Less than a year ago, the provisions of Regulation PE 305/2011 began to apply, and with them the obligation on window manufacturers to draw up declarations of performance in accordance with the given template. In the opinion of the EP and the Council, the solution adopted proved to be not very flexible and difficult to apply in practice. Therefore, from 01 June 2014, a new template and new rules for preparing declarations of performance are being introduced to the market, or rather a lack of a uniform template is sanctioned.
Declaration of performance – standards
Below are two templates for the declaration of performance. The no longer binding, constituting the original Annex III to Regulation (EU) No 305/2011 of the European Parliament and of the Council of 9 March 2011, and the current one from Commission Delegated Regulation (EU) No 574/2014 of 21 February 2014
Applicable principles and forms of declaration of performance
When preparing the declaration of performance the manufacturer:
Uses the formulas and headings given in the formula that are not enclosed in square brackets
Replaces the blank spaces and square brackets with the required information.
Manufacturers may also provide in the declaration of performance a reference to the website on which a copy of the declaration of performance is made available in accordance with the provisions of Article 7 item 3 of Regulation (EU) No 305/2011. Such reference may be given after point 8 or elsewhere where it does not affect the legibility and clarity of the mandatory information.
Exceptions to the rule
Subject to providing mandatory information required under Art. 6 of Regulation (EU) No 305/2011 in a clear, complete and consistent manner, when drawing up the declaration of performance, you can:
Use a different system than specified in the formula.
Connect the points of the pattern by presenting some of them together.
Present the points specified in the formula in a different order or using one or more tables.
Omit some of the points in the model that do not apply to the product in respect of which the declaration of performance is being drawn up. This is possible, for example, because the declaration of performance may be based either on a harmonized standard or on a European Technical Assessment issued for a product, which means that one of these options does not apply. Such omissions could also refer to points regarding the authorized representative or the use of the relevant technical documentation and specific technical documentation.
Show points without numbering.
If the manufacturer intends to issue one declaration of performance covering different versions of a product type, at least the following elements should be presented separately and legibly for each product version: number of the declaration of performance, identification code in point 1 and the declared performance in point 7.
A step to a mess
Looking at the changes introduced in the model and rules for preparing declarations of performance for windows and balcony doors from the clients of the window industry, it’s hard to admire. In practice, nothing changes, it doesn’t change for the better, of course. The scope of information is preserved, only the form of presentation changes. We move from classical to any style. Certainly it will be easier for producers than buyers. Was that it?
The basic problem of declaring is and will be “typology”. Few window manufacturers want and are able to divide the production range into specific types of products with representative levels or classes of performance in relation to the essential characteristics. A large part does not specify the levels and classes of performance at all, using cascade testing at best, often in violation of the rules. That is why, among other things, manufacturers do not inform sellers, but sellers do not inform buyers about the performance of windows. In this way, the basic message of the EN 14351-1: 2006 standard is distorted regarding the method of window selection by comparing the requirements and the declared level of product performance, as well as the idea of universal access to product information contained in Regulation 305/2011 of the EP. The first changes to this regulation on our market will not change anything. The choice of windows will still be more a lottery and a coincidence than the thoughtful use of technical information and applicable law.
Author: UPVC Windows