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This bulletin summarises the key points that the Harmonised Technical Specifications
construction industry must address by 1st July 2013. Assessment and Verification of Constancy of
Performance
2 BM TRADA 2013
Technical Bulletin - CE marking: from 1st July 2013
The second part, ZA.2, provides the procedures for To achieve this, the CPR uses five AVCP systems (System 4
conformity assessment, namely, who does what between - System 1+) and six tasks, as shown in Table 1.
the Manufacture and the Notified Body. This is the
Assessment and Verification of Constancy of Performance
(AVCP), formerly known as the System of Attestation of Declaration of Performance (DoP)
Conformity (AoC) in the CPD. The Manufacturer must make a declaration of
performance (DoP) of the product before placing that
The third part, ZA.3, describes the process for CE marking product on the market. The Manufacturer, Authorised
and labelling. Representative or Trader must then take responsibility for
the conformity of the construction product.
European Technical Assessment (ETA)
A European Technical Assessment (ETA) can be issued for The DoP must express the performance of the construction
any construction product not covered or not fully covered product in relation to the essential characteristics as
by a harmonised standard or for which the performance in specified in the harmonised Technical Specification(s) and
relation to its essential characteristics cannot be entirely should contain the following information:
assessed according to an existing harmonised standard.
the reference of the product type
ETAs can be issued if at least one of these applies: the system or systems of AVCP
the product does not fall within the scope of any
existing harmonised product standard the reference number and date of issue of the hEN
or ETA used for the assessment of each essential
the assessment method provided for in the harmonised characteristic
standard is not appropriate for at least one essential
characteristic of that product where applicable, the reference number of the
specific technical documentation used and the
the harmonised standard does not provide for any requirements with which the manufacturer claims the
assessment method in relation to at least one essential product complies
characteristic of that product.
the intended use or uses for the construction product,
in accordance with the applicable harmonised
Technical Specification
Table 1: Third party involvement according to AVCP system
3 BM TRADA 2013
Technical Bulletin - CE marking: from 1st July 2013
the list of essential characteristics, as determined ensure that their construction product(s) bear a type,
in the harmonised Technical Specification for the batch or serial number or any other element, for
declared intended use or uses identification
the performance of at least one of the essential indicate their name, registered trade name or registered
characteristics of the construction product, relevant for trade mark and their contact address on the product or
the declared intended use or uses on its packaging or in an accompanying document
where applicable, the performance of the construction ensure that the product is accompanied by instructions
product (by levels or classes, or in a description) if and safety information
necessary based on a calculation in relation to its
take immediate corrective measures to bring a product
essential characteristics
into conformity or, if appropriate, to withdraw or recall
the performance of those essential characteristics it should there be reason to believe that the product
of the construction product which are related to the does not comply with the DoP
intended use or uses
when requested, provide National Authorities with
for the listed essential characteristics for which no all the information and documentation necessary
performance is declared, the letters NPD (meaning no to demonstrate the conformity of the construction
performance determined) product with the DoP and compliance with other
applicable requirements.
when an ETA has been issued for CE marking that
product, the performance (by levels or classes, or in Authorised Representatives
a description) of the construction product in relation The CPR allows for Manufacturers to appoint Authorised
to all essential characteristics contained in the Representatives , by mandate. Although not responsible
corresponding ETA. for preparing technical documentation, the Authorised
Representative is responsible, due to the chain of custody,
for the compliance of products supplied.
Obligations in the construction industry
The CPR is based on a chain of custody approach for The Authorised Representative must:
construction products being placed on the market. The keep the DoP and other technical documentation
following obligations apply from 1st July 2013.
when requested, provide National Authorities with
Manufacturers all the information and documentation necessary
Manufacturers of construction products covered by to demonstrate the conformity of the construction
harmonised European Product Standards (hENs) must: product with the DoP and compliance with other
make a DoP and affix the CE mark applicable requirements
prepare technical documentation for the product when requested, co-operate with National Authorities
describing all the relevant elements related to its on any action taken to eliminate the risks posed by
system of AVCP construction products covered by the mandate.
