LIGHTING COLUMN TECHNICAL FORUM

CE MARKING OF LIGHTING COLUMNS TO BS EN 40

1 INTRODUCTION

All the major manufacturers1 of lighting columns have come together to review
the relevant legislation and standards and have published this guidance, for the
UK Lighting Industry, on the administration and practical implementation of CE
marking lighting columns.

This document is the conclusion of 12 months of research and discussion within

the lighting industry. It summarises the general requirements for CE marking
from the European legislation and UK law, as communicated through the British
and European Standards. It outlines the responsibilities of manufacturers and
suppliers and sets out the lighting industry’s agreed best practice for meeting
these requirements for lighting columns manufactured from concrete, steel,
aluminium and fibre reinforced polymer composite (FRPC).

2 LEGISLATION

Council Directive 89/106/EEC2, hereafter referred to as the Construction Products

Directive or CPD, was published in the European Union in 1989. The CPD was
transferred into English Law as the Construction Products Regulations (1991)3.

CE marking, according to the provisions of the CPD, also takes account of Council
Directive 93/68/EEC (the “CE Marking Directive”) amending the CPD in respect of
CE marking, and of Council Decision 93/465/EEC4 on the rules for the affixing
and use of the CE conformity marking.

A presumption of compliance with the Construction Products Regulations (1991)

can be achieved through compliance with the harmonized standard for lighting
columns, the British and European Standard BS EN 40.

1
This paper was prepared by the Lighting Column Technical Forum comprising CU Phosco
Lighting, Fabrikat, Post and Column Company, Aluminium Lighting Company, Mallatite, Abacus
Lighting, Thorn Lighting, Woodhouse, Joseph Ash and Valmont along with the assistance of Corus
and Stainton Metal Company.
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3 CE MARKING UNDER THE CONSTRUCTION PRODUCTS DIRECTIVE

CE marking, under the Construction Products Directive, signifies that a

construction product has been assessed (through initial type testing) for
characteristics which have an influence on the satisfaction of the ‘essential
requirements’ of the works. The performance of the product under each
requirement is declared in the information accompanying the CE mark.
The ‘essential requirements’ of the CPD are presented in Annex A5 of the
Directive.

This states:

“The products must be suitable for construction works which (as a whole and in
their separate parts) are fit for their intended use, account being taken of
economy, and in this connection satisfy the following essential requirements
where the works are subject to regulations containing such requirements. Such
requirements must, subject to normal maintenance, be satisfied for an
economically reasonable working life. The requirements generally concern actions
which are foreseeable.“

The essential requirements are then detailed under the headings:

1. Mechanical resistance and stability.

2. Safety in case of fire.
3. Hygiene, health and the environment.
4. Safety in use.
5. Protection against noise.
6. Energy economy and heat retention.

4 CE MARKING TO BRITISH AND EUROPEAN STANDARD BS EN 40

Standards such as BS EN 40 are voluntary unless made a requirement under

national law of a country. A European Member State’s regulations define how
the standard is used. Compliance with a particular standard may be one of many
ways, be the preferred way or may be the only way to meet a Member State’s
requirement.

However, CE marking is not required by the standard. Even if the main body of a
standard was made compulsory, the harmonised part, Annex ZA, would remain a
voluntary annex informing manufacturers (or other relevant parties - see Section
6.3) how to CE mark their product. Only when a Member State’s own
Regulations require products placed on their market to be CE marked does a
manufacturer/supplier have to CE mark.

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The CE mark symbolises that these specific harmonised performance criteria

(threshold values) in Annex ZA are fulfilled, and that all tasks linked to attestation
of conformity (see Section 5) have been completed. It does not require
compliance with the remaining parts which may be ‘voluntary’ (i.e. where it says
“should” or the annex is stated to be informative) or normative (i.e. where it says
“shall” or the annex is stated to be normative).

In the UK, the Construction Products Regulations (1991) reference the European
harmonised standards, but do not require manufacturers to CE mark their
products. Should the UK change its legislation and make CE marking a
requirement, manufacturers would then have to comply and CE mark according
to Annex ZA.

Most other European MS’s have already legislated to require CE marking, and
therefore importing lighting columns into those countries already requires that
the essential requirements are met and that CE marking is completed.

