FAQs - CE marking for EN 14351

Frequently asked questions relating to the product standard for pedestrian, external doors and windows (without fire performance).


1. Do I need to CE mark my external doors and windows?

Yes. It is illegal to place windows and external pedestrian doorsets...
Yes. It is illegal to place windows and external pedestrian doorsets on the market without a CE mark and a Declaration of Performance. This is due to the European Construction Products Regulation which is EU law.

2. Construction Products Regulation (CPR) - ensuring products comply

The approved method to demonstrate compliance with the CPR...
The approved method to demonstrate compliance with the Construction Products Regulation for external doors and windows is described in the European Standard EN 14351-1 windows and external pedestrian doorsets without resistance to fire and smoke leakage characteristic. 

This lists a series of tests that may need to be undertaken. Once the appropriate testing has been successfully completed, the manufacturer then needs to prepare and retain a ‘Declaration of Conformity’ which entitles them to affix a CE Mark to their product.

3. The CE marking process - what are the manufacturers' responsibilities?

There are 3 main areas that manufacturers are responsible for: ...
These are:

1) Collect the relevant evidence:
The evidence you need to collect (and retain in a secure location) should be in the form of written documents. This evidence will typically include test reports and COSHH sheets.

Annex ZA of the standard EN14351-1 lists the characteristics of the product that you will need to have considered when gathering your evidence. However you will only have to gather evidence of compliance with those characteristics that are applicable to your particular product.

The 6 essential characteristics you will need to have considered are:

Thermal (as a requirement of building regulations in the UK)
Within the UK building regulations thermal performance is required. This normally consists of calculations based on EN ISO 10077-1 and EN ISO 10077-2. Sometimes ‘Hot Box’ testing is required. This testing is carried out to EN ISO 12567-1 and EN ISO 12567-2. You will need to have evidence of performance in the form of a written technical report to demonstrate compliance with these standards.

Weathertightness
In the UK we test with reference to BS 6375 Part 1 which, since the 2004 edition of the standard, has referenced the European test methods to be used. This means that tests conducted after 2004 are likely to have been conducted in accordance with the appropriate EN test methods. You will need to have evidence of performance in the form of a written test report to demonstrate compliance with this standard.

Dangerous substances
COSHH sheets for the product and elements should be retained which demonstrate that in normal use toxic or radioactive material are not emitted by the door or window. 

Impact resistance (glass or fragmental material)
The recommended class for impact resistance of glazing within door and window systems in the UK is class 0. Class 0 means no performance determined with respect to impact resistance. If class 0 is declared, no performance testing is required. If a higher class is declared, the door or window will need to be tested in accordance with BS EN 13049 and evidence of performance in the form of a written test report will be required to demonstrate compliance with this standard.

Load bearing capacity of safety device
Where a safety device is present (opening restrictor or similar device) it should have been tested on the window as described in EN 14351-1 and you will need to have evidence of performance in the form of a written test report to demonstrate compliance with this standard.

Ability to release (exit devices)
This falls under AVCP system 1 and requires that a Notified Body confirms your compliance by providing a Certificate of Constancy of Performance (CoCoP) for your doorset. 

Any emergency exit device or panic exit device fitted to a doorset must have been tested and CE marked (typically by the hardware manufacturer) to relevant standards EN 179, EN 1125, prEN 13633 or prEN 13637.

Hinges must have been tested and CE marked to EN 1935. If the chosen hinge device cannot be tested to EN 1935, there might be alternative routes to compliance which will need to be agreed with your Notified Body. You will need to have evidence of compliance with the relevant standard by means of a CE Declaration of Performance (DoP). This DoP must include a reference to the CoCoP provided by the stated Notified Body for the hardware manufacturer. The CoCoP will show the tested classifications for the specific device or hinge.

Any other characteristics within EN 14351-1 (such as acoustic performance) will only be required when specified by specific projects in the UK. These characteristics are listed in Annex ZA of the standard. Again you will need to have evidence of performance in the form of a written test report to demonstrate compliance.

2) Ensure you have a factory production control system in place 
You may already meet this requirement if you have an existing ISO 9000 (or equivalent) quality management system in place. If so, you will simply need to ensure that all relevant paperwork is complete and organised correctly.

If you do not already have a documented factory production control system in place, guidance on the key considerations is contained in the Exova BM TRADA information sheet CE marking of windows and external pedestrian doorsets (TI-16).

3) Produce a Declaration of Conformity
Your Declaration of Conformity should contain the following:
  • name and address of the manufacturer and the manufacturing site
  • description of the product (type identification, use, etc.) and a copy of the information accompanying the declaration
  • a list of the performance characteristics and classes achieved for the product from relevant evidence
  • limitations on or conditions applicable to the use of the product
  • name and address of the notified testing laboratory(ies)
  • name of, and position held by, the person empowered to sign the declaration on behalf of the manufacturer. Identification of the Notified Certification Body (AVCP system 1 only)

4. Declaration of Conformity - can existing test evidence be used?

Yes, historical test evidence using valid European standards...
Yes, historical test evidence using valid European standards can still be used.

5. Does CE marking replace 3rd party quality marking or SBD?

No. Generally CE marking to EN 14351-1 is a self declaration...
No. Generally CE marking to EN 14351-1 is a self declaration by the manufacturer which verifies that the product meets the requirements of the Construction Products Regulation and as such allows trade across Europe with fair comparison of performance characteristics. It does not act as independent proof of quality of manufacture.

6. More information

For additional information, please refer to our technical information sheet...
You can refer to Exova BM TRADA's technical information sheet (TI-16) CE Marking of Windows and External Pedestrian Doorsets - Guidance for Manufacturers.