The UK has left the European Union (EU), and the transition period after Brexit comes to an end this year. This has some implications for suppliers to both the UK and EU regions.
New UK product marking UKCA replacing the CE for Great Britain
Products previously supplied to the UK with the CE mark will require a new UK product marking called the UKCA. The UKCA (UK Conformity Assessed) marking will be used for applicable goods being placed on the market in Great Britain (England, Wales and Scotland). For Northern Ireland products will require both the CE and the UKCA marking. It will cover most goods which previously required the CE marking.
UKCA and CE Transition period
The UKCA marking can be used from the 1st of January 2021. However, the CE mark may be used during the transitional period that will end on the 1st of January 2022 to allow companies to prepare the documentation and label products appropriately. If the product is sold in both the EU and the UK then both the CE and UKCA mark will be required, there is no reciprocal agreement.
So how does this affect your company
Products covered by the UKCA are on the whole the same as for CE marking with the addition of aerosols and the lack of REACH, UKCA applicable products include the following:
- Toy safety
- Recreational craft and personal watercraft
- Simple pressure vessels
- Electromagnetic compatibility
- Non-automatic weighing instruments
- Measuring instruments
- Radio equipment
- Pressure equipment
- Personal protective equipment
- Gas appliances
- Outdoor noise
- Low voltage electrical equipment
- Restriction of hazardous substances
Some products under the UKCA marking have some special rules and may require UKCA recognised notified bodies:
- Medical devices
- Rail interoperability
- Construction products
- Civil explosives
On the whole for most suppliers to the UK this will be an administrative exercise. However, if your product falls under the scope of directive that may require a notified body then there will be more work to do.
UKCA and CE notified body changes
Presently all CE notified bodies within the UK will automatically be granted UKCA notified body status for the same scope. However, these UKCA notified bodies will no longer be recognised as CE notified bodies. And current CE notified bodies within Europe will need to apply to become UKCA notified bodies before been recognised.
What do we need to do for UKCA compliance? Your UK Declaration of Conformity (DoC).
Many of the standards that will be used to demonstrate compliance initially will be identical to the equivalent CE standards with the prefix changed. So, for example, EN 55032 for CE compliance will become BS 55032 for UKCA compliance, your UKCA declaration of conformity will need to indicate this. In addition to this, the applicable BS (UKCA) will align with the UK legislation and not the CE directives as per the use of harmonised standards, both of these will require DoC changes.
The UKCA Declaration of Conformity will basically be the same as what is currently required on an EU CE Declaration of Conformity. However similar to CE requirements this can vary per directive/legislation but generally should include:
- your name and full business address or that of your authorised representative
- the product’s serial number, model or type identification
- a statement, stating you take full responsibility for the product’s compliance
- the details of the approved body which carried out the conformity assessment procedure (if applicable)
- the relevant legislation with which the product complies
- your name and signature
- the date the declaration was issued
- supplementary information (if applicable)
As stated previously you will need to modify to include:
- relevant UK rather than EU legislation
- UK designated standards rather than standards cited in the Official Journal of the European Union
CE legislation vs UK legislation
|EU legislation||UK legislation|
|Toy Safety – Directive 2009/48/EC||Toys (Safety) Regulations 2011|
|Recreational craft and personal watercraft – Directive 2013/53/EU||Recreational Craft Regulations 2017|
|Simple Pressure Vessels – Directive 2014/29/EU||Simple Pressure Vessels (Safety) Regulations 2016|
|Electromagnetic Compatibility – Directive 2014/30/EU||Electromagnetic Compatibility Regulations 2016|
|Low Voltage Directive 2014/35||Electrical Equipment (Safety) Regulations 2016|
|Non-automatic Weighing Instruments – Directive 2014/31/EU||Non-automatic Weighing Instruments Regulations 2016|
|Measuring Instruments – Directive 2014/32/EU||Measuring Instruments Regulations 2016|
|Lifts – Directive 2014/33/EU||Lifts Regulations 2016|
|ATEX – Directive 2014/34/EU||Equipment and Protective Systems Intended for use in Potentially Explosive Atmospheres Regulations 2016|
|Radio equipment – Directive 2014/53/EU||Radio Equipment Regulations 2017|
|Pressure equipment – Directive 2014/68/EU||Pressure Equipment (Safety) Regulations 2016|
|Personal protective equipment – Regulation (EU) 2016/425||Personal Protective Equipment Regulations (Regulation (EU) 2016/425 as brought into UK law and amended)|
|Gas appliances – Regulation (EU) 2016/426||Gas Appliances (Product Safety and Metrology etc (Amendment etc) (EU Exit) Regulations 2019)|
|Machinery Directive 2006/42/EC||Supply of Machinery (Safety) Regulations 2008|
|Outdoor Noise Directive 2000/14/EC||Noise Emission in the Environment by Equipment for use Outdoors Regulations 2001|
|Directive 92/42/EEC hot-water boilers AND Ecodesign Directive 2009/125/EC||The Ecodesign for Energy-Related Products and Energy Information (Amendment) (EU Exit) Regulations 2019|
|Restriction of the Use of certain Hazardous Substances in Electrical and Electronic Equipment (RoHS) – Directive 2002/95/EC||The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012|
For more information please visit the UK government website UKCA information.