CE Marking is less than three months away

There is a lot of confusion within the industry about what is required, so the BWF is working to dispel the myths and help the industry get ready.

Questions and Answers

What needs to be CE Marked from 1 July 2013?
Any construction product covered by a Harmonised Standard. For joinery manufacturers this means Windows and external doorsets, wood flooring, garage doors, shutters, gates, cladding and in some instances panelling. CE Marking is not yet required for internal doorsets or staircases.

What do I need to do for CE Marking?
Most companies will need to do three main things to comply:
• Set up a factory production control (FPC) system
• Provide a declaration of performance (DoP) for each product
• Physically label your products with the CE Mark

How do I set up Factory Production Control (FPC)?
The FPC document is intended to show there is consistency in your production method. The BWF provides a free template, which can be easily customised to an individual business, and using the template will help ensure all the key areas are covered.

Your FPC system does not need to be audited by the BWF or any other organisation for the purposes of CE Marking.

The BWF also offer a chargable FPC consultancy service, where an expert will help implement your system in your workshop.

Do I need FPC if I have ISO 9001?
No, the ISO 9001 standard is more comprehensive than FPC. So as long as the certification covers your production, you will not need a separate FPC system.

What do I need for the Declaration of Performance?
A Declaration of performance (DoP) should include the ‘essential characteristics’ as defined by the harmonised standard (eight for windows and 11 for doorsets) and as a minimum the three “essential characteristics” mandated by the building regulations.
In the case of windows and external doorsets the three essential characteristics are:
• thermal (u-value)
• dangerous substances
• load bearing capacity of safety devices
So long as you do not promote it elsewhere, you can list “no performance declared” for other “essential characteristics”.
A template DoP is available on the BWF website.

What is required for labelling?
You must display the CE mark with your product, and it can be done in one of the following ways:
• On the window/doorset—this could be on the glass, or hidden in the close of the window or on the frame of a doorset.
• With or on the packaging—place the CE mark on the wrapping of each product or provide an accompanying document
You also have the option of providing a link to your website with the full DoP information.
The BWF can offer a range of labelling options for windows and external doorsets if required.

Are there any changes to what U-Value I must declare?
There are no changes to the u-value requirements, which remain 1.6W/m²K for windows and 1.8W/m²K for doorsets in line with current building regulations.
However, If your business has 10 or more employers OR an annual turnover > €2m, your u-value calculation must be accredited by a ‘notified body’. If you’re unsure if your u-value calculations are “accredited”, the BWF technical helpline can advise.

I do bespoke work, do I need to CE Mark?
The definition of ‘bespoke’ can be difficult. Where products are made to ‘non-series’ specifications or made in a traditional, non-industrial way for heritage and restoration projects, CE Marking is not required. In all other cases CE marking will apply.

When do I need to start implementing CE Marking?
Any products made before 1st July, 2013 but sold from this date will need the new procedures and markings. You can CE mark your products ahead of the deadline, but failure to comply after July 1st could result in prosecution.

Further help
For further advice and help on CE marking, contact the BWF Technical Help Line on:

    Tel:    0844 209 2610
    e mail:    Kevin.underwood@bwf.org.uk
    web:    www.bwf.org.uk