A1S Group Policy When Quoting UKCA* or CE Marked Fire Shutters For our UK and European Customers
The UK Government have extended the UKCA deadline until 2025.
CE (now UKCA for the UK or UKNI for Northern Ireland) marking of all powered doors under the machinery directive has been mandatory since 1995. This has not changed.
The following represents a simplified compliance guide to fire shutter certification following the mandatory changes and additional requirements due to the Construction Products Regulation (EU) 305/2011 which is NOW (as of 01/11/19) a legal requirement in Europe. UK Construction Products Regulations 2013 apply in the UK. A1 Shutters Limited’s certification is valid in both the UK and Europe and our UK notified body has established a subsidiary in the EU27 to facilitate this process.
1. As per our internal policy, we will always ask a customer if they are fully aware of the new legislation? If they say yes, we reconfirm that they know manufacturers must be able to provide installers with a certificate of constancy of performance. (see below) Without this the install is illegal as the product cannot be UKCA/CE marked. It is the installer’s responsibility to check this and there are serious legal consequences for the installer if the product is not UKCA/CE marked or perhaps more relevantly, correctly UKCA/CE marked. We will always check what structure, usage requirement, fire performance and dimensions the customer needs for the shutter before quoting.
2. If a customer is not familiar with the new harmonised legislation, we will ask what structure the shutter is to be fitted to, what fire performance is required, how many times a day the shutter will be used (to determine the appropriate motor) and what are the dimensions. We will then explain the following. Fire shutters must be UKCA/CE marked. It is illegal to manufacture a fire shutter without a UKCA/CE mark. It is illegal to install the shutter without a UKCA/CE mark. It is illegal for an employer or landlord to use a shutter that is not UKCA/CE marked. To be able to UKCA/CE mark, the manufacturer must go through the following process in its entirety.
3. Separate fire tests to flexible (timber stud) and rigid (steel/masonry) structures are now mandatory. If a manufacturer does not have any tests they cannot manufacture any fire shutter. If they have one test they can only manufacture a fire shutter for that end use, and the installer can only install to that one type of structure. The A1S Group has tested successfully to both flexible and rigid structures.
4. Following the test an extended application MUST be provided by a notified body, i.e. Warrington. Certification must also be registered with an EU 27 notified body to be able to CE mark. Without an Extended Application, variant sizes on those tested CANNOT be manufactured. The document looks like this.
If a manufacturer cannot provide an EXAP, they cannot UKCA/CE mark so again the products are illegal and cannot be fitted or used. At the back of the EXAP are 12 pages of permissible sizes against structure and fire performance. Fire performance can be up to 240 minutes depending on the structure, and dimensions. If the required structure, size and performance is not on the EXAP, the product cannot be made. The matrices must be checked on every occasion. They look like this. If the matrices do not have a section for fitting to timber stud, the product CANNOT be used for such a structure and it is the responsibility of the installer and the end user to verify the manufacturer’s certification.
5. Factory audits are then required. No audits, no UKCA/CE mark.
6. Next, a Certificate of Constancy of Performance is granted to the manufacturer to verify fire resistance characteristics. It looks like this.
If a manufacturer cannot provide this document, the shutters are illegal as they cannot be UKCA/CE marked. There is absolutely no wriggle room and this document which can take many months to obtain following the test, audit and extended application process MUST be held at point of commissioning.
7. We must provide end users and installers with a Certificate of Conformity and a Declaration of Performance. Essential characteristics covered by EN BS 13241 and EN BS 16034 will always be cited on this document. This declaration can only be given by a company with the testing, extended application and certificate of constancy of performance in their name from a notified body, i.e. Warrington Fire. The certificates look like this. Variants now include UKCA and UKNI against the UK Construction Products Regulations 2013 as well as CE marking against Construction Products Regulation (EU) 305/2011.
8. All fire shutters must be UKCA/CE marked with a label against the relevant essential characteristics of both EN BS 13241 and EN BS 16034:2014 as well as the long-standing Machinery Directive. The UKCA/CE Marking label looks like this.
To conclude, as a company, we will always
1) Demonstrate proof of testing to both or the relevant flexible or rigid structure.
2) Reference our extended application matrices to confirm the shutter can be legally manufactured to the correct dimension, structure and fire performance.
3) Attach our certificate of constancy of performance to our quotation. This has been awarded because all other stages are completed along with requisite factory visits.
4) Provide our manufacturer’s declaration of performance and a certificate of conformity.
5) Finally, a correctly applied UKCA/CE label citing the machinery directive, BS EN 16034: 2014 and BS EN 13241 : 2003 + A 2 :2016 will be attached to every shutter. Audit is required from in our case Warrington Fire to confirm use of UKCA marking.