Zoo Hardware is raising awareness on the need for compliant mirror certification on construction hardware products, which fall within the scope of European harmonised and UK designated standards, and should therefore be conformity marked as CE/UKCA CE+NI. Technical product, certification & compliance manager for ERA Home Security and Zoo Hardware, Jason Tonks, Reg AI, reports.
Confusion, misunderstanding and misguidance has developed around the requirements for mirror certification in recent years, at a time when accurate, current and transparent information has never been more important. Failure to correctly certify own-brand or rebranded products can leave customers in a very difficult situation as their product is not legally covered to be placed on the market, so a good understanding of the requirements and certification process is essential for mitigating compliance risk to their business.
Mirror certification explained
Mirror certification and new requirements for own branded construction products covered by a hEN (Harmonised European Standard) or UK designated standard were introduced as far back as 2019, as part of an important update within the amended European Construction Products Regulation (EU CPR). They stated that the same certification obligations apply to both a main certificate holder (also known as the manufacturer placing the product on the market), and a company which own-brands or rebrands that product and places it on the market under its own brand (also known as a branding manufacturer).
The changes apply to any product regulated by a European harmonised or UK designated Standard for which CE, UKCA or CE+NI marking is a requirement when fitted to a fire-rated door.
From 2019, the company placing the product on the market is now responsible for that product and therefore must supply its own CE/UKCA/CE+NI CoCoP (Certificate of Constancy of Performance) and supporting Declaration of Performance (DoP) relating to the CE/UKCA/CE+NI CoCoP certificate, before placing on the market.
There are a number of products being placed on the market in the UK that are still not correctly mirror certificated, and those companies selling them need to be aware of the risk they are carrying.
The current compliance environment
Simply put, the need for clear and unambiguous certification is now part of the ever-changing environment of compliance, risk and certification that is being more stringently regulated around the UK and Europe.
The CPR’s updated mirror certification requirements in 2019 go a long way to making it easier for product, branding and main manufacturers of that product to be identified from the certificate information that should be present with the product, fitting instructions and packaging. This is also a crucial part of the ‘golden thread’ for reliable, up-to-date and accurate building information, now becoming a requirement as part of a post-Grenfell industry and society.
Requirements for AIs supplying own-brand products
For those companies already supplying own branded construction hardware products covered by a CE/UKCA/CE+NI marking certificate which does not belong to the mirror branding company, they should speak with their manufacturer and arrange an application for mirror certification as soon as possible.
The first step for AIs placing an own-brand product onto the market is to talk to the original manufacturer placing the product on the market about their requirements for own branding. If the related product requiring own branding is within the scope of a European harmonised or UK designated standard, then a mirror certification application must be raised with the notified/approved body, either by the AI directly or by the manufacturer on the AI’s behalf and permissions will need to be given by the main certificate holder (manufacturer).
The original manufacturer placing the product on the market should manage the liaison and permissions for the branding manufacturer with the notified body, which will need to approve both the original and mirror certification. This gives the AI approval to use the original test evidence covering the original CoCoP for their own branded product.
The implications of non-compliance
Awareness, understanding and adherence to these requirements remains varied across the industry, but it is illegal under the CPR not to comply. Companies found to be non-compliant face legal action, and post Grenfell, the Building Safety Act and CCPI, it is more critical than ever to be clear and unambiguous with the product you are placing on the market.
This is something I am extremely keen to educate our customers and wider industry on, to raise awareness across the industry.
Douglas Masterson, technical manager at GAI, said: “The GAI wholeheartedly supports Jason and Zoo Hardware’s stance on mirror branding and certification in line with the requirements of the Construction Products Regulation, and we are delighted to see them lending their technical expertise to support our industry.
“Responsibility for mirror certification may rest with the branding manufacturer, but we would urge companies looking to own-brand to lean on manufacturers, like Zoo, to understand their own or their customers’ requirements.
“This will help them achieve compliance, by securing the necessary certification for own-label and rebranded products. GAI members can also refer to the updated guidance on mirror certification issued in February 2022, which covers common scenarios, and roles and responsibilities.”
Zoo Hardware has been giving its technical expertise for several years now to champion this issue amongst its customer base. It has invested heavily in mirror certification for own-branded hinges, door closing devices and locks, and provided important guidance, resources and advice to help its customers comply with the requirements of the Construction Products Regulation.
