Does Missing CE Marking Mean Fire Door Hinges or Locks Must Be Replaced?

What Is CE Marking?

CE marking is a product conformity marking. It indicates that, when the product was placed on the relevant market, the manufacturer declared that the product met the applicable legal requirements. For construction products, this is normally supported by a Declaration of Performance where the product is covered by a harmonised or designated standard. CE marking is not the same as a general "quality mark", nor does it mean that an authority has individually approved the product as safe.

The purpose of CE marking is to create a consistent method of declaring product performance and to allow products to be traded across the relevant market. In Great Britain, CE marking continues to be recognised for construction products, and UKCA marking can also be used where the relevant UK requirements are met.

When Did CE Marking Become a Requirement?

For construction products covered by a harmonised European standard, or by a European Technical Assessment, the Construction Products Regulations 2013 introduced legal requirements in the UK from 1 July 2013. These requirements relate to products being supplied or placed on the market, including the need for a Declaration of Performance and appropriate conformity marking where applicable.

This is an important distinction. CE marking requirements are primarily product supply requirements. They do not automatically make all previously installed hinges, locks or door hardware non-compliant simply because they pre-date the current marking regime or because a visible mark cannot now be found.

CE Marking Is Not Retrospective

Legislation of this type is not generally applied retrospectively to require the automatic replacement of existing, previously installed components. An older fire door assembly may have been installed before CE marking became mandatory for the relevant product type, or the marking may have been on packaging, labels, documentation or another location that is no longer available after installation. Government guidance also recognises that, where a product is too small, conformity marking may be applied to packaging, a label, data plate or accompanying documentation rather than directly on the product itself.

Therefore, the correct question is not simply, "Can I see a CE mark?" The correct question is whether the fire door, including its ironmongery, remains suitable, adequately maintained, compatible with the door assembly and capable of performing its fire safety function — themes we cover in our fire door inspection guide.

Fire Safety (England) Regulations 2022

The Fire Safety (England) Regulations 2022 came into force on 23 January 2023. Regulation 10 introduced duties relating to fire doors in multi-occupied residential buildings, including the provision of fire door information to residents and routine checks of fire doors in buildings over 11 metres.

The government's fire door guidance makes clear that these checks are intended to be simple checks, based on the assumption that the fire risk assessment has already considered the suitability of the fire doors. The guidance also states that the purpose of the regulations is not to ensure that existing flat entrance doors meet the current standards for new blocks of flats. It further notes that the absence of certification does not, in itself, mean that a door is unfit for purpose.

In practical terms, the Fire Safety (England) Regulations do not require automatic replacement of fire door hinges, locks or other ironmongery solely because a CE mark cannot be identified. For a broader overview of those Regulations and how they fit with the Fire Safety Order, see our Fire Safety (England) Regulations 2022 article.

What Should Fire Door Inspections Consider?

A fire door inspection should consider the condition and performance of the door assembly as a whole. This includes whether the door closes effectively, whether hinges are secure and free from obvious defects, whether the lock or latch has damaged or compromised the door, whether there are excessive gaps, whether seals are present and in good condition where required, and whether there have been unsuitable alterations.

If hardware is damaged, loose, incompatible, incorrectly fitted, missing, or is preventing the door from closing and latching correctly, remedial action may be required. Where replacement hardware is needed, new components should be suitable for use on fire doors and should be supported by appropriate evidence, such as CE or UKCA marking where applicable, a Declaration of Performance, test evidence, certification, manufacturer's instructions or confirmation of compatibility with the doorset.

If you are documenting routine checks, use a structured approach such as our step-by-step checklist in How to Inspect a Fire Door, and engage accredited specialists when you need independent verification or formal surveys.

Summary

Missing CE marking on existing fire door hardware is not, by itself, an automatic requirement for replacement. The focus should be on whether the fire door remains suitable, properly maintained and capable of performing its required fire safety function. When you need help with surveys, remediation or specification on site, our fire door services team supports buildings across London and the South East.