Three documents have recently emerged from the Group of Notified Bodies and the Commission affecting the way notified bodies operate:
The EU Commission’s paper of 22 January 2018 confirms that, from 30 March 2019, UK notified bodies will cease to be recognised by the EU, (unless a transitional agreement is reached which establishes a different date). Members currently using UK notified test laboratories or notified product certification bodies are advised to ask about arrangements being made by their existing notified body to ensure continuity of service after the above date.
The Group of Notified Bodies for the CPR has issued a guidance paper concerning rebranding and subcontract manufacture. This defines the “physical producer” who manufactures a product intended to be placed on the market as a rebranded construction product under the name of another company, known as the “rebranding manufacturer”. It is made clear that the physical producer in this situation is NOT the manufacturer for the purposes of the CPR. Consequently, the physical producer is not responsible for CE marking the product or issuing a DoP in their own name.
The rebranding manufacturer is responsible for placing the product on the market and hence is responsible for applying the CE marking and issuing the DoP.
If the product requires a notified body certificate, the certificate must be issued in the name of the rebranding manufacturer; it is not possible for the rebranding manufacturer’s DoP to refer to a certificate in the name of the physical producer.
The Group of Notified Bodies for the CPR has issued a guidance paper on use of subcontractors by notified bodies. This represents a change from the practices permitted under the old Construction Products Directive.
It is no longer possible for responsibility for any essential characteristic to be shared between notified bodies; one notified body must take full responsibility. However, the responsible notified body may use subcontractors to carry out work on their behalf, provided that they take full responsibility for the assessment and the work of their subcontractors.
Any subcontractor must meet the requirements of CPR relating to impartiality and independence; consequently, a notified body cannot subcontract any work to a manufacturer’s own laboratory or inspection body.
However, this would not necessarily prevent the use of manufacturer’s facilities, provided that any testing is clearly managed and controlled by the notified body.
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