CE Marking of Wood Products, in particular MDF


Introduction

The great variety of national requirements for construction products – and incorporated in the building regulations - in the Member States of the European Union constitute a real barrier to the creation of a truly internal market where products and services should be circulating free. Aiming at solving this problem, the European authorities adopted the Construction Products Directive (CPD) of which the CE marking is the visible result in practice.


The Construction Products Directive

The Construction Products Directive was published in the Official Journal of the European Union under the reference 89/106/EEC. The CPD aims at ensuring that all construction products are fit for their intended use by requiring that they allow construction works to satisfy six essential requirements during an economically reasonable working life. These six essential requirements are:

1. Mechanical resistance and stability;
2. Safety in case of fire;
3. Hygiene, health and the environment;
4. Safety in use;
5. Protection against noise;
6. Energy economy and heat retention.

The requirements of the CPD have been translated into performance characteristics and factory production control methods that are laid down in “harmonised European standards (EN)” or in “European Technical Approvals (ETA)” that allow the Member States to formulate their requirements in a common language.

For the purposes of the CPD, a construction product is defined as “any product which is produced for incorporation in a permanent manner in construction works, including both building and civil engineering works”. Severals products may form together a kit which is considered as one produit by the directive.


The CE marking

The CPD requires that all construction products shall bear the CE marking before being placed on the market. With this CE marking, the manufacturer declares that the product complies with all the specifications in the reference documents and that he is therefore allowed place it on the entire market of the European Economic Area. The manufacturer may put additional quality marks on his products, provided these marks do not do not cover characteristics concerning the essential requirements, are not compulsory by nature, to not hamper the legibility of the CE marking and do not confuse the user.


The procedure for the attestation of conformity

The European Commission has given mandates to CEN (European Committee for Standardisation composed of national standardisation bodies) to develop harmonised standards. These mandates specify for each product family which procedure shall be applied for attesting the conformity with the Directive. Several systems of attestation of conformity exist (called 1+, 1, 2+, 2, 3 and 4, from the most complete to the most basic). The system of attestation of conformity specifies the role of the manufacturer and the notified body in ensuring that the product is in conformity with the requirements of the CPD. Notified bodies are nominated by the Member State to be experts in independant certification according to the CPD. They are notified by the Member States to the European Commission and have competence on the entire EU market for construction products. The list of Notified Bodies can be consulted at the following addresses: http://europa.eu.int/comm/enterprise/nando-is/cpd/home/ or http://europa.eu.int/comm/enterprise/newapproach/legislation/nb/en89-106-ec.pdf.

The more essential the role of the product in the construction work, the higher the system of attestation of conformity will be and the more important will be the role of the notified body. Nevertheless, even in cases where the CE marking does not require more than a simple declaration of conformity by the manufacturer (system 4), the producer shall install an internal factory production control in his factory. If the market surveillance mechanism, organised by the Member State, identifies a non-conformity, the investigation of the internal factory production control system will indicate in how far the manufacturer may be held responsible.

Regardless of the form in which it appears simple (solid timber) or complex (wood-based panel, composite elements…), wood often performs two essential functions that necessitate the most severe system of attestation of conformity : a structural function and/or a fire retardant function.


Which obligations and when?

The CE marking for construction products is being introduced gradually as the harmonised European standards and the European technical approvals become available. CE marking will normally become obligatory for a construction product 21 months after the date of publication of the harmonsed standard or the ETA. The procedure for the implementation of a harmonised European standard and an ETA are explained in detail in the document « Guidance Paper J » which is available onhttp://europa.eu.int/comm/enterprise/construction/internal/guidpap/guidpap.htm.

For the time being, in the field of wood products only the harmonised standard for wood-based panels has been published officially by CEN. It has the reference number EN 13986 “Wood-based panels for use in construction – Characteristics, evaluation of conformity and marking” and was harmonised by the European Commission through the publication of the reference to the standard with the implementation dates of the CE marking in the Official Journal of the European Union. A « co-existence period » allows the Member States to replace their national standards and to adapt their regulations to the new EN standards.


Transformation and use of wood: which products are affected?

Over time, all construction products will show the CE marking, as it will be a legal requirement before the product can be placed on the market in the countries of the European economic Area. The list of harmonised standards (published and prENs under development as well as the European Technical Approval Guidelines (ETAG) applicable to wood products can be consulted at the following adresses:http://www.cenorm.be/sectors/construction2/resources/Snapshot.pdf and http://www.eota.be.

Each production unit will be obliged to apply the requirements of the CPD and the CE marking regardsless its size. However, the CPD applies only to products that are produced for incorporation in a permanent manner in construction works. Consequently, a significant part of the woodworking sector is not concerned by the CPD, such as the furniture and the packaging industry.

The raw material wood, whether solid wood or wood-based panels, is sourced from all over the world. An American or an Asian producer will therefore be required to affix the CE marking and to comply with the CPD in exactly the same manner in order to get access to the European construction market.

