The UKCA mark is the new UK product marking that will be required for certain products being placed on the market in Great Britain (England, Wales and Scotland). It covers most products that previously required the CE mark. UKCA marking declares that the product conforms to all applicable UK legislative requirements and that appropriate conformity assessment procedures have been successfully completed.
From 1 January 2021, the technical requirements for UKCA-marked equipment will be identical for CE-marked equipment. The intention is for that to remain throughout 2021, but EU legislative changes may have an impact.
The technical standards used will be fundamentally the same, however although the technical content is the same, for UKCA marking, the BSi Group versions of the standards should be used.
Any impact of UKCA marking on manufactured food or agriculture products, cosmetics, marine equipment, medical devices, road vehicles, chemicals, medicines, rail interoperability, transportable pressure equipment, construction products or civil explosion products is different and not considered here. There are special requirements for these areas .
For most other CE-marked products, from 1 January 2021, the Great British market will accept either UKCA marking or CE marking. Many CE-marked products will continue to be allowed until 1 January 2022, unless the EU changes its relevant legislation and Great Britain doesn’t keep in step.
Some newly-manufactured products will need UKCA marking from day one, these being ones sold in Great Britain that require and use a UK third-party approval system. EU third-party approvals will only be accepted for CE-marked products from 1 January 2021. If UK approved bodies are used instead, the product will need to be UKCA marked.
If a product is already on the market as part of existing stock, say at a distributor, or fully manufactured but not yet delivered to the customer, the sale of CE marked products of any form can continue after the 1st of January 2021.
Northern Ireland is a special case and presently the position is that Northern Ireland will continue to accept all forms of CE-marked equipment without a present limitation date. It is important to note however, that Northern Ireland will not be accepting UKCA marked equipment unless it also has a CE mark. Northern Ireland also have its own marking system, the UK(NI) mark, and manufacturers will be able to either mark their products with CE or with UK(NI).
Manufacturers will need to produce a dedicated declaration of conformity (and/or incorporation) for UKCA marking, so if the product is also CE-marked there will be at least two versions of these declarations.
Please note that either CE or UKCA marking requires compliance with all relevant directives or regulations. The recommended position is to have combined declarations for all relevant ones, whether it is low-voltage equipment, pressure equipment or hazardous area equipment.
Over time, the UKCA mark will become controlled in a similar way to the present CE mark, but for the immediate future until January 2023 it won’t need to be permanently fixed, so for example it could be just a sticker.
If the manufacturer undertakes the importing, then this makes the process simpler, but third-party importers may ask for copies of the manufacturers’ technical files, as their responsibilities generally last for ten years after supply.
In many cases, end users buying directly from manufacturers in the EU, or vice versa, will suddenly become importers. Importers into the EU, Great Britain and Northern Ireland will all be asked to check manufacturers’ documentation. This will include: the validity of the declaration, that a suitable technical file exists that these can provided if ever asked.
The quality of manufacturers’ declarations could very quickly become important, whereas at the moment that is not the case. For many goods, the name and addresses of importers need to be identified either on the product or on the packaging, so additional labeling is required.