The advice relates, in particular, to the definition of series production and whether or not the exclusion given in Article 5a of the Construction Products Regulation applies to the manufacturing of curved steel sections.
Article 5 provides three exclusions from the requirement to CE Mark a construction product. These are:
a) Where the product has been individually manufactured or custom made in a non-series process in response to a specific order.
b) Where the product has been manufactured on site.
c) Where the product has been manufactured using traditional methods.
The Council reviewed the processes used to manufacture curved steel sections and the European Commission’s guidance on the interpretation of series and non-series production given in CPR 07/07/1 – Explanation of Article 5a of the CPR and Guidance Paper M.
KCC concluded: “Due to the nature of the industrial processes commonly used in their manufacture, curved steel sections are a construction product whose method of production falls within the definition of series production.”
British Constructional Steelwork Association (BCSA) Director of Engineering Dr David Moore said: “In simple terms this means that curved steel sections manufactured using an industrial process must be CE Marked in accordance with BS EN 1090-1.”
Primary Authority assured advice drives greater consistency and certainty and once issued must then be taken into account by other local authorities when dealing with that regulation.
Working with KCC’s trading standards, the BCSA is able to seek clarification on the requirements of BS EN1090 and CE marking as it has a direct partnership with the Council’s Trading Standards Service via a primary authority agreement.