What is the UKCA mark?

As of January 2021, due to the changes being brought in due to Brexit, the UK Government has brought in a new safety mark for products that are sold in the UK: the UK Conformity Assessed marking- UKCA. The UKCA mark was designed as a way of marking products sold on UK shelves. This mark was supposed to replace the European CE mark,[1] which, it was hoped, would be out of circulation by January 2022. However, the deadline for UKCA marking was extended on 24th August 2021, in part due to delays caused by the COVID-19 pandemic and the commercial landscape in a “post- COVID economy,” which has limited the uptake of the marking system.

The UKCA mark, in black letters on a white background

Any product previously granted CE marking will have to have UKCA marking by January 2023, including, but not limited to:

  • Toys

  • Pyrotechnics

  • Recreational craft and personal watercraft

  • Simple pressure vessels

  • Electromagnetic compatibility

  • Non-automatic weighing instruments

  • Measuring instruments

  • Lifts

  • ATEX

  • Radio equipment

  • Pressure equipment

  • Personal protective equipment

  • Gas appliances

  • Machinery

  • Equipment for use outdoor

  • Ecodesign

  • Aerosols

  • Low voltage electrical equipment

  • Restriction of hazardous substances.[2]

The path to market for construction equipment may be slightly different however and is explored in ‘Scope four.’

This scope outlines that construction equipment will need to carry the UKCA mark to be placed on the English, Scottish, and Welsh markets, as further changes on 1st January 2021 now align Northern Irish construction product recommendations with the continued use of CE marking, as allowed under the Norther Ireland Protocol.[3]

This will mean that if products are manufactured for use across Europe, the UK, and Northern Ireland, then a product may require multiple safety markings, including the traditional CE mark, the UKCA, and the new UK(NI)/ UKNI- the UK Conformity Assessed marking for Northern Ireland.

UKNI mark written with black lettering on a white background

All industries that produce goods for manufacture can continue to use the CE mark until 1st January 2023, ‘some CE marked goods, that meet EU requirements, may continue to be placed on -the GB market,’[4] but the Government warns that this will not continue long-term, reiterating that after the deadline, 1st January 2023, this will no longer be tolerated.

Long Term Confusion over Marking

However, the issue for manufacturers now is the apparent confusion over information. While the Government maintains that it will continue to support manufacturers and provide webinars, finding a clear answer to important questions remains difficult, which will surely make changing over before the deadline of 1st January 2023 even harder, and less likely.

For example, if a fire product was manufactured for distribution and use across Europe, the UK, and Northern Ireland, does it require the CE, UKNI, and UKCA marking?

Can one product destined for all three markets bear all three markings?

Or must manufacturers now mark each product with only one combination of markings?

Table to demonstrate which goods require which markings

This table, from a UK Government website suggests that the UKCA and the UKNI mark are generally interchangeable if the product is to be sold in the rest of the UK, and Norther Ireland respectively, however as expected until the end of 2022, the CE mark still features as accepted. [5]

The difference, and concrete answer we were looking for, appears to be based around UK ‘Approved Bodies,’ for conformity assessment.

These approved bodies ‘are able to undertake conformity assessment activity for UK designated standards. Where an approved body has undertaken the assessment, the manufacturer (or their authorised representative) must affix the UK marking’[6] (the UKCA mark.) Conformity assessment until the end of 2022 will mirror CE marking conformity assessment, and as such will not be an issue for manufacturers until after the deadline.

To be used on the UK market and to bear the UKCA mark after the deadline, it must be approved by one of the newly formed ‘Approved Bodies,’ officially recognised on 1st January 2021. These UK notified bodies operated under the EU Construction Products Regulation 2011 (EU Regulation No. 305/2011) and were based in the UK and can now be found in the new UK database, The UK Market Conformity Assessment Bodies database. These Approved Bodies will assess and deliver the UKCA marking to acceptable goods moving forwards.

Products sold in Northern Ireland however, ‘will be required to carry the CE mark and if tested by a UKAS Approved Body, must also carry the UKNI mark.’[7] This means that any NI product using a UK body to carry out mandatory third-party conformity assessments, such as a UKAS Approved Body, will also need to apply a UKNI marking, alongside the CE mark.[8]

Black map of the UK on a white background

UKCA and the Fire Industry

While individual items that are placed on the market in Great Britain before 1st January 2022 can continue to circulate with CE marking after the deadline until they reach their end user, the FIA, a cornerstone source for the Fire Industry, has outlined their concerns regarding the change over from CE marking.

‘Our primary concerns are that:
cost our industry sectors in the region of £20m for product re-certification plus an estimated timeline of over 36 months to realistically carry out the process.
dual product certification will cause major disruption to companies that make/sell products across the UK, EU and global markets, which, subject to any unknown divergence, will add significant costs to the process.
This process does not add any value or quality to the product at a time when businesses are already stretched with Brexit and Covid-19.’[9]
Orange and white fire on a black background

The FIA, and many other businesses within the Fire Industry, continue to express concern over the confusing, time consuming, and potentially very costly switch over to a new marking system in time for January 2023.

Especially as they continue to navigate a world in which the challenges to businesses are rapidly increasing, and the proposed benefit of a change is long-reaching and very limited.

Is your business ready for UKCA marking?

Are you confident you will make the extended deadline of 1st January 2023?

Share your thoughts with us in the comments!

________________________________________________________________________ [1] Captec, ‘WHAT DOES THE NEW UKCA MARK MEAN FOR UK BUSINESSES?’, <https://captec-group.com/the-new-ukca-mark-and-what-it-means-to-uk-businesses/ >, 08.10.2021 [2] Gov.UK, ‘Using the UKCA marking,’ updated 24.08. 2021<https://www.gov.uk/guidance/using-the-ukca-marking> [3] Gov.UK, ‘Using the UKNI marking,’ updated 01.02.2022, <https://www.gov.uk/guidance/using-the-ukni-marking> [4] Gov.UK, ‘Construction products regulation in Great Britain,’ updated 24.08.2021, <https://www.gov.uk/guidance/construction-products-regulation-in-great-britain> [5] Table taken from above source. [6] Gov.UK, ‘Construction products regulation in Great Britain,’ updated 24.08.2021, <https://www.gov.uk/guidance/construction-products-regulation-in-great-britain> [7] INCA-Ltd.org.uk, ‘CE mark vs UKCA/ UKNI mark, published by INCA technical committee chairman Kevin Mangan, <https://www.inca-ltd.org.uk/external-wall-insulation-ce-vs-ukca-ukni-marking/#:~:text=Initially%2C%20the%20UKCA%20and%20UKNI%20mark%20will%20use,we%20are%20no%20longer%20part%20of%20the%20EU.> 04.04.2022 [8] Gov.UK, ‘Using the UKNI marking,’ updated 01.02.2022, <https://www.gov.uk/guidance/using-the-ukni-marking> [9] FIA, ‘Important UKCA survey for the fire industry,’ pubished 15.02.2021, <https://www.fia.uk.com/news/important-ukca-survey-for-the-fire-industry.html>

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