement which stands for No Performance Determined This is NOT currently required. Your Declaration of Performance can be marked NPD for this requirement which stands for No Performance Determined British Blind and Shutter Association, PO Box 232, Stowmarket, Suffolk, IP14 9AR T: F: info@bbsa.org.uk Please note the information contained in this document is intended for general guidance and should not be taken as definitive advice. You should ensure you take advice based upon your particular circumstances. The BBSA is not responsible for the content of external websites referred to in this document. BBSA 2013 V1 06/13 11