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Construction Products Regulation and what it means for CE marking of flat glass

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Friday 17 May 2013

CE (Conformité Européenne) marking of construction products – including flat glass, glazing, architectural glass and ballotini for road markings - becomes compulsory from July 1st 2013CE (Conformité Européenne) marking of construction products – including flat glass, glazing, architectural glass and ballotini for road markings - becomes compulsory from July 1st 2013 and means major changes for many manufacturers and companies wishing to supply their products into or within the European Economic Area (EEA).

"We have been working with glass and glazing system manufacturers across the supply-chain to ensure that there are no interruptions or delays to the certification of their products. I also wish to thank NSG Group - who have been working with us for more than a year in preparation for these changes," says Dr Nick Kirk, Technical Director of GTS.

In this article Richard Cave, Technologist – Product Performance at Glass Technology Services Ltd (GTS), outlines the changes and the CE Marking "roadmap" for the flat glass supply industry. GTS is a centre for glass research, development, analysis and support services and one of only a few specialized providers to hold Notified Testing Laboratory status.

“The new Construction Products Regulation (CPR) shortly replaces the current Construction Products Directive (CPD) and means that after 1st July 2013, all glass used in construction or road markings within the European Economic Area (EEA) must be performance assessed (initial type tested) by a legally and technically independent notified testing laboratory. The CPR is enforceable across the European Union and applies to all construction products that are covered by a harmonized European Standard (hEN).” , explains Richard. 

Introduction to the Construction Products Regulation

The Construction Products Regulation (CPR, Regulation (EU) 305/2011), which although came into force on the 24 th April 2011, will completely replace the Construction Product Directive (CPD, Council Directive 89/106/EEC) as of the 1 st July 2013.

“The new CPR aims to create harmonised conformity for the regulation of construction products within the European Economic Area and its introduction results in some changes for manufacturers and processors of construction products covered by harmonised European Norms (hENs) – who have previously been able to self-certify or simply opt-out of CE marking their products.”, says Richard.

CE Marking

The main change for manufacturers (or companies wishing to sell within the EU/EEA) is that the CE marking of a construction product will be compulsory.  Until this change comes into effect the requirement in the UK was only to manufacture and supply the products to the EU standards including the appropriate AoC level without the need to add the CE mark.

CE marking can only be applied to products that conform to the requirements laid out in relevant harmonised European Norms (hENs) as defined by the European Commission’s New Approach Notified and Designated Organisations (NANDO) site. In order to demonstrate conformity, attestation of conformity (AoC) must be carried out. The level of AoC required is dependent upon how safety critical the product is.

Table 1: Attestation of Conformity Systems and Requirements;

Example:- Glass used for fire, bullet or explosion resistance are AoC level 1 and insulating glass units and glass used for impact resistance or burglar resistance typically toughened or laminated glass are AoC level 3.

 

Attestation of Conformity (AoC) System

1

1+

2

2+

3

4

Manufacturer Tasks

Factory Production Control (FPC)

 

 

 

 

 

 

Further Scheduled Testing

 

 

 

 

 

 

Initial Type Testing (ITT)

 

 

 

 

 

 

Notified Body Tasks

Initial Type Testing (ITT)

 

 

 

 

 

 

Certification of FPC

 

 

 

 

 

 

Surveillance of FPC

 

 

 

 

 

 

Audit Testing of Samples

 

 

 

 

 

 

Notified Bodies

Large pendulum body impact testing, UKAS accredited in accordance with BS EN 12600 under GTS' ISO:17025 accreditation To satisfy the requirements of AoC, a Notified Body is generally involved. Notified Bodies are appointed by the Member State in which they are based, after recommendation by that Member States’ National Accreditation Body (NAB), which in the case of the UK is UKAS – the United Kingdom Accreditation Service. Notified Bodies must satisfy the requirements laid out in the CPR, which includes providing evidence of legal identity, having appropriate quality systems and being competent to carry out the tasks required.

There are three types of Notified Bodies; Product Certification Bodies, Testing Laboratories and FPC Certification Bodies, each with a different remit under the CPR depending upon the AoC System being followed. The level of involvement of Notified Bodies in the AoC is determined by the level, with 1, 1+ and 2+ requiring substantial involvement; 2 and 3 requiring less; and 4 requiring no external involvement.

