DASMA Questions on the Construction Products Directive and Garage Doors
What is the CE Marking?
The manufacturer affixes the CE marking to his product after meeting the requirements of the applicable CE marking directive(s). After May 1, 2005, when the standard for industrial, commercial, and residential garage doors (EN 13241-1) goes into effect, those products will require CE marking under the Construction Products Directive. In addition, industrial, commercial and residential garage doors will have to continue to meet CE marking requirements for the Machinery Directive (as they were required to in the past). If the garage doors are powered, manufacturers will have to continue to meet CE marking requirements for the Electromagnetic Compatibility (EMC) and Low Voltage Directives. The EMC and Low Voltage Directives have been mandatory for a number of years for makers of electrically-powered garage doors. The manufacturer should affix the CE marking to its product only after meeting the requirements of all the directives the product falls under.
How is the CE marking obtained?
In the case of the Construction Products Directive, a manufacturer obtains the CE marking by meeting the requirements in EN 13241-1. The chart in Table ZA.3 entitled “Assignation of evaluation of conformity tasks for non fire/smoke doors under system 3" lists the characteristics that manufacturers have to meet. The top part of the chart shows what the manufacturer can do on his own: 1.) Factory production control (FPC) and 2.) Initial type testing (ITT) for geometry of glass and mechanical resistance. The bottom two-thirds of the chart shows tasks for the notified body to complete. Under system 3, the notified body (a testing laboratory) must perform the initial type tests for: Water tightness; release of dangerous substances; resistance to wind load; thermal resistance; air permeability; durability of water tightness, thermal resistance and air permeability; safe opening; and operating forces. Manufacturers are responsible for selecting representative samples for the product that is placed on the market.
Some EU member states do not require all those characteristics. However, at least one EU member state does require one of those characteristics. Therefore, in order for a manufacturer planning to sell throughout the European Union to be sure of meeting CE marking requirements for all member states, all the initial type tests for the characteristics given in the second list above must be met. This requires the assistance of a notified body.
The notified bodies perform tasks such as testing, inspection, and certification and issue the relevant documents such as test reports and certificates which the manufacturer needs in order to determine the product’s performance and to complete his technical file. In all cases, the manufacturer signs the declaration of conformity and decides to apply CE marking to his products. In this case (attestation of conformity system 3), the notified body only performs tests.
There are a number of supporting standards referenced in EN 13241-1, such as EN 12604, EN 12444, EN 12424, and EN 12453. Use of supporting standards may be necessary in order to enable a manufacturer to meet the requirements of EN 13241-1. The complete list of supporting standards for garage doors is listed in EN 13241-1.
What standards/directives govern the obtaining of a CE marking?
In most CE marking directives, a manufacturer can, but does not have to, use European standards to show compliance with the CE marking directive applying to his product. Use of European standards does confer a presumption of conformity to CE marking requirements. However, in the case of the Construction Products Directive, if there is a harmonized standard issued for a product (such as EN 13241-1 for garage doors), then the manufacturer has to comply with that standard in order to affix the CE marking. The manufacturer of a garage door, which is manually powered, also must meet the requirements of the Machinery Directive in addition to meeting requirements of the Construction Products Directive.
A harmonized standard is one that has been approved by European Union Member States and has been published in the EU’s Official Journal. Some of the clauses in a harmonized standard are commercially or technically useful in making a product, but are not deemed relevant to the directive. The harmonized clauses (which are requirements) in EN 13241-1 are referenced in Annex Z. Any other clauses are voluntary.
A company that makes electrically-powered garage doors must meet requirements for the Low Voltage and Electromagnetic Compatibility Directives, in addition to meeting provisions of the Construction Products and Machinery Directives.
A company could self-certify for the EMC, Low Voltage, and Machinery Directives, meaning it does not need to get a test report or certificate from a notified body. As part of the self-certification process, however, a company would need to get a test from a lab to prove it had conformed to the appropriate European standards for the EMC and Low Voltage directive.
A garage door manufacturer could meet the CE marking requirements for the Machinery Directive by doing a safety analysis report covering the essential health and safety requirements in Annex I that apply to garage doors.
A safety analysis report involves identifying applicable hazards in Annex I and then indicating how these hazards were eliminated. If the hazards weren’t eliminated, then the manufacturer must warn people of the residual risks.
