Is there a legal requirement to retrofit CE marked hinges to existing fire doors?

[Guest Peter]

I own a flat in a purpose built 5 storey, 9 flats block built in 2004. Following a fire survey we have been advised that all 20 fire doors are in good condition but need new intumescent strips and replacement hinges (no standard information on existing hinges). All hinges are identical. All hinges are substantial and in good condition. I am a director of the management committee and have a joint responsibility for the safety of the building. My view and that of some of my fellow directors is that this expense is unreasonable and unnecessary.  The building needs other essential work and we regard replacement hinges as a low priority and low level of risk. Do we have to replace the hinges in the short term?

[AnthonyB]

No, if the original hinges approved at the time of installation are in good order and the correct rating for the weight for the door they should be fine - CE marking on new products is not retrospective. Sadly poorly trained risk assessors and unscrupulous fire door companies are costing leaseholders lots of money on things that add no fire real safety advantage.

[Neil Ashdown MAFDI]

As Anthony has said, Construction Product Regulations are not applied retrospectively. There is no requirement to replace existing hinges because they don't have a CE or UKCA mark. Current building regulations (Approved Document B Appendix C) require that:  

[Guest Simon]

Hi, I am a director of a Residents Management Company.  We manage seven four-storey blocks of  flats, built during 2010 to 2012. The flat entrance doors are fitted with three Eclipse adjustable self-closing hinges marked “BS EN 1634 1 HOUR” (image attached).

We commissioned a Fire Door Inspection Report which stated for each door “Replace Door Closer With Fire Rated Type to Current Regulations (Comment: Install an overhead closer compliant with BS EN 1154)”.

I’d be grateful if you could advise whether it would instead be acceptable to (a) adjust the tension on the hinges to ensure they fully close (b) if this is not possible, replace them with “like for like” hinges.  It appears that these hinges can still be obtained from Screwfix.

My concerns with installing new overhead closers are (1) it would more expensive (2) there would then be both overhead closers and self-closing hinges on each door (3) it would appear to go against the following advice from the Fire Protection Association: “… It is essential that the door closer chosen for any specific application or use has been tested in combination with the full fire doorset to ensure that the entire ensemble works effectively as a whole and offers the required level of fire resistance”

Many thanks.

[AnthonyB]

In theory if these are the original correct hinges fitted as part of the fire doorset at the time of installation and are in good order and shut the door flush in frame then they remain acceptable. If truly adjustable they are an improvement on single chain door closers (which aren't) and aren't explicitly forbidden like a traditional rising butt hinge would be. However they are deprecated in some industry guidance so the fire risk assessor should set the acceptable benchmark.
If any are worn beyond adjustment then they could be replaced like for like as still sold and do have test evidence although replacement with standard fire door hinges and a separate EN1154 closer may be preferred. 

https://www.ironmongerydirect.co.uk/product/adjustable-self-closing-fire-door-spring-hinge-102-x-76-x-3mm-polished-chrome-pack-of-3-692924?vat=1&GSP=true&gad_source=1&gclid=CjwKCAjwwLO_BhB2EiwAx2e-3xZjdaWmx_G4CPBW-VTNHS1EbwQua2O8OZedFbdegbS8FR5xUh4vaBoCvCAQAvD_BwE

[Neil Ashdown MAFDI]

Building Regulations mandate that flat entrance doors must self-close from all door-open positions.  The issue with spring hinges is that they often fail to do this completely and reliably. 

https://assets.publishing.service.gov.uk/media/67d2bb074702aacd2251cb94/Approved_Document_B_volume_1_Dwellings_2019_edition_incorporating_2020_2022_and_2025_amendments_collated_with_2026_and_2029_amendments.pdf

This is why guidance at the Code of Practice: Hardware for Fire Doors & Escape Doors requires self-closing devices that meet BS EN 1154 power size 3, as a minimum requirement. 

https://www.firecode.org.uk/Code_of_Practice_hardware_for_fire_and_escape_doors_issue_5.pdf