Starting on 1 March 2002, manufacturers of thermal insulation products can affix the CE Marking to their products. On 1 March 2003, CE Marking becomes an obligation for manufacturers putting those products onto the market in the EEA.
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The CE marking, affixed to a construction product, means that the product satisfies the provisions of the Construction Products Directive (89/106/EEC), by showing conformity with the relevant harmonised technical specification, including the conformity assessment procedures laid down in the relevant Attestation of Conformity decision. For thermal insulation products, it means that the product is in conformity with the harmonised part of the European standards, elaborated by the CEN Technical Committee 88 "Thermal insulation products". |
The Annex ZA of those standards, reflects the content of the harmonised part of those standards. Characteristics, which are part of the product standard, but which are not being referred to in Annex ZA, have no relationship with the CE Marking.
In case construction products are subject to other Directives with regard to other aspects, which also provide for the affixing of the CE marking, the CE marking indicates that the product also satisfies the essential requirements of those other Directives. This is however not the case for thermal insulation products.
The CE marking thus demonstrates that the product meets all the legal requirements necessary for it to be placed on the entire European Internal Market, comprising the EEA Member States, consisting of the 15 European Union Member States and three of the European Free Trade Association Member States (not Switzerland).
The Construction Products Directive expressly forbids product markings which might deceive or mislead third parties as to the meaning or form of the CE Marking, or that reduce its visibility or legibility. However, the European Commission accepts additional markings if they provide an added value in signifying conformity with requirements or performances that are different than those of the CPD, so the basis for delivering these other markings must go beyond the essential requirements, harmonised standards and/or conformity assessment procedures required by the CPD.
The European Commission promotes European-wide voluntary "quality" markings that provide added-value and hopes that they will gradually replace existing nationally based marks, instead of merely complementing or duplicating them.
| The insulation industry, supported by third party conformity assessment bodies, active in that sector, introduces a certification scheme, the CEN/CENELEC Keymark for its products, because it is being felt that the CE Marking does not fully cover market and industry needs. |
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Contrary to the CE Marking, the Keymark for thermal insulation products stands for conformity with the complete European product standards produced by CEN/TC88, rather than only the harmonised part of the standard. Furthermore the scheme foresees testing by an independent laboratory, the competence of which has been recognized by SDG 5, i.e. an SDG-5 registered laboratory, and full certification of all the declared characteristics, i.e. also the thermal conductivity of the products, which is not a requirement according to the CPD.
The CEN/CENELEC Keymark scheme is completely voluntary, but it is generally assumed that the market (builders, architects, engineers) will require manufacturers to show that they meet the stringent European requirements for the most essential property of thermal insulation products, the thermal conductivity.
Because a number of countries already have national voluntary certification schemes in operation, the Keymark scheme foresees that the Keymark will be accompanied by one of the well-known and trusted national markings, to ensure confidence in the new marking throughout the construction sector.
