Is the CE marking misleading?
The CE mark has been used for quite a long time, for example, on machinery and electrical products. With the new Construction Products Regulation, it became mandatory from 1 July 2013 in all EU countries for construction products for which a harmonised product standard has been drawn up. If products do not fall within the scope of a harmonised product standard, they can be CE marked voluntarily. In that case, the product must first obtain an ETA approval.
It is important to understand that the purpose of introducing the CE mark has been solely to facilitate trade between EU countries. Its use was intended to eliminate the country-specific approval procedures used in different EU countries, which had prevented and slowed down imports.
Unfortunately, the general public has started to believe – because they have been wanted to believe it – that the CE mark guarantees quality and safety. This is not the case. It is highly regrettable that the Ministry of the Environment did not bring this aspect out at all when launching the CE mark. Tukes, on the other hand, whose task is to monitor the correct use of the CE mark, does emphasise that the CE mark is not a guarantee of the product’s safety or superiority.
The current way of using the CE mark provides a good opportunity for less conscientious manufacturers. Why do I claim this? Let us look at what kind of information the authorities require manufacturers to provide to customers. Even if a product has ten important properties that are essentially related to the product’s operation and mentioned in the standard, the manufacturer only has to declare one of them in its declaration of performance. The declaration of performance is the manufacturer’s document from which the customer can see the product’s properties. Here is a quotation from the Ministry of the Environment’s website:
“If the manufacturer does not wish to declare the values of a property, they can put NPD (no performance determined = performance not declared) in this section. The manufacturer must declare at least one performance relating to the basic characteristics of the construction product that is relevant to the intended use in cases where the Member State has no relevant official regulations at all.”
This means that the customer does not learn about all the properties essential for the use of the product if they are not regulated in Finnish official regulations or the manufacturer leaves them undeclared. Pretty absurd, isn’t it?
Another serious problem with the CE mark is that no one actively monitors its use. The responsibility for monitoring has been shifted to citizens, who can report an observed misuse to Tukes. Once it has received a report, Tukes starts its own process, and presumably few resources have been allocated to this work.
Let us take a couple of examples of how CE markings can mislead a roofing screw selector.
Many roofing screw manufacturers and importers have a CE mark based on the ETA procedure. The ETA approvals of these roofing screws are based, with regard to corrosion resistance, on standard EN 1993-1-3. This standard does not recognise painted screws, so painted roofing screws must be treated according to their metallic coating. When examining the requirements set for the coating in different atmospheric corrosivity categories, the coatings of current CE-marked roofing screws meet only the requirements of atmospheric corrosivity category C1, meaning that they are suitable for dry indoor air. You can read more about atmospheric corrosivity categories.
This means that all CE-marked, painted roofing screws have been classified as indoor-use screws, so they must not be used outdoors. This is not mentioned in the manufacturers’ or importers’ declarations of performance. One importer of roofing screws, for their part, refers in their own CE mark to a standard that is the standard for plasterboard screws. How many Finnish metal roofs have screws intended for indoor use?
It is also worth paying attention to the form of the CE mark. CE can also mean that the product has been manufactured in China. Do you notice the difference?
