The UKCA (UK Conformity Assessed) Mark is the new UK product marking for goods being placed on the market in Great Britain (England, Wales, and Scotland). It covers most goods that previously required the CE marking.
What is the timeline for the UKCA mark?
From January 1, 2021, businesses placing products onto the UK market, regardless of where in the world they are based, have the choice to either use the CE marking or begin applying the UKCA marking. As of January 1, 2022, the option to use the CE mark will cease, and the UKCA mark must be used (save for some limited exceptions). Although the rules are broadly similar between the two regimes, some differences must be observed.
Which products require the UKCA mark?
Most products that are currently covered under CE marking will fall under the new UKCA requirements. There are exceptions and different rules for certain products, including medical devices, construction products, and vehicles. Element is an approved body, and we work in partnership with manufacturers to help to gain UKCA marking for a range of products, including:
- Electrical and electronic equipment
- Radio equipment
- Low voltage equipment
- Equipment used in potentially explosive atmospheres
- Marine equipment
What does it mean for my business?
All of this means that businesses should act now to ensure that they have everything in place for the January 1, 2022 deadline. Beyond this point, CE marking will no longer be recognized in the UK for these products. This may mean new paperwork, new labels, new packaging, and new relationships with importers, to name but a few.
Broadly speaking, each of the CE marking directives has been transposed into UK law under a corresponding UK Regulation. For example, the Electromagnetic Compatibility Directive 2014/30/EU has been transposed into the Electromagnetic Compatibility Regulations 2016, and the Radio equipment Directive 2014/53/EU has been transposed into the Radio Equipment Regulations 2017. Despite some changes in the text, the essential requirements remain largely the same, as do the options for conformity assessment procedures.
UKCA mark and self-declaration
Because the conformity assessment procedures remain largely unchanged, this means the option for self-declaration still exists, but only for products that also qualify for self-declaration under the CE marking rules. Each directive and regulation has different criteria for this, so it is always best to check before placing any products on the market.
The UKCA declaration of conformity will look very similar to the UK declaration of conformity, but will refer to the UK legislation instead of the EU legislation. There may also be a requirement to list new standards.
For some products, the self-declaration alone will not be sufficient, and an approved body may be required in order to issue a UK-type examination certificate for the product. If in doubt, Element can advise on the appropriate conformity assessment procedure for any given product.
Which standards should I use, and do I need more testing?
Where the EU maintained lists of harmonized standards, so too does the UK maintain lists of designated standards, which can be used to support the UKCA declaration of conformity, and each UK Regulation has its own list of standards. Some of these lists will differ from the analogous EU list, and so different standards may be used on declarations of conformity. It is worth noting that the choice of standards may impact the conformity assessment procedures available to you.
As it stands, it is not likely that a product will require additional testing to satisfy CE and UKCA compliance. Even where standards differ, further testing is not often needed. For example, a BS version or an EN version of the same standard may exist and be easily covered in a single set of testing or by carrying out a read-across from one test report to another version of the standard.
What about CE marking?
CE marking will continue to be recognized in the EU. However, as of January 1, 2021, manufacturers in the UK are no longer located within the EU. As such, businesses within the EU receiving CE-marked goods from UK companies take on a new role; they became an importer under EU rules. They take on more responsibility, and as such, UK companies can expect more scrutiny from their EU-based importers (and market regulators) to ensure paperwork is in order.
What about Northern Ireland?
As of January 1, 2022, CE marking will cease to be recognized in the UK, apart from products imported into Northern Ireland. These products may continue to bear the CE mark with the addition of the UKNI marking. There are also different rules for manufacturers in Northern Ireland placing goods on the rest of the UK market.
The Element advantage
Element has a team of technical experts that can advise on the new UKCA Mark, CE Marking, and the UKNI Mark. We help manufacturers to allow for a smooth transition for their products to meet the new standards. Contact our team today to get more information on the requirements in your specific case.
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