Advice on ITT Testing for CPR Compliance and CE Marking

Sharing Initial Type Testing

Insulating glass units – CE Marking and compliance with the Construction Products Regulation (CPR) – sharing Initial Type Test (ITT) Data

The Glass and Glazing Federation have been asked to clarify a section within BS EN 1279-5: 2005 +A2: 2010 Glass in Building – Insulating Glass Units. Part 5: Evaluation of conformity.

This is can you share test data with other companies or between brands? The answer is yes however there are some very specific rules to allow this to happen – these are summarized within Annex A of the above Standard, to assist the reader these are summarised below:-

1.     General

 An IGU manufacturers may use ITT results obtained by a third party e.g. other manufacturer, system developer, etc., to justify their conformity with EN  1279-5:2005, 5.2.2, for a product manufactured to the same design. This data is referred to as ‘other party ITT results’. However, to rely ‘other party ITT results’ there needs to be in place appropriate agreements[1],[2]

Role of the manufacturer supplying the ‘other party ITT results

The manufacturer shall undertake, via a specific agreement, to supply the following:

1)     A ‘System Description’ that details the insulating glass unit;
2)     Details of the essential characteristics the insulating glass unit is expected to comply with;
3)     reports of Initial Type Testing to EN 1279-2 and if relevant EN 1279-3 on units representative of the ‘System Description’;

NOTE: The testing being undertaken by a Notified Body

4)     test reports to EN 1279-4 covering the applicable components as described in the ‘System Description’;

5)     fully documented factory production control systems in accordance with EN 1279-6 specific to the ‘System Description’ and directly related to the production facility that is being operated;

6)     details of all components and constituents necessary to produce an insulating glass unit to the ‘System Description’;

7)     for the manufacturer requesting the use of ‘other party ITT results’, the appropriate procedures as detailed above shall be verified.

3.     Role of the manufacturer using the ‘other party ITT results’ 

The manufacturer shall, subject to the specific agreement, undertake the following:

Manufacture insulating glass units in accordance with the following:

  • The given ‘System Description’;
  • Using the specified components and constituents
  • Operating the given Factory Production Control procedure;

2)     Only claim essential characteristics as per the agreement;

3)     Place the product on the market under its own declaration of conformity and be responsible for any problem with the product;

4)     Maintains a copy of the ITT report complying with the following requirements that also contains the information needed for verifying that the insulating glass unit is manufactured according to the agreement:

  • The results of each test, independent of whether this test is part of the initial type or audit testing by the manufacturer or a third party need to be recorded in a “test report”. The test report should at least include the following information:

-        Manufacturer and manufacturing plant;

-        Identification of the construction product in accordance with this standard

-        Information about:

-        Sampling;

-        Date of testing;

-        Involved personnel;

-        Applied testing methods according to this standard;

-        Identification of the organsiation and personnel executing the test;

-        Place and date;

-        The results of the test, including analysis of these when relevant;

-        Place and date of the delivery of the test report;

-        Registration number of the Notified Body (when relevant) or laboratory;

-        Signature of the head of the testing laboratory and stamp (when relevant).

-        The test report must comply with the relevant clauses of this standard;

  • The complete set of test reports will be kept by the manufacturer and be made available to the “relevant bodies”;

5)     Undertake the short climate test as detailed in EN 1279-6:2002 – Annex B

In summary ITT date can be shared however the 2 organisations / factories are required to have exactly the same manufacturing and control systems with exactly the same components.