ASFP Technical Guidance Document - TGD 21

CE Marking of Operable Fabric Curtains

September 2020
After 01 November 2019 CE marking of operable fabric curtains has become
Mandatory. Following the re-citing of EN 16034:2014 in the OJEU on 28 October
2016, CE marking can only be applied in combination with either
EN 14351-1:2006+A2:2016i or EN 13241:2003+A2:2016ii.

The European Commission (EC) is responsible for proposing legislation,

implementing decisions, and upholding the EU treaties. Although the European
Commission has considerable in-house expertise, it needs specialist advice from
outside experts as a basis for sound policymaking, as such, it seeks advice from an
Advisory Group on Construction Products for which SG06 is the relevant group.

Neither EN 14351-1:2006+A2:2016 or EN 13241:2003+A2:2016 identify Operable

Fabric Curtains within their scopes, unlike EN 16034:2014, and as such this matter
created confusion within the marketplace.

Guidance was sought from GNB-CPR-SG06iii and a Position Paper was circulated to
its Membership of which some Notified Bodies and the ASFP rebutted. However,
they determined at the 19th meeting of SG06 in November 2018, that it is possible to
CE mark Operable Fabric Curtains with the EN 16034:2014 only in combination with
EN 13241:2003+A2:2016.

As a consequence, manufacturers wishing to CE mark operable fabric curtains are

advised to seek further independent legal advice on this issue or consult with bodies
such as the Construction Products Association (CPA) for further clarification.

This document covers CE marking requirements necessary to meet the Construction

Products Regulations. Installed operable fabric curtains may also be covered by
other regulations, such as the Machinery Safety Regulations, the LVD or EMC
Directives. A separate guidance document is being drafted to cover the requirements
of these non-fire performance regulations.

The ASFP has published a short guide to CE marking which can be downloaded
here: http://is.gd/GbGyXC

i EN 14351-1:2006+A2:2016 - Windows and Doors. Product standard, performance characteristics. Windows and external pedestrian doorsets

ii EN 13241:2003+A2:2016 - Industrial, commercial, garage doors and gates. Product standard, performance characteristics

iii SG06. Guidance from the Group of Notified Bodies for the Construction Products Regulation for door and windows. 305/2011/EU