A manufacturer is obliged to comply with the CPR and the harmonised technical specification(s) applicable to their construction product(s) which is in this case the chimneys and terminals. 

Additionally, the manufacturer is obliged to meet obligations derived from the accreditation standards, as the accreditation standards require the certification body to specify certain requirements to their client, e.g. to maintain records of complaints. This should be defined by the contract between the manufacturer and the notified FPC certification body.

In principle, the FPC requirements defined in harmonised technical specifications (e.g. EN 1856-1/-2, EN 13084-7) should be sufficiently detailed to serve as a comprehensive basis for assessment of the manufacturers‟ FPC.

However, it is well-known that some harmonised technical specifications do not go into sufficient detail about FPC requirements. In such cases, Commission Guidance Paper „B‟ may serve as a useful interpretative tool; as may CEN guidance for drafting AVCP clauses in harmonised standards.

Irrespective of how detailed the FPC clauses are in the harmonised technical specification, the notified FPC certification body (Kiwa) shall satisfy itself that the FPC as implemented by the manufacturer is effective, i.e., the manufacturer is effectively able to manage and demonstrate the actual performance of the construction products.

The notified FPC certification body shall assess the FPC-system (as implemented) in its entirety for the initial inspection regarding its effectiveness as described above.

This implies that all parts of the documented system and the operational practices of the manufacturer with relevance to the conformity/performance of the essential characteristics being assessed shall be subject to assessment.