Door Industry Journal - Winter 2015

Also online at: www.dijonline.co.uk THE door industry journal winter 2015 industry news feature 6 CE-marking and installing a powered garage door - What are the installer’s CE-marking duties when installing a powered garage door? Over the last couple of months there has been a lot of talk in the garage door industry about the legal considerations to be aware of when automating doors using garage door openers from different suppliers. Naturally, many dealers have been concerned about what they see as onerous installers’ obligations. Consequently this resulted in us receiving several calls asking for clarification to answer these industry concerns. Not being experts ourselves in this field, we turned to Michael Skelding, General Manager at the Door and Hardware Federation (DHF) to provide some expert guidance for the industry through the article below. Introduction Under the Machinery Directive and the Construction Products Regulation the powered door must be CE marked when first made available on the EU market. Is the installer the responsible person? The answer depends on whether the installer has acquired any of the duties of a “manufacturer” under the legislation. Where the installer is not responsible If the installer has bought a door and drive unit intended to work together from a single supplier located in the EU and they have not modified the products, then the installer has no responsibility to apply the CE marking. The installer does, however, have to ensure that all the relevant documents have been provided by the manufacturer and are passed on to the end-user: 1. Declaration of Performance (DoP) under the Construction Products Regulation 2. Declaration of Conformity under the Machinery Directive 3. Instructions for use, including maintenance 4. CE marking on the powered garage door Where the installer is responsible The most common situation where the installer will be responsible is when they select a manual door from one manufacturer and an operator from another manufacturer. In this case, the installer becomes the responsible person because he or she is the first person to make the complete powered door available on the market. So what needs to be done? The installer becomes responsible for creating the documents listed above and for passing these to the customer. The installer should also retain copies of these, together with the other documents identified below, in a technical file. The remainder of this article is an outline of the process by which these documents can be created; in the relatively simple case of combining a door and operator from different manufacturers, this should not be too daunting! Construction Products Regulation The manual door should already have a Declaration of Performance (DoP) under the Construction Products Regulation; this has been a legal requirement since 1 July 2013. This document, made by the original manufacturer (or possibly the importer if the door was manufactured outside the EU), will declare the product’s performance against ten “essential characteristics” listed in the European standard, EN 13241-1. For some of these characteristics it is possible to declare