The essential requirements for lighting columns are specified in Annex ZA of

BS EN 40 as:

‰ resistance to horizontal loads (clauses 6 and 8);

‰ durability (clause 11); and
‰ performance under vehicle impact or passive safety (clause 16).

There are versions of Annex ZA for each construction material (concrete, steel,
aluminium and Fibre Reinforced Polymer Composite or FRPC) set out in parts 4,
5, 6 and 7 of BS EN 40, respectively. References to Annex ZA in this document
infer reference to any or all of these four parts. References to clauses are for
BS EN 40-5, but similar or equivalent clauses exist in BS EN 40 parts 4, 6 and 7.

5 ATTESTATION OF CONFORMITY PROCEDURE

The procedure for proving conformity with the CPD which allows manufacturers
to CE mark their products is known as Attestation of Conformity. This process is
described in Annex ZA of BS EN 40. Once this procedure has been completed
products may be CE marked; which under system 1 requires the manufacturer
to:
‰ satisfy a notified product certification body and be issued with an EU
Certificate of Conformity which entitles the manufacturer to affix a CE
mark; and
‰ draw up a Declaration of Conformity.

The attestation of conformity procedure under system 1 places responsibilities on

both the manufacturer and on the certifying body (also known as the Notified
Body) as set out in Table ZA.3 of Annex ZA.

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Manufacturers are responsible for Factory Production Control (FPC) and for
further sample testing.

The certifying body is responsible for Initial Type Testing (ITT), initial inspection
of the factory and FPC, and for an annual assessment and approval of the FPC.

5.1 Factory Production Control – Manufacturer

5.1.1 Production Control System

As part of the FPC, manufacturers must have a production system in place that
controls:

‰ Specification and verification of raw materials.

‰ Checking of new or modified designs (see section 5.1.2 below).
‰ Testing by manufacturer and testing frequency.
‰ Identification of non-conformities.
‰ Correction of non-conformities.

The production system must also record specific details about, and the results of,
the testing carried out as part of the FPC.

In addition, the following three mandated performance characteristics must be

met.

5.1.2 Resistance to horizontal loads

Clause 6 of BS EN 40-5 requires a design and design verification, where design
verification is another term for a design calculation check. This ensures the
column is satisfactory for the applied loads, being vertical and horizontal forces
resulting from self-weight, wind load and other imposed loads. Clause 8 requires
that joints (e.g. flange to base, base to shaft, shaft to bracket) be strong enough
to withstand the applied forces. Clause 7, in essence, requires that the welds be
strong enough to withstand the applied forces.

5.1.3 Performance under Vehicle Impact

BS EN 40-5 clause 16 requires that where passive safety performance is claimed,
columns be designed to provide that passive safety performance. For the
majority of columns for which no passive safety performance is claimed, columns
are defined as Class 0. Where passive performance is provided, conformance to
EN 12767 is required. Changes to the column design or manufacture which may
affect the passive performance of that column require Initial Type Testing to be
repeated.

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5.1.4 Durability
For mild steel columns, BS EN 40-5 clause 9 requires a mechanical impact test to
prove durability of the columns. In addition, clause 11 provides informative
recommendations for corrosion protection. There are, at the time of writing, no
normative corrosion protection requirements, although it is expected that this will
be addressed by the Standards Committee in future. However, this does not
remove the need to consider durability when CE marking. It is recommended
that three surface corrosion protection classes are defined and specified for each
of the three column surfaces identified in BS EN 40, as follows:

Surface Protection Classes

SP0 : Surface protection not provided.

SP1 : Surface protection coatings provided.
SP2 : Inherent corrosion protection provided.

Column Surface Protection Areas6

Area A : The exterior surface of the column from the top to a minimum of
0,27 m above ground level, or the whole exterior for a column with
flange plate.
Area B : The exterior surface of the ground section including a minimum
length of 0,25 m above ground level.
Area C : The interior surface of the column.

A sample label for a mild steel galvanized column with painted root should then
state the following under durability:

Durability
Resistant to impact
Resistance to corrosion – HDG steel, painted root; A-SP1, B-SP1 C-SP1.

A stainless steel column painted above ground should state as follows, as it is

assumed that the inherent corrosion resistance of the column will make the paint
coating redundant.

Durability
Resistant to impact
Resistance to corrosion – Stainless Steel Painted; A-SP2, B-SP2 C-SP2.

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The minimum values in A and B can be increased in countries where snow can cause corrosion
problems.
7
The minimum of 0,2 m allows a protection overlap.

