Controlled door closers can be CE and/or UKCA marked (and should be) if they meet EN1154 and are to be sold in the EU or UK market. They do not need to be fire-rated to meet this standard, although the classification must show if they are, or are not suitable for fire doors.
The minimum standard for any construction product is CE/UKCA marking. How you go about this procedure depends on the product’s ‘System’ that it fits within under AVCP (Assessment and Verification of Constancy of Performance).
In addition to the legal minimum, manufacturers can choose to participate in additional quality assurance, by participating in third-party administered schemes such as the police’s SBD (Secured By Design) initiative, or accreditation certification schemes such as Certifire or IFC.
Fire-rated hardware, such as door closers for fire doors, are subject to stricter regulation that involves rigorous fire testing to recognised national or international standards.
Again there are minimum legal requirements, and then additional certification schemes that manufacturers can choose to subscribe to.
What is legally required, and what are optional extra third-party accreditation schemes are often confused. We stress ‘extra’ as the principle of any voluntary accreditation scheme is that it raises the bar on the legal minimum and is not an ‘alternative route’ to compliance.
The confusion is not confined to those new to the trade or general consumers. We have even heard of Trading Standards officials questioning why they can’t find a door manufacturer’s Declaration of Performance (required for CE marking) on a third-party accreditation scheme’s website. These accreditation bodies would only show the optional certification that that particular manufacturer has with them.
In a case earlier this year, someone with years in the hardware industry suggested that as a certificate for one of two (optional) third-party certification schemes had expired for a product, it somehow invalidated the original CE testing and Certificate of Consistency of Performance (CoCoP)!
In this article, we outline the difference between the legally required tests for CE/UKCA compliance and optional third-party accreditation schemes that companies like Rutland voluntary subscribe to.
Throughout this article we use terms based on the UK regime. This parallel terminology is a result of the UK leaving the EU, and at a practical level we can summarise:
UK Market terminology | EU Market teminogy |
UKCA* | CE |
UKAS (United Kingdom Accreditation Service) | Member State’s national accreditation body (Eg Germany’s TÜV) |
Approved Body (as listed on UKAS) | Notified Body (as listed on NANDO) |
Construction Product Regulations | Construction Product Directive |
Designated standard (BS EN…) | Harmonised standard (EN.…) |
Declaration of Performance (DoP) | Declaration of Performance (DoP) |
* The CE mark will continue to be recognised in the UK for some years for most product regulations. There is also a UK(NI) mark, jointly recognised by the UK and EU for construction products sold in Northern Ireland.
Practical and detailed guidance on how the Building Regulations (2010) can be implemented are found in the “Approved Documents”, published by the Ministry of Housing, Communities and Local Government.
With the clear need to improve building fire safety; from design, through construction and then ongoing maintenance, various updates to the Fire Safety Order (FSO) have been made since it was originally published in 2005. The Fire Safety Act (2021) was followed by The Fire Safety (England) Regulations 2022, and further updates to the testing regime and Approved Documents are expected to come.
The Construction Products Regulation (CPR) mandates that all construction products covered by a European harmonised standard must have a Declaration of Performance (DoP). This is written by the manufacturer and details the ‘essential characteristics’ of the product. The manufacturer must then affix a UKCA mark on the product, which signifies it complies with the relevant standard/s.
While the basic principles remain the same, different categories of construction products entail varying degrees of oversight from an approved body. The chart below shows the ‘system class’ and whether the task can be done by the manufacturer or if it needs to be done by a third-party UK Market Conformity Assessment Body. In any case, the ownership and responsibility for the DoP remains with the manufacturer.
Task | AVCP System 4 | System 3 | System 2+ | System 1 | System 1+ |
Assessment of product performance | Manufacturer | Approved / Notified Body (Conformity Assessment Body) | Manufacturer | Approved / Notified Body (Conformity Assessment Body) | Approved / Notified Body (Conformity Assessment Body) |
Factory production control (FPC) | Manufacturer | Manufacturer | Manufacturer | Manufacturer | Manufacturer |
Initial inspection of factory and FPC | Manufacturer | Manufacturer | Approved / Notified Body (Conformity Assessment Body) | Approved / Notified Body (Conformity Assessment Body) | Approved / Notified Body (Conformity Assessment Body) |
Further (regular) testing of batch samples | Not required | Not required | Manufacturer | Manufacturer | Manu4acturer |
Continuous surveillance, assessment and evaluation of the FPC | Not required | Not required | Approved / Notified Body | Approved / Notified Body | Approved / Notified Body |
Audit testing of samples | Not required | Not required | Not required | Not required | Approved / Notified Body |
Neither the CE or UKCA mark has an expiry date and remains valid so long as every item placed on the market remains true to its DoP; i.e. its characteristics remain the same as the original sample tested by the Notified Body. It should be noted that systems 2+, 1 and 1+ require the ongoing involvement of a UKAS-approved third-party for surveillance, with System 1+ products also requiring periodic sample auditing.
The third-party approved body that conducts surveillance can be any organisation holding UKAS approval for that particular product area and competency, on the principle of mutual recognition.
Rutland have a door closer test rig that operates door closers by forcing the sample ‘door’ open and letting it close hundreds of times a day. In addition to R&D on new products and applications, this provides the manufacturer’s regular testing on every model needed for BS EN1154 compliance.
For any construction product, it is essential that manufacturers maintain a functional factory production control (fpc) system which, in the words of the CPR is “the documented, permanent and internal control of production in a factory, in accordance with the relevant harmonised technical specifications”.
Manufacturers of products in Systems 2+ to 1+ require a third-party Approved body to undertake continuous assessment and evaluation of their FPC. This work requires trained and competent inspectors and hours of site visits and face to face meetings, and was severely disrupted by the Covid lock-downs and restrictions. It is only in the last quarter of 2024 that we are seeing a final return to normal timescales for audits and certificate renewal.
Since Brexit, Rutland Door Controls have used Notified Bodies including Effectis (France) and Element (Netherlands) for CE conformance surveillance and have continued with Warringtonfire and IFCC for UKCA requirements. Although not legally required, many models of Rutland closers have been approved by more than one independent third party. This is detailed on the product page listing.
The legally required DoP for each product is available to download from its listing on this site, along with links to the current third-party certification scheme certificates. Each certificate's validity can be verified on the scheme's website, using the manufacturer's name or certificate number.
The Grenfell phase 2 report identified manufacturers who were dishonest, an approved certification body who was incompetent (“procedures were neither wholly independent nor rigorous”) and a test house who were unprofessional (“unprofessional conduct, inadequate practices, a lack of effective oversight, poor reporting and a lack of scientific rigour”). All those found out in this tragedy were big names in the industry, showing we must never assume quality, competence, or compliance.
It is no surprise that the entire construction industry is now under such scrutiny, and must work hard to ensure that everyone knows their responsibilities and takes these issues seriously.
The Grenfell report shows the importance of competent fitters when it comes to building safety compliance. It notes that the contractor’s “staff were unaware of the requirements of the Building Regulations relating to fire safety, the guidance in Approved Document B or industry guidance and did not understand the underlying testing regime.” This shows the importance of understanding the testing regime by everyone involved in construction, and of cross-checking between the many different organisations involved.
Product competancy and practical knowledge
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