Voluntary Approvals and CE
Marking
The construction sector has always required and has always been
provided with two parallel and complementary solutions (i.e.
standards and technical approvals*) which make independent product
specifications available to those specifying and using construction
products and also permit the demonstration of product/system
compliance with existing regulatory and other
requirements. This need of the market is reflected in the
existence of independent technical assessment organisations which
issue approvals as product specifications for mainly innovative
products/systems, where the state-of-the-art is not yet
sufficiently consolidated and for products in niche markets, where
European standardisation would be too expensive.
* The approvals are the results of technical assessments and
have a number of different names – Agrément certificates, Avis
Techniques, Zulassung, Documento de Idoneidad Tecnica, Technical
Approval, Agrément Techniques etc.
These voluntary approvals are 'tailor made' and always foresee
appropriate provisions for the applicants concerned, including
SMEs. Problems that some SMEs occasionally experience, i.e. long or
costly assessment methods and FPC requirements, can appear in the
technical approval process when there is little knowledge (or the
need for convincing demonstration) about the behaviour of the
installed product.
In the year 2008 there has been much discussion concerning the
approval of construction products and systems. This discussion has
been set against the background of the proposal by the European
Commission for a regulation to replace the Construction Products
Directive (89/106/EEC). It is therefore appropriate at this time,
to provide a clear explanation of the collective role played by the
organisations as members of UEAtc and, thereafter, to demonstrate
how the documents they issue complement CE marking.
UEAtc comprises seventeen member institutes from across the EEA
that have been working in voluntary co-operation since 1960. The
specific aim of UEAtc is to facilitate the transfer of construction
products between countries through the practice of mutual
recognition of voluntary approvals (see definition above). This
co-operation has resulted in the issue of seventy technical guides
agreeing the methods for assessment of innovative construction
products and the exchange (or confirmation) of several thousand
approvals between members. That has been to the benefit of many
manufacturers across Europe.
Each UEAtc member institute is independent, non profit making
and capable of delivering sound technical judgements in the
construction field. In the issue of their voluntary approvals,
member institutes work in collaboration with representatives from
all stakeholders in the construction industry, i.e. manufacturers,
specifiers, contractors, regulators and insurers. No stakeholder
group is favoured above another and procedures are applied equally
toevery manufacturer, large or small.
A fundamental characteristic of these voluntary approvals is
that they deal with the fitness for purpose of construction
products and systems i.e. after they have been incorporated into
the works. It is this characteristic which differentiates them from
showing compliance to technical specifications such as standards
and which underlies their role (for CE marked products) as being
complementary to CE marking.
The process which results in an approval is all embracing and
covers:
i) assessment
of the production process (whether fully developed or
prototype)
ii) assessment of key
performance characteristics
iii)
assessment of the installation process and, where relevant and
appropriate, training of the associated personnel
iv)
statements of whether the product/system performance will meet
national building regulations/codes
v)
statements of whether the product/system will comply with
requirements of other stakeholders i.e. insurers, architects,
designers, contractors and occupants
vi)
assessment of the product/system durability
vii)
assessment and surveillance of the factory production control
system
As a result end users have all the relevant technical
data/information, enabling them to make the best use of the
product/system (through design and installation phases) at the
interface with other products/systems in the works. They are able
therefore to make responsible choices concerning the use of
products/systems for optimum quality work.
Taking into account these considerations in relation to CE
marking, UEAtc has created a category of voluntary approvals called
Application Documents*. The items iii) to v) are the key
complementary additions, since the voluntary application documents
concern the incorporation of a product/system into the works and
address the national requirements of individual countries. It
should be noted that the documents can also permit product
differentiation by allowing manufacturers to exceed regulated
levels of requirement and to include non-regulated aspects of
fitness for purpose should they so wish.
*These are also known by different names i.e.
Document
Technique d'Application, (139Kb PDF), Documento de
Idoneidad Tecnica Plus, CE Marking
Application Guide (90Kb PDF), Technical
Recommendation (672Kb PDF), Zulassung (487Kb PDF) etc.
The affixing of CE marking may be compared to the use of a
passport, which allows free entry to any country, but in order to
conduct daily life (e.g. buying an apartment, opening a bank
account) there is a need for documentation beyond that provided by
the passport. Similarly, the application documents issued by UEAtc
members assist the entry to market provided by CE marking.
Some examples of these voluntary application documents and their
relation to the harmonised specifications which underpin the CE
marking are given in the attached files (see links above).