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For an aluminium column with painted root, under BS EN 40-6, where there are
recognized problems with corrosion of the aluminium root section if protection is
not provided, a label should state:

Durability
Resistant to impact
Resistance to corrosion – Aluminium, Painted Root; A-SP2, B-SP1 C-SP2.

For FRPC columns, under BS EN 40-7, polyurethane coatings may be applied to

provide protection above ground against UV radiation, or acrylic coatings may be
provided to protect against chemical attack below ground. These can be treated
similarly:

Durability
Resistant to impact
Resistance to corrosion – FRPC, Acrylic Root; A-SP2, B-SP1 C-SP2.

5.2 Initial Type Testing (ITT) and Initial Type Calculation (ITC) – Certifying
Body
Initial Type Testing or Initial Type Calculation is a complete set of tests or other
procedures described in the harmonized standard, determining the performance
of samples of products representative of the product family (see Section 5.7). It
verifies that a product complies with the harmonized standard.

Annex ZA of BS EN 40 sets out the tasks of the Notified Body (NB) for ITT and
ITC which calls up all characteristics listed in Table ZA.1 and the evaluation
clauses to apply. Construction Products Regulations Guidance Paper K8 provides
general guidance on how NBs and manufacturers should interpret and make
practical their responsibilities for various systems of attestation, including how
NBs validate and verify calculations for ITC purposes for the various systems of
attestation. Guidance Paper K Annex 3 clause (13) in Section 3.1.2 states that
the NB is: “responsible for checking and validating the calculation (tools and
results) used by the manufacturer to design the product, by any appropriate
means… judging and, if deemed appropriate, performing independent
calculations for validation.”

Within the UK lighting industry, column calculations are undertaken by

manufacturers using a standard calculation program for all columns produced. It
is current best practice procedure for these calculation programs to be formally
verified and validated independently, by a third party. The resulting calculation
validation certificates are available to the NBs to confirm that the calculations are
in compliance with the harmonized Standard, BS EN 40. It is therefore
considered unnecessary for NBs to undertake further validation calculations,
particularly where these calculations would have to be undertaken by a third

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party engineering consultant. The role of the NB in validating the calculations is

therefore to review the typical input data used in the calculation, to review the
third party validation certificate and, where considered appropriate, to confirm
the technical competence and impartiality of the third party. This may be
achieved by confirming the third party is a Chartered Civil Engineer or Chartered
Structural Engineer.

BS EN 40 Annex D.1 requires that on first certification, each product family (see
Section 5.7) must undergo ITT. Thereafter, newly developed products which fall
outside the limits of the product families already tested, would need to undergo
ITT as a new product family. The exceptions to this are for small series
production and single item production when the ITC should be limited to the
demonstration of the manufacturer’s technical ability to perform the calculations
specified in the harmonized standard and his ability to take into account
parameters that may change win new (small) series (Guidance Paper K Annex 3
clause 5).

ITT requires that each product family be proved, by either calculation or physical
testing, against the parameters outlined in BS EN 40-5 Annex D.2, being:
a) dimensions, straightness, materials, welding, protection against
mechanical impact; and
b) design, corrosion protection, and performance under vehicle impact
(passive safety).

The test requirements to comply with the list in Annex D.2 are relatively
straightforward. The tests are chosen by the manufacturer to be consistent with
the intended use and the declared characteristics, while the NB undertakes all
physical testing relevant to ITT. For example, a straightness test would only be
relevant to a straight column and curved columns would not need to comply.
Likewise, a column claiming Class 0 for passive safety performance would not
need to undergo or pass the ‘performance under vehicle impact’ test.

5.3 Initial Inspection of the Factory and Factory Production Control

The certifying body is required to confirm that the procedures required under FPC
are being carried out.

European Guidance Paper B9 on FPC under the Construction Products Directive

states:

"Manufacturers having an FPC system which complies with EN ISO 9001/2 and
which addresses the requirements of the appropriate harmonized standard are
recognized as satisfying the FPC requirements of the Directive".

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It is expected that when CE marking becomes mandatory, the FPC requirements

will be included in the manufacturer’s ISO 9001 quality procedures. Then
manufacturers who are certified to EN ISO 9001 will not require any additional
inspections of the Factory and FPC, beyond those existing requirements for EN
ISO 9001.

