BWF Technical Director, Kevin Underwood provides important information regarding changes to CE marking and which products this will apply to in the woodworking sector.
It is the UK Governments intension to legislate to end the recognition of the CE marking for construction products from the 1st of January 2023. If the appropriate legislation is laid, manufacturers of construction products which require to be conformity marked for the Great Britain (GB) markets, i.e. England, Wales and Scotland, will have to apply the UKCA marking as the CE marking will no longer be accepted.
For the woodworking industry these products will be external doorsets, including fire rated external doorsets, windows, garage doorsets, industrial and commercial doorsets, and wood flooring. It is worth noting that internal doorsets and internal fire rated doorsets cannot be conformity marked. Conformity marking only applies to complete assemblies or kits and does not apply, for example, to door leaves or replacement casements or sashes for windows. The legislation will also not apply to truly bespoke products that are produced to a customer’s order for use in only one building. Products that are produced to a repeated design or system are not exempt. Some materials and components that are used by the woodworking industry, for example, glass units and some hardware, will also be affected by these changes.
For manufacturers in Northern Ireland (NI), the CE mark will still be accepted as will the CE & UK(NI) marking and, for products produced in Northern Ireland with either of these marks, there will be unfettered access to the GB markets. Goods with the UKCA mark alone are not accepted on the Northern Ireland market.
The Government advice is that businesses manufacturing products construction products must prepare for the end of recognition of the CE marking in GB and affix the UKCA marking by complying with all relevant requirements under the Construction Products Regulation 2011 as retained in UK law.
The Government has published separate guidance on the Construction Products Regulation in Great Britain and Northern Ireland and it is important that manufacturers of construction products access the most appropriate information
For the GB markets, https://www.gov.uk/guidance/construction-products-regulation-in-great-britain
For the NI market, https://www.gov.uk/guidance/construction-products-regulation-in-northern-ireland.
The Government has not provided guidance itself for those woodworking manufacturers who wish to supply construction products to the European Union (EU) market, stating that it is for the EU to determine the arrangements that apply.
From the 1st of January 2023, should the Government legislate as they intend to, it will become important whether any testing or certification that has been, or will be, carried out to determine the performance of a construction product, was undertaken by either an EU body or a UK body as there will be restrictions in the use of evidence for the UK markets. For example, historic test evidence undertaken by an EU body before the 31st December 2022 will remain acceptable for the UK market but after that date, any new test evidence would have to come from a UK body.
When searching for guidance on the gov.uk website it is important for the manufacturers of construction products to only consider information that is relevant to construction products. The UKCA, CE and UK(NI) markings can be applied to a range of products and the rules around the use of the markings and their meaning will be different. For example, some furniture products will be regulated under the General Product Safety Regulations 2005.
It is important for the manufacturers of construction products to ensure that they comply with the relevant legislation and apply the conformity markings appropriately as the UK (GB and NI) has powers to carry out market surveillance and enforcement (Trading Standards in GB and district councils in NI) to ensure that non-compliant products can be removed from the UK market.
Contact Kevin Underwood kevin.underwood@bwf.org.uk if you have any questions concerning the topic covered in this column.
