CEN Keymark scheme for Thermal Insulation Products

This glossary gives the full name and status of terms used,in abbreviated form or in full and intends to help with the understanding of the terms used.

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Q: What is the CCB

The CEN Certification Board supervises certification activities of CEN including the administration of the CEN/CENELEC European Mark of conformity to European Standards (EN) within CEN’s field of activity. It develops and monitors CEN Mark Schemes and oversees finances of the system. It operates and promotes the Keymark and protects against its misuse.

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Q: What is SDG-5

The Keymark System, the CEN/CENELEC European Certification Mark System, originated in 1993/1994 in response to a resolution of the EU Council of 18 June 1992, which recommended the introduction of a European mark showing compliance with European standards. CEN and CENELEC are joint owners of the Keymark. The Keymark System is based on individual scheme rules for each product. This requires the creation of so-called Scheme Development Groups (SDG) to establish conformity assessment procedures tailored to specific products.
SDG-5 is the Scheme Development Group that accomplished this work for Thermal Insulation Products, it consists of thermal insulation products manufacturers and certification bodies and testing laboratories, active in this sector. Once the Keymark is operative, its work will be taken over by the "General Assembly".

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Q: How do manufacturers obtain the right to use the Keymark ?

A manufacturer who wishes to obtain the right of use of the Keymark, should submit an application to an empowered Certification Body. The list of empowered certification bodies for the Keymark for thermal insulation products shall be kept on this website.
The Certification Body will provide appropriate information regarding the applicable Keymark Scheme, including details relating to testing and inspection procedures, and related costs. This website provides some of that information.
The manufacturer and the chosen Certification Body shall sign a contract, which sets their relationship, with respect to implementation of the Keymark system for the product(s) concerned.

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Q: Which requirements should manufacturers comply with ?

The Keymark is a voluntary third party certification, the process to be followed for the Keymark certification requires:

Approval of the manufacturer: the factory is carefully examined by the an inspection body, ensuring that the staff and the equipment are suitable to guarantee and control product quality.
Approval of the thermal insulation product: on every product for which the manufacturer requests the Keymark, the empowered certification body has the necessary tests performed in a registered laboratory. The manufacturer is entitled to use the Keymark only if the empowered certification body issues the certificate of conformity
Factory Production Control (FPC): the manufacturer entitled to use the Keymark must ensurethat the quality will be maintained and that control tests will be carried out on a regular basis. The certification body verifies that FPC provisions are complied with.

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Q: What are the benefits of the system ?

Compliance with European Standards: the Keymark gives to customers and users the clear and simple message that the thermal insulation product complies with the whole European product standard.
Access to the international market: the Keymark is recognised in all European countries, where the national standardisation body is a member of CEN (20 countries at the moment).
Combined marking: Products bearing the Keymark, can only be products meeting the CE Marking requirements (minimum safety level, in accordance with EC Directive 89/106/CEE). On top of that, the well-known national markings are also added, to ensure confidence in the national markets. Nevertheless, the "once-tested, accepted everywhere" principle is upheld, leading to reduced costs for manufacturers.
Transparency for consumers: products bearing the Keymark are inspected by independent 3rd parties.

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Q: How do certification bodies become empowered ?

The responsibility for the operation of the Keymark system rests with the CEN National Standardisation bodies (NSB), as does that for contractual arrangements with the certification bodies.
The CEN Certification Board (CCB) coordinates and empowers appropriate certification bodies that may grant the Keymark licence. This involves the following steps:
The NSB accept applications from (national) certification bodies, checking the preconditions in conformity with the CEN rules. CCB decides on the empowerment of the Certification Body. The NSB makes an agreement with the Certification Body on the Keymark licence, entitling the Certification Body to grant the Keymark together with its national (quality) mark (if it so wishes).

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Q: How can you obtain access to "Members only pages" on this website ?

To prevent confusion between working documents and final documents, the public part of the website only contains documents approved by SDG-5 or SDG-5 and the CCB. The "Members only pages" contain SDG-5 working documents. SDG-5 membership, including access to the Members only pages, is open to every thermal insulation products manufacturer, showing an interest in obtaining the right to use the Keymark, and certification bodies and testing laboratories, working in this field.
To obtain a login password, please contact the SDG-5 Secretary. Depending on availability, providing the login password might take a few days.

