Complaints

Complaints about certified products should be raised with the customers. If no satisfactory response is received, the complaint may be raised with the empowered Certification Body, or the KEYMARK Management Organization, who will inform the empowered Certification Body.

The empowered Certification Body shall ensure that complaints are investigated by the customer as soon as possible and, where appropriate, advise the complainant of the outcome. If the investigations of the empowered Certification Body reveal non-compliance with the requirements of the relevant European standard(s) or the KEYMARK Scheme, the required action arising from the investigation of this complaint is notified by the empowered Certification Body to the client in a registered letter.

This action can be a corrective action, suspension of the right to use the KEYMARK, or withdrawal of the right to use the KEYMARK.

Inspection Bodies

Product-related Factory Production Control (FPC)

Precondition for the certification is the establishment and the operation of a specific product-related FPC, taking into account the elements of EN ISO 9001 and the process of the related production line from the raw material to finished product and storage of the product. The FPC is an integral part of the customer’s quality management system, if any. The empowered Certification Body makes the necessary arrangements with the customers for the initial inspection at the factory and the Initial Type Test (ITT). 

The initial inspection covers the evaluation of the FPC (see above) and normally includes the selection of samples for the ITT. If not specified otherwise in the European standard(s) or KEYMARK Scheme, at least one sample shall be selected. 

The regularly factory inspections include verification of the documentation of the related FPC at least once a year, as well as sampling for tests at least every second year, unless otherwise specified in the European standard(s) or KEYMRK Scheme. If necessary, samples can be taken from the market. With regard to the FPC, particular attention is to be drawn to any changes of product design, materials or methods of production which may affect the conformity as established through the ITT of the product.

For the purpose of surveillance the customers agrees to allow the empowered Certification Body, or bodies acting on its behalf, reasonable access to its premises.

Requirements for Inspection Bodies

All Inspection Bodies, whether internal or external, shall be accredited on the basis of EN ISO/IEC 17021 by a signatory to the relevant Multilateral Accreditation Agreement (ILAC).

There might be further specific requirements and procedures for Inspection Bodies taking part in the specific KEYMARK Scheme Rules to be fulfilled.

Furthermore, all internal or external Inspection Bodies shall:

  • participate in meetings relevant to the operation of the KEYMARK Scheme
  • not receive any financial subsidy to support their inspection activities, in order to avoid unfair competition
  • maintain confidentiality of the information obtained in the course of conformity assessment procedures, unless explicitly agreed upon in writing in advance
  • have a contract with the involved empowered Certification Body to act as sub-contractor

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Certification Bodies

 

More and more European Certification Bodies are interested in granting the European quality mark KEYMARK for products and services based on European Standards in order to provide the respective certification service. Since mid 2015, the empowerment of new Certification Bodies for granting the KEYMARK is done by a KEYMARK Management Organization (KMO) on behalf of CEN.

The Way to KEYMARK Empowerment

The application for empowerment for granting the KEYMARK has to be sent in writing or as PDF by the Certification Body to the KEYMARK Management Organization. On behalf of CEN, the KMO will assess the provided application documents and evaluate if the requirements for empowerment are fulfilled (for French Certification Bodies, in close cooperation with AFNOR Certification).

The proof of competence is done according to the CEN-CENELEC Internal Regulations, Part 4 "Certification" and is based on:

  • a valid accreditation according to EN ISO/IEC 17065 and the applied scope
  • appropriate experience as Certification Body
  • the Testing Laboratories accreditation according to EN ISO/IEC 17025 and the applied scope sub-contracted by the Certification Body
  • if applicable, the evaluation of the respective certification scheme of the Certification Body if it is in conflict with the CEN-CENELEC Internal Regulations

If the result of the assessment is positive, a licence agreement is concluded and the Certification Body receives a corresponding certificate of empowerment. Together with the certificate of empowerment, the certification body will get an Identification No. (ID) which has to be used in conjunction with the granted KEYMARK.


The empowerment is unlimited valid as long as the Certification Body fulfills the requirements of the licence agreement and can furthermore show that they are still accredited for the respected scope as required.

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Testing Laboratories

More and more Testing Laboratories are interested in offering tests within the European KEYMARK certification for products and services based on European Standards and to provide the respective testing service.

Requirements for Testing Laboratories

All Testing Laboratories, whether internal or external, shall be accredited on the basis of EN ISO/IEC 17025 by a signatory to the relevant Multilateral Accreditation Agreement (ILAC).

There might be further specific requirements and procedures for Testing Laboratories taking part in the specific KEYMARK Scheme Rules to be fulfilled. 

Furthermore, all internal or external Testing Laboraotories shall:

  • participate in meetings relevant to the operation of the KEYMARK Scheme Groups
  • not receive any financial subsidy to support their testing or inspection activities, in order to avoid unfair competition
  • maintain confidentiality of the information obtained in the course of conformity assessment procedures, unless explicitly agreed upon in writing in advance
  • have a contract with the involved empowered Certification Body to act as sub-contractor

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Third Parties

Requirements for Third Parties (Conformity Assessment Bodies)

Within the scope of the harmonization of the European market, testing, inspection and certification has to satisfy high requirements in terms of independence, neutrality, and organisation. A Certification Body and its internal or external sub-contractors shall satisfy the criteria and requirements established in the Internal Regulations Part 4 in order to be able to operate a KEYMARK Scheme. These criteria and conditions by no means prejudice the commercial competition between the conformity assessment bodies.

To ensure this, the third parties have to demonstrate their competence and be accredited to perform

Only Certification Bodies can be empowered to grant KEYMARK certificates. All other conformity assessment bodies shall act as sub-contractor of the Certification Body (bound by contract). Certification Bodies which seek to award the KEYMARK must also undertake a formal empowerment process and receive authorization to do this by KMO (KEYMARK Management Organization) on behalf of CEN.

General Requirements

European standards within the scope of an application, shall have been implemented in the country of the Certification Body.

Each Certification Body, and where appropriate its internal or external sub-contractors shall:

  • participate in meetings relevant to the operation of the KEYMARK Scheme
  • not receive any financial subsidy to support their certification, testing or inspection/assessment activities, in order to avoid unfair competition
  • maintain confidentiality of the information obtained in the course of conformity assessment procedures, unless explicitly agreed upon in writing in advance.

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