For a NB to make use of the work undertaken for certification to EN ISO 9001 in
the FPC, thus gaining a reduction in joint costs of certification, the certification
may need to be undertaken by a single NB acting in both capacities.

5.4 Continuous Surveillance, Assessment and Approval of FPC

Continuing surveillance, assessment and approval of the FPC is required to
maintain the validity of the NB certificate – typically this involves an annual visit.
As with 5.3 ‘Initial Inspection of the Factory and FPC’, cost savings are possible if
the NB completes the continuing FPC surveillance during the same visits as for
EN ISO 9001, and makes use of sample testing etc. for both processes.

5.5 Evaluation and Acceptance Criteria for ITT

The evaluation criteria for ITT are set out in BS EN 40 clauses 13.3 (dimensions),
13.4 (straightness), 13.5 (materials), and 13.6 (welding).

Protection against mechanical impact requirements are set out in BS EN 40

clause 8 of part 4, clause 9 of parts 5 and 6, and clause 10 of part 7.

The acceptance criteria against which the certifying body will certify the ITT are
set out in clause 14 of BS EN 40.

5.6 Sample Testing outside of CE marking

Sample testing is only required where specified by the customer. Where
sampling is required, the tests carried out should be chosen to match the
requirements set out in the customer’s specification.

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5.7 Product Family Definition

A product family is generally a group of products with similar characteristics with
respect to the essential safety requirements. A product family may cover several
versions of the product, provided that the differences between the versions do
not affect the level of safety and the other requirements concerning the
performance of the product.

Product families are defined by the manufacturer to suit the range of products
being produced. The manufacturer’s selection of product families would then be
agreed by the NB. Significant and justifiable reasons would need to be provided
by the NB to require these product families to be modified.

The definition of a product family for the purposes of ITT and FPC has been
subject to some debate. Clarification was provided by the CEN CE marking
expert, Steven Rein, to the CEN/TC 50 committee (which authored EN 40) at the
meeting in Berlin on 5th October 2004. Resolutions were passed at the meeting
to help clarify areas of confusion and misinterpretation:

Resolution No. 1 – this defined what a Product Family consisted of, for the
purposes of ITT and FPC.

Resolution No. 2 – this clarified the use of computer design software for the
purposes of design verification for ITT and FPC. CEN/TC 50 document N556
relates to this.

The text of these Resolutions is presented below.

Resolution No. 1 – This allows the manufacturer to demonstrate that the

results of a particular characteristic from any one product in a family are
representative for all the lighting columns within that same family. Within the
task requirements of the certifying body, for example Table ZA.3 of EN40-5:2002,
there is a requirement characteristic of ‘Resistance to Horizontal Loads’ (see
clauses 6 and 8) to be fulfilled. As most lighting columns are designed using
computer software, they can be deemed to form part of the same product family
for the purpose of the characteristic of Resistance to Horizontal Loads.

A product may be in different families for different characteristics.

Resolution No. 2 – This concurs with the above statement, and representative
calculations will be provided to show to the Notified Body that they can be
deemed to apply to all lighting columns within the same product family.

This resolution adds another paragraph to D1 in Annex D of BS EN 40-5 (or

Annex C of 40-6 and Annex C of 40-7) which states:

“where verification of design is by calculation, using computer software, design

verification for the purposes of ITT and FPC shall be deemed to apply to all

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lighting columns within the product family designed by the same software,
provided that the representative calculation(s) have been verified”.

In other words, the product family is a group of columns, defined by the working
limits of the design calculation software used by each manufacturer. Where the
appropriate variables are included in the calculation program, columns in a
product family may have different:
‰ material types and grades (these are represented by a yield strength
which varies based on material).
‰ section shapes (equations for octagonal and circular profiles are
included in BS EN 40 and the correct equation can be selected and
used in the calculation).
‰ column dimensions (the height, diameter, tube thickness, bracket
length, etc. can be included as variables).
‰ appendages (lantern, signs or other appendages can be included in
terms of their weight, wind area and centres of mass and area within
the calculation sheet).

Where such a fully flexible calculation program is provided, only one product
family may be required for all the columns manufactured by a company, and only
one design verification is required.

It is highlighted that the clarification text from Resolution 2 has already been
included in the recently published EN 40-4 as clause C3 in Annex C. It is
intended that this will be undertaken in the next revision10 of EN 40 parts 5, 6
and 711.

