You generally cannot UKCA/CE mark a non-fire internal pedestrian doorset under the Construction Products Regulation (CPR) because there is currently no harmonised standard cited in the OJEU that covers it.
For a construction product to be UKCA/CE marked under the CPR, there must normally be either:
- A harmonised European standard (hEN) cited in the OJEU, or
- A European Technical Assessment (ETA) based on a European Assessment Document (EAD).
Without one of those routes, the CPR does not provide a basis for UKCA/CE marking.
External windows and external pedestrian doorsets are covered by:
- EN 14351-1
This standard has been harmonised and cited, so manufacturers can draw up a Declaration of Performance (DoP) and affix the UKCA/CE mark where the CPR applies.
Internal pedestrian doorsets are covered by:
- EN 14351-2:2018
Although this standard was published by CEN in 2018, it has never been cited in the OJEU.
As a result:
- There is no harmonised standard route under CPR.
- A DoP cannot be based on EN 14351-2 as a harmonised standard.
- You cannot affix a UKCA/CE mark simply by testing to EN 14351-2.
When it comes to fire doors is where things become confusing.
Fire-resisting and smoke-control doorsets are covered by EN 16034 however, EN 16034 is not a standalone product standard. It must be used together with a relevant product standard.
For external fire doors, that product standard is EN 14351-1 + EN 16034
For internal fire doors, the intended pairing was EN 14351-2 + EN 16034
Because EN 14351-2 has not been harmonised, the CPR route for internal doorsets has been problematic and incomplete for many years.
The issue is largely regulatory rather than technical.
During the CPR harmonisation process, the European Commission raised concerns about several standards developed under older mandates. Many standards required revision to align with CPR requirements, particularly around:
- Assessment and verification of constancy of performance (AVCP)
- Declaration of Performance requirements
- Essential characteristics
- Legal wording and Annex ZA requirements
EN 14351-2 became caught up in that wider CPR harmonisation backlog and its citation never progressed.
If you manufacture a standard internal doorset (for example, a timber office door or apartment entrance door that is not being UKCA/CE marked via another route):
- You can test to EN 14351-2.
- You can declare performance contractually.
- You can use the standard as evidence of performance.
- But you cannot claim CPR UKCA/CE marking based on EN 14351-2 because it is not harmonised.
- It is therefore illegitimate to UKCA/CE mark internal doorsets.
Many specifiers mistakenly assume that because EN 14351-2 exists, UKCA/CE marking is available. Publication of a standard and harmonisation of a standard are two different things.