I had to do a bit of research on CE Marking for steel frames (and what it means for concrete) for one of our major projects so I thought I’d share the output. It’s not just for electronic goods now!
Summary
The EU’s Construction Products Regulation (CPR) requires:
- All steelwork products to have CE marking from 1st July 2013.
- All fabricated steelwork delivered to site to have CE marking from 1st July 2014.
This note summarises the key issues for engineers working designing projects in the EU.
- Prequalification statements and specifications will need to be updated to reflect this requirement.
- Clients and main contractors need to be aware of their obligations when appointing a steelwork contractor, especially if from outside the EU.
- Engineers need to specify the Execution Class for the steel structure, components and details
If a pre-existing contract is continuing to deliver steelwork over this transition period the client will need to put in place measures to ensure that the CPR’s requirements are met.
For concrete structures and components the obligations placed on designers are less onerous due to lack of harmonised standards across the EU. These obligations are discussed.
Introduction
In response to the obligations of the EU’s Construction Products Regulation (CPR), the construction industry is adopting mandatory CE marking of construction products across the EU and European Economic Area. This requirement is aimed at creating a wider market for all such materials within the European Union countries.
CE stands for Communaute Europeenne. Products or materials bearing this mark are presumed fit for their intended use when incorporated into a building or other structure, and are free to circulate within the entire community with no further testing and certification work required.
As the CARES website notes: “CE marking of construction products is only possible where ‘Harmonised’ technical specifications exist such as European Product Standards and European Technical Approval Guidelines (ETAGs). The term ‘harmonised’ means ‘agreed’ and in this sense agreed by the European Commission that the particular technical specification is suitable to support CE marking.”
A full list of the harmonised standards under the Construction Products Regulation (CPR) can be found on the NANDO information system website:
Implications for steelwork
For structural steelwork the key standards have been harmonised. Thus:
· From 1st July 2013 all products must have CE Marking to demonstrate compliance where harmonised standards exist. For steelwork this includes:
o open sections (BS EN 10025-1),
o hollow sections (BS EN 10210-1 and BS EN 10219-1),
o plates (BS EN 10025-1) and
o structural bolts (BS EN 15048-1 and BS EN 14399-1.
· From 1st July 2014 BS EN 1090-1 becomes mandatory and thus it becomes a legal requirement for all fabricated steelwork delivered to site from that date to be CE Marked.
According to the BCSA/Tata Steel document “CE Marking” the 1 July 2013 requirement “should not cause any disruption in the supply of materials as manufacturers, such as Tata Steel..... have been CE Marking their products for a number of years on anticipation of the CPR requirement.”
It should be noted that the BCSA has made CE Marking compliance a condition of membership of the Association from 1 July 2014, so selection of a BCSA Member company will guarantee compliance.
Prequalification statements for new steelwork contracts
From correspondence with the BCSA they recommend that the following prequalification conditions are required to be complied with if steelwork is to be delivered to site after 1st July 2014:
Statement for specialist sub-contractors: On 1st July 2013 it will be a legal requirement to CE Mark construction products that are covered by either a harmonised standard (CE Marking standard) or a European Technical Assessment (an alternative CE marking procedure for proprietary products). From 1st July 2013 manufacturers and suppliers of CE Marked products will be required to provide construction products with the appropriate CE Mark, the Declaration of Performance (DoP) and any other supporting information (including Safety instructions). The DoP may be supplied in paper or electronic format.
Pre-qualification statement for steelwork contractors: The CE Marking standard for fabricated steelwork doesn't come in to force until 1st July 2014. From 1st July 2013 onwards steelwork contractors will need to provide evidence that they have the necessary CE Marking systems in place or that they are working towards CE Marking and will have it in place by 1st July 2014.
New steelwork specifications:
Contracts for fabricated structural steel to be delivered to site on or after 1 July 2014 should include the following specifications, which incorporate the obligations of BS EN 1090-1 and BS EN 1090-2 on the steelwork contractor:
· For buildings: National Structural Steelwork Specification (NSSS) for Building Construction 5th Edition CE Marking Version
· For bridges: Model Project Specification for Building Construction (SCI Guide P382) revised January 2012
The client and/or main contractor’s responsibility
For steelwork delivered to site after 1 July 2014 the client or main contractor is responsible for appointing a steelwork contractor with a Execution Class equal to or greater than that required by the project. Given the time taken to achieve accreditation it is recommended that well in advance of this deadline clients and main contractors only award projects to steel work contractors who have already achieved or a close to achieving suitable CE Marking accreditation.
If a non-EU steelwork contractor is used on a project the CPR puts liability onto the client or main contractor. The party engaging the steelwork contractor would be classed as an importer under the CPR and must comply with the ‘Obligations of Importers’ given in its Article 13.
