Will fire doors soon have CE markings? Read the review by Per Adolfsson of Brandposten Magazine
The EN 16034:2014 product standard, which covers, for example, fire doors, fire shutters, fire curtains, fire gates, and openable fire windows (not fixed fire windows), was made both a European and Swedish standard in 2014.
However, CE markings are permitted only when the European Commission has cited the standard in the Official Journal of the European Union (OJEU). The European Commission cited the EN 16034:2014 with some conditions in 2015, and the starting date was set to December 1, 2015, and involved a three-year coexistence period.
These conditions were not met by December 1, 2015, so the starting date was first moved to September 1, 2016 and then to November 1, 2016. The conditions are now met so probably there will be no more delay.
However, it is most likely that CE-marking cannot be done to the EN 16034 alone. It must be combined with other standards: windows and external doors must be CE-marked according to EN 14351-1, internal doors to EN 14351-2, industrial/garage/commercial doors and gates to EN 13241-1 and power operated pedestrian doors to EN 16361.
However EN 14351-2 is not approved by CEN and EN 16361 is approved but not cited in the OJEU. This means that internal doors and power operated pedestrian doors cannot be CE-marked from the starting date of the EN 16034. The time schedule for EN 14351-2 and EN 16361 is unclear and hopefully we will have more information soon.
During the co-existence period, CE marking and national certification systems can be used in parallel, but a product cannot be simultaneously CE marked and marked according to a national approval system. In Sweden, this will mean that type approvals that include resistance to fire (for example EI 30) and/or smoke control (Sa/Sm) will be discontinued at the end of the co-existing period, which is November 1, 2019.
The standard prescribes the use of the AVCP (‘Assessment and Verification of Constancy of Performance’) 1 system, which means that the manufacturer must, among others, have a certificate issued by a notified product certification body (hereafter a ‘Notified Body’) as part of the documentation that is required to CE mark a product. SP has applied to become a Notified Body, although we are already able to perform the tests, assessments, classifications, and factory production inspections that are prescribed by the standard.
The road to CE marking
According to EN 16034, Appendix ZA, which relates to CE marking, a manufacturer can choose to declare the following essential characteristics:
- Resistance to fire
- Smoke control
- Ability to release
- Durability of ability to release
- Durability of self-closing against degradation (cycle testing)
- Durability of self-closing against ageing (corrosion)
- All essential characteristics are subject to the AVCP 1 system, which, among other things, states that the Notified Body is responsible for sampling in connection with testing.
We recommend that SP is contacted prior to sampling being performed in order to ensure that it is undertaken in a manner that conforms to the requirements of the Construction Products Regulation (CPR). Prior to sampling, the Notified Body shall assess the need for testing, which is based on categorisation into product families and performed according to any relevant assessment (EXAP – ‘EXtended APplication of test results’) standards.
Categorisation into product families is normally done for each essential characteristic, which means that all similar doors in a range of doors are considered to be one product family.
Thus, one door in the product family is tested, and the results are considered to be applicable for all other doors in the family. The categorisation into product families and use of assessment standards are important tools for minimising the amount of testing to be performed.
The EN 14600 standard, which relates to all essential characteristics and which is referred to in, for example, EN 13501-2 and EN 1634-1, has recently been abolished, and parts of it have been added to EN 16034.
Resistance to fire
Resistance to fire is declared in classes (e.g. EI2 30), which are defined in classification standard EN 13501-2. A Notified Body issues a classification report based on fire tests performed according to EN 1634-1 and, if applicable, an EXAP report according to relevant standards in the EN 15269-x series. EXAP signifies an extension of the test result (assessment) according to regulations which are common throughout the entire EU.
According to Swedish building regulations, it is possible to replace a door belonging to the EI XX class with two classes in accordance to the European system, EI2 15/EW XX, where XX represents the time in minutes of resistance to fire. If, for example, the requirement on the door is EI 60, this is considered to be the equivalent of EI2 15 and EW 60.
It is the responsibility of manufacturers to ensure that doors function in conjunction with all possible hardware. This can be verified through manufacturers’ own test reports, or those of the manufacturers of the hardware that can be used as a basis for the EXAP report.
That a hardware is itself CE marked for use with fire-resistant and/or smoke control doors is normally not sufficient, as it is not guaranteed that the CE marking of the hardware is valid together with any given door type.
Performance tests should be carried out for doors that are to be fire tested by opening and closing them 25 times. For doors that have been equipped with a self-closing function, the door should be opened manually and allowed to close normally. A special shakedown test (5000 cycles) should be performed for doors which contain material that can be compressed, for example loose-fill insulation, or that is in any other way sensitive to shaking and vibration.
