Is CE/UKCA Compliance the Biggest Risk Facing Your Business?

To be honest, we don’t know the answer to that question. Checks by Building Inspectors are rare, the only factory inspections most of us have experienced are for health and safety, and when was the last time anyone asked you for a Declaration of Performance?

What we can do is explain what has already happened in the glazing sector, share what we’ve learnt through our research into UKCA/CE marking, and explain why we believe every joinery manufacturer should now take compliance much more seriously.

What’s the legal position?

The legal position is straightforward. It is a legal requirement to provide your customer with the appropriate UKCA or CE marking information for every window or external pedestrian doorset that you place on the market.

UKCA is the UK’s post-Brexit conformity marking scheme, while CE marking remains relevant where products are exported to Europe and for Lignum products, may also be accepted in Great Britain. Both rely on the product standard EN 14351-1, which defines performance characteristics for windows and external pedestrian doorsets, regardless of whether the frame is timber, PVC or metal.

The legal requirement is longstanding. What is changing is the intensity of scrutiny – and the need for manufacturers to prove that their systems work in practice.

What are you required to do?

Every external pedestrian doorset and window covered by EN 14351-1 must be supported by a valid Declaration of Performance (DoP), Initial Type Testing (ITT), a compliant Factory Production Control (FPC) system and the technical documentation required by the standard. Without these, manufacturers may be placing products on the market unlawfully.

CE marking for windows and external doorsets became mandatory in July 2013. But unless you work in new build, you may never have been asked for a DoP. Local authorities rarely check it, and competent-person schemes such as FENSA and CERTASS do not routinely need to see the supporting evidence.

The person signing the Declaration of Performance is confirming that the declared performance is supported by the required technical evidence. Where those declarations cannot be substantiated, both the business and those responsible for its compliance may face significant legal and commercial consequences.

So why does it matter now?

The Office for Product Safety and Standards (OPSS) is the national regulator for construction products. It leads market surveillance and enforcement, supports local authority Trading Standards and works closely with the Building Safety Regulator.

Where a manufacturer cannot demonstrate that products were made under a compliant Factory Production Control system, it may be unable to evidence conformity for products already placed on the market. A regulator can investigate historic supply and require corrective action. This can create significant legal and commercial exposure if products are challenged by regulators, clients or insurers.

If you joined the OPSS seminar in June, kindly organised for The Joinery Network by the Glass and Glazing Federation, it’s senior officers were clear about the regulator’s approach.

Between September 2024 and May 2025, OPSS carried out unannounced inspections of 28 UK manufacturers that heat soaked thermally toughened glass using in-house equipment. Inspectors checked Declarations of Performance, Initial Type Testing and Factory Production Control processes.

The published findings were stark. At initial inspection, none of the 28 manufacturers could produce a fully compliant Declaration of Performance. Only around 40% were complying with Initial Type Testing requirements, while 50% were not correctly carrying out required FPC testing and equipment calibration. OPSS recorded 256 corrective actions, including 114 serious non-compliances. In the most serious cases, Prohibition Notices stopped identified products from being supplied until obligations were met.

OPSS has not published an equivalent inspection programme for window and door manufacturers. However, it confirms that construction-products market surveillance is increasing and includes product testing, site inspections and technical-documentation reviews.

These results do not prove that the joinery sector has the same compliance profile. They do show how OPSS investigates: comparing declarations with technical evidence, observing production controls, testing traceability and preventing supply where serious failures undermine confidence in performance. They are also able to carry out surveillance in local areas. take a look at the table below to better understand the structure:

This table below shows, at a high level, how the construction-products and building-safety regimes work nationally and locally. Based on our research, the main factors likely to influence enforcement action include product failure, failure to comply with standards, product quality concerns, safety issues on site and widespread reports of manufacturer non-compliance:

This is a simplified overview: responsibility and powers can overlap depending on the product, project and circumstances.

What do you need to do?

Fortunately, not too much. Because you are manufacturing the Lignum system, we cascade to you the Initial Type Testing required to support compliance with EN 14351-1, enabling you to produce the relevant UKCA/CE marking documentation.

Initial Type Testing is not the same as PAS 24. It is the stringent weather and performance testing carried out by The Joinery Network on a frequent basis, to demonstrate that the products are fit for purpose.

This means that you only have to focus on following the correct procedures in your joinery workshop.

That is exactly what Factory Production Control is designed to achieve. Ensuring every product you manufacture continues to match the performance demonstrated during Initial Type Testing.

But just having current certification and test reports, or applying a UKCA/CE label is not enough.

Compliance depends on maintaining an effective Factory Production Control system, producing the correct Declaration of Performance, retaining technical records and ensuring products are manufactured consistently in accordance with the evidence supporting those declarations.

How will The Joinery Network help?

As regulation becomes increasingly focused on evidence, traceability and product performance, compliance is moving from a technical exercise to a fundamental business risk.

In August, we will be announcing a complete support package to keep your manufacturing legal and future-proofed.

Official evidence:

OPSS, Heat Soaked Thermally Toughened Glass: Sector Regulatory Report, published 5 March 2026 — https://www.gov.uk/government/publications/heat-soaked-thermally-toughened-glass/heat-soaked-thermally-toughened-glass-sector-regulatory-report