If a pre-existing contract is continuing to deliver steelwork over this transition period the client will need to put in place measures to ensure that the CPR’s requirements are met. The engineer should flag this responsibility to clients who may not be aware of this.
The engineer’s responsibility
Designers need to be aware of the purpose, and the limitations of CE marking in order to be able to fully safeguard the interests of their clients and to protect their own potential liability. CE markings were originally designed for national market surveillance and enforcement authorities, rather than specifiers and consumers. CE marking was not intended as a quality standard and current EN and BS standards remain the correct references for specification.
Some harmonised standards make demands of the specifier. For steel structures for example, from July 2014 the engineer is responsible for specifying the Execution Class for the steel structure, the components and the details. In effect this will define the level of quality control in the fabrication process and it may even define who may legally undertake the work.
In some cases this Execution Class will be the same whilst in others they may be different. Execution Class must be assessed based on A3 of BS EN 1090-2. Whilst each building needs to be considered on its own merits EXC2 will be appropriate for the majority of steel constructed in the UK. This requirement does not apply to concrete products.
CE marking and the Building Regulations
As the Concrete Centre notes an updated Materials and Workmanship section of the Building Regulations (Part 7) also comes into effect on 1st July 2013. It continues to list CE marking as just one way in which the suitability of a material can be assessed for use for a specific purpose. It notes that it is important that the declared performance of a material with CE marking is checked as being suitable for the proposed use.
As the Concrete Centre notes an updated Materials and Workmanship section of the Building Regulations (Part 7) also comes into effect on 1st July 2013. It continues to list CE marking as just one way in which the suitability of a material can be assessed for use for a specific purpose. It notes that it is important that the declared performance of a material with CE marking is checked as being suitable for the proposed use.
For many standardised products, CE marking may become the default definition of suitability in the eyes of Building Control Officers. For many other products, particularly bespoke solutions, other means of compliance will continue to be used. These include British Standards and other national and international technical specification; independent certification schemes; tests and calculations (3rd party accredited) and/or past experience.
Note that there remains no requirement for proof of CE marking to be routinely supplied for Building Control approval.
What products don’t require CE marking?
These include:
· traditionally made products or in a manner appropriate to heritage construction
· those manufactured on the construction site
· bespoke products (i.e. those manufactured specifically for an identified construction project.)
The interpretation of the legislation around this last exemption is currently a matter for conjecture and is likely to be resolved over time. One interpretation is that a product that requires design input to be used or requires specific manufacture (e.g. cut to length) does not need to bear CE markings. One that has a standard design and is ready to use does, for example a fence post or a concrete block. However, this does seem to conflict with the approach being taken from July 2014 by steel fabricators.
Which concrete products require CE marking?
Not all concrete products require CE marking. For example, concrete (as a material) is not covered by the CPR; the European Standard for concrete EN206, is not harmonised and so therefore CE marking does not apply to ready-mixed concrete.
As noted by the Concrete Centre, the summary of concrete related product groups that are included in the CPR and should eventually have harmonised standards and therefore require will eventually CE marking are as follows: “precast concrete products; cladding; roof tiles; cement, building limes and other hydraulic binders ; reinforcing and prestressing steel (and ancillaries); masonry and related products, masonry mortars and ancillaries; aggregates; road construction products; products related to concrete mortar and grout; screeds; fixings; structural metallic products and ancillaries; structural timber products and ancillaries.”
For reinforcement, as the CARES website notes: “Unfortunately due to severe delays in the standards writing process, the European Standards for those products with which CARES is mostly concerned are not yet harmonised; EN10080 for reinforcing steel and EN10138 for prestressing wire, strand and bar. Until these standards are issued as harmonised standards then CE Marking cannot be applied to these products.”
A list of the standards that have been harmonised related to concrete can be viewed here. For quality ready mixed concrete various 3rd party accredited quality assurance schemes exist such as QSRMC and BSI and CARES for reinforcement. Where there is ambiguity specifiers should seek guidance from manufacturers and their trade associations.
Conclusion
For structural steelwork our designers need to be aware of the requirements being set within the EU market for work carried out after 1st July 2013 and 1st July 2014. Our specifications and the choice of fabricator needs to reflect these requirements. It is important to note that our engineers need to define the Execution Class for all steelwork that will be delivered to site after 1st July 2014.
For structural steelwork our designers need to be aware of the requirements being set within the EU market for work carried out after 1st July 2013 and 1st July 2014. Our specifications and the choice of fabricator needs to reflect these requirements. It is important to note that our engineers need to define the Execution Class for all steelwork that will be delivered to site after 1st July 2014.
For concrete products the requirements are more varied due to lack of industry harmonisation. Some products and materials are now covered by harmonised standards and specifications will need to be updated reflect this requirement from 1st July 2013. Beyond that time we will need to monitor the implementation of CE marking for the various product types as their standards become harmonised.
