Do you manufacture Construction Products? Earlier this year the new Construction Product Regulation (EU) No. 305/2011 came into force and required all construction products in scope to be CE Marked. This present a major change for the UK market, which had largely ignored the previous Construction Products Directive (89/106/EEC) as it had been made voluntary in the UK.

To those who have never been previously been required to go through the CE Marking process, the new Regulation, which came into force on the 1^st July 2013, appeared to be very complicated and featured many twists and turns. In reality, the new Regulation can actually be very easy to navigate, but only when you know which way to steer.

The CE Marking Association has already helped hundreds of companies understand their requirements of CE Marking under the Construction Products Regulation, but are always looking for new ways to reach new manufacturers, distributors and importers of construction products. So we have teamed up with Coventry University Enterprises to offer a new support programme.

The new support programme, for SMEs based in the West Midlands area, consists of:

– FREE attendance to a TWO step Seminar & Workshop
– 50% funding towards additional support (if required/chosen by the company)

To register and for further details please go to our online flier: http://www.cemarkingassociation.co.uk/cue-cpr/

The following list(s) of harmonised standards referenced on the European Commission’s Official Journal have been updated in September & October 2013:

– Glandless standalone circulators and glandless circulators integrated in products: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2013:254:0009:0010:EN:PDF

– General Product Safety: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2013:254:0003:0008:EN:PDF

– Low Voltage Directive: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2013:255:0001:0103:EN:PDF

– ATEX Directive: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2013:259:0001:0010:EN:PDF

– New Legislative Framework: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2013:258:0004:0007:EN:PDF

– Lifts Directive: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2013:265:0012:0014:EN:PDF

– Cableway Installations Directive: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2013:268:0001:0004:EN:PDF

– R&TTE: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2013:297:0001:0031:EN:PDF

– Safety of Toys: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2013:317:0005:0006:EN:PDF

Members of the CE Marking Association frequently send questions into the Technical Team for support on Product Compliance. Where the dilemma may be of interest to a wider audience we like to publish the questions and answers as guidance for other manufacturers. Please note that the question and answer may have been altered for confidentiality reasons.

Question

We supply generators to turbine manufacturers, therefore a machine without a drive unit. My understanding is that we cannot declare the generator as a partly completed machine due to only the drive system being absent. However, according to the guidance on the Machinery Directive we are obliged to carry out a risk assessment on the complete assembly to include another manufacturers turbine. Would you advise on where our obligations lie and whether we are actually supplying a partly completed machine?

Answer

Thank you for your query.

Firstly, electrical motor-generators in the voltage limits of the Low Voltage Directive 2006/95/EC ( 50-1000V AC, 75-1500V DC) are exempt from the Machinery Directive, see Article 1 Scope indent 2k. If this is not the case with your generators then the following points should be noted;

I believe the point you reference in the guidance notes is at bottom of page 29. This paragraph is referring to machines that are in scope of the Machinery Directive that have been supplied without a drive system. The point of the discussion is that the machinery is NOT partly completed machinery but IS complete machinery albeit without a drive system. Which then goes on to say on page 30 that it is complete machinery and must ALSO be supplied with;

For machinery to be supplied without a drive system:

– the manufacturer’s risk assessment must take into account all the risks associated with the machinery, including those relating to the drive system to be fitted to the machinery – see §158: comments on General Principle 1 of Annex I;

– the machinery manufacturer must set out in his instructions all the necessary specifications for the drive system to be fitted such as the type, power and means of connection, and provide precise fitting instructions for the drive system – see §264: comments on section 1.7.4.2 (i) of Annex I;

– the conformity assessment of the machinery must cover the specifications of the drive system to be fitted and the fitting instructions;

– the CE-marking on the machinery and the EC Declaration of Conformity that accompanies the machinery must cover the specifications and instructions relating to the drive system to be fitted.

If the above conditions are not fulfilled, machinery without a fully specified drive system must be considered as partly completed machinery – see §46: comments on Article 2 (g). In that case, the combination of such partly completely machinery and the drive system must be considered as the final machinery and must be subject to a specific conformity assessment – see §38: comments on the fourth indent of Article 2 (a).

On the above basis, I conclude that turbine is the “Drive System”, albeit a Partly Completed Machinery as well,  and your generator is the “Machine”, unless the above conditions have been met then the generator will be considered “Partly Completed Machinery”

REFERENCES

Machinery Directive 2006/42/EC; http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:157:0024:0086:EN:PDF

EU Guidance Notes; http://ec.europa.eu/DocsRoom/documents/9483/attachments/1/translations/en/renditions/native

We, here at the CE Marking Association, are excited to announce that we are moving to new premises at Wootton Park on the 20^th September. We have been at our current location since 1993 and over the years the good work that we do has helped us to continuously grow. But we have now outgrown our current facilities and the time has come to move.

The Great Barn (pictured on the right) at Wootton Park will be, from the 20^th September, our new home and as part of our drive to achieve and maintain high standards we have invested in new larger facilities and new equipment to build upon and improve our services to support manufacturers and importers with their CE Marking and compliance requirements. Wootton Park is set just outside the village of Wootton Wawen (just north of Stratford-upon-Avon) and provides an attractive and peaceful location for our training workshops and seminars. We are located in the Great Barn, which is over 150 years old and used to be home to a herd of 120 cows, but was recently carefully converted into office space which we will be using as our new main office.

One of the great benefits of moving is that we will soon have a larger on-site electrical safety testing facility that will enable us to accommodate and test larger products and machines to support our growing client base. In addition, there is also plenty of space for future expansion, including space for an OATS (Open Area Test Site) facility. We have also invested in new test equipment including a new electrical safety tester and a new environmental chamber.

Further more, our new larger rooms will provide a much improved meeting and training environment with plenty of free parking and the farm house also provides on-site accommodation for those who wish to stay locally when attending training courses.

We move on the 20^th September and we look forward to seeing you at our new premises.

Our new address:

CE Marking Association

The Great Barn
Wootton Park
Alcester Road
Wootton Wawen
Henley-in-Arden
Warwickshire
B95 6HJ

(For SATNAV use postcode: B95 6HH)

Tel: 01527 595066
Fax: 01527 595033

Germany has been referred to the European Court of Justice by the European Commission as a result of failing to respect the rules of the EU regarding the harmonisation of the trade of construction products. Manufacturers within EU member states have been faced with major setbacks in placing construction products on the German market as a result of German ‘Bauregellisten’ (Lists of Building Regulations).

A number of complaints have been lodged with the commission by manufacturers and importers who have met with difficulties when trying to sell their products on the German market. These issues have arisen due to the current additional marks and approvals that are required in Germany in order to meet national Building Regulations which are required before construction products can be allowed onto the market, irrespective of any CE mark that the product may have which would otherwise allow the product to be sold legally in all EU member states.

Within the provisions of the Construction Products Directive 89/106/EEC, member states may establish performance requirements for construction products, upon the condition that they do not restrict the free movement of CE marked products. This rule can also be found, with more clarity, in the recently adopted Construction Products Regulation 305/2011/EU and therefore the mandatory requirement for additional conformity or approval marks is believed to be in breach of European single market rules.

If you are in doubt as to how the new Construction Products Regulation (CPR) affects you and your business, the CE Marking Association are currently running regular CPR awareness seminars. If you would like to further details about these seminars, or would like to book your free place, please contact us on 01527 595066 or email info@cemarkingassociation.co.uk.