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DE-01 Incorrect CE-marking of products
Report ID: 835
Report Overview
A reporter from Germany raises concerns about wrongly declared and/or insufficient DoPs (Declaration of Performance) for products according to the harmonized European standards with CE-marking.
Report Content
A reporter from Germany raises concerns about wrongly declared and/or insufficient DoPs (Declaration of Performance) for products according to the harmonized European standards with CE-marking. In one case, the fabricator of steel tension rod couplers did not provide the required information on material properties relevant for structural safety and design (design properties). The CE Doc (Declaration of Conformity) and DoP for this product indicated “No Performance Declared” (NPD) for all relevant material properties.
Furthermore, the reference made for these structural properties calls out DIN EN 1993-1-1 which, according to the reporter, seems incorrect as this type of connection is not included in this code. Anyhow, the product has been CE-marked and the reporter feels that this could lead to misuse of such kind of products during construction. The reporter feels that CE-marking itself seems to be sufficient for most people to not request further information.
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This report raises a wider concern in that a designer’s instinct may be to just accept that a product is certified and not look any further. Designers should be aware that CE marking on construction products does not guarantee that the product is safe for its intended use and the onus is on the designer to know all the product properties which they require, including the required Execution Class for steel, and then check that what is offered is satisfactory.
It is a well-known issue that some fabricators of construction products do not declare all possible characteristic product properties in their DoC and/or DoP which should be based on Annex ZA of corresponding harmonized European Standard. This permission is granted through the Construction Products Regulation (CPR) which only foresees the necessity to specify one specific product property to declare conformance with regulations (in this case harmonized European standard EN 1090-1). The BMTRADA document CE marking for structural steel to BS EN 1090-1 provides useful information on CE marking for structural steel.
Properties for construction products must be declared in tender documents based on structural/fire design and calculation and checked by all relevant parties during and after construction. In some cases, this requires very specific knowledge from highly trained and experienced personnel. As the reporter mentioned, DIN EN 1993-1-1 is not the correct code reference. Even EN 1993-1-8 as a reference would not be correct, since tension rod couplers are not specified in this code and they behave differently from bolted connections.