Is the CE Marking mandatory, or will it become mandatory? What countries are involved in the enforcement of the CE marking?
Garage doors have been covered by the Machinery Directive since that directive went into effect in 1995. Electrically-powered garage doors are covered by the Machinery Directive as well as by the Electromagnetic Compatibility Directive (since 1996) and the Low Voltage Directive (since 1997). When EN 13241-1 becomes mandatory on May 1, 2005, manufacturers will have to meet the requirements of that standard, which makes CE marking for the Construction Products Directive mandatory. In addition, manufacturers must continue to meet CE marking requirements for the Machinery Directive and if applicable, the Low Voltage and EMC directives.
The countries involved in the enforcement of the CE marking are the 27 European Union countries, as well as Turkey, Norway, Switzerland, Iceland, and Liechtenstein.
If the CE Marking will become mandatory, when is the effective date?
EN 13241-1 becomes mandatory on May 1, 2005. Manufacturers will have to meet CE marking requirements for the Construction Products Directive at that time, since EN 13241-1 is a harmonized standard (approved by the European Union Member States), mandated under the Construction Products Directive. Garage door manufacturers will need a test report from a notified body (or more than one) showing they met CE marking ITT requirements for EN 13241-1, and this will involve a laboratory test by an EU-affiliate lab. There are some EU-affiliate labs located in the U.S. (See question 7).
What scope of products are covered? Garage doors and rolling doors? With and without operators? Residential, Commercial, and Industrial?
The scope of EN 13241-1 states: “This European standard specifies the safety and performance requirements for doors, gates, and barriers, intended for installation in areas in the reach of people, for which the main intended uses are giving safe access for goods and vehicles accompanied or driven by persons in industrial, commercial and residential premises.
This standard also covers commercial doors such as rolling shutters and rolling grilles when used as doors on retail premises which are mainly provided for the access of persons rather than vehicles or goods.
These doors may include pass doors incorporated in the door leaf which are also covered by this standard.
These devices may be manually or power operated.
This standard does not cover operation in environments where the electromagnetic disturbances are outside the range of those specified in EN 61000-6-3.”
EN 13241-1 then lists doors which are excluded from its scope. Those exclusions include:
 | Block gates and dock gates; |
| doors on lifts; |
| doors on vehicles; |
| armored doors; |
| doors mainly for the retention of animals; |
| theater textile curtains; |
| horizontally moving manually operated doors with a leaf size less than 6.25 m2; |
| horizontally moving power operated doors less than 2.5 m wide and 6.25 m2 area, designed principally for pedestrian use in accordance with prEN 12650-1:2001: |
| revolving doors of any size; |
| railway barriers; |
| barriers used solely for vehicles. |
This standard does not cover the radio part of doors. If a radio operating device is used, the relevant ETSI standards should be applied in addition.
This European standard does not cover fire resistance or smoke control characteristics which are covered in prEN 13241-2.
This standard does not cover specific requirements regarding noise emitted by a door in relation with the Machinery Directive.
This standard does not contain any specific requirement for doors which are moving because of energy stored by dedicated means from human power such as manually tensioned springs.
This standard does not contain any specific requirements for doors on escape routes. The ability to open the door leaf safely and easily cannot normally be achieved by industrial, commercial and garage doors due to size, weight and/or mode of operation.
In summary, EN 13241-1:2001 deals with the safety and performance requirements for doors and gates in an industrial, commercial or residential environment. The doors and gates must ensure the safe passage of goods and vehicles accompanied by people. Roll-down shutters that are used as a door or gate are also covered by the standard. The products covered by the standard can be both manually and power operated. In addition, EN 13241-1:2001 lists a series of supporting standards.
Where does a manufacturer go to obtain the CE marking?
Annex Z defines the attestation system which applies in the conformity assessment for EN 13241-1:2001. The two tasks that a manufacturer has to perform are: Factory production control (FPC) and initial type testing (ITT). The attestation level for EN 13241-1:2001 is 3. Level 3 means that:
The manufacturer must establish and maintain an internal factory production control that complies with Article 6.4 of the standard. The manufacturer can do this on his own without having to go to a notified body. The chart in Annex Z also shows that the manufacturer can perform Initial type testing on his own for geometry of glass and mechanical resistance.
