Coastal Group

CE Marking White Paper

CE Marking 1 | P a g e

© Coastal Specialist Ironmongery 2013

Connectin

g C

raftsm

ansh

ip w

ith S

olu

tions

What is CE Marking? The letters ‘CE’ appear on many products that are traded on the single market in the European

Economic Area (EEA), consisting of the 27 member states of the EU and European Free Trade

Association countries Iceland, Liechtenstein and Norway. The CE marking is required for many

products and attests the verification by a manufacturer that these products meet EU safety, health

or environmental requirements.

CE marking is a key indicator of a product’s compliance with EU legislation and enables the free

movement of products within the European market. By affixing the CE marking on a product, a

manufacturer is declaring, on his sole responsibility, conformity with all of the legal requirements

to achieve CE marking and therefore ensuring validity for that product to be sold throughout the

EEA, the 27 member states of the EU and European Free Trade Association countries - Iceland,

Norway, Liechtenstein and Turkey. This also applies to products made in third countries which are

sold in the EEA and Turkey. However, not all products must bear the CE marking. Only those

product categories subject to specific directives that provide for the CE marking are required to be

CE marked.

CE marking does not indicate that a product was made in the EEA, but merely states that the

product is assessed before being placed on the market and thus satisfies the legislative

requirements, e.g. a harmonised level of safety, to be sold there. It means that the manufacturer

has verified that the product complies with all relevant essential requirements, e.g. health and

safety requirements, of the applicable directive(s) or, if stipulated in the directive(s), had it

examined by a notified conformity assessment body.

CE Marking 2 | P a g e

© Coastal Specialist Ironmongery 2013

Connectin

g C

raftsm

ansh

ip w

ith S

olu

tions

The Manufacturer’s Responsibility It is the manufacturer’s responsibility to:

1. carry out the conformity assessment

2. set up the technical file

3. issue the EC Declaration of Conformity (DoC) or EC Declaration of Performance (DoP)

4. affix CE marking on a product

Distributors must verify the presence of both the CE marking and the necessary supporting

documentation. If the product is being imported from a third country, the importer has to verify

that the manufacturer outside the EU has undertaken the necessary steps and that the

documentation is available upon request.

The Myth CE Marking will affect all joinery manufacturers. Do not think that because you make a one off

window or door that you will not have to CE mark. This is not true. If an item requires a U-value

then it also needs a CE mark.

Some joinery companies are still not providing U-values or the correct U-value, which relate to

building regulations – Part L. This stipulates (since October 2010) that external windows need to

have a U-value of 1.6 for a renovation project (or 2 in a new build) and external doors require a u-

value of 1.8. If you are currently just calling the local glazing company for the U-value of the glass

this is not the same as the overall U-value. The overall U-value is based on the following; type of

timber, centre pane U-value and the Psi value of the spacer bars (see below). It is likely although

not confirmed that U-values will be lowered in April 2014. If a U-value is not required due to

conservation exclusion then CE marking will not be required either.

Most ‘Bespoke’ windows WILL require a U-value as they are not truly bespoke. (Truly bespoke

windows will be exempt from requiring U-value and therefore CE marking.)

Most joinery companies use standard section sizes. If the manufacturer has used the same section

size before then the item is NOT bespoke and if the manufacturer uses the same section size again

then subsequent windows of that section size are not bespoke either.

See also http://www.bwf.org.uk/assets/ce-mythbusting-factsheet-may-2013v3.pdf for a more

comprehensive factsheet.

CE Marking 3 | P a g e

© Coastal Specialist Ironmongery 2013

Connectin

g C

raftsm

ansh

ip w

ith S

olu

tions

What items need to be covered by CE Marking? In relation to CE Marking for external doors and windows, the three areas that need to be cared for

are as listed below.

Hazardous Substances

U-values

Safety Devices

Hazardous Substances

This is quite an easy issue to overcome. It is very unlikely that you will be selling a window or door

set that is likely to cause harm to passers-by and people in contact with it. In reality a window does

not give off toxic gases or spray harmful liquids so as already mentioned, an easy one to comply

with.

U Values

This is an area which has been brought up before and most joiners would have had windows tested

for U-Values previously. With this being the case, it should be something you already have in place

so once again should be any easy aspect to achieve.

The requirements for U-Values as of 1st July 2013 are shown below:

Fitting (a) Standard for new fittings in new dwellings

(b) Standard for replacement fittings in an existing dwelling

Window, roof window and roof light U-Value = 2.0W/m²K

U-Value = 1.6W/m²K or Window Energy Rating = Band C

Doors with more than 50% of their internal face area glazed 2.0W/m²K

1.8W/m²K (or exempt if fitted into existing door frame)

Other doors 1.8W/m²K 1.8W/m²K (or exempt if fitted into existing door frame)

There a few aspects that can help achieve your U-Values. Coastal’s Tempo/Deventer weather seals

carry their own CE testing and have been tried and tested, and have passed time after time for

Current U-Values. Indeed, the Tempo SP Performance Weatherseals are now been used extensively

in PassivHaus projects in the UK and abroad.