5.8 Changes to Product Families

BS EN 40-5 Annex D1 deems that significant changes to the raw materials or
production processes would constitute a new product family, and therefore
require ITT. It is anticipated that the changes to raw materials (e.g. steel or
aluminium strip or tube) would not be significant, except where the parameters
of the new material are outside the capability of the design calculation program
as described in clause 5.7. Where new raw materials are incorporated, the
design program will then either accept or reject the design as part of the design
process.

10
Work on the revisions to EN 40 by CE-TC/50 has been stalled as BSI has withdrawn from its
position as the Secretariat. LCTF and the B509/50 British Standard committee for BS EN 40
have been actively working to reinstate a Secretariat to allow this urgent outstanding work on EN
40 to be completed. Italy have agreed to take on the Secretariat responsibilities and this work is
now restarting. However, until the revisions have been completed the UK lighting industry are
adopting the Resolutions of the CEN-TC/50 committee as current best practice.
11
In principle manufacturers have the option to share the validation costs of software used for
ITC if SG04 agree to this, i.e. a certification body would accept the validation of the same
software validated by another notified body of another manufacturer according to GP M.

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Changes to minor constituent materials supplied in conformance with the

relevant British Standard, such as welding consumables, would not be considered
significant where the new material is of equivalent of better quality, standard or
performance than that specified. This decision should be recorded for approval
by the NB during continuing FPC.

The additional text proposed in Resolution 2 requires that a computer program or

modifications to a computer program be validated to confirm correct performance
as declared on the basis of ITC. Simpler and cheaper validation methods than
those involved for ITC may be acceptable for FPC (see Guidance Paper M clause
5.2).

6 CE MARKING AND LABELLING

6.1 Existing Product Labelling for Identification

For the purposes of product identification, columns are currently being labelled in
accordance with BS EN 40 (e.g. steel columns - see BS EN 40-5 clause 12). This
requires that the following information be provided on a label:

‰ Name or symbol of the manufacturer (i.e. CU Phosco Lighting)

‰ Year of manufacture (e.g. 2005)
‰ Reference to the standard (i.e. BS EN 40)
‰ A unique product code (e.g. FR2605A01)

CE Marking requirements call for additional information to be displayed on the

product through one of the methods outlined below.

6.2 CE Marking Labelling Methods

Three full labelling methods and a simplified labelling method are set out in the
European Directive. Examples of these labelling methods are provided in
Appendix A. The labelling method adopted should be appropriate for the
contract supply chain and specification under which the column is sold.

For example:
‰ Where a manufacturer’s standard columns are selected and
purchased for appropriate use from the product catalogue or other
product documentation, use labelling method 1.
‰ Where manufacturers are selling columns to meet contract
specifications (e.g. based on wind speed and location information),
use labelling method 2.
‰ Where a customer has a full detailed design and specifies the critical
dimensions of the column (and, where appropriate, the bracket), use
method 3.

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Annex ZA in BS EN 40-4 provides all three labelling methods above. However, BS

EN 40 parts 5, 6 and 7 currently only provide for labelling method 2. A proposal
has been submitted to the CEN-TC/50 committee to have all three methods
included in each part, but note comments in footnote in Section 5.7.

In addition to fixing the CE mark, producers are required to provide data about
the product characteristics. The required data varies depending on the labelling
method employed.

For Method 2 (clause ZA.3.4 in Annex ZA), the CE mark labelling consists of a
box showing the official CE mark, along with the accompanying product
characteristics:

‰ Identification number of the certification body (e.g. BSI)

‰ Name or symbol of the producer (e.g. CU Phosco Lighting)
‰ Registered address of the producer (e.g. Charles House, Great
Amwell, Ware, SG12 9TA, UK)
‰ Last two digits of the year the CE mark was affixed (e.g. 05)
‰ Number of the EC certificate of conformity
‰ Reference to the European Standard (i.e. BS EN 40)
‰ Description of the product and its intended use
‰ Characteristics values of the product as defined in BS EN 40 clause
ZA.1, to include:
o Resistance to horizontal loads (type of verification, i.e. testing
(T) or calculation (C); reference wind velocity; wind area;
weight at top; deflection class; terrain category if different to II)
o Performance under vehicle impact (performance type; backfill;
type of testing if not standard)

At the CEN-TC/50 meeting in Berlin, Resolution 6 was agreed which requires that
values for Partial Load Factor Class and Wind Velocity, Vref , be included with the
CE mark under ‘resistance to horizontal loads’.

