Article by SSS Industrial Doors Ltd
Why do fire shutters need to be CE marked?
All manufacturers of roller shutter products and components must supply the correct documentation and assessment data for CE marking to be applicable. It has been a compulsory requirement for CE marking of roller shutters since the introduction of the Machinery Directive 1995. However, this regulation was not appliable for fire roller shutters.
Under the Construction Product Regulations (EU) 305/2011, the legislation requires “assessment and verification of constancy of performance for essential characteristic” of the product is a requirement. A standard roller shutter comes under the scope of AVCP system 3 and therefore does not require additional testing data and can simply be CE marked and referenced within manufacturers Factory Product Control file (F.P.C). A fire shutter on the other hand comes under the scope of AVCP system 1. Therefore, it is a necessary requirement that a notified body audit test the manufacturer prior to the furnace test being considered (BS EN 1634-1). Once the notified body observes a successful completion of the furnace test, a certificate of Constancy of Performance is provided. This certificate allows the manufacturer to produce, supply and install their fire shutters within the UK marketplace.
Since the 1st November 2019, new legislation was introduced regarding the manufacturing, testing and installation of fire shutters. It is now a mandatory requirement that all fire shutters must be CE marked to BS EN 16034:2014 under the Construction Product Regulations (EU) 305/2011. The previous standard BS 476 part 22 (1987) is now a non-compliant and cannot be sold on the UK marketplace.
The testing methodology for fire shutters has altered slightly, the furnace test (BS EN 1634-1) is a compulsory requirement which is observed and recorded by a notified body. A manufacturer of roller shutter products and components must supply the correct documentation and assessment data for CE marking to be applicable.
What is CE marking?
The CE mark is a conformity mark that is recognised worldwide. Primarily, the CE mark is only applicable within the European Economic Area (EEA). However, some countries also accept CE mark products due to the manufacturer’s declaration which states the product meets the EU standards for health, safety and environmental protection requirements. The CE mark is not a quality indictor for the product(s) or a certification mark.
As a result of the United Kingdom’s referendum in 2016, which took place on the 23rd June 2016. The United Kingdom and Gibraltar asked the electorate whether the country should remain within the European Union as a member state or leave. The people of the United Kingdom voted to leave the European Union. Therefore, on the 31st January 2020 the United Kingdom left the EU27.
Will CE marking still be applicable after the UK has left the EU27?
From the 1st January 2021, the United Kingdom will leave the European Union with or without a potential agreement. As a result, CE marking will no longer be recognised within the UK marketplace after the transition period between January 2021 and January 2020. It will be replaced by the United Kingdom Conformity Assessment mark, commonly referred to as UKCA mark.
UKCA marking will still be applicable for goods currently subject to the CE marking. The technical requirements (‘essential requirements’) for the conformity assessment processes and standards will still be required. The previous EU standards will become ‘designated standards’ within the UK marketplace and therefore will still have relevance and be required.
All CE marked fire shutters manufactured within the United Kingdom will be recognised and legally compliant up until the end of the transition period. Once this date has passed, it will be necessary for fire shutters to be UKCA marked.
All notified bodies, such as WarringtonFire, within the UK which were previously EU notified bodies will no longer be recognized. They will however be recognized as UK notified bodies and will be able to provide UKCA marked certification.
SSS Industrial Doors Ltd have pro-actively transferred their certification (BS EN 16034) from WarringtonFire Ltd (UK) to Elements Materials Technology (Rotterdam), which is the subsidiary company based within the Netherlands. As a result of transferring the fire certification, SSS Industrial Doors Ltd will be able to continue to CE mark fire shutters regardless of any potential agreement between the UK and EU27. WarringtonFire will also be able to supply UKCA marked certification once the transition period has begun.
Is it possible to identify if a manufacturer can supply CE marked fire shutters?
BS 476 part 22 (1987) is no longer a recognized standard and is non-complaint. If a fire shutter does not have a valid conformity mark (CE marked) it is illegal to be manufactured, distributed and installed within the United Kingdom.
Any manufacturer of compliant fire shutters will be aware of the testing procedure(s), documentation and regulations which are necessary for CE marking a fire shutter. Prior to purchasing a fire shutter, it is recommended that the customer request a copy of the certificate from the notified body which states BS EN 16034, ‘Declaration of Performance’ and ‘Certificate of Constancy of Performance’. Failure to provide the following documentation is evidence of non-compliant fire shutter.
The notified body, who provided the manufacturer with the certification, will be to confirm the validity of the certificate if required. Also, the ‘Declaration of Conformity’ will clearly state the classification of the fire shutter and include the certificates reference number.
Can a fire shutter be CE marked if it is installed on a different structural type than that which was tested?
A fire shutter is tested to BS EN 1634-1 at a notified body testing facility. However, due to the limitations of the testing facility it is not possible to test fire shutters that are installed on larger applications. Therefore, the notified body use data collated from the furnace test and calculate the necessary components required to increase the size of the fire shutter or integrity rating of that which was tested. The Extended Application Report (BS EN 15269-10), commonly referenced to as the EXAP report, is calculated by the notified body and provides the manufactured with critical information on the components required for manufacturing fire shutters.
If a fire shutter was originally tested to a masonry (rigid) structure, then the manufacture can only supply fire shutters which are intended to be installed masonry structural type. The same applies to fire shutters tested to a timber (flexible) structure. If a manufacturer cannot provide the additional test data for both structural types, then they cannot fully CE mark the fire shutter.
SSS Industrial Doors Ltd recommend that any contractor/installer should ask to see the additional test data as evidence that their fire shutters are tested to both timber and masonry structural types.