UKCA Marking:  1st January 2021

The last minute "deal" was very "thin" and has had no effect on the product regulatory situation (i.e. no "mutual recognition" agreement included... or even mentioned!). From 1st January 2021 , any new product brought to market in Great Britain (different rules apply for Northen Ireland),  that currently require CE Marking, will (also) need UKCA marking. 

 

Click here to see the official guidance , carry on below to see a brief summary.

  • UKCA marking can be used from 01/01/2021 and must be used on new products put onto the market in Great Britain for the first time after this date.

  • However, for existing products CE marking can still be used until 01/01/2022  

  • CE marking will only be valid in Great Britain , different rules apply to Northern Ireland

  • Northern Ireland will be different and CE Marking will continue for an unspecified time ….and these will be able to be legally shipped to the rest of the UK!  Manufacturers in NI can chose either when "exporting" to Great Britain.

  • The "Technical aspects" relating to the conformity process and various requirements are unchanged , previously the EU Directives were taken into UK law via "statutory instruments" , now these SI are the  UK stand-alone rules, but nothing in them of any significance has changed. Basically for the time being its just a change from directives to SIs and from CE to UKCA. All of the "Technical documentation" requirements are effectively unchanged. 

  • If EU rules change, and you CE mark the product on basis of new rules, you will not be able to use CE mark to sell into GB, even before 31/12/2021. (Note that this is highly unlikely to happens as the EU typically take 2-3 years to bring in legislation and nothing is on the immediate horizon) 

  • UKCA mark will not be recognised in EU/EAA market, CE mark will still be needed for products sold on EU markets.  

  • A UK Declaration of Conformity must be drawn up for most products lawfully bearing UKCA mark. Information required will largely be same as for the EU DoC , but will reference the UK Statutory Instruments rather than the EU Directives and Regulations .

  • A list of EN standards has now been published which can provide a Presumption of Conformity for UKCA . this is a direct copy from the EU Official Journal , so no surprises.

  • From 01/01/2023 the UKCA mark must, in most cases, be affixed directly to the product. 

  • Special rules apply to some product types (Medical Devices, ATEX etc) 

Statement: Petts Consulting Ltd will provide an Organization with the knowledge of the Directives and an appropriate process which, when applied correctly will demonstrate due-diligence. However, the CE-marking is the manufacturers claim that the product meets the essential requirements of all relevant European Directives. In many cases the process to be carried out is a self-declaration process and the responsibility for any decisions lie with the management of the Company. During the course of the project Petts Consulting Limited will provide guidance and advice but ultimately it cannot be held responsible for such decisions.

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