Be aware that, because all contruction products will be marked at a certain moment in time, the CE marking does not present a criterion for choice and even though the external control will be effected by a notified body, the CE marking must not be considered as a quality mark.


The example of wood-based panels

Wood-based panels are pioneers in the field of CE marking. Since 1 April 2003, the CE marking of panels is permitted but not compulsory. It is compulsory for all wood-based panels intended for use in construction from 1 April 2004 onwards.

The CE marking consists of the letters “CE” in the format specified in the CPD, accompanied by several important informations. As an absolute minimum, the CE marking of wood-based panels shall always show the following:
• The characters ;
• Name and/or identifying mark of the producer;
• Last two digits of the year when the marking was affixed;
• Number of the relevant harmonised standard (EN 13986) with which the product complies;
• For structural or fire treated elements: identification of the notified body and number of the EC certificate of conformity.

The CE marking and the accompanying information shall be placed on the product itself, on a label attached to it, on its packaging, or in the accompanying commercial documents. A combination of locations for the CE marking and the accompanying information may also be used, provided the complete information is given on any of these locations.


CE marking of standard MDF

The CE marking information for standard grade MDF (density 600 kg/m_) for internal use in dry conditions on the accompanying commercial documents may be presented as follows:
 

This CE marking was affixed by the company “AnyCo” in the year 2004. The product complies with the performance characteristics for type MDF given in Table A.9 (according to EN 622-5) and it is classified as class E1 according to Annex B of EN 13986.

The manufacturer declares that the density of his panels for the thickness classes covered by the CE marking (e.g. for a 16 mm panel) exceeds the threshold value limit in Table 8 of EN 13986. He also declares that his product achieves the threshold value requirements for the performance characteristics specified for type MDF in EN 622-5 and provides these values for information to the customer.

Furthermore, the product meets the requirements for the Euroclass D-s2,d0 for reaction to fire in accordance with Table 8 and has a PCP-content of less than 5 ppm, so the PCP-content is not specified in the CE marking and has not been treated against biological attack, therefore this treatment is not specified in the CE marking.

Where the manufacturer wishes to deliver a summary of the CE marking with each package, he may do this in the form of a label as illustrated below, which could also be printed on the packaging.

Finally, a minimum of CE marking information may be affixed on the product itself with a designation as follows:

AnyCo, EN 13986, MDF, 15 mm, E1
CE marking of MDF for use in structural applications in dry conditions

The CE marking information for MDF (density &Mac179; 600 kg/m_; thickness &Mac179; 9 mm) for internal use as a structural element in dry conditions (type MDF.LA) may be presented on the commercial documentation or as a label or printed on the packaging as follows:

This CE marking was affixed by the company “AnyCo” in the year 2004. This company is under the supervision of the notified body 0123-CPD-2345, where 0123 = the identification number of the notified body and 2345 = the individual number that was given by the notified body for this product that is intended for structural applications.
The product complies with the performance characteristics for type MDF.LA given in Table A.9 (according to EN 622-5) and it is classified as class E1 according to annex B of EN 13986.
Furthermore, the density of the panel is > 600 kg/m_ meets the requirements for the Euroclass D-s2,d0 for reaction to fire in accordance with Table 8 of EN 13986. Consequently, the reaction to fire classification is not specified. The product has not been treated against biological attack, therefore this treatment is not specified in the CE marking. Finally, the product contains less than 5 ppm PCP. Consequently, the PCP-content is not specified on the CE marking.
A minimum of CE marking information may be affixed on the product itself with a designation as follows:

  0123-CPD-2345 AnyCo 04 EN 13986-MDF.LA 15mm E1


CE marking of fire retardant MDF for use in structural applications in humid conditions

The CE marking for MDF for internal use as a structural element in humid conditions (type MDF.HLS) that has been treated with fire-retardant chemicals may be presented on the commercial documentation or as a label or printed on the packaging as follows:
 

This CE marking was affixed by the company “AnyCo” in the year 2004. This company is under the supervision of the notified body xxxx-CPD-yyyy, where xxxx = the identification number of the notified body and yyyy = the individual number that was given by the notified body for this product that is intended for structural applications.
The product complies with the performance characteristics for type MDF.HLS given in Table A.9 (according to EN 622-5) and it is classified as class E1 according to annex B.
Furthermore, the board has been tested and classified in accordance with EN 13501-1 as Euroclass C-s2, d0. The reaction to fire class alone is given on the label or be printed on the packaging. However in this case, the end-use conditions are given in the commercial documentation. The product has not been treated against biological attack, therefore this treatment is not specified in the CE marking. Finally, the product contains less than 5 ppm PCP. Consequently, the PCP-content is not specified on the CE marking.

A minimum of CE marking information may be affixed on the product itself with a designation as follows:

  0123CPD2345 AnyCo 04 EN 13986MDF.HLS 22mm  E1 C-s2, d0