On your marks
Trade barriers across Europe are being removed, but architects must keep an eye on manufacturers' compliance criteria CE marking is one of those pieces of legislation that has been around for ages but is now just about to spring out on an unsuspecting industry.
In the UK, the Construction Products Regulations came into force in 1991 and the CE marking directive in 1995. Both are intended to harmonise technical and performance standards across the European Union, where national standards currently prevail. For example, DIN (Germany), AFNOR (France) and BS (UK) are all individually reliable but do not always translate across borders.
By developing a set of standards which can be relied upon across the board, specifiers' lives should be made easier.
Building Standards were set up in the UK in 1901. In 1903, the government provided a grant for the National Standards organisation. In 1946, the ISO was established to produce world-wide standards.
Competition for national advantage, however, has been seen by some as providing something of an incentive to improve products and steal a march on foreign suppliers. The introduction of the harmonised standards will challenge de facto protectionism and apply to trade to, from or within member states of the European Economic Area (EEA) as well as those states in the European Free Trade Association (EFTA). It will apply, for example, to more than 50 per cent of all goods currently exported from the US to Europe.Any manufacturer with CE marked products cannot have them refused entry to EEA markets on technical grounds.
However, even if compliance is demonstrated by affixing a CE mark to a product, it might still be barred - legitimately - because the product might not suit the particular climatic or locational peculiarities of where it is to be installed. For example, the DTLR (as was) cites an externally fitted product which 'may be fit for use in the drier, sunnier climes of the south, but may be entirely unsuited to the more inclement weather conditions of the north'. Therefore, within this relatively 'free-market' condition, national rules may be set by a given country to establish 'levels and classes' of performance which will put conditions on the acceptance of a given product.
CE marking will provide manufacturers with the opportunity to access foreign markets. For specifiers, the new regulations will mean that certain products which comply with national standards will not be allowed to be exported for use in other countries.
In the UK, cement is the only construction product which currently qualifies for CE marking, but the construction product directive (CPD) will apply to thermal insulation by 1 March 2003. By 2005, it is estimated that CE marking will be applied to more than 600 construction products.
Importantly, the EU-based testing methods will replace conflicting British Standards and these superseded British Standards will be withdrawn at this time. In order to comply with the new regime, some products may have to be modified by their manufacturers, although some others will probably have to be withdrawn completely.
Compliance criteria One of the main objectives of the CPD is to vouchsafe products in situ, that is, they should be certified as part of a construction as a whole, and not as an isolated product. This has meant that there are a new series of standards which have to be designed as benchmarks against which to judge their performance.
For CPD compliance, and to be eligible for CE marking, products which have been produced for 'incorporation in a permanent manner - in buildings, roads, bridges and other civil engineering works' - must show compliance in certain essentials:
mechanical resistance and stability; safety in the case of fire; hygiene, health and the environment; safety in use; protection against noise; and lenergy economy and heat retention.
Existing products will have to be retested to the new standards to demonstrate compliance with any, or all, of the above, provided that the test criteria are relevant to the material in use. If there is no requirement for acoustic performance, say, then that property need not be determined and declared by the manufacturer - this refers to insulation products, for example, which are marketed for their thermal properties only. Specific acoustic quilts will have to be tested for sound insulation qualities but not necessarily for thermal performance.
Unsurprisingly, the CPD does not apply to that rare group of products that: have no implications for health, safety or energy efficiency of construction works; or lwhere the product was supplied (in the UK) before 27 December 1991.
CE marking of construction products in the UK is not mandatory.
However, to legally export to other countries in the EU (excluding Finland, Sweden, Ireland and Portugal - which have also opted out), CE marking will be required. Architects will need to check compliance before specifying for, or from, foreign markets. Furthermore, EN 13162 states that, for insulation for example, the thermal performance of a product must be monitored over the course of a year; so in order to be compliant by the deadline date of March 2003, manufacturers - including composites' manufacturers - will need to have set their compliance testing criteria in motion now.
The table specifies the earliest date on which the CE marking may be applied to the thermal insulation product and the latest date from when CE marking becomes mandatory. For standards, the latest date (see case study above) corresponds with the date of withdrawal of any national standards that conflict with the European Standards.
External insulation composite systems and mechanically fastened systems, including roofing insulation products, must be CE marked.
Where such a kit is being CE marked, it is not essential that all the components are individually CE marked.
Thanks to Jon Bowdidge and Huw Evans at Rockwool for their assistance.
Contact tel 01656 862621
UNDERSTANDING THE JARGON
'The letters 'CE'stand for Conformite Europeene and were introduced in 1993 (Directive 93/68/EEC). CEN stands for European Committee for Standardisation. CE marking on a product is the manufacturer's declaration that the product complies with the 'essential requirements of the relevant European health, safety and environmental protection legislation by many of the so-called Product Directives'.
Product Directives are the 'essential requirements' and/or 'performance levels' and 'Harmonised Standards' are the technical specifications, to which construction products must conform.
'Construction product'means any product which is produced for incorporation in a permanent manner in construction works, including both buildings and civil engineering works.
lCE marking on a product indicates to governmental officials that the product may be legally placed on the market in their country (see main text for exceptions); ensures the free movement of the product within the EU single market; and permits the withdrawal of the non-conforming products by customs and enforcement authorities.
Notified bodies are the independent agencies that perform tests of compliance as set out in the directives.