Window film is a product designed to supplement glass performance. The building blocks of window film are usually polyester film made out of Polyethylene Terephthalate (PET). These films are applied to the surface of windows in homes, commercial buildings or vehicles.

There are numerous types of window films, some contain multiple layers of PET to offer shatterproof capabilities, like the Clear C12 window film, others are tinted and offer reduction of visible light transmission or block heat coming through.

Architects and facility managers considering window film are often met with safety and performance standards that they need to evaluate, which means a maze of unfamiliar codes. CE marking window films indicate a mandatory conformity mark for products entering the European Economic Area (EEA). It suggests that the product meets the health, safety, and environmental standards and can be legally sold in the EU.

EU Regulatory Requirement for Window Films

CE should be regarded as a passport for products that would like to enter the EEA. It is shaped by how products interact with building performance, safety, and energy efficiency. Of course, not all window films fall under the same legal requirements since they have different uses. Yet some of them fall under the Construction Products Regulation (CPR) in the EU. Below is a quick rundown of some major classifications in the EU related to window film intended to modify the performance of the glazing:

• Safety Window Film
  This type of film impacts the mechanical safety of windows and must comply with impact resistance. They fall under the EN 12600 evaluation.

• Solar Control Window Film
  Window film that aims to reduce solar heat gain, improve insulation, or reduce glare falls under the EN 410 evaluation.

Automotive Window Film

Automotive film obviously does not fall under the CPR or CE. Instead, it falls under vehicle-specific regulatory frameworks such as UN/ECE Regulation No. 43.

Finally, it’s important to note that CE marking is not used for decorative-only film, which does not have any safety or performance claims.

Obligations for Manufacturers, Importers & Installers

Across the supply chain, the CE marking, according to the Construction Products Regulation (EU) No 305/2011, is a shared responsibility. While the manufacturer holds the brunt of responsibility, importers, distributors, and installers also share some of the responsibility.

Manufacturers must provide a Declaration of Performance (DoP), perform required testing, and maintain proper documentation of all the processes for at least 10 years.

Importers and distributors are the gatekeepers of CE verification, meaning that they represent compliance checkpoints. They need to verify CE marking before releasing products. If the packaging is modified in any way, then part of the manufacturer's CE obligations are inherited by an importer/distributor. Similar to the manufacturers, the importers also need to have extensive documentation that needs to be kept for up to 10 years.

Finally, the installers are the ones who determine whether the CE-marked performance is achieved in the real-world application. This means that they must install the product according to the CE-linked instruction and ensure that the film is suitable for the intended use. Moreover, the installers need to provide CE information to building owners and comply with national or state building requirements.

Future Trends and Regulatory Developments

The regulatory environment in the EU is continuously evolving so there are plenty of upcoming changes to CPR. These changes will potentially include digital product passports and more rigorous factory controls. There will also be an increasing emphasis on sustainability and environmental impact, which might result in a need to add a carbon footprint report to the CE marking in the future.

Conclusion

CE marking window films are not a one-size-fits-all label for all use cases. Since it depends on the film’s intended use, manufacturers must ensure that their products are labeled and tested properly, as well as documented across the entire process. Importers have the responsibility to verify that only compliant products enter the EU market, while installers must preserve the marking via proper installation of the products.

Future regulatory changes may include additional responsibilities across the supply chain, which translates into the need to stay informed about harmonized standards, CE-marking obligations, and market surveillance trends.

For more insights on window films, energy efficiency, and compliance best practices, you can explore additional resources on the Solar Screen blog.