The manufacturer must get a test report from a notified body covering all other initial type tests listed in Annex Z. These characteristics requiring a notified body test report are: Water tightness; release of dangerous substances; resistance to wind load; thermal resistance; air permeability; durability of water tightness, thermal resistance and air permeability; safe opening; and operating forces. Notified bodies use samples supplied by the manufacturer for their evaluations and then compile a report.
Manufacturers of garage doors will need to contact a notified body or a laboratory affiliated with a notified body to obtain CE marking. The Commerce Department has identified several places where garage door companies can get CE marking testing, inspections, and certificates:
British Standards Institute at 011-44-1442-230442, contact Chris Lewis;
TUV Rheinland of North America at 919-554-3668, contact Bill Ronzio.
Intertek Testing Services at 1-800-967-5352 or 608-836-4400
Other UK certification organizations are:
For more information on notified bodies, consult the EC’s Nando-CPD database and click on nando-CPD, then click on enter, then click on notified bodies in the box on the left hand side.
To find the notified bodies that have been specifically authorized to issue certificates for EN 13241-1, go to the nando-CPD website, click on enter, then click on standards in the box on the left hand side. Go down the page until you get to EN 13241-1 and click on it. A list of notified bodies named to do testing for EN 13241-1 will appear.
Where does a manufacturer go to obtain sufficient data, i.e., testing/engineering?
The technical data for meeting requirements can be found in standard EN 13241-1. EN 13241-1 also lists supporting standards which contain technical information. The notified body lab that the manufacturer decides to work with can also provide advice on obtaining data.
Who is responsible for overseeing the requirements for the CE Marking?
In one sense, the notified body would oversee requirements for the CE marking because its report indicates that CE marking requirements for characteristics referred to in question 7 have been met. If this question is referring to enforcement of the CE marking, then that is up to the Member States. Member States enforce CE marking directives through active surveillance (by inspecting shops and construction works), through control at the borders, and finally by passive surveillance (usually sending an inspector to the site of a complaint).
Who is responsible for developing the content of the standards/directives associated with the CE marking?
Directives are proposed by the European Commission, then sent to the European Parliament and the Council of Ministers for review and finally approved by the Council of Ministers (representatives of the Member States). During a preliminary stage, before the directive is drafted, the Commission hears reports from various committees on reasons why a directive is needed and on what the content of the directive should be. European industry’s views are heard at this stage. Industry (including European, U.S., Asian) has often lobbied the European Parliament and the Commission to change a directive. Sometimes industry’s points are taken, sometimes they aren’t.
Once a directive has been adopted, the European Commission will mandate the European standards organizations, either CEN, CENELEC, or ETSI, to produce standards enabling companies to meet the safety requirements for the CE marking directive in question. European companies and trade associations are actively involved with committees in developing EU standards. U.S. companies and other non-EU firms have very limited input into EU standards produced by CEN or CENELEC. If a U.S. firm has a manufacturing plant in the EU, then it can participate in the standards-setting process. U.S. firms can make comments on EU draft standards through the American National Standards Institute, but there is no guarantee European standards groups will accept these comments. Non-EU firms with no manufacturing presence in the EU are at a disadvantage in having any say in the development of EU standards for most New Approach (ie, CE marking) directives. ETSI has a more liberal policy as far as letting non-EU companies participate in the standards-setting process for the Radio and Telecommunications Terminal Equipment Directive.
| CEN European Committee for Standardization |
| CENELEC European Committee for Electrotechnical Standardization |
| ETSI European Telecommunications Standards Institute |
What role do the Door & Shutter Manufacturers Association (DSMA) and the European Door and Shutter Federation play in influencing both requirements for the CE marking and the content of the standards/directives?
The British Door and Shutter Manufacturers Association (DSMA) along with the European Door and Shutter Federation (EDSF) have been involved in working parties that have developed the standards for garage doors. Each member country has a representative on the committee. The trade associations mentioned above sit on these committees and in some cases hold chairmanships, so they play a key role in developing standards.
DSMA plays a role because it is represented in the BSI (British Standards Institution) committee for doors. BSI is a voting member of CEN and sends delegates (who have generally been DSMA nominees) to CEN meetings. Although DSMA strongly influences how BSI will vote on a particular issue, views of other national organizations (representing for example architects and consumers) are taken into account. EDSF is a liaison member of CEN TC/33 and cannot vote as such.