The UK Conformity Assessed mark (UKCA)
For better or worse the UK leaves the EU on 31st December 2020 at the end of the transition period. This will have a significant impact on electrical standards, certification, CE marking, and UKCA marking. Until 31st December 2021, electrical products sold into the GB market will need the CE mark, UKCA mark, or both.
From 1st January 2022 products must carry either the UKCA mark, or both UKCA and CE where the standards are identical. Moreover, from that date, GB will not recognise the CE mark for ‘specified areas’ so it will not be acceptable to sell those bearing only the CE mark. Time will tell how worldwide manufacturers interpret these changes and change their product markings to suit.
The term ‘specified areas’ accords with the current EU requirements for CE marking. This includes the Low Voltage directive (LVD), Electromagnetic Compatibility (EMC) directive, RoHS, and the Machinery Directive.
Despite the accompanying bureaucracy, there are advantages of the all-encompassing European Standards and CE marking. In addition to their acceptance by law across Europe, they are a passport to many markets worldwide. So where does that leave UK producers? While GB and EU standards remain harmonised, producers can use both the UKCA and CE mark on their products. However, if one standard changes but not the other, dual marking cannot be used. This will necessitating two versions of the product, one for each market.
While standards remain harmonised, these problems will not occur. In light of this, in 2018 the BSI and the European Standards Organizations CEN and CENELEC confirmed securing BSI’s full membership post-Brexit. The decision enables the UK industry and stakeholders to continue shaping and maintaining best practice and standards used across Europe and internationally. It also gives the BSI the opportunity to follow EU standards and ensure British Standards remain harmonised.
GB is now different from the UK
The UK Conformity Assessed mark (UKCA) is the new UK product marking for standards compliance. UKCA covers most goods which previously required the CE mark. It is for use on goods placed on the market in Great Britain (GB), namely England, Wales, and Scotland). The UKCA marking is not for use on goods placed on the Northern Ireland market, which require the CE mark or UK(NI) marking.
Selling goods in Great Britain
From 1st January 2021, the technical requirements and the conformity assessment processes and standards will be largely the same as they are now. EU rules are part of UK law and will remain so. The UK standards will be the same in substance and with the same reference as the standards used in the EU. However, they will use the prefix ‘BS’ to indicate that they are standards adopted by the British Standards Institution as the UK’s national standards body.
The CE marking will only be valid in Great Britain for areas where GB and EU rules remain the same. If the EU changes its rules, producers who CE mark their product based on those new rules will not be able to use the CE marking to sell in Great Britain even before 31st December 2021.
Selling goods in the EU
However, the EU market will not recognise UKCA marking. Products currently requiring a CE mark will still need CE marking for sale in the EU. Dual UKCA/CE marking will be acceptable providing it has CE compliance verification. However, CE products certified by UK test houses need retesting by EU accredited test houses.
This does not apply to existing stock in the supply chain. For example, if your goods were fully manufactured and ready to place on the market before 1st January 2021 you can still sell them in GB with CE marking even if covered by a certificate of conformity issued by a UK body.
Watch this space.