Can balustrades and handrails be CE Marked under EN1090-1?
In Short the Answer is NO!
There has been considerable confusion throughout the entire construction industry as to exactly what is covered with-in the scope of the Construction Products Regulation and more specifically what falls within the scope of EN1090-1.
It has been difficult to find an unbiased source of information, as many associations, consultants and other personnel in the UK have very definitely (and incorrectly) stated that all balustrading IS included, and therefore have a lot to lose by now admitting that it isn’t! But to summarise the full article below:
“Therefore we consider that balustrades can NOT and must NOT be CE marked under EN 1090-1.”
– GEORGIOS KATSARAKIS
Civil Engineer NTUA
European Commission
The word “must NOT” conveys the seriousness of this situation. As we mentioned in the full article below it is illegal to apply a CE mark to a product that has been produced under an incorrect harmonised European standard.
Read The Full Article & Explanation Below
Background
As of the 01 July 2013, it become mandatory for manufacturers to apply CE marking to any of their construction products covered by a harmonised European standard (hEN) or European technical assessment (ETA), under the Construction Products Regulation (CPR).
The intent of the CPR is to ensure that construction products are ‘safe’, by providing a ‘level playing field’ and ‘common technical language’, offering comparable Execution Class products, with uniform assessment methods of the performance of those construction products.
In simple terms a European standard is a document drawn up by industry experts which establish important criteria for products, services and processes. Standards, therefore, help to make sure that products and services are fit for their purpose and are comparable and compatible.
However it is also illegal to apply a CE mark to a product that has been produced under an incorrect harmonised European standard.
Scope of the European Standard EN1090-1
There has been considerable confusion throughout the entire construction industry as to exactly what is covered with-in the scope of the Construction Products Regulation and more specifically what falls within the scope of EN1090-1.
It has been difficult to find an unbiased source of information, as many associations, consultants and other personnel in the UK have very definitely (and incorrectly) stated that all balustrading IS included, and therefore have a lot to lose by now admitting that it isn’t!
Therefore our technical team have invested a lot of time working directly with the European Commission to try clarify the situation on behalf of the balustrade industry in the UK.
Consider this Exaggerated Scenario
A company could be certified to apply CE marks to products under a European standard for, let’s pick for arguments sake, electric kettles. Common sense would tell us that this does not mean that if the company was to decide to produce structural steelwork it could automatically apply a CE mark to steel work too. This is because a consumer would see this CE marked structural steelwork and assume (incorrectly) that the steelwork has been safely manufactured to the correct standards. However, obviously, the procedures required to safely manufacture electric kettles would be very different to the procedures required to safely manufacture structural steelwork.
So why include this “silly example”?
EN1090-1 was developed specifically to establish important criteria for safe production of steelwork that is supporting (or holding up) a building. Therefore to apply a CE mark to a balustrade on the basis of EN1090-1 could mislead the consumer (or purchaser) into believing that the balustrade has been made to the best, approved European Standard for balustrades, when the European Commission have never drawn up a standard to cover balustrades. So in fact, although certain aspects of EN1090-1 are relevant to balustrades, there is no guarantee that it is any better than applying a CE mark based on the European Standard for electric kettles!
Conclusion
The European Commission have now advised us, in writing that:
- The European Commission’s mandate to CEN was to develop a harmonised standard but was LIMITED to products which have a structural function for the works (i.e. their collapse will cause the collapse of the building).
- Therefore balustrades can NOT and must NOT be CE marked under EN 1090-1.
- If you need (on a VOLUNTARY basis) to apply EN 1090-1 for the production of balustrades you can do it but you cannot CE mark the product on the basis of EN 1090-1.
- They agree with the following statement and have put this forward to the technical committee as the recommended text to be added to the list of exclusions on the website:
- Balustrades and handrails, provided they do not structurally support any part of the building or civil engineering work are excluded from CPR requirement for CE marking.
“Therefore we consider that balustrades can NOT and must NOT be CE marked under EN 1090-1.”
– GEORGIOS KATSARAKIS
Civil Engineer NTUA
European Commission
The word “must NOT” conveys the seriousness of this situation. As we mentioned at the beginning, it is illegal to apply a CE mark to a product that has been produced under an incorrect harmonised European standard.
Confirmation From UK Government
Following extensive correspondence we met with government officials at Whitehall and following meetings between them and the European Commission have confirmed in writing that this is correct.