Determination of Attestation of Conformity (AoC)

To determine the assessment required, the AoC system requirement can vary within the same product. For example, thermally toughened soda lime silicate safety glass must confirm to EN 12150-2:2004. However it is its intended use that determines the AoC system that must be used.

Table 2: Examples of AoC System determined by Intended Use (EN 12150-2:2004)

Product example

Intended Use(s)

Level(s) or Class(es)

AoC System(s)

Thermally toughened soda lime silicate safety glass

For use in a glazed assembly intended specifically to provide fire resistance

Any

1

For uses subject to reaction to fire regulations

Euroclass A1*

4

For uses subject to external fire performance regulations

Products Requiring Testing

3

Products “deemed to satisfy” without testing

4

For use as anti-bullet, or anti-explosion glazing

---

1

For other uses liable to present “safety-in-use” risks and subject to such regulations

---

3

For uses relating to energy conservation and/or noise reduction

---

3

For uses other than those specified above

---

4

Therefore, to continue this example, if the intended use of the toughened glass was for insulating glass units (IGUs) where there was a potential for accidental human impact (taking into consideration Building Regulations Part K - protection from falling collision and impact, 2010), then “For other uses liable to present “safety-in-use” risks and subject to such regulation” would be the most appropriate option, thus requiring System 3 AoC.

Under System 3, the manufacturer (or their agent based in the EEA) is responsible for the preparation of the EC Declaration of Conformity, which requires the following tasks to be completed:

Table 3: Tasks for Manufacturer and Notified Body under AoC System 3 (EN 12150-2:2004)

Responsibility

Task

Manufacturer

Factory Production Control

Parameters related to all relevant characteristics.

Initial Type Testing

All other relevant characteristics, other than those to be determined by the Notified Body.

Notified Body

Initial Type Testing

External Fire Performance

Burglar Resistance

Pendulum Body Impact Resistance

Direct Airborne Sound Insulation

Thermal Properties

Radiation Properties

Declaration of Conformity and CE Marking

Once all tasks have been completed, the manufacturer will draw up the declaration of conformity which allows the CE marking to be fixed to the product. CE marking must be affixed in accordance with Regulation (EC) 765/2008.

Table 4: CE Marking Process

Determine Product Type

Define Intended Use

Selection of AoC System

Tasks for Manufacturer

Preparation of EC Declaration of Conformity

Affix CE Marking

Tasks for Notified Body

It is vital when commending the assessment of a product for the EU market, that the appropriate hENs and EU and local regulations be considered to ensure that the product placed on the market has the appropriate declaration of conformity for its intended use and the CE mark. Failure to do this can result in legal actions against manufacturers, their agents and/or Notified Bodies.

Specialist Knowledge in Glass

Glass Technology Services Ltd (GTS) is a Notified Test Laboratory (Notified Body Number 2461) under the CPR for the Initial Type Testing of glass products under AoC System 3. Characteristics currently assessed are pendulum body impact resistance, thermal properties and radiation properties of glass. Our test procedures are in accordance with relevant European Norms (EN 12600, EN 410, EN 673 and EN 12898) and are UKAS accredited. Enquiries for the assessment of other performance characteristics are welcome.

An independent specialist, GTS works across the glass supply chain providing laboratory and on-site testing and analysis for glass manufacturers, processors and manipulators, fillers, brand owners, retailers, architects, building contractors and consulting engineers. Its international client base is drawn from a wide range of markets including architectural and automotive, food and drink, pharmaceutical and technical, defence, photonics and biomedical.

For more information please visit www.glass-ts.com , email enquiries@glass-ts.com or telephone +44 (0) 114 290 1801.


Further Information and Guidance Relating to the CPR and CE Marking:

Information about CE marking, including guidance and additional resources, can be found on the EC Europa website at the following address: 
http://ec.europa.eu/enterprise/policies/single-market-goods/cemarking/

The CPR regulation and a list of harmonised standards that fall under this regulation can be found at the following address:
http://ec.europa.eu/enterprise/policies/european-standards/harmonised-standards/construction-products/index_en.htm


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