The CPD requires, in all cases, that the manufacturer operates a Factory Production Control (FPC) system as part of the Evaluation of Conformity process. For some products, the FPC system needs to be certified by a Notified FPC Certification Body, while for other products the FPC system needs to be inspected by a Notified Body as part of Product Certification.

The requirements for FPC are laid down in European product standards and European Technical Approval Guidelines. However, difficulties with these requirements can still arise if, for example, they are:

·        written for series production rather than one-off or limited production,

·        not clear about the test methods to be used for FPC,

·        require process control which is not be possible where the person CE marking the product is not its manufacturer.

If you are a manufacturer and are uncertain about what the FPC provisions in a standard or ETAG mean, you have doubts about how to apply these provisions, you believe that the provisions cannot be applied to your products or production, or you have any other questions or queries relating to FPC, APSR Associates can help you. Contact us via our Consultancy, Advocacy or Representation Services.