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UKCA/CE Marking for importers and exporters
You are probably already familiar with the
The UKCA marking process is virtually safety-related EU product directives for
identical to that for CE marking across
CE marking, such as the Machinery, ATEX
many product directives.
and Pressure Equipment Directives.
For machinery, UKCA marking indicates Following the Brexit referendum, there was
compliance with the Supply of Machinery uncertainty over product marking in the UK.
(Safety) Regulations, which is the GB
What we have ended up with is UKCA
equivalent of the EU Machinery Directive. marking in Great Britain (GB), which is very
There is a small but important difference similar to the EU’s CE marking. The
here. CE marking requires the Declaration Northern Ireland Protocol means the
of Conformity (DoC) to name someone situation there is different from GB
based in the EU as being responsible for (England, Scotland and Wales), even though
compiling the technical file.
Northern Ireland (NI) remains part of the
UK.
For UKCA marking, the UKCA What are the implications for importers and
Declaration need not name anyone exporters in terms of UKCA and CE
marking?
in GB. The same is true for a Declaration of Incorporation (DoI) Importing from the EU:
for partly completed machinery.
However, if an EU Notified Body certifies machinery prior to 1 January 2025, it can be UKCA marked and placed on the GB market on the basis of that EU certification.
This relaxation of the rules will continue until the certificate expires or until 31 December 2027, whichever is sooner.
Note: The Department for Business Energy and Strategy, BEIS, have changed the requirements several times, the dates given above are correct at the time of writing, but may change. You can use the link below to check the latest details ... https://www.gov.uk/guidance/using-the- ukca-marking.
A further difference between UKCA marking and CE marking is that UKCA declarations should state "Designated Standards" whereas CE declarations use the term "Harmonised Standards".
"Designated Standards" v "Harmonised Standards"
1 Jan 2028
"visible, legible and indelible" permanent UKCA mark required on both product
and documentation for goods placed on GB market
Since 1 January 2021, documentation needs to show goods as being UKCA marked. Until 31 December 2024, goods that were CE marked prior to 31 December 2020 can continue to be placed on the market in GB with the UKCA mark shown on the accompanying documentation and applied to the product using a ‘sticky label’.
For goods – such as Annex IV machinery – needing third-party conformity assessment, the assessment must be undertaken by a GB-based Conformity Assessment Body instead of an EU Notified Body, as previously required.
1 Jan 2021
UKCA marking regulations came into effect. UKCA markings can now be used
on products placed on the GB market
CE marked product placed on market before 31 Dec 2024 can remain in circulation without remarking
1 Jan 2025
UKCA markings required on products or their documentation for
manufactured goods placed on GB market. Temporary markings may be used.
UKCA marked product placed on market before 31 Dec 2027 can use temporary markings and remain in circulation without remarking
19. UKCA markings
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