The resistance to horizontal loads information can be nominal minimum values at

which the column is proved to be safe for use, even though this information is
misleading to customers. The product characteristic data required with the CE
mark are commonly presented on lighting column data sheets (see Manual of
Contract Documents for Highway Works Volume 2 Notes for Guidance on the
Specification of Highway Works, Series 130012, Appendix 13/2). These data
sheets include allowable values of maximum luminaire weight and windage that
can be applied to a column, with or without bracket, for various wind load
conditions.

To provide useful information to the customer and to avoid confusion by

providing loading data which does not relate to the ability of a column to resist

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the applied loads, the lighting column industry recommend that the CE Marking
information is published in accompaniment to the column data sheet information.
This is publicly available information currently published in product catalogues,
product data sheets, and on company websites. This data will allow end users to
select a column of appropriate maximum luminaire weight and windage for the
location and site wind conditions. These values would then represent the safe
loads information to be published with the CE mark.

This best practice approach would be consistent with labelling method 2. For full
clarity, the lighting column industry recommend that in addition to the data sheet
CE mark and information, the simplified label should be provided on the column
with an accurate reference to the document containing the full CE mark
information.

6.3 Who is responsible for CE marking lighting columns?

The commercial supply of lighting columns will involve a number of different
parties. Depending on their individual responsibility in the supply chain, a role
may be classified as one of the following.

Supply Chain Responsibility CE Marking Role

Architects and Specifiers Producer
Column Designers Producer / Manufacturer
Column and Bracket Manufacturers Producer / Manufacturer
Independent Bracket Manufacturers Producer / Manufacturer
Commercial Agents Authorised Rep. / Importer / Distributor
Wholesalers Authorised Rep. / Producer / Importer / Distributor
Contractors Importer / Distributor / Assembler / Installer
End Users (local authorities/developers) User

The roles are categorised in Section 3 of Guide to the implementation of

directives based on the New Approach and the Global Approach13 published by
the European Commission, as follows:

Manufacturer
The definition of manufacturer for the purposes of the CPD is somewhat different
from the common usage. A manufacturer is the person (natural or legal) who is
responsible for designing and/or manufacturing a product with a view to placing
it on the Community market on his own behalf. The manufacturer has an
obligation to ensure that a product intended to be placed on the Community
market is designed and manufactured, and its conformity assessed, to the
essential requirements in accordance with the provisions of the CPD. The
manufacturer may use finished products, ready-made parts or components, or
may subcontract these tasks. However, he must always retain the overall control

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and have the necessary competence to take responsibility for the product. The
manufacturer does not need to be based inside the Community or Member State.

Authorised Representative
The manufacturer may appoint a person to act on his behalf as an authorized
representative. For the purposes of the CPD, the authorized representative must
be established inside the community. The authorized representative is explicitly
designated by the manufacturer (in writing) and he may be addressed by the
authorities of the Member States, instead of the manufacturer, with regard to the
latter’s obligations under the CPD. The manufacturer remains generally
responsible for actions carried out by an authorized representative on his behalf.
The authorized representative cannot modify a product on his own initiative in
order to bring it into line with the CPD. The authorized representative can, at the
same time, act as a subcontractor to the manufacturer on the condition that the
manufacturer retains responsibility for the design, manufacture and compliance
with the CPD. The authorized representative can at the same time act as an
importer if his responsibilities are extended accordingly.

Importer (a person responsible for placing on the market)

In the meaning of the CPD, an importer is any person established in the
Community who places a product from a third country on the Community market.
The importer must ensure that he is able to provide the market surveillance
authority with the necessary information regarding the product, where the
manufacturer is not established in the Community, and has no authorised
representative in the Community. The person who imports a product into the
Community may, in these situations, be considered as the person who must
assume the responsibilities placed on the manufacturer.

Distributor
Provisions regarding distribution are in general not included in the CPD. A
distributor is to be considered as any person in the supply chain who takes
subsequent commercial actions after the product has been placed on the
Community market. The distributor shall act with due care in order not to place
clearly non-compliant products on the Community market. He shall be capable of
demonstrating this to the national surveillance authority.

