Gas Appliances Regulation: Guide for EU Importers and Manufacturers

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Gas Appliances Regulation

Planning to import or manufacture gas appliances and fittings in the European Union? This article provides information about the Gas Appliances Regulation requirements, including CE marking, documentation, harmonised standards, and testing requirements.


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What is the Gas Appliances Regulation?

The Gas Appliances Regulation (GAR) establishes a framework and sets appliance-specific requirements for importers and manufacturers of gas appliances and their fittings.

Specifically, the regulation specifies the safety requirements of covered products. It also sets energy efficiency requirements for those products unless more specific eco-design legislation applies (e.g. the Ecodesign Directive).

Product Scope

The Gas Appliances Regulation covers appliances that burn gaseous fuels for purposes that include:

  • Cooking
  • Air conditioning
  • Refrigeration
  • Space heating

Gas appliances examples

Here we list some examples of covered products:

  • Gas ovens and grills
  • Gas heated catering equipment
  • Gas-fired central heating boilers
  • Gas-fired storage water heaters

Fitting examples

The regulation also covers fittings either designed for incorporation into an appliance or connected to comprise an appliance, such as the following:

  • Safety devices
  • Controlling devices
  • Regulating devices
  • Sub-assemblies thereof

Exemptions

The Gas Appliances Regulation does not cover appliances that are designed specifically for:

a. Usage in industrial operations on industrial establishments

b. Usage on aircraft and railways

c. Temporary lab-based research purposes

Harmonised Standards

Harmonised standards provide a presumption of conformity with requirements set by specific directives or regulations. As such, products compliant with relevant harmonised standards can be assumed to conform to the regulation’s technical requirements.

For example, importers and manufacturers can use the following harmonised standards to meet the Gas Appliances Regulation requirements for ovens, outdoor barbeques, and other products:

a. EN 498 – Specification for dedicated liquefied petroleum gas appliances — Barbecues for outdoor use

b. EN 203-2-2 – Gas heated catering equipment — Part 2-2: Specific requirements — Ovens

c. EN 1106 – Manually operated taps for gas burning appliances

d. EN 13278 – Open fronted gas-fired independent space heaters

e. EN 203-2-4 – Gas heated catering equipment — Part 2-4: Specific requirements — Fryers

f. EN 203-2-11 – Gas heated catering equipment — Part 2-11: Specific requirements — Pasta cookers

Essential Requirements

Manufacturers should construct gas appliances and their fittings such that the appliances operate safely and as intended. The appliances should also pose no danger to people, pets, or property. As such, those products should adhere to the essential requirements set in Annex I of the regulation.

These requirements consist of three categories:

  • General requirements
  • Materials
  • Design and construction

The Gas Appliances Regulation provides the full set of essential requirements. We list just a few of those below.

General requirements

The Gas Appliances Regulation generally requires manufacturers to select the most relevant solutions by applying the following principles:

a. Ensure the product is safely designed and constructed by removing or decreasing risks as much as possible

b. Take precautions for hazards that cannot be fully eliminated

c. Warn users of any remaining risks, and provide them with appropriate precautions

Materials

Materials that are used to manufacture appliances or fittings should suit their intended purpose and withstand conditions to which the appliance might be subjected, such as:

  • Mechanical conditions
  • Chemical conditions
  • Thermal conditions

Design and construction

The Gas Appliances Regulation provides design and construction requirements for appliances, divided into seven subsections. We provide an overview below.

General

This section covers general requirements (e.g., an appliance should not explode due to external fires).

Unburned gas release

This section covers requirements related to gas leakage (e.g., the appliance should be designed to limit the gas release to prevent a hazardous buildup of unburned gases).

Ignition

This section covers requirements regarding an appliance’s ignition (e.g., the appliance should provide for ensure cross-lighting, smooth ignition, and reignition).

Combustion

This section covers requirements related to stable combustion (e.g., the appliance should not accidentally release combustion products).

Rational use of energy

This section covers requirements regarding the rational use of energy (e.g., an appliance should ensure sensible energy usage).

Temperature

This section covers requirements relating to temperature regulation (e.g., parts of appliances meant for installation or placement near surfaces should not reach dangerous temperatures).

Contact with food and water intended for human consumption

This section covers requirements regarding the materials and parts used to construct an appliance coming into contact with food or water meant for human ingestion (e.g. those parts and materials should not compromise the food or water’s quality).

Conformity Assessment

According to Article 14 of the Gas Appliances Regulation, manufacturers of gas appliances and fittings must submit their product to a notified body for one or more of the conformity assessment procedures listed below before placing said product on the market.

