CE Marking for Construction Sealants: What EN 15651 Requires

EN 15651 is the harmonised European standard for "Sealants for non-structural use in joints in buildings and pedestrian walkways," issued under the EU Construction Products Regulation (CPR, 305/2011). It is split into four parts covering different joint applications: facades (EN 15651-1), glazing (EN 15651-2), sanitary joints (EN 15651-3), and pedestrian walkways (EN 15651-4). Any sealant product placed on the EU market for these uses generally needs CE marking against the relevant part.

CE marking under EN 15651 is a manufacturer or importer declaration, not a third-party product certification in most cases — the standard uses an "AVCP System 3" conformity assessment level for most sealant characteristics, meaning the manufacturer self-declares performance based on initial type testing carried out (or supervised) by a notified laboratory. This is an important distinction for procurement teams: CE marking confirms the product has been tested and its performance declared against the standard, not that a third party has approved every batch.

• Applicability — EN 15651 covers curtain wall and facade joints, glazing seals, sanitary sealing, and pedestrian walkway joints — a wide range that includes many butyl-based sealing tape and compound applications
• Declaration of Performance (DoP) — the manufacturer or their EU-based authorised representative issues a DoP stating the declared performance values against essential characteristics defined in the standard
• CE marking affixed to the product/packaging — accompanied by the DoP reference, notified body number (where applicable), and manufacturer identification
• Post-Brexit UK note — the UK operates a parallel UKCA marking scheme; many suppliers currently maintain both CE and UKCA documentation for GB market access, though CE marking continues to be accepted in Great Britain under extended transitional arrangements — buyers should confirm current requirements before specifying

For a raw butyl compound or tape manufacturer supplying converters and fabricators rather than placing a finished sealant directly on the EU market, CE marking obligations typically sit with the downstream party who places the finished, packaged sealant product on the market — but the underlying performance data still needs to trace back to the raw material.

When qualifying a butyl tape or compound supplier for EU/UK construction projects, procurement teams should confirm which EN 15651 essential characteristics the supplier's test data covers, and whether that data supports your own finished-product Declaration of Performance if you are converting or repackaging.

• If you buy finished butyl tape to apply directly on a building envelope, ask whether the specific product/width/thickness combination has its own DoP or falls under a family assessment
• If you convert raw compound into your own branded sealant or tape, you become the "manufacturer" for CPR purposes and are responsible for the DoP and CE marking of your finished product
• Keep documentation on file for at least 10 years from the date the product was placed on the market, as required under CPR record-keeping obligations

Garmy's butyl compound and tape products are manufactured under IATF 16949 and ISO 9001 with batch-level CoA and SDS provided as standard, giving converters and fabricators the underlying data needed to support their own EN 15651 documentation.

Procurement teams new to CPR/CE marking requirements often make one of a few recurring mistakes when sourcing butyl sealing products for EU projects.

1. Assuming "CE marked raw material" is a real category — EN 15651 CE marking applies to finished sealant products placed on the market for specific joint uses, not to raw butyl compound sold to a converter. Ask suppliers for underlying performance data rather than a CE mark on the compound itself
2. Confusing EN 15651 parts — a product tested and declared for facade joints (Part 1) does not automatically cover pedestrian walkway use (Part 4); confirm the DoP references the correct part for your application
3. Overlooking the AVCP System 3 vs System 4 distinction — some characteristics require notified body involvement in initial type testing; verify which characteristics your supplier's test reports cover and by whom they were carried out
4. Not archiving documentation — CPR requires the DoP and supporting technical documentation to be retained; a common audit failure is being unable to produce this on request years after installation

Building these checks into supplier qualification from the outset avoids costly rework later — particularly for facade and rooftop projects where re-certifying an already-installed sealant is impractical.

Q: Does a butyl compound manufacturer need to CE mark raw material sold to converters?

A: Generally no. CE marking under EN 15651 applies to the finished sealant product placed on the EU market for a specific construction joint use. A raw compound or bulk tape sold to a converter for further processing is not itself the "product" being CE marked — but the converter needs reliable performance data from the raw material supplier to support their own Declaration of Performance.

Q: What is the difference between CE marking and UKCA marking?

A: CE marking applies across the EU under the Construction Products Regulation. UKCA is the UK's post-Brexit equivalent marking scheme. As of current transitional arrangements, CE marking continues to be accepted for construction products in Great Britain, but requirements have changed multiple times — buyers should confirm the current position before specifying for a UK project.

Q: Which EN 15651 part applies to butyl tape used around window frames?

A: This typically falls under EN 15651-1 (facade elements) or EN 15651-2 (glazing), depending on the specific joint being sealed. The correct classification depends on the exact application — confirm with your supplier's technical documentation which part their test data addresses.

Q: How long is a Declaration of Performance valid?

A: A DoP remains valid as long as the product and its manufacturing process are unchanged from what was tested. A material formulation change, a new production site, or a change to declared performance values requires a new DoP and, where applicable, retesting.

Q: Do I need a notified body to CE mark a butyl sealant product?

A: It depends on which essential characteristics you are declaring and the AVCP system that applies to them under EN 15651. Some characteristics can be self-declared by the manufacturer (System 4); others require notified body involvement in initial type testing (System 3). Confirm the applicable system for each characteristic before assuming self-declaration is sufficient.

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