Note that the full window or door U-value is NOT the same as the centre pane value and should

take into consideration the timber type, section size, overall size, spacer bar and materials used.

There are various methods of calculating the U-value including testing of sample windows, or

calculation by a competent person in accordance with BS EN ISO 10077-1:2006 Thermal

performance of windows, doors and shutters – Part 1.

Safety Devices

The only items that currently need to have testing certificates for CE marking are those items

deemed to be a safety device. The main fittings that fall into this category are the restrictors.

Coastal are currently in the throes of getting all their restrictors tested and as soon as this

information is available it will be cascaded for all joiners to use in their DOP. Window restrictors, if

sold as a safety device need to be tested to have a load bearing capacity of 350N push value in

accordance with BSEN 14351.

CE Marking 4 | P a g e

© Coastal Specialist Ironmongery 2013

Connectin

g C

raftsm

ansh

ip w

ith S

olu

tions

What hardware needs to be tested to comply with CE marking? The answer to this question is basically answered in the previous Question. Hinges and other

hardware do not need a DoP or certification unless they contribute to any of the three items as

previously mentioned (Hazardous Substances, U-Values and Safety Devices). The Tempo/Deventer

weather seals do have a CE certificate which you can download from http://coastal-

group.com/WP/tempo_cecertificate.pdf

What is a DoP, and what should it contain? By making a DoP the manufacturer, importer or distributor is assuming legal responsibility for the

conformity of the construction product with its declared performance. DoPs must be publicly

available.

Where minimum or maximum values have been set in the technical specifications, these need not

be repeated in the DoP. Classes of performance may be declared within the DoP, with the key to

the classes appearing in the technical specification. A detailed knowledge of the technical

specification is therefore often needed.

Where a parameter is covered in the hEN or ETA, it is not permissible to quote any results obtained

for that parameter using a different test method or different units.

Together with the technical specification, the DoP should give all the information needed by

specifiers and regulators to judge whether the product meets all relevant regulations in the

Member State upon whose market it is to be placed.

Provided that the manufacturer has met the requirements of at least one characteristic in the

declaration of performance they are not required to determine and/or declare values relating to

characteristics for which regulations do not exist in the chosen market sector (i.e. Member

state/intended use). In these cases, a declaration of ’no performance determined’ (NPD) may be

made, as provided for in the hEN.

Does Coastal Joinery Hardware sell CE marked restrictors? Coastal are currently in the process of getting all their window restrictors tested and as soon as this

information is available, it will be cascaded for all joinery manufacturers for use in their DoP.

CE Marking 5 | P a g e

© Coastal Specialist Ironmongery 2013

Connectin

g C

raftsm

ansh

ip w

ith S

olu

tions

Why bother? A Potential €5,000 fine or imprisonment should be a good reason why to bother.

CE marking will be enforced not by building regulations but by Trading Standards Services. If an

enforcement body finds your product does not meet CE marking requirements, they will often

provide you with an opportunity to ensure it is correctly marked. If you fail to comply with this, you

will be obliged to take your product off the market.

You may also be liable for a €5,000 fine or imprisonment.

The plastic industry will be complying with the new regulation and if timber window and door

manufacturers do not comply sales opportunities and market share will be lost to the plastic

industry.

Joinery manufacturers should see that the ability to comply with legislation, whether enforced or

not, is a key sales tool for joinery manufacturers to compete and sell their products.

CE Marking 6 | P a g e

© Coastal Specialist Ironmongery 2013

Connectin

g C

raftsm

ansh

ip w

ith S

olu

tions

What’s next? It isn’t as hard as you think... But the situation shouldn't be ignored.

1) Download the FPC Template Manual from http://www.bwf.org.uk/publications/ce-marking

and adapt to suit your firm

2) Download the template DoP and complete for your products

3) Decide on a labelling system, purchase labels and apply.

Trade bodies such as The British Woodworking Federation (BWF) have a lot of helpful advice on the

implications of CE Marking. Visit www.bwf.org.uk/toolkit/ce-marking or call the technical team on

0844 209 2610.

Another solution is to use the Joinery Management Software (JMS) from Joinerysoft, which provides

manufacturers with a complete factory control system which will help to ensure that you comply with both u-

value and CE marking regulations with ease. Visit www.joinerysoft.com or call 01608 643302 for more

information.

Coastal Group

Global House, Bojea Industrial Estate, Trethowel, St Austell, Cornwall PL25 5RJ

While every attempt has been made to ensure the accuracy and completeness of the information in this document, some typographical or

technical errors may exist.

Coastal Specialist Ironmongery cannot accept responsibility for customers’ losses resulting from the use of this document. The information

contained in this document is subject to change without notice.

This document contains proprietary information that is protected by copyright. This document, in whole or in part, may not be photocopied,

reproduced, or translated into another language without prior written consent from Coastal.

Coastal Group is at the leading edge in joinery hardware. Customer care and quality are at the core of everything we do – you can be confident

that a call to Coastal will be the only call you need to make for all your joinery hardware needs.