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Q: Relationship Keymarking and CE Marking

The Keymark for thermal insulation products is licensed for use together with the conformity marks of existing national certification systems. This has been deemed necessary, for the Keymark to gain recognition and confidence in national markets.
However, the Keymark does indicate to the customer that the product has been tested and certified in accordance with uniform criteria that apply throughout Europe. At the same time, the Keymark demonstrates the difference to CE marking and sets a standard of quality in the non-regulatory sector.

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Q: Which documents are required to both CE and Keymark ?

Because CE Marking and Keymarking are normaly being applied simultaneously, it is important for manufacturers to know which documents are relevant, next to the SDG-5 documents, to obtain the CE Marking and the Keymark.
The following documents are relevant for CE Marking:

Standards:

EN 13162 through 13171: Product standard factory made products for buildings
EN 13172: Evaluation of Conformity standard
Draft EN 13172:2001/prA1:2001 Amendment 1 to Evaluation of Conformity standard
Supporting test standards referred to in the above standards

Notes:
The standards above gives the requirements for the relevant products. These standards are developed based on the CPD, the EC mandates to CEN/TC88 and the Guidance papers A through K.
These documents should be obtained from the CEN National Standardisation Bodies.

Notified bodies sector group 19 (thermal insulation products):

NB SG 19 N 15: Accuracy statements test methods (CEN/TC88/WG1)
NB SG 19 N 23: Guidance note for CE marking of thermal insulation products
NB-CPD/01/03 (SG19 N24): Criteria for notification of laboratories (SG 19 resolution 1)
NB SG 19 N 30 rev.1: How to achieve and maintain declared thermal conductivity for a manufacturer
NB SG 19 N 37: Guidance for the system of attestation of conformity (interpretation of AoC caused by reaction to fire declaration)
NB SG 19 N 38: Transitional arrangements for the CE-marking of thermal insulation products (a synthesis of and supersedes N 32 and N 36)

Note:
These documents can be obtained on the Circa website of the European Commission, or from the Empowered Certification Bodies.

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The Construction Products Directive 89/106/EEC of 21 December 1988,amended by Directive 93/68/EEC of 22 July 1993, has the purpose to eliminate technical barriers to trade for construction products.

This goal shall be achieved by requesting Member States to take all necessary measures that only products, which are fit for the intended use, may be put on the market.
On the other hand products which are considered fit for their intended use in one Member State, must also be allowed to be used in the other Member States.

The main scope of the directive is the abolishing of unjustified technical barriers in the free movement of Construction products.
Fit for the intended use means, that the products "have such characteristics that the works in which they are to be incorporated, assembled, applied or installed, can, if properly designed and built, satisfy the essential requirement referred to in Article 3 (Mechanical resistance and stability, safety in case of fire etc) when and where such works are subject to regulations containing such requirements".

For the purpose of the CPD „construction product" means any product, which is produced, for incorporation in a permanent manner in construction works including both buildings and civil engineering.
Construction products also include installations and parts therefor heating, air conditioning, ventilation, sanitary purposes, electrical supply and storage of substances harmful to the environment, as well as prefabricated construction works which are marketed as such, for example prefabricated houses, prefabricated garages and silos.
Further to this the Commission has issued a Guidance Paper C „The treatment of kits and systems under the Construction Products Directive". A construction product is a "kit" when it is a set of at least two separate components that need to be put together to be installed permanently in the works. There it becomes an „assembled system". The kit is a construction product; the assembled system is none.

For construction products which conform to a harmonised European specification according to the CPD and which bear the CE-marking it shall be presumed, that they are fit for the intended use.

For some construction products not only the CPD applies, but also other relevant Directives; e.g. permanently installed sewage-pump is by definition a construction product, for which not only the CPD has Essential Requirements concerning the protection of health, hygiene and environment but to which also Essential Requirements of the Directive on safety of Machinery and of the Low Voltage Directive apply. The essential requirements of all relevant directives have to be fulfilled for the purpose of CE Marking.

By the principles of the New Approach, the CPD and the Directives for public procurement the European standardisation gets a special importance.

In general „normal" European Standards, transposed into national standards, have the status of recommendations or voluntary specifications, which become binding only when agreed upon e.g. by contract or a special administrative or legal act.

