The short answer
A powered industrial door usually carries two sets of conformity evidence. As a construction product under BS EN 13241 it needs a Declaration of Performance and CE or UKCA marking. As a machine it needs a Declaration of Conformity from whoever completes it, often the installer. Great Britain accepts CE or UKCA; Northern Ireland requires CE.
Key points
- Industrial doors need construction product evidence (DoP); powered doors also need a machinery DoC.
- Great Britain accepts CE or UKCA; the government has committed to keep recognising CE for construction products.
- Northern Ireland requires CE; UKCA alone is not accepted there.
- The EU Machinery Regulation applies directly in Northern Ireland from 20 January 2027.
- An installer who completes or converts a powered door usually issues the Declaration of Conformity.
Why does an industrial door need conformity marking?
An industrial door needs conformity marking because the law treats it as a construction product and, once powered, as a machine. Each regime asks for its own evidence. The construction products rules show how the door performs, for example in wind or as insulation; the machinery rules show it is safe to use.
| Regime | What it covers | Key document | Who issues it |
|---|---|---|---|
| Construction products (BS EN 13241) | Declared performance: wind resistance, thermal resistance, air permeability, water tightness, safe opening and more | Declaration of Performance (DoP) | The door manufacturer |
| Machinery (GB: Supply of Machinery (Safety) Regulations 2008) | Safety of the complete powered door in use | Declaration of Conformity (DoC) | Whoever completes the powered door, often the installer |
| Partly completed machinery | Motors and operators supplied for incorporation | Declaration of Incorporation | The motor manufacturer |
A manual door needs the construction product evidence but not the machinery Declaration of Conformity. A powered door needs both.
What is a Declaration of Performance under BS EN 13241?
A Declaration of Performance is the manufacturer's formal statement of how its door performs against the essential characteristics in BS EN 13241, the product standard for industrial, commercial and garage doors and gates. It is issued under the Construction Products Regulation, and the CE or UKCA mark on the door refers back to it.
A typical DoP lists characteristics such as:
- resistance to wind load, as a class;
- thermal resistance or U-value;
- air permeability and water tightness, as classes;
- safe opening and mechanical resistance;
- release of dangerous substances.
Fire resistance and smoke control are not covered by BS EN 13241 alone; fire-rated doors and shutters also come under BS EN 16034. The declared values belong to the manufacturer's tested product and apply only when the door is built and installed as the manufacturer specifies. We supply doors carrying the manufacturer's DoP and pass it on at handover.
Which mark is accepted in Great Britain: CE or UKCA?
In Great Britain both UKCA and CE marking are currently accepted for construction products such as industrial doors. The government has committed to continuing to recognise CE marking for construction products, with any future change subject to a transition period of at least two years. Its February 2026 white paper on construction products reform confirmed the intention to keep CE recognition within the reformed framework.
For machinery, legislation that came into force on 1 October 2024 extended recognition of CE marking in Great Britain indefinitely, so a powered door can carry either UKCA or CE for its machinery conformity.
In practice most doors supplied in Great Britain carry CE marking, UKCA marking, or both. What matters is that the marking matches valid documents: a DoP for the product, and a DoC for the finished powered door. Where both marks are used, the documents must meet both regimes' requirements.
The rules continue to evolve as the government reforms construction products regulation, so check current GOV.UK guidance for any project with a long programme, and ask manufacturers to confirm the marking their products will carry at delivery.
What applies in Northern Ireland?
Northern Ireland follows EU product rules for these goods under the Windsor Framework, so industrial doors placed on the Northern Ireland market need CE marking. UKCA marking alone is not accepted there.
- Construction products: CE marking, or CE marking with the UK(NI) indication where a UK approved body carried out mandatory third-party assessment.
- Machinery: currently the Supply of Machinery (Safety) Regulations 2008 as they apply in Northern Ireland, with CE marking. From 20 January 2027 the EU Machinery Regulation (EU) 2023/1230 applies directly in Northern Ireland and replaces those rules there; products already compliantly placed on the market can continue to be made available.
- Regulator: HSENI enforces workplace health and safety in Northern Ireland.
