UKCA mark to become conformity assessment marking for Great Britain from January 2022
04 September 2020
The UK government announced on September 1 that the new UKCA (UK Conformity Assessed) marking can be used from 1 January 2021, however, to allow businesses time to adjust to the new requirements, the CE marking may still be used until 1 January 2022 in most cases.
The UKCA mark is a new UK product marking that will be used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods which previously required the CE marking, including the ATEX Directive.
When to use the UKCA marking
You will need to use the new UKCA marking immediately after 1 January 2021 if all of the following apply. Your product:
- is for the market in Great Britain
- is covered by legislation which requires the UKCA marking
- requires mandatory third-party conformity assessment
- conformity assessment has been carried out by a UK conformity assessment body and you haven’t transferred your conformity assessment files from your UK body to an EU recognised body before 1 January 2021
This does not apply to existing stock, for example if your good was fully manufactured and ready to place on the market before 1 January 2021. In these cases, your good can still be sold in Great Britain with a CE marking even if covered by a certificate of conformity issued by a UK body.
CE marking for the GB market
You will be able to use the CE marking until 31 December 2021 if any of the following apply:
- you currently apply the CE marking to your good on the basis of self-declaration
- any mandatory third-party conformity assessment was carried out by an EU-recognised notified body (including a body in a country with which the EU has a relevant mutual recognition agreement)
- the certificate of conformity previously held by a UK approved body has been transferred to an EU-recognised notified body
You can only place CE marked goods that meet EU requirements in Great Britain while UK and EU requirements are the same. This will be the case on 1 January 2021 and there are no UK plans to diverge at this time. Nonetheless you are encouraged to be ready as soon as possible, and by 1 January 2022 at the latest. If the EU changes their rules and you CE mark your goods based on new EU rules which are different from the requirements in the UK, you will no longer be able to use the CE marking in the UK. This will be the case even if the change happens before 1 January 2022.
CE marking for both the GB and EU market
The UKCA marking will not be recognised on the EU or Northern Ireland markets. Products currently requiring a CE marking for sale in the EU will continue to need a CE mark.
You will not need to take any action from 1 January 2021 if either of the following apply:
- you self-declare the conformity of your good against the regulations
- you voluntarily use a testing or notified body to test against European or international standards
You may need to take additional action if your good needs third-party conformity assessment.
Check whether your UK notified body is taking steps that help you continue to export to the EU without needing to find a new EU notified body.
If not, you may need apply for a new certificate from an EU notified body. Your existing notified body should provide another body of your choice information relating to your conformity assessments in order to facilitate this.
Using both the CE and UKCA marking
Goods can carry both the CE and UKCA markings so long as they are fully compliant with both UK and EU regulations.
From 1 January 2021 the essential requirements and standards that can be used to demonstrate conformity with them for UKCA marked goods will be the same as they are now. That means that if your goods is currently made to the technical requirements necessary for CE marking then it will be made to the same technical requirements that will exist for UKCA marking from 1 January 2021. However, the conformity assessment bodies that test them may need to be different.
Conformity assessment for the EU market
From 1 January 2021 any mandatory third-party conformity assessment for the EU market will need to be carried out by an EU-recognised conformity assessment body. This includes both EU based bodies and bodies in countries with which the EU has concluded a mutual recognition agreement.
UK conformity assessment bodies will no longer be able to carry out mandatory conformity assessment for products being placed on the EU market unless agreed in negotiations.
The new UK legal framework
From 1 January 2021, the UK government is putting in place a domestic legal framework that will allow UK conformity assessment bodies to continue operating for most products being placed on the GB market. The new UK legal framework and the technical requirements for becoming a UK approved body or a UK-recognised RTPO, UI or TAB will be broadly the same as they are now.
EU notified bodies are required to share information with UK approved bodies when requested by a certificate holder, and UK approved bodies should do the same with EU notified bodies. This will help facilitate the issuing of new certificates of conformity, where needed, without the need to repeat the entire certification process.
Most conformity assessment bodies in the UK will automatically have their status converted under the new UK framework. UK-based notified bodies will become UK approved bodies, and UK-based RTPOs, UIs and TABs will become UK-recognised RTPOs, UIs and TABs respectively. You do not need to take any action to be transferred under this arrangement. UK-based notified bodies who become approved bodies will keep the same 4-digit identification number as they have now.
Further information:
Using the UKCA mark from 1 January 2021
Conformity assessment bodies: change of status from 1 January 2021
Placing manufactured goods on the market in Great Britain from 1 January 2021
Placing manufactured goods on the EU market from 1 January 2021