Re:- CE marking of Construction Products Regulations
Mansfield Steel Services Ltd is a fabrication company involved in the manufacture, supply and installation of various types of shelters, canopies, walkways and street furniture. In Feb 2013, in response to the then forthcoming incorporation of structural steel and aluminium products within the scope of the regulations for the CE marking of Construction Products, the Company carried out investigations as to whether its product range came within the scope of the requirements of the regulations.
Initial enquiries were carried out through BRE at that time, and it was made clear that the requirement only applies where the particular product is covered by a Harmonised European Standard or European Technical Assessment. The only standard to have potential relevance to the Company’s product range is BS EN 1090-1 and 2, which details requirements for structural metal work. The product range offered by the Company is considered to be secondary, rather than structural metalwork, in that the integrity of the building structure is unaffected by the removal of the Company’s product, and provides no structural support to any other component of the building.
Additionally, it would appear that bespoke products are not covered by the CE marking requirements. The canopy and walkway range supplied by Mansfield Steel Services Ltd is in virtually all cases a bespoke manufacture for the particular building or project that it is being supplied for.
The following is taken from L 88/12 EN Official Journal of the European Union 4/4/2011
Derogations from drawing up a declaration of performance By way of derogation from Article 4(1) and in the absence of Union or national provisions requiring the declaration of essential characteristics where the construction products are intended to be used, a manufacturer may refrain from drawing up a declaration of performance when placing a construction product covered by a harmonised standard on the market where:
(a) the construction product is individually manufactured or custom-made in a non-series process in response to a specific order, and installed in a single identified construction work, by a manufacturer who is responsible for the safe incorporation of the product into the construction works, in compliance with the applicable national rules and under the responsibility of those responsible for the safe execution of the construction works designated under the applicable national rules”
We consider our manufactured product to have a temporary lifespan, and as such, in our view, is not applicable to the Construction Products Regulations outlined by the BS EN 1090-1 which describes work for incorporation into buildings or structures that are placed in a permanent manner
The Company has revisited the subject on numerous occasions, and as yet cannot obtain any authoritative, definitive information providing clear guidance on CE marking for the specific product range supplied by the Company.
We realise that the Client and/or the Main Contractor has the sole responsibility regarding CE marking compliance, if your Company stance remains that CE marking is a requirement for a particular project, we will unfortunately have to decline acceptance of any orders for such works.
Mansfield Steel Services Ltd has a strong reputation and long history of providing quality products and services, and has quality systems and procedures in place to ensure consistency, reliability, and traceability across its product range, reinforced by a 10 year guarantee on the structural integrity of all products.