Note that all modules require a Declaration of Conformity while all modules, excluding module B, require the CE marking. You can find the full set of requirements regarding conformity assessment procedures in Annex III of the Gas Appliances Regulation.

MODULE B: EU TYPE-EXAMINATION — PRODUCTION TYPE

Manufacturers applying for an EU type-examination certificate must include the following information in their application:

a. Name and address of the manufacturer (and if relevant, the authorised representative)

b. A written declaration stating that the manufacturer has not sent an application to another notified body

c. Technical documentation (e.g. product descriptions, concept design, list of harmonised standards, test reports, instructions)

d. Representative product specimens

e. Supporting evidence that their technical design solution is adequate

f. Declaration of Conformity

g. Fittings documentation (if relevant)

A notified body performs a Module B assessment to analyse the appliance or fitting’s technical design. Its goal is to verify and confirm that the product’s technical design conforms with the Gas Appliances Regulation applicable requirements.

After this, the notified body should issue an EU type-examination certificate to the manufacturer, provided that the product is compliant with all requirements.

Besides complying with the requirements of Module B, manufacturers should also comply with the requirements of one of the five modules listed below.

MODULE C2: CONFORMITY TO TYPE BASED ON INTERNAL PRODUCTION CONTROL PLUS SUPERVISED PRODUCT CHECKS AT RANDOM INTERVALS

Manufacturers who choose Module C2 should fulfil requirements such as the ones listed below:

a. Ensure that the manufacturing process complies with applicable requirements

b. Allow the chosen notified body to carry out annual product checks

MODULE D: CONFORMITY TO TYPE BASED ON QUALITY ASSURANCE OF THE PRODUCTION PROCESS

Manufacturers choosing to comply with Module D should fulfil its requirements, which include:

a. Apply for the chosen notified body to assess a quality system (for production, final product inspection, and product testing)

b. Operate an approved quality production system

c. Allow the chosen notified body to carry out surveillance at the manufacture, inspection, testing, and storage locations

MODULE E: CONFORMITY TO TYPE BASED ON PRODUCT QUALITY ASSURANCE

Module E includes requirements such as:

a. Apply for the chosen notified body to assess the quality system that shall ensure product compliance with the regulation’s requirements

a. Operate an approved quality system

c. Allow the notified body to surveil the inspection, manufacture, testing, and storage locations

MODULE F: CONFORMITY TO TYPE BASED ON PRODUCT VERIFICATION

Module F includes requirements such as the following:

a. The manufacturer should ensure the uniformity of each batch of appliances and fittings, and submit said batches of appliances and fittings for verification by the notified body

b. The chosen notified body should carry out verification examinations or tests to ascertain the conformance of appliances and fittings with the regulation’s requirements

c. The notified body should issue a Certificate of Conformity

MODULE G: CONFORMITY BASED ON UNIT VERIFICATION

Module G mandates requirements that include the following:

a. Manufacturers should set up a manufacturing and monitoring process to ensure conformity

b. The chosen notified body should carry out relevant examinations and tests

c. The notified body should issue a Certificate of Conformity

Summary

We summarise requirements for importers and manufacturers of gas appliances and fittings in the table below.

Module Name Requirements
MODULE B
  • EU type-examination certificate
  • Technical documentation
  • Declaration of Conformity
MODULE C2
  • Product checks at random intervals
  • CE marking
  • Declaration of Conformity
MODULE D
  • Approved quality production system
  • Permit notified body to surveil inspection, manufacturing, storage, and testing sites
  • Technical documentation
  • CE marking
  • Declaration of Conformity
MODULE E
  • Approved quality system
  • Permit notified body to surveil inspection, manufacturing, storage, and testing sites
  • Technical documentation
  • CE marking
  • Declaration of Conformity
MODULE F
  • Appliance and fittings verification
  • Certificate of Conformity
  • CE marking
  • Declaration of Conformity
MODULE G
  • Appliance and fittings verification
  • Certificate of Conformity
  • CE marking
  • Technical documentation
  • Declaration of Conformity

Documentation

The Gas Appliances Regulation mandates importers and manufacturers to provide the required documentation when requested, as evidence of their product’s compliance with the regulations.