4 BM TRADA 2013
Technical Bulletin - CE marking: from 1st July 2013
not place on the market products that do not meet Cases in which obligations of Manufacturers
the DoP until conformity is achieved may apply to Importers and Distributors
inform the Manufacturer or market surveillance An Importer or Distributor will be considered to be a
authorities where they believe the product presents Manufacturer and will be subject to the obligations of
a risk the Manufacturer if they place a product on the market
under THEIR name or trademark or modify a construction
indicate THEIR name, registered trade name or product already placed on the market in such a way that
registered trade mark and their contact address affects its conformity with the DoP.
on the product or on its packaging or in an
accompanying document
Further help
ensure that the product is accompanied by
TRADA members may contact the Members Helpline
instructions and safety information
for free on: 01494 569601
while a construction product is in their care,
ensure that storage or transport conditions do not BM TRADA is a notified body and ETA issuing body for
jeopardise its conformity with the DoP the Construction Products Directive and can provide
CE certification services where required.
carry out sample testing of products placed or made t: 01494 569671
available on the market to ensure the accuracy, www.bmtrada.com
reliability and stability of the declared performance
European Commission:
keep a register of complaints of non-conforming This is the website of the European Commission and is
products and of product recalls useful for looking up Notified bodies and assessment bodies.
http://ec.europa.eu/enterprise/newapproach/nando
take immediate corrective measures if they consider
or have reason to believe that the product does not CEN
comply with the DoP This is the website of CEN and is useful for checking
keep a copy of the DoP and make this available to progress on harmonised standard activity.
authorities upon request. www.cen.eu/cen
Distributors NANDO
Distributors have a duty of care when placing a NANDO is the acronym for New Approach Notified and
product on the market. Before placing the product on Designated Organisations and provides useful
the market, distributors must: information on Notified Bodies, Standards, etc.
http://ec.europa.eu/enterprise/newapproach/nando
ensure that the product bears the CE marking and
is accompanied by the required documentation and EOTA
also by instructions and safety information EOTA is the European Organisation for Technical Approvals
and comprises of the Approval Bodies nominated to issue
not place on the market products that do not
European Technical Approvals (ETAs) by EU Member States
comply with the DoP until conformity is achieved
and EFTA States who have contracted to the European
inform the Manufacturer or market surveillance Economic Area Agreement.
authorities where they believe the product presents
a risk This website is useful for looking up valid ETAs and ETA
issuing bodies.
ensure that while a construction product is under www.eota.be
their responsibility, storage or transport conditions
do not jeopardise its conformity with the DoP
5 BM TRADA 2013
Acknowledgements
While every effort is made to ensure the accuracy
Prepared by the publishing team at BM TRADA with the
of the advice given, the company cannot accept
assistance of Niresh Somlie and Ross Newman.
liability for loss or damage arising from the use of
the information supplied.
References All rights reserved. No part of this publication
1. Construction Products Regulation 305/2011/EU may be reproduced, stored in a retrieval system or
transmitted in any form, by any means, electronic,
2. Construction Products Directive 89/106/EEC as
mechanical, photocopying, recording or otherwise,
amended by Directive 1993/68/EEC
without the prior permission of the copyright owner.
BM TRADA Q-Mark.
Technical Information
CE Marking of windows & external
pedestrian doorsets:
Guidance for manufacturers
Introduction Considerations
From 1st July 2013 it will be illegal to place windows and
2. What performance
external pedestrian doorsets on the market without a CE 1. What products characteristics do I need /
Mark and a Declaration of Performance (DOP). This is due do I make? want to claim?
to the introduction of the European Construction Products
Regulation (CPR) which is an EU law and is being adopted by
all member states including the UK.
3. What am I responsible for?
This guide explains what manufacturers / assemblers of
complete window and external doorsets (that are not fire,
smoke or emergency escape doors) will need to do to comply 4. What test evidence /
5. What factory controls do I
with the CPR, which means meeting the requirements of the performance declarations
have / need to put in place?
Product Standard BS EN 14351-1: 2006 +A1:2010: Windows do I have / need to get?
and doors Product standard, performance characteristics Part
1: Windows and external pedestrian doorsets without resistance
to fire and / or smoke leakage characteristics. 6. How do I make a
Declaration of Performnce?
This guide seeks to provide an overview of the CE Marking
process but we recommend that you read BS EN 14351-1
which describes in detail what must be done. 7. How / where must I
apply a CE Mark?
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