CE Marking and the Sealed Unit Manufacturer

The implications of Document L are fast approaching, soon every insulating glass unit will have to be made with K glass or equivalent. This fact alone will create major difficulties for many. It is estimated that out of the 4000 manufacturers currently producing units, this figure could drop to between 1500 to 2000.

So, for those that remain, the future should be good, just sit back and wait for the work to come in. THINK AGAIN

Following close behind Document L is CE Marking. CE Marking requires companies to have their units tested to EN 1279 Part 2 for standard units and, if gas filling is employed, EN 1279 Part 3 as well. The second major requirement is that a system of factory production control be operated conforming to EN 1279 Part 6.

We now know that EN 1279 will be fully published by June 2003 with a twelve month transition period before it becomes law. After that point, anyone supplying units either without a CE Mark or illegally exhibiting a CE Mark will be liable to a fine up to £5000 and/or three months imprisonment. This is enforceable by local Trading Standards Offices

At present, the preferred and only logical route to attain EN 1279 is via British Standards. BSI have invested over £500,000 in test equipment and laboratories in order to respond to the testing requirements. BSI will Kitemark against this new standard when EN 1279 Parts 1,2 and 3 are published. This is due in August, and it will be known as BS EN 1279. BS 5713 may run alongside this for a while but with current licensees, approx 250, already well into the EN 1279 testing programme, it is not feasible for new applicants to test to anything other than BS EN 1279. In fact, in many cases, it will be significantly cheaper this way.

Now, we come to the important part, BSI have an overall testing capacity of 330 sets of units per year. Take out the current EN 1279 testing programme for existing licensees and ongoing EN 1279 Part 3 testing for gas filled units and they probably have a capacity for about 500 new applicants until CE Marking becomes law. However, there may be as many as 1500 companies wanting to apply.

BSI operate on a strictly first come, first served basis. Nobody can jump the queue. You don’t need to be a maths genius to work out that 1500 into 500 doesn’t go. Therefore if you are serious about manufacturing insulating glass units, you need to weigh up the consequences and act now. Waiting twelve months or even six months could have a drastic effect on your ability to get units tested on time. These 500 slots will soon fill up and you should therefore ask yourself – do I want to be one of the 500 in the system or one of the 1000 left on the outside, waiting to see if anyone else can test units for them.

It is unlikely that anyone is going to make the level of investment, between £500,000 and £1,000,000, to make up the testing shortfall. Especially when a large majority of the equipment could be redundant after two years when everyone had been tested. Even if you can find another test house, the costs will be, at best, similar. You will still require a quality system written for the factory production control, assuming you can find a consultant to write it. The result may be that you would be able to CE Mark, but your competitors who acted quickly will have the Kitemark as well as the CE Mark and will be able to use that to maximum advantage.

Unfortunately, this has now become a numbers game, if you don’t do anything about it, someone else will. Although a lot of this information may seem doom and gloom, the opportunities for those who plan ahead now are tremendous. At DJ Glass Services, we can offer you the following consultancy options:

25 years unparalled experience in unit manufacturing at all levels – you may need assistance or advice with your unit manufacturing process to maximise your chances of passing the stringent EN 1279 test.

Cost-effective pricing structure covering writing of quality manual, full implementation, audit training and assistance at assessment and post-assessment corrective actions.

Adaptable for all types of unit manufacturing operations.
Please contact David Frost for further details.
Email: d.frost3@ntlworld.com