Understanding the use of the UKCA Mark for UK markets
07 October 2020
Due to the UK leaving the EU, UKCA (UK Conformity Assessed) is a new UK product marking regulation that will be used in place of the CE mark for goods being placed on the UK market.
(Click here to read article in the October issue of Hazardex)
Starting January 1, 2021, UKCA will be the conformity assessment marking for goods entering the UK market that are currently subject to CE marking. However, to allow time for adjustments to the new requirements, businesses will still be able to use the CE marking until January 1, 2022.
Businesses should be ready to use the UKCA marking from 1st January 2022 at the latest, although they should look to use the UKCA marking as soon as possible.
Using the UKCA Mark
From January 1, 2021 businesses can apply the UKCA marking to their product or to the packaging. In some cases, it may be placed on the manuals or on other supporting literature. This will vary depending on the specific regulations that apply to the product.
The following general rules apply using the UKCA mark:
• UKCA markings must only be placed on a product by the manufacturer or authorised representative (where allowed for in the relevant legislation)
• When attaching the UKCA marking, businesses take full responsibility for their product’s conformity with the requirements of the relevant legislation
• Businesses must only use the UKCA marking to show product conformity with the relevant UK legislation
• Businesses must not place any marking or sign that may misconstrue the meaning or form of the UKCA marking to third parties
• Businesses must not attach other markings on the product which affect the visibility, legibility or meaning of the UKCA marking
• The UKCA marking cannot be placed on products unless there is a specific requirement to do so in the legislation
UK Declaration of Conformity
The UK Declaration of Conformity is a document which must be drawn up for most products lawfully bearing a UKCA marking.
In the document businesses, or an authorised representative (where allowed for in the relevant legislation), should:
• Declare that the product is in conformity with the relevant statutory requirements applicable to the specific product
• Make sure the document has the name and address of the manufacturer (or an authorised representative) together with information about the product and the conformity assessment body (where relevant)
The UK Declaration of Conformity should be available to market surveillance authorities on request.
The information required on the Declaration of Conformity will be largely the same as what is currently required on an EU Declaration of Conformity. This can vary depending on the application legislation but generally should include:
• Business name and full business address or that of an authorised representative
• The product’s serial number, model or type identification
• A statement, stating the business takes 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
• Business’s representative’s name and signature
• The date the declaration was issued
• Supplementary information (if applicable)
You will need to list:
• Relevant UK legislation instead of EU legislation
• UK designated standards rather than standards cited in the Official Journal of the European Union
Continuing use of the CE Mark
The CE marking will be accepted in the UK until January 1, 2022 for some products such as those with certificates of conformity issued by an EU-recognised Notified Body or pre-existing stock.
Businesses will be able to use the CE marking until December 31, 2021 if any of the following apply:
• The business currently applies the CE marking to their goods 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 Notified Body has been transferred to an EU-recognised Notified Body
Conformity assessment for the EU market
Starting January 1, 2021 any mandatory third-party conformity assessment for the EU market will need to be carried out by an EU-recognised conformity assessment body.
Very few Testing, Inspection and Certification (TIC) providers have the physical presence and Notified Body status in both the EU and UK to meet the requirements and issue the CE and UKCA marks.
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 EU and UK regulations.
CSA Group maintains both an EU-27 Notified Body (CSA Group Netherlands B.V, Notified Body number 2813), and will become a UK Approved Body (Sira Certification Service No. 0518) on January 1, 2021, ensuring we can offer UKCA and CE services in a seamless and efficient manner.
Affixing the UKCA mark to a product
In most cases, UKCA marks need to be affixed to the product itself. A transitional measure being introduced allows for the UKCA mark to be affixed to an accompanying document (in lieu of the actual product) until January 1, 2023 (after which the UKCA mark must be affixed directly to the product) to ease any potential burden on product labelling changes.
Documentation needed for a UKCA assessment
Documentation that is used in the assessment process will emulate that of the CE mark in the EU market so the documents for CE mark should be sufficient, with appropriate amendments to include the UKCA marking.
CSA Group maintains both an EU-27 Notified Body (CSA Group Netherlands B.V, Notified Body number 2813), and will become a UK Approved Body (Sira Certification Service No. 0518) on January 1, 2021, ensuring we can offer UKCA and CE services.
CSA Group Testing UK Ltd.
+44 (0) 1244 670 950
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