If a project in Northern Ireland is due to complete around January 2027, confirm with the door and motor manufacturers which machinery rules their documentation covers.
When does the installer issue the Declaration of Conformity?
The installer issues the Declaration of Conformity when it is the party that completes the powered door, which is usually the case when it fits a motor and controls to a door on site or converts a manual door to power. HSE's guidance says that in most such cases the installer or converter becomes the product manufacturer.
Before issuing the DoC, the Responsible Person must:
- carry out a risk assessment of the complete installed door;
- apply appropriate protective measures and safety devices;
- compile a technical file and keep it available for the authorities;
- test and commission the door, including force measurement where relevant;
- apply the conformity marking and issue the DoC;
- hand over user instructions covering use, checks and maintenance.
Where a door manufacturer supplies a complete powered door system and takes responsibility for it, the manufacturer may issue the DoC instead. Agree in writing who will do it before the order is placed. See door automation and controls for how we approach this on powered installations.
What should you check in the handover documents?
Check that the documents match the door that was actually installed. A Declaration of Performance for a different model, or a motor's Declaration of Incorporation offered in place of a Declaration of Conformity, are common gaps.
- Does the DoP name the door model and list the declared characteristics?
- Is there a DoC for the complete powered door, naming the Responsible Person and the regulations it conforms to?
- Is the conformity mark on the door's identification plate, with the manufacturer and serial number?
- Are the user instructions specific to the installed door and controls?
- Are commissioning and force test records included where force limitation is used?
- For fire shutters, is there test or certification evidence for the fire rating?
Keep these with the building's operation and maintenance records. They are the first thing an inspector or insurer will ask for after an incident, and they are much harder to obtain years later if the original installer has moved on or the manufacturer has changed its range.
Does changing a door affect its marking?
Changing an existing door can affect its conformity. Replacing worn parts like-for-like is maintenance and does not usually change anything. Fitting a different type of motor, changing from hold-to-run to automatic operation, adding remote controls or altering the door's construction may be a substantial modification, which can make the modifier responsible for the door's conformity as if it were new.
Before you approve changes to a powered door, ask the contractor whether the work alters conformity and who will issue updated documents. Our guide to converting a manual door to electric explains the most common example, and industrial door installation covers new doors supplied with full documentation.
Frequently asked questions
Is a CE-marked door legal to install in England, Wales and Scotland?
Yes. Great Britain currently accepts CE marking for construction products, and the government has committed to continuing that recognition with at least two years' notice of any change. CE marking is also recognised for machinery in Great Britain. The door must still come with valid documents and be installed as the manufacturer specifies.
What is the difference between a DoP and a DoC?
A Declaration of Performance states how the door performs as a construction product, such as its wind resistance class, U-value and air permeability, and is issued by the door manufacturer. A Declaration of Conformity states that the complete powered door meets machinery safety requirements, and is issued by whoever completes the powered door, often the installer. A powered door needs both.
Our motor came with a Declaration of Incorporation. Is that enough?
No. A Declaration of Incorporation covers partly completed machinery, such as a motor or operator intended to be built into something else. It tells the person completing the door what the motor does and does not cover. The finished powered door still needs its own risk assessment, technical file, marking and Declaration of Conformity.
Do fire shutters need different paperwork?
Yes. Alongside the usual product and machinery evidence, a fire shutter needs evidence of its fire resistance. A new CE or UKCA-marked shutter is tested to BS EN 1634-1 and classified to BS EN 13501-2 under BS EN 16034, which covers fire and smoke characteristics, and its Declaration of Performance states that classification. Older installed shutters may instead hold test evidence to BS 476-22. The evidence belongs to the manufacturer's tested product and applies only when installed and maintained as tested.
Sources
- Construction Products Regulation in Great Britain (GOV.UK)
- Product regulations by sector and current approaches to product marking (GOV.UK)
- Construction Products Regulation in Northern Ireland (GOV.UK)
- Supply of Machinery (Safety) Regulations 2008: Great Britain (GOV.UK)
- Powered gates and doors: legal responsibilities (HSE)
This guide is general information about UK rules and good practice, not legal advice. Check the official sources and your own risk assessment for your site.