Assembler and Installer

The installer and assembler of a product, which is already placed on the market,
should take necessary measures to ensure that it still complies with the essential
requirements at the moment of first use within the Community. This applies to
products where the directive in question covers putting into service, and where
such manipulations may have an impact on the compliance of the product.

User
The CPD does not lay down obligations for users, apart from those related to
putting into service. Community legislation concerning health and safety of the

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workplace has an impact on the maintenance and use of products covered by the
CPD that are used in the workplace.

Producer
A producer is a manufacturer of a finished product or a component part of a
finished product, a producer of any raw material, or any person who presents
himself as a manufacturer (for example by fixing a trade mark). It includes a
designer who subcontracts the manufacture of a product but places the product
on the market under his own name. Importers placing products on the
Community market from third countries are all considered to be producers
according to the Directive on product liability. The CPD states that the producer
is responsible for the conformity of the product at the time it is placed on the
European Economic Area (EEA) market (i.e. the initial action of making a product
available on the EEA market, with a view to its distribution and/or use within the
EEA).

Whether each party in the supply chain is a manufacturer, an authorised

representative, a producer, an importer, a distributor, an assembler and installer,
or an end user and whether they will need to undertake CE Marking will depend
on the chain of contracts between parties in the supply chain. It will also depend
which of the parties are based within the Community. Some examples of typical
supply chains within the UK are presented below as examples.

Example 1 Column and Bracket Manufacturer (manufacturer) to

Local Authority/Developer (user)
Column and bracket is designed and manufactured by one company and sold
directly to the Local Authority or Developer purchasing and using it. The column
would be designed under BS EN 40. The column and bracket would be labelled
on the backboard and inside the end of the column base with the simplified
labelling method.

The CE mark and accompanying information is supplied in the commercial

documentation. The accompanying information would use the data from the
standard column data sheet (maximum luminaire weight and windage for post
top or various bracket lengths, quoting the wind speed, terrain category and
altitude that would be required to give the Rationalised Wind Load Factors as
quoted in PD 6547: 2004 Guidance on the Use of BS EN 40-3-1 and BS EN 40-3-
3).

Data sheets for other site specific wind conditions may be requested by the
purchasers at the quotation stage, and any additional cost for the bespoke
designs and data sheets incorporated into the price of the sale.

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Example 2 Column Manufacturer (manufacturer) to

Contractor who adds bracket (assembler and installer)
before selling to Local Authority/Developer (user)
The column is designed and fabricated by the manufacturer, and supplied with
simplified labelling information on the column and with CE mark and information
on a data sheet in the commercial documentation.

The contractor adds the same manufacturer’s standard bracket to the column
taken from his stockyard, before installing it on site along with a luminaire. As
the contractor is using the column within the limits intended in the column design
and foreseen by the column manufacturer during design, the ability of the
column to meet the essential requirements is not being changed. No alteration
to the CE marking label or data sheet is required, but the CE mark and
accompanying information should be transferred with the column resale.

If a bracket from a different manufacturer was added to the column, the

contractor would be responsible for re-applying the CE Mark fully in compliance
with BS EN 40. In effect, this may prevent this particular practice, except with
the authorisation and/or assistance of the column manufacturer.

Example 3 Column Manufacturer (producer) as subcontract to

Bracket Manufacturer (manufacturer) to
Local Authority/Developer (user)
The column is design and manufacture to BS EN 40 is subcontracted to the
column manufacturer by the bracket manufacturer. The bracket manufacturer
designs and fabricates a special bracket which is added to the column before its
sale. The bracket manufacturer confirms that the weight and windage of the
bracket are within the capacity of the column as stated on the column data
sheet. The bracket manufacturer provides a data sheet showing the allowable
luminaire weight and windage for the column and bracket combination, and
applies a new CE mark to the column and bracket assembly. The bracket
manufacturer may have to subcontract the column manufacturer to complete the
design to satisfy the essential requirement for “resistance to horizontal loads”
and to provide the maximum luminaire weight and windage values for the
column and bracket assembly data sheet, but the bracket manufacturer would be
fully responsible for the design and manufacture of the column and bracket
assembly when it is first placed on the market, and for CE Marking.

Example 4 Bracket Manufacturer to

Local Authority/Developer
No CE marking is required as brackets are not covered by themselves by the
requirements of BS EN 40. However, they may be designed and manufactured
under the requirements of other standards requiring compliance with the
Construction Products Directive.