Doors equipped with a self-closing function are normally fire tested with the closing function disconnected, in order to facilitate classification of the door both with and without the self-closing function.
There are two classes for smoke control – Sa and S200 – which are defined in the classification standard EN 13501‑2. Sa applies to smoke control at room temperature and S200 to smoke control at a temperature of 200°C. A Notified Body issues a classification report based on testing performed according to EN 1634-3 and, where applicable, the EXAP report.
Performance testing should be performed for the door that is to be fire tested. The door is opened and closed 25 times. If the door has been equipped with a self-closing function, the door should be opened manually and allowed to close normally.
Ability to release
This performance characteristic is to be tested if the door is delivered with electrically controlled door holders, for example electromagnetic door holders.
This testing is best performed in connection with fire-resistance or smoke control testing. As a rule, the testing is simple to perform, and involves holding the door open using the powered door holder and simulating a fire alarm by, for example, cutting the power, after which the door is to close.
This is repeated three times, and the door should close during all three tests. Passing the test is expressed as ‘released’.
This performance characteristic is tested only for self-closing doors. Testing is performed prior to fire-resistance and/or smoke control testing, and involves opening the door 10 or 30 degrees, after which it is released and the door is then to close.
The opening angle is 10 degrees for doors with a closing function that features a controlled closing speed (normal door closers) and 30 degrees for doors with an uncontrolled closing speed (such as those fitted with spring hinges). For double doors with a door coordinator, testing is performed for both leaves together and also each door leaf separately. Passing the test is expressed by ‘C’.
Durability of the ability to release
This performance characteristic is satisfied if the electrically controlled door holder meets the requirements of the EN 1155 or EN 14637 standards. Compliance with the standards is expressed as ‘release maintained’.
Durability of self-closing against degradation (cycling testing)
Testing of resistance to repeated opening and closing is performed according to the EN 1191 standard for pedestrian doors and the EN 12605 standard for industrial doors, garage doors, etc, and involves opening and closing the door for a number of cycles, dependent on the desired use category.
There are six categories – 0 to 5 – which are defined in EN 16034. Category 0 means 1-499 cycles; 1, at least 500 cycles; 2, at least 10,000 cycles; 3, at least 50,000 cycles; 4, at least 100,000 cycles; 5, at least 200,000 cycles.
Swedish building regulations recommend category 1 as a minimum. However, a ‘better category’ can be necessary, depending on the intended use of the door.
The test result is expressed with a digit of 0 to 5 according to the use categories.
Durability of self-closing against ageing (corrosion)
Hardware should meet the ageing (corrosion) requirements of the hardware standards, which are listed in EN 16034, and, if possible, be CE marked. If there is no relevant standard, the hardware should be tested and assessed according to EN 1670.
Door manufacturers that have hardware that they have developed themselves (hinges, for example) and that are only used in their own doors are exempt from the requirement relating to CE marking, but the products should still meet the requirements of the relevant standard.
Compliance with the standards is expressed as ‘achieved’.
Factory production control (FPC)
The manufacturer should have systems in place for production control in the factory (FPC systems) so as to ensure that products that are CE marked continually fulfil the characteristics of the Declaration of Performance (DoP). FPC-systems must include, among other things, a test plan and routines for the handling of non-complying products, control and testing, and modifications to products.
A manufacturer who has a quality management system that is certified by an accredited certification body according to EN ISO 9001:2015 can be considered to fulfil some of the basic requirements of the FPC system. This includes, for example, control of document, responsibilities and authorities, the management of measuring equipment, and so on.
An initial inspection of the FPC system and the factory should be made by the Notified Body, and all nonconformities must be resolved by the manufacturer prior to the issuing of the certificate. Subsequently, inspections are normally performed at yearly intervals. Additional inspections may have to be performed if modifications are made to the production process, FPC system, or product.
The manufacturer is obligated to consult the Notified Body prior to making modifications to any of these if these modifications would in any way affect the performance of the product as stated in the Declaration of Performance.
CE marking certificate
When all aspects are satisfactory and in accordance with the above, the Notified Body issues a certificate of constancy of performance of the construction product.
The certificate is not a public document, and should be used by the manufacturer as a basis for the Declaration of Performance. There are, however, no restrictions on the manufacturer distributing copies of the certificate to, for example, its clients on a voluntary basis.
During market surveillance, the manufacturer must submit certificates and other documentation, which form the basis for the Declaration of Performance, to the responsible government authority.
