EN STANDARDS and CE MARKING.
How solid fuel appliances are certified in Europe.
From 2013 manufacturers or suppliers of Solid Fuel appliances in Europe are required to take absolute responsibility for their products, just as suppliers of other potentially dangerous products, such as electrical equipment, already do.
The Construction Products Regulation of 4 April 2011 makes it compulsory throughout Europe from 1 July 2013 for equipment for incorporation in buildings to meet 'harmonised' Euro Norm (EN) standards. For solid fuel equipment these include EN 12815 Cookers, EN 13229 Inset appliances & open fires, EN 13240 Roomheating Stoves etc.
The 'CE' Mark, showing how it is correctly laid out
These are the only Standards used, and no European country or organisation is permitted to use any other certification system, though individual areas can have their own limits for efficiency and emissions. Standards documents can be purchased (at high cost) from National Standards Organizations, such as: BSI or NSAI, or your local library may offer online access at no direct cost to you.
Proof of compliance with the Standards is never by any external 'approval' - a system widely abused, where neither party takes responsibility for the product - but by a legal affidavit signed by the actual person responsible for the product, with their contact details, who can be sued if it isn't right. The supplier themselves must test the performance and quality of the product, and it is the supplier alone who must issue the proving documents.
Ten Years in Prison, and...
In the UK, falsely claiming conformity to Standards or supplying false documentation can be an offence of criminal deception, for which the tariff can be ten years imprisonment, an unlimited fine, confiscation of all property, and debarment for life from being a company director. This system has already been hugely effective in all but eliminating non-conforming children's toys and electrical equipment.
What a stove supplier must do...
1 Test their products ...
Suppliers are required to test and asses their own products for quality, safety, performance and conformity to Standards. To make sure factors like efficiency are all tested the same way, they are also required to have some thermal tests on a sample product done by a government-approved 'Notified Body'. Although they can just rely on their own thermal testing for;
● One-off appliances built to order. (s39 CPR)
● Historic reproductions for use in listed buildings. (a5 c CPR)
● Products manufactured by 'micro enterprises'. (a37/38 CPR)
● Mere family variations of existing appliances (EN Standards and s34 CPR)
The testing by a Notified Body does not itself confer any sort of 'approval', nor is it an indication of quality. Rather, the Notified Body supplies some of the test data which will help the supplier decide for themselves, along with their own tests, if their product meets European Standards.
2. Put the 'CE' Mark on their products and literature...
The CE mark is an official symbol by which the manufacturer or distributor of a product personally declares that it meets the Standards that make it fit for sale throughout Europe. It must be fixed to the product, or to a label or packaging. It is not any form of 'approval'. It is a way of saying "I declare this product is safe and sound - sue me if I'm wrong". There are no exceptions.
3. Supply a 'Declaration of Performance' ...
The manufacturer or the supplier in Europe must make permanently available a "Declaration of Performance" (cII, a4 CPR)- a certificate stating what the equipment is supposed to do, how much heat it will give for instance, what standards it meets and who tested it where and when. It must be signed by the actual person responsible for the product in Europe, usually the chairman, head of design or of quality at the manufacturer, who can be sued personally if the product is wrong. A signature from an outside body or from a tester will not do, nor will a simple claim that it complies with standards.
Amongst other things, the Declaration of Performance must ...
● Be in the language of the State where the product is supplied
● Give the name and address of the manufacturer or supplier in Europe
● Give the essential performance characteristics of the products, for solid fuel appliances that includes at least...
● Heat output to the room
● Heat output to water
● CO emission at a standardised atmosphere
● Be signed by the person responsible for the product
Example of a Declaration of Performance
Click to enlarge, or Click Here to download a Sample Template
Who enforces all this?
You do. A strength of this system is that anyone anywhere can start proceedings against non-complying suppliers simply by telling their local Trading Standards Office. And they do.
WE GET ASKED...
Can't I just pay a company to certify my product for me ?
Absolutely not. Paid-for certification sets up a master-and-servant relationship where it is in both parties interest to 'approve' the product, yet neither then takes full responsibility for it. Whether for French breast implants, USA mortgages or solid fuel stoves, paid-for certification have been shown to invite laxity and corruption. You must take complete, public, liability for your own products, and do so by yourself.
Some companies claim they can approve my product for me
Marks of conformity other than the CE mark are not allowed (s33 CPR & Article 7), but specifiers should be aware of 'certification' schemes run by private commercial companies, some of whom try to give the impression that they have official approval. These may possibly offer some form of additional product assurance, but are generally simply a form of advertising where manufacturers pay (often a very considerable sum) for an 'approval'. Where a product is covered by a Harmonised Standard, and solid fuel appliances are, no other form of certification is permitted.
Testing by Notified Bodies is very expensive. We can't afford it.
There are lots of Notified stove test labs - you don't have to use the one in your home country, you can shop around for the best price. Very small 'micro enterprises' (variously defined, but commonly turnover <€1M) are allowed to do their own tests in a simplified way.
We're a 'micro-enterprise', how do we do these simplified tests?
You must decide for yourself what tests will give you the same results as those laid down in EN Standards. You've still got to put your name to a public Declaration of Performance, and you can still be sued if it isn't right. If you don't know how to design suitable tests, should you really be making the product?
What about outdoor products, like Chimenea ? They don't seem to have a Standard to test or conform to.
Where there is no existing official Standard you can create your own 'Technical Document' in conjunction with one of the Notified Bodies.
What about open fires?
The Standard for open fires is EN13229. All new open fires must meet it, carry the CE mark and have a Declaration of Performance. No exceptions. Open fires, as the usual British and Irish type, which are assembled on-site from disparate components (grate, fret, fire-back, throat lintel etc) may be certified by the person who assembles them.
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