Declaration of Conformity

Importers and manufacturers should draft a Declaration of Conformity stating that they have met the requirements outlined in Annex I of the regulation. They should present the Declaration of Conformity per the format in Annex V, and provide information such as the following:

a. The appliance’s or fitting’s model (product, type, batch or number)

b. Manufacturer’s name and address

c. A statement declaring the manufacturer’s responsibility for issuing the Declaration of Conformity

d. Identification (and image) of the appliance or fitting

e. A statement declaring the appliance or fitting’s compliance with relevant harmonised EU legislation (e.g., the Gas Appliances Regulation)

f. References to the applicable harmonised standards in use or to additional technical requirements for which conformance is claimed

g. A statement declaring which notified body conducted the necessary intervention, and issued the relevant certificate(s)

h. Instructions for incorporation of fittings into appliances to comply with requirements for finished appliances

i. Additional information, as necessary

j. “Signed for and on behalf of” statement, with the date and place of issue, as well as name, function, and signature of the submitter

Technical Documentation

The Gas Appliances Regulation requires manufacturers of gas appliances or fittings to submit technical documentation, which, according to Annex III of the regulation, should at least include the following information:

  • General description of product
  • Concept design, manufacturing drawings
  • Descriptions and explanations to understand how the appliance or fitting works
  • List of applied harmonised standards
  • Results of design calculations, examinations
  • Test reports
  • Instructions for installing and using the finished appliance
  • Declaration of Conformity

EU Type-examination Certificate

The notified body should provide the manufacturer with an EU type-examination certificate if the appliance or the fitting type complies with the regulation’s requirements.

The EU type-examination certificate should include the following information:

  • Manufacturer’s name and address
  • Identifying drawings and descriptions
  • Examination conclusion
  • Preconditions (if any) for validity
  • Obligatory data for determining the approved type (e.g., gas type, appliance category)

Certificate of Conformity

If the manufacturer chooses to conformity assessment procedure outlined on module F or G, the notified body should also issue a Certificate of Conformity concerning the examinations and tests that have been carried out.

The Gas Appliances Regulation doesn’t provide additional details on the information that should be included in the certificate.

Instructions

According to the regulation, manufacturers must issue with the appliance:

a. Installation instructions meant for the installer

b. Product user and servicing instructions

Labelling requirements

The Gas Appliances Regulation mandates importers or manufacturers to label their products by affixing a CE marking and a set of inscriptions onto their appliances and fittings.

CE Marking

CE Mark

The CE marking must be affixed to the appliance, fitting, or data plate in a clear, readable, and permanent manner. If doing so is impossible, importers and manufacturers may place the CE marking on the packaging and the accompanying documents

It should be followed by the notified body’s identification number as well as the last two digits of the year in which the CE marking was placed.

Other marks indicating a particular risk or use may follow the CE marking and the notified body’s identification number.

Inscriptions

In addition to the CE marking, importers and manufacturers must visibly, clearly, and permanently affix inscriptions onto their appliances, fittings, or data plates before selling their products.

They should include the following pieces of information:

  • Manufacturer’s name
  • Appliance type, batch, or serial number
  • Type of electrical supply used (where applicable)
  • Appliance category marking
  • Appliance’s nominal supply pressure
  • Installation instructions

Lab testing

Lab testing carried out by the notified body is necessary for importers and manufacturers to prove compliance with the technical requirements set by the regulation.

Test examples

Below are a few examples of tests relevant to the gas appliances and their fittings:

  • Construction tests
  • Safety tests
  • Rational use of energy tests
  • Fitness for purpose tests

Test report

When the appliances or fittings pas the lab testing, the importers or manufacturers receive a test report that proves the product’s compliance with relevant requirements.

Notified bodies

Below we list five notified bodies that offer services concerning the Gas Appliances Regulation, as well as the countries in which they operate:

a. TÜV SÜD Product Service GmbH (Germany)

b. BSI Group The Netherlands B.V. (Netherlands)

c. INTERTEK Italia S.p.A. (Italy)

d. AENOR INTERNACIONAL, S.A. (Spain)

e. CERTIGAZ SAS (France)

The European Commission provides a list of notified bodies on this page.

  • (USA & EU)

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    • Request a free 30-minute call with Ivan Malloci to learn how we can help you with:
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    • Lab testing

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    Disclaimer: The Site cannot and does not contain legal advice. The legal information is provided for general informational and educational purposes only and is not a substitute for professional advice. Accordingly, before taking any actions based upon such information, we encourage you to consult with the appropriate professionals. We do not provide any kind of legal advice. THE USE OR RELIANCE OF ANY INFORMATION CONTAINED ON THE SITE IS SOLELY AT YOUR OWN RISK.

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    Sources: Our articles are written in part based on publicly available information, and our own practical experience relating to product compliance. These are some of the primary sources we use:

    • ec.europa.eu
    • echa.europa.eu
    • ecfr.gov
    • cpsc.gov
    • ftc.gov
    • fcc.gov
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