THE CONTEXT
The Regulation (EU) No 305/2011
Regulation (EU) No. 305/2011 'Construction Products' (Regulation) introduced harmonised rules
for the expression of the performance of construction products in relation to specific essential characteristics
for the affixing of CE marking on construction products
According to the Regulation, a 'construction product' is any product or kit which is manufactured and placed on the market for being
incorporated in a permanent manner in construction works - i.e. buildings and civil engineering works - or parts thereof, and
whose performance affects the performance of the construction works with respect to the so-called Basic Works Requirements (BWR)
The above-mentioned harmonised rules have been translated in practice by the Legislator into the instrument of the Declaration of Performance and CE marking under the Regulation, which the Manufacturer is obliged to fill in and affix to the construction product respectively when
the construction product falls within the scope of a harmonised standard to the Regulation
the construction product is in conformity with a European Technical Assessment issued for that product
The harmonised technical standard EN1090-1:2009+A1:2011
The technical standard EN1090-1:2009+A1:011 "Execution of steel and aluminium structures Part 1: Requirements for conformity assessment of structural components" is a harmonised technical standard under the Regulation and provides for the mandatory CE marking under the Regulation from 1 July 2017 for steel and aluminium structural components intended for structural use in all types of construction works.
The European Commission, through a dedicated FAQ published on the portal of DG Growth - Section 'Construction' has specified that CE marking under the Regulation on the basis of the harmonised technical standard EN1090-1:2009+A1:2011 is mandatory if:
the construction product is manufactured and placed on the market for incorporation in a permanent manner in construction works or parts thereof and whose performance has an effect on the performance of the construction works with respect to the basic requirements for construction works
the product has a structural function in relation to the construction work;
structural function means that any 'failure/collapse' of the product would affect the Basic requirement BWR 1 'Mechanical Strength and Stability of Construction';
the product does not already fall within the scope of a technical standard harmonised with the Regulation or does not already comply with a European Technical Assessment.
CE MARKING OF THE GRATING PANEL
Based on the above considerations, the position of ASSOGRIGLIATI Anima Confidustria Association for the correct application of the Regulation is as follows.
When dealing with metal grating, two distinct functions must be borne in mind
the intrinsic function of supporting an applied weight, which must be considered in relation to the very resistance of the metal grating which, subject to an action (such as a weight or other loads), must not collapse, thus guaranteeing the safety of goods or persons;
the structural function referred to in the Basic Requirement BWR 1 of the Regulation, which must be considered in relation to the construction work, for which any failure could lead to the collapse (complete or partial) of the construction work.
Considering the possible applications of metal grating
Metal grating intended for those applications where it is only required to perform its intrinsic function - e.g. the construction of fences and perimeters, partitions and walls, infills to fixtures,... - DOES NOT fall within the scope of application of the technical standard EN1090-1:20009+A1:2011 harmonised with the Regulation, which is mandatory from 1 July 2017.
Consequently, it does not need to be accompanied by the declaration of performance and be CE marked in accordance with the Regulation.
However, it is the manufacturer's option to accompany the product with a declaration of its characteristics.
Metal gratings intended for structural applications fall within the field of application of the technical standard harmonised with Regulation EN1090-1:20009+A1:2011, mandatory from 1 July 2017.
Consequently, metal grating intended for structural applications must, from 1 July 2017, be accompanied by the declaration of performance and be CE marked in accordance with the Regulation.