The following question was put to us by someone involved in the Fire-door supply chain:
The entity responsible for first "placing the goods on the market" (i.e. the manufacturer or importer), is legally obliged to ensure that the fire doorsets comply with current national legislation. The manufacturer attests to this by affixing a UKCA or CE (for GB and EU markets respectively), and issuing a Declaration of Performance (DoP). This is governed by the Construction Products (Amendment etc.) (EU Exit) Regulations.
The DoP must contain details of the designated Standards that the firedoor has been tested to (i.e. EN 14351-2 and EN 16034), along with the performance data of the "essential characteristics" that relate to those standards. In order to obtain this data, the manufacturer uses an independent third-party Approved Body (approved by UKAS in the case of the GB market). As the UKCA and DoP are the manufacturer's responsibility, the involvement of the third-party ends once the test results are passed to them.
The official name for this is a “Certificate of Constancy of Performance” or CoCop, but colloquially known as the “UKCA Certificate” - named after the marking that the certified product carries.
The UKCA mark is the United Kingdom’s replacement for the CE Mark. Both the CE and the UKCA marks are valid on Construction Products until 30 June 2025 (link last checked 3 Aug 2023), after which only the UKCA mark will be recognised in the GB market [July 2023 update: UK government policy is evolving on this point. There is talk they might continue to accept the CE mark, at least for some products.]
In the case of construction products, a UKCA CoCoP certificate is issued to the manufacturer by a UKAS-approved Conformity Assessment Body, following the successful completion of the relevant tests.
A Declaration of Performance (DoP) is a document drawn up by the doorset manufacturer, based on the assessment data. The DoP states the intended use, technical performance (“essential characteristics”), and designated Standard/s that the product complies with. If any hazardous substances are contained in the product, these should be detailed too. A DoP is essential for any product covered by the Construction Products Regulations.
The manufacturer will have both of these documents; they are obliged to make the DoP freely available alongside their products. To help you find the manufacturer, their Trade Mark an/or company name is always displayed along with the UKCA symbol.
The UKCA mark - like its EU equivalent the CE mark - is self-declared and remains the responsibility of the manufacturer. For this reason, you won't find CoCoPs or DoPs on the websites of the testing house or certifier. This can cause confusion even to those in the trade and government authorities, as certificates issued by Approved Bodies for the purposes of a certified third-party scheme are usually available on their website for verification, whereas CoCop certificates are not.
To demonstrate the difference between a UKCA/CE CoCop certificate and a 3rd-party Approved Product Scheme certificate, let's compare the two certificates below:
(These two certificates are for the same product, made by the same manufacturer, and issued by the same 3rd-party Approved Body)
In the case of fire doorsets, the manufacturer is responsible to have their products tested by an Approved Body against the designated standards BS EN 14351-2 (performance of doors and windows excepting fire-preformance) and to BS EN 1634-1 (Fire resisting properties). If the manufacturer is abroad, then the importer becomes responsible as the entity "first placing the goods on the market". Whilst the manufacturer isn't obliged to re-test the products, they need to ensure that the product:
1) Is labelled with their name and address, or distinctive Trade Mark (for traceability).
2) has been tested by the manufacturer in conformity to UK regulations.
3) Carries a valid UKCA mark and any other labeling obligations are met.
Additionally, the importer must not supply products into the GB market if they have reason to believe they don’t comply with applicable UK regulations, regardless of the manufacturer’s DoP.
Construction Products conformity is sometimes a complex and evolving area, particularly in regard to AVCP System 1 products like fire-doors. Rutland work with many fire doorset manufacturers to help them meet ever-increasing standards of safety. Please get in contact if we can assist you.
Sources:
https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:088:0005:0043:EN:PDF
https://www.gov.uk/guidance/construction-products-regulation-in-great-britain
https://www.gov.uk/guidance/ukca-marking-conformity-assessment-and-documentation
Leave us your contact details and we will call you back for a free consultation about your requirements.
