How Brexit might affect the fire protection sector

International director, BRE Ltd

March 8, 2019

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The vast majority of fire protection products such as fire detection and suppression systems, construction materials and products, fire stopping and service installations are within the scope of the European Construction Products Regulation (CPR) No. 305/2011.

The CPR harmonises how the performance of construction products is assessed and marketed and provides the means for verifying the conformity of construction products to a series of European technical standards (hEN or EAD, i.e. harmonised European standards or European Assessment Document).

This means that a manufacturer should only have to carry out the assessment and verification of conformity of their product in one Member State of the European Union (EU) and once the CE mark is obtained, that product can be placed on the market anywhere in the EU.

The process of assessing and verifying the conformity of products for manufacturers is carried out by Notified Bodies. These are certification and/or testing bodies accredited within their Member State and designated by their associated government department. These bodies and the associated scope of their accreditations are listed on a central EU website called NANDO.

Planning for No Deal

When the UK leaves the EU, whether that is on the 29 March 2019 with a ‘no-deal’ Brexit or December 2020 with a deal agreed, UK Notified Bodies (testing and certification) will lose their Notified Body status. All UK Notified Bodies will be removed from the NANDO website and their Notified Body number deleted.

Clearly, the current political situation is creating uncertainty for all businesses that are involved in or rely on trade between the EU and UK and CE marking of products. Faced with such uncertainty, a large number of companies that work with current UK Notified Bodies from within the EU have taken the decision to plan for a no-deal Brexit.

BRE Global is a UKAS-accredited testing and certification body and is also a Notified Body listed on the NANDO website. Since the referendum result was announced, we have been planning for Brexit and have set up a legal entity in Dublin called BRE Global (Assurance) Ireland.

We have successfully completed our assessment with the Irish National Accreditation Board (INAB) (you can view our scope of services on the INAB website) and expect to be listed on the NANDO website with a new Notified Body number this month.

At that point in time, we will have two fully accredited and designated Notified Bodies operating within the EU. This major decision for our business was not taken lightly and it is the subject of continuing significant investment to set-up in an EU27 Member State.

Our customers, like those of other UK Notified Bodies, need to continue to CE mark their products to place them on the market in Europe. Based on the current uncertainties and a worst-case scenario, it seems that most customers are looking to transition their CE marking certificates across to an EU27 Notified body and in our case BRE Global Ireland.

Due to the extremely short timescale, this is a priority matter for all those concerned and has resulted in a high workload. This is inevitably impacting manufacturers’ resources in terms of bringing new products to market.

Under CE marking procedures, the Technical Specification – hEN or ETAG (if still current) or EAD – specifies the Assessment and Verification of Constancy of Performance (AVCP) level. The AVCP level defines the requirements placed upon the manufacturer and the Notified Body.

Products that are AVCP system 1 require the manufacturer to enter into a contract with a Notified Body who will be their recognised third-party certification body and who will be demonstrably competent and responsible for the management of:

  • assessment of the performance of the construction product
  • certification of constancy of performance
  • factory production control certification

The testing can be undertaken at a laboratory (by sub-contract) chosen by the Notified Body and be located outside of the EU provided that the project management/certification activities and final assessment function of the Notified Body:

  • are within the EU
  • have demonstrable management control of the process (as designated)
  • have been undertaken with the appropriate technical capability
  • have been carried out in the jurisdiction

The testing of such products can continue at UK laboratories and continue to be fully compliant with the requirements of the Construction Products Regulation post Brexit.

As part of BRE’s strategic approach, BRE Global is planning to increase its fire testing capacity with a new facility which will be located in the Republic of Ireland from where we plan to offer both reaction to fire and fire resistance testing.

This is particularly relevant for the testing of products which have an AVCP system 3 requirement. Such systems only need the involvement of a notified test laboratory (not a certification body.) As such, our current understanding is that this testing will need to be undertaken within the EU27 to be compliant with the Construction Products Regulation.

‘UK Approved Body’ and ‘UK CA’ (UK Conformity Assessment mark)

 In the event of a “no deal” Brexit on the 29th March 2019, BRE Global and other UK Notified Bodies will transfer to become a ‘UK Approved Body.’ In this circumstance, after a still undefined transition period, all products placed on the UK market will be required to carry a “UK CA” mark (UK Conformity Assessment mark) instead of CE marking.

BRE Global UK will provide the necessary assessment of conformity and the certificate which will initially “mirror” the requirements for CE marking under the Construction Products Regulation, Marine Equipment Directive (MED), Pressure Equipment Directive (PED) and Transportable Pressure Equipment Directive (TPED). More information on this subject can be found on the government website.

Continuity of standards

The UK government has indicated its commitment to the continued support and adoption of European Standards (ENs) that are developed and published by CEN and CENELEC, after Brexit. BSI in its role as the UK National Standards Body will remain a member of the relevant European Standards Organisations (CEN CENELEC and ETS) and they will publish the standards as BS ENs.

The UK will continue to contribute to the development of the standards through the provision of Chairs, Technical Secretariats and Technical Experts who are generally elected by their peers from a broad industry representation to the relevant committees. BRE Global staff are active participants in the key committees and will continue to contribute in their elected functions without change.

Product certification

An increasing number of countries are now adopting ENs and as our certification schemes are typically based on ENs, the Authorities will readily accept LPCB certification.

Guidance in support of the UK Building Regulations state that Building Control Bodies can accept certification of products, components, materials or structures as evidence of compliance if it is established that the scheme is adequate and relevant to the purposes of the Building Regulations. Product certification is optional and not mandatory. It is also not to be confused with classification which is based on the outcome of a specific test or set of tests which define the field of application of a product (the limitations on how and where it can be used) and no more.

Independent third-party schemes of certification provide confidence in the consistency of manufacture linked to the performance of a product. They provide confidence that if installed properly, the product will deliver a level of performance.

The product related information is published by certification bodies so that users can validate manufacturers’ claims and satisfy themselves that the right product has been selected for an application. BRE Global UK has for many years provided certification of fire and security products using the LPCB brand.

In a post-Brexit world, there will be no change at all in this area of our work and certification will continue to be based on our Loss Prevention Standards (LPS) many of which are based on ENs. For the product manufacturer all current LPCB certificates will remain valid.

The LPCB brand is accepted by authorities, having jurisdiction in approximately 65 countries worldwide. There is no reason why this should change.

European associations

BRE Global is active and will continue to participate in associations such as EFSG (European Fire and Security Group). This group brings together BRE, VdS, CNPP, AFNOR, DBI, SBSC and ANPI as certifiers of fire detection and alarm systems, intruder alarm systems, safes and high security locks who will grant certification for a product based on one set of tests from any member Associated Test Laboratory. This can deliver significant cost savings for manufacturers.

BRE Global will also continue with its membership of EGOLF (European Group of Organisations for Fire Testing, Inspection and Certification) and is relevant to the plethora of testing and classification standards for construction products, services and passive fire protection products.

BRE Global is an independent third party organisation offering certification of fire, security and sustainability products and services around the world. BRE Global (LPCB) will be showcasing their services and consultancy at IFSEC International Stand No IF550, London 18-20 June 2019. Register now to secure your free ticket.

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