The certificate is valid until further notice under the condition that the FPC system is maintained and the product remains unchanged. If changes are made to the product or the standard is updated, a new or revised certificate is normally required.
System houses such as Forster, Sapa, Schüco, and Stålprofil do not, unlike in the type approval system currently in place in Sweden, receive their own certificates within the CE marking system.
They may, however, submit documentation (classification reports, test reports, and so on) for one or more essential characteristics to systems manufacturers (also called assemblers), who in turn can use these as a basis for certificates.
These assemblers should have a FPC system which includes the manufacturing instructions of the system house, their own Declaration of Performance, CE mark under their own name, and so on – that is, everything that is required of a ‘regular’ manufacturer.
Agreements that regulate responsibilities, obligations, and other terms should be drawn up between the system house and the assembler.
Doors partially manufactured on the construction site
CE marking is valid for complete doors that are manufactured in a factory. If a door is sold without essential components, such as hardware or a glass, a Declaration of Performance cannot be made and CE marking cannot take place.
If the manufacturer sells a complete door but the hardware and/or glass are installed at the construction site, the door can be CE marked if the door manufacturer assumes responsibility for the completion of the door within their own FPC system.
It is as yet unclear how other variants will be handled within CE marking, for example if the door manufacturer prepares the door for hardware which are subsequently installed by the contractor on the construction site.
Installation of the completed door in the connecting wall is not part of CE marking, but the door manufacturer must provide installation instructions (see below).
Declaration of performance
The manufacturer should draw up a Declaration of Performance of their own accord, the contents of which should adhere to the CPR and Appendix ZA of EN 16034. The manufacturer can choose to declare ‘NPD’ – that no performance has been determined – for one or more essential performance characteristics.
The Declaration of Performance is a public document and must accompany the product, either on paper or electronically. Alternatively, the Declaration of Performance can be published on a website if certain conditions are met. However, a paper copy should always be available on request.
Examples of CE marking for which SP is a Notified Body
(SP’s identification number as Notified Body)
Manufacturer Ltd, P.O. Box 11, SE-103 50, Lund, Sweden (The manufacturer’s name and address)
16 (The last two digits of the year when the CE marking was affixed the first time)
Q54-2016-05-17 (Reference number of the DoP)
EN 16034:2014 (No. of CE marking standard)
Q54-2016-05-17 (Unique identification code of the product-type)
Fire and/or smoke compartmentation and/or escape routes (Intended use of the product according to EN 16034:2014)
(Level or class of the performance declared)
Resistance to fire (for fire compartmentation uses):
Smoke control (only for applications where limitation of smoke spread is required): S200
Ability to release: released
Self-closing function (only for self-closing fire resistant and/or smoke control doorsets and/or openable windows): C
Durability of ability to release: release maintained
Durability of self-closing (only for self-closing fire resistant and/or smoke control doorsets and/or openable windows):
– against degradation (cyclic testing): 2
– against ageing (corrosion): achieved
It is the responsibility of manufacturers to affix a CE marking such that it meets the requirements of the CPR and Appendix ZA of EN 16034.
The marking should be placed on the door and present information in a manner similar to the example opposite. If this is not possible, it should be given on the packaging or in the accompanying documentation.
Manufacturers are in some instances required to provide information regarding dangerous substances, in accordance with the REACH chemicals regulation, together with the Declaration of Performance. This information is not checked by the Notified Body.
Manual and safety regulations
According to the CPR, the manufacturer must include instructions for users and safety information with the door. These documents are not inspected by the Notified Body.
For construction products that are sold in Sweden, the marking label with the CE marking should be in Swedish, but this is not a requirement. The Declaration of Performance, instructions for users and safety information must be in Swedish, however. Language requirements in other member states can be obtained at ‘contact points’, which are listed at www.boverket.se.
Remark: The Swedish National Board of Housing, Building and Planning will provide Swedish translations of essential performance characteristics, which are currently only available in English, in the future.
The CPR applies
The configuration of the Declaration of Performance and CE marking, retention period for the technical documentation, and other such matters should conform to the requirements of the CPR. The CPR may contain information that contradicts that which is given in CE marking standards.
This is especially true for older standards, which were drawn up in relation to the Construction Product Directive (CPD), but it is the CPR that takes precedence, as it is an EU regulation and has the power of national laws.
More information on CE marking can be found in the EU Commission’s folder ‘CE Marking of Construction Products Step by Step’, which is available in English and other EU languages and can be downloaded from the EU Commission’s website. Find out more.