The Danish Enterprise and Construction Authority to inspect CE marking of windows and pedestrian doors

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1 23. december 2010 The Danish Enterprise and Construction Authority to inspect CE marking of windows and pedestrian doors The Danish Enterprise and Construction Authority s market surveillance of construction products ensures that products marketed and sold in Denmark are safe and not detrimental to health. At the same time, it is also important to contribute to fair market competition. From the beginning of November 2010 until the end of February 2011, the Authority will focus on CE marking of windows and pedestrian doors. From 1 February 2010, it became mandatory to CE mark windows and pedestrian doors. During the months of November and December, the Authority informed manufacturers and distributors of the applicable rules and of the upcoming inspection, as well as the implications if the rules are not met. Where will the inspection of windows and pedestrian doors be carried out? Market inspections of windows and doors will be carried out at the premises of builders merchants and manufacturers. The Enterprise and Construction Authority will not be able to inspect all sales points but unannounced inspections will take place. The unannounced inspections will take place all over Denmark. Maybe we will come to see you! The inspections will be carried out during January and February We are going to request documentation for the CE marking, and we will check if the windows meet the requirements of the Danish Building Regulation (BR10). What is subject to the CE marking requirement? The harmonised product standard EN :2006+A1:2010 "Windows and doors - Product standard, performance characteristics - Part 1: Windows and external pedestrian doorsets without resistance to fire and/or smoke leakage characteristics identifies the windows and doors to be CE marked. Examples include: windows; roof windows; terrace doors;

2 2/6 external pedestrian doorsets; unframed glass doorsets; doorsets for escape routes; window and door sections; The product standard published by Danish Standards also describes how to determine the characteristics to be declared in connection with CE marking. For further information on the standard, visit Danish Standards website Chapter 7 of the Danish Building Regulation sets the requirements for the characteristics of pedestrian doors and windows. Remember that as from 30 December 2010 only BR10 applies, which means that after this date the solar factor (g) and light transmittance (tauv, former LT) of standard glazing must also be declared. What is CE marking of a construction product? The CE marking requirement has been introduced to facilitate cross-border trade in construction products and to contribute to an efficient internal market for construction products. If a harmonised standard or a European Technical Approval covering your construction product exists, the product must be CE marked. CE marking of a construction product is neither an approval and nor a quality stamp, but may be described as a labelling providing information on the characteristics of the construction product. A characteristic has been determined based on the same method in all of the EU; Manufacturers are subject to the same requirements for production control; Manufacturers are subject to the same requirement for third party monitoring. Therefore, it is possible directly to compare different manufactures of the construction product which is needed. This way, you can choose the product most suitable for your building. CE marking is a travel pass, which makes it possible for a construction product to cross borders without having the authorities stopping it with a requirement for further tests. It is allowed to market your construction products in all EU and EEA countries, but there is no guarantee that application of a specific product is permitted. This is stipulated in national Danish legislation, e.g. the Building Regulation (BR10).

3 3/6 In Denmark the following is laid down: which of the characteristics mentioned in Annex ZA1 of the product standard must be declared; the value for the characteristics. BR10 requirements may result in a need for e.g. a window with a particularly good heat insulation performance (U W or Eref). The manufacturer has the responsibility for the CE marking, but the designer, contractor, purchaser, project supervisor and client also have a responsibility to use CE marked construction products. What should manufacturers be aware of? CE marking is mandatory, also if a manufacturer only produces and markets for the domestic market. You are to find the standard that covers the construction products that you manufacture. If you are in doubt, you can submit a product description at and within 24 hours you will receive an answer informing you which standard is applicable for your product. CE marking is based on 2 main principles for attestation of conformity. 1. ITT (Initial Type Testing). 2. FPC (Factory Production Control), which is the manufacturer s own production control. ITT is the initial type tests, which define the characteristics of the construction product. The relevant standard describes how these are tested or calculated. FPC is the production control (quality management), which ensures that your construction product continues to conform to the characteristics determined in connection with ITT. Windows and pedestrian doors belong to attestation levels 1, 3 or 4 depending on the intended use. The tasks that you as a manufacturer must carry out before CE marking your windows and pedestrian doors are stated in the below table. System for attestation of conformity

4 4/6 Tasks under the responsibility of the manufacturer Initial Type Testing (type testing, ITT) Factory Production Control (FPC) Further testing of samples taken at the factory EC declaration of conformity /technical documentation CE marking Tasks under the responsibility of the notified body Initial Type Testing (type testing, ITT) Certification of production control (EC Certificate) Monitoring of production control Audit testing of samples Relevance for windows and pedestrian doors Whether or not a notified body is involved, you are to place the CE label on the product or on the related documents. You are to prepare a declaration of conformity, where you confirm that the requirements of the product standard have been met. It is important that the CE label accompanies the product, otherwise it may be rejected at the construction site. Furthermore, it is important that consistency exists between the CE marking and marketing of the products. What should designers be aware of? Special attention should be paid to: specifying the right requirements for the construction product; the fact that several of the characteristics declared in connection with the CE marking are to be applied in the design process;

5 5/6 the fact that the Danish requirements for the complete building are defined in the Building Regulation (BR10). It is not an option just to state that all construction products shall be CE marked. It is necessary to assess whether the CE marking has become mandatory for the individual construction product. What should a distributor/purchaser/importer be aware of? If you purchase windows and pedestrian doors, you must pay special attention to the following: that windows and doors are CE marked; that windows and pedestrian doors must meet the legal obligations for the complete building. These have been specified in the Building Regulation (BR10). What should a contractor be aware of? As a contractor you have the responsibility to use legal construction products. Consequently, special attention should be paid to the following: what the designer has stated in the project description; that you must purchase CE marked construction products, when it is mandatory to use CE marked products; that the Danish requirements for the complete building are defined in the Building Regulation (BR10); good offers these also have to be CE marked! Therefore, it is a good idea to carry out an inspection on receipt, so that any faults and imperfections are discovered, before the product is built into the building. What is requested in connection with the market surveillance in relation to documentation for compliance with BR10? When marketing products for use in new buildings, annexes and altered application, documentation for both Eref and Uw for windows and roof windows will be requested in connection with the market surveillance. For pedestrian doors, documentation for U D is required. As for reconstruction/replacement, Eref for windows and roof windows as well as U D for external pedestrian doors must be documented.

6 6/6 For application in holiday cottages, U W for both windows and roof windows and U D for pedestrian doors as well as Eref for windows and roof windows are required. U W is required for both windows and roof windows and U D for pedestrian doors for application in pavilions. Please note that requirements for Eref are for a reference size, while U W requirements apply to the actual size! For the application of windows in workrooms, a declaration of the light transmittance (tau V ) of the glazing is required. Sanctions In practice, the Danish Enterprise and Construction Authority will divide the sanctions into 3 categories: 1. a request At the inspection, you will be requested to provide the correct CE documentation within a defined time period; 2. a yellow card If there is no response to the request, or a written notice on providing the correct CE documentation is received immediately after, it may be necessary to discontinue the work until the matter has been rectified. 3. a red card can be given instantly or if a yellow card has been disregarded In this case, you may be subjected to: a request to provide documentation; scrutiny of documentation by experts; tests in an approved laboratory; stopping work at the building site; a police report and a fine. The sanctions are thoroughly described in Regulation 1075, Statutory order on the marketing, sale and market control of construction products.

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