By the provisions of the CPD and other directives „harmonised" European Standard becomes binding in particular for Member States governments' and similar bodies.

"Harmonised" standards are those standards for which the Commission has given a mandate under a „New Approach Directive" to CEN to elaborate such a standard.
Based on the CPD such mandates are given for product standards and related test standards.

In the Interpretative Documents therefor distinction is made between A-Standards and B-Standards:

The most important preconditions for marking a construction product with the CE-marking are the attestation of conformity of the product by the manufacturer.

The procedure for attestation of conformity consists of different elements, which may be performed by the manufacturer in its own responsibility or with involvement of an approved testing, inspection or certification body.

CPD annex III lists the elements that may be used for attestation of conformity. Furthermore the annex contains systems with a combination of elements which should be applied for construction products preferably.

The system to be applied for a product is specified by the Commission. The decision has to take into account (see CPD article 13(4)):

The decisions are published in the Official Journal of the EC; they are binding for all manufacturers. The systems will be further detailed in the technical specifications.

The Commission decides on the composition of the system for each product family. The decisions are published in the Official Journal.

A survey on the systems, which has been decided upon by the Commission, is given underneath. In the systems, it is clearly stated which tasks have to be done by which party, the manufacturer or the approved body. Approved bodies may be testing bodies, inspection bodies or certification bodies depending on the tasks given to them. It is task of the specification writers to detail further in the technical specifications the specific tasks of the different parties; this will lead to a comparable performance of the attestation system in all European states and by this gives confidence in the CE-marking, independent of the origin of the product and the bodies involved.

In the case of the CPD, the CE marking indicates that the product complies with the relevant national standards transposing the harmonised standards, or a European technical approval, or one of the national technical specifications referred to in Article 4 (3), and that the system of attestation of conformity laid down in the Commission Decision relating to the product has been applied.

Member States are obliged to take appropriate measures to protect the CE marking.

The CE marking is the only marking which indicates that the products conform to the directives based on the principles of the New Approach. It must replace any mandatory conformity markings having the same scope as the CE marking, which possibly existed in the national laws, regulations and administrative provisions of Member States before harmonisation occurred.

The CE marking is neither a mark of origin, indicating "made in the EEA", nor a quality mark. Once all obligations arising from EC law (directives, Treaty provisions etc.) have been respected, a product may also bear different marks arising from other systems, such as a voluntary quality mark or a voluntary standardisation mark concerning non-harmonised aspects, on condition that the visibility and legibility of the CE marking are not reduced, and provided that such marks are not likely to deceive third parties as to the meaning and form of the CE marking.

A producer remains entitled to go beyond the strictly legal requirements, for commercial or marketing reasons, allowing a product to be positioned on the market in the normal way. Any statements accompanying a product but relating to non-harmonised aspects must be kept distinct from the information accompanying the CE marking.

Non-harmonised aspects must not, under any circumstances, be presented in such a way that they may be confused with harmonised ones, nor in such a way that the CE marking, either deliberately or by mistake, may be considered to apply to them.
The CE marking must be affixed visibly, legibly and indelibly, with the form as described in Council Directive 93/68/EC and Council Decision 93/465/EC, and must be easily accessible for the market surveillance authorities. In the case of the CPD, the CE marking must be affixed on the product itself, on a label attached to it, on its packaging, or on the accompanying commercial documents. The CE marking must be affixed before the product is placed on the market.

The manufacturer, or his authorised representative established in the EEA, may decide when to affix the CE marking, depending upon the circumstances of the production process of the product in question. Where the CE marking is affixed sometime after the manufacture of the product, for example after storage in a warehouse, the validity of the testing carried out during production must be confirmed. The CE marking must include the identification number of the notified body, where this body is involved in the production control stage, as defined by the relevant directive. All products shall indicate their intended use in one form or another (e.g. in words, symbols, abbreviations, pictograms, ...), unless reference to the technical specification itself is sufficient. If necessary, the technical specification shall lay down rules concerning the means for indicating the intended use(s) of the product(s) concerned.

The producer is responsible for the conformity of the product at the time it is placed on the EEA market (i.e. the initial action of making a product available on the EEA market, with a view to its distribution and/or use within the EEA). He has no responsibility to ensure that the accompanying information passes further down the supply chain.

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