CE marking translated

The september deadline for mandatory CE marking is here

We often use words and phrases long after we have forgotten their origins. One example, straight from the horse’s mouth, refers to examining a horse’s teeth to determine its age, thus providing reassurance to the buyer before making the purchase.

With the language used in European standards and CE marking, it is often the meaning as well as the origin that is not known. It seems a new language has evolved, eurojargon.

Learn the lingo

Terms such as, initial type testing, essential requirements and system of attestation of conformity might lead a cynic to conclude that they have been made deliberately difficult to understand.

Informatics, a word used in a recent document emanating from Brussels, had me looking in the Oxford English Dictionary.

Perhaps, then, it is no surprise that when CE marking began for glass products in September 2005, the industry appeared underwhelmed by it. If this process can be dejargonised, it will help to foster a better understanding, and acceptance of CE marking.

In very broad terms, a manufacturer must demonstrate that his product complies with a European-wide standard. This must be done through one-off external testing and on-going production control. When the product is compliant, the manufacturer makes a legal and transparent declaration, which allows CE marking of the product. It can then be sold in the European Union.

Industry relevant

Informatics, a word used in a recent document from Brussels, had me looking in the Oxford English Dictionary

It could be argued that there are two types of standards relevant to CE marking, harmonised European norms and supporting standards.

Harmonised European norms, (hENs) are considered mandatory. They are usually referred to as ‘Part X: Evaluation of conformity’ or ‘Product Standard’ and include details on how the product is expected to conform. An example of a hEN for glass is EN 1096-4 for coated glass.

Supporting standards, usually referenced in hENs, can provide definitions, characteristics, generally accepted values, calculations or test methods for product performance. An example of a supporting standard for glass is EN 12600, which details the test and classification method for pendulum body impact resistance.

The first group of hENs were applicable from 1st September 2005 and covered products like basic soda lime silicate (float, wired, patterned and channel-shaped glass), coated (on-line and off-line), toughened and heat-strengthened glass. These standards are mandatory from 1st September 2006, which is the end of the transition period.

The second group of hENs, which cover products such as laminated glass, heat soaked toughened glass and insulating glass units, applicable from 1st March 2006, will become mandatory on 1st March 2007. The hENs for glass in building and their key dates are shown in table 1.

External testing, or initial type testing (ITT), in eurojargon, represents two aspects: proving the product is the product and demonstrating claimed performance for certain characteristics, for example pendulum body impact resistance.

ITT must be undertaken by a third party, or notified body, but may not involve actual testing. For some characteristics, ITT may be in the form of calculations or generally accepted values. For others, it may be possible to pass on the information from the supplier, if it remains unchanged.

Factory production control is in three stages: material, production and product control. Material control covers the materials used to manufacture the product and may consist of simple visual checks on the incoming materials or cross checks against the purchase specification. Production control is process control and is covered by standard operating procedures. Product control concerns the product after manufacture and may involve visual checks, inspections and measurements.

It is the manufacturer’s responsibility to demonstrate that
his product meets hEN requirements

Most of what needs to be controlled or checked in the factory is likely to be common practice already. However, it is important that a manufacturer obtains a copy of the product standard.

It is the manufacturer’s responsibility to demonstrate that his product meets the relevant hEN requirements. Membership of a national third party voluntary mark scheme does not automatically cover all the responsibilities of evaluating conformity.

As an added complication, UK and Ireland are two of the four member states that have decided not to make CE marking mandatory, however, meeting the requirements of the hEN is still necessary. We will have to wait and see what this actually means in practice. Certainly companies selling products in several EU member states, as well as those importing into the UK and Ireland, will CE mark their products.

Internet answers

Since September, experience indicates that glass manufacturers are using the internet to deliver the full CE marking information, including all the declared values. It took them a long time, but the European Commission appears to have recognised that the internet exists and accepted the principle of electronic CE marking. The thought of a piece of paper being generated every time an insulating glass unit is manufactured in Europe is a scary thought. An example of the way in which glass manufacturers are approaching CE marking can be found on the Pilkington website at www.pilkington.com/ce.

GEPVP, the European trade association for flat glass manufacturers, has issued a series of CE marking guides. These documents can be downloaded free from www.gepvp.org.

Pilkington has also set up a dedicated email address, CE.marking@pilkington.com in order to respond to queries on CE marking and European standards.

This is a simplified gallop through the basics of CE marking for glass products. Of course, the devil is in the detail. I wonder what the origin of that phrase was?