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Where the brackets and columns to be combined by a secondary vendor are

fabricated by the same manufacturer. To comply in this case, the CE mark
product characteristics should present maximum safe weight and windage
capacity including data for a bracket of the relevant length. Note that in the case
of column and bracket assemblies, manufacturers should provide the maximum
lantern weight and windage in the data having deducted the weight and windage
of any standard bracket before publication.

Typical industry data sheets include for both post top columns and columns with
standard brackets of various lengths. For the purposes of CE marking, a
standard bracket is considered to be a substantially straight tubular outreach
bracket attached to a vertical upstand which mounts on the column spigot.
Critically, there are no additional decorations or adornments which would
increase the weight and windage above that of a standard tubular bracket.

For non-standard brackets, the organisation adding the bracket would remain
responsible for applying a new CE mark, along with the revised accompanying
information for the new assembly.

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APPENDIX A – EXAMPLES OF CE MARKING LABELS

A.1 Example of Simplified Label

CE conformity marking consisting of the
CE symbol given in directive 93/68/EEC
Identification number of the Notified Body

0123
AnyCo Ltd, PO Bx 21, B-1050 Name or identifying mark and registered address of
the manufacturer
Product identification number and last two digits of
45PJ76/05 the year in which the marking was affixed

0123-CPD-0456 Number of the EC certificate

EN 40-5 Number of this European standard

A.2 Example of CE marking with Method 1

CE conformity marking consisting of the
CE symbol given in directive 93/68/EEC

Identification of the Notified Body

0123
AnyCo Ltd, PO Bx 21, B-1050 Name or identifying mark and registered address
of the manufacturer
45PJ76/05 Product identification number and last two digits of
the year in which the marking was affixed

0123-CPD-0456 Number of the EC certificate

EN 40-5 Number of this European standard

Steel lighting column for circulation areas Generic name and intended use
Material – Welded carbon steel tube to EN
10210 Information on product geometry and material
characteristics including detailing
Grade – S355J2
Geometric characteristics (to be adapted to the specific product
Length L = 9200 mm by the manufacturer)
Wall thicknesses:
Notes:
T1 = 4.0 mm 1.Numerical values are only as example.
T2 = 6.3 mm 2. A sketch should be included unless equivalent
Diameters: information is available in referenced Technical
D1 = 88.9 mm Information (e.g. product catalogue or datasheet)
D2 = 168.3 mm referred to
Performance under vehicle impact (passive
safety):
Untested - Class 0 or
Tested – 100:NE:3
For durability see Technical Information
Technical Information:
Product Catalogue ABC : 2002 – Clause ii
Data Sheet : No 5678

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A.3 Example of CE marking with Method 2

(verification by calculation or testing)
CE conformity marking consisting of the
CE symbol given in directive 93/68/EEC
Identification of the Notified Body
0123
AnyCo Ltd, PO Bx 21, B-1050 Name or identifying mark and registered
address of the manufacturer
Product identification number and last two
45PJ76/05 digits of the year in which the marking was
affixed
0123-CPD-0456 Number of the EC certificate
EN 40-5 Number of this European standard

Steel lighting column for circulation areas Generic name and intended use
Information on product mandated
Resistance to horizontal loads:
characteristics
Wind Partial Deflection Maximum Maximum Maximum
velocity load class Bracket luminaire luminaire
Vref factor length m weight kg windage m2
m/s class

26 B 3 2.5 20 0.25

Performance under vehicle impact (passive safety):

Untested - Class 0 or
Tested – 100:NE:3
For durability and other NDPs see the Technical Documentation
Technical Documentation:
Product Catalogue ABC : 2002 – Clause ii

A.4 Example of CE marking with Method 3

CE conformity marking consisting of the
CE symbol given in directive 93/68/EEC

Identification of the Notified Body

0123

AnyCo Ltd, PO Bx 21, B-1050 Name or identifying mark and registered

address of the manufacturer
45PJ76/05 Product identification number and last two
digits of the year in which the marking was
affixed

0123-CPD-0456 Number of the EC certificate

EN 40-5 Number of this European standard
Steel lighting column for circulation areas Generic name and intended use and
For resistance to horizontal loads, performance under Information on product mandated
impact (passive safety) and durability see the design characteristics
specifications
Design Specification:
Order Code .....................................................xxxxxx

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