Answering Some UKCA Questions

What’s this new UKCA Mark?

The UKCA (UK Conformity Assessed) mark is the new UK product marking that will be required for products being placed on the UK market (England, Scotland, Wales). This new mark will cover most products that were previously covered by the EU’s CE mark.

Now we’re out of the EU, the CE mark will no longer be recognised to indicate compliance in the UK, and conversely, the UKCA mark will not be recognised in the EU to infer the same. This means that any products sold into the EU from the UK will still require the CE mark to be applied.
The Northern Ireland Protocol means that the rules covering CE marking will still apply.

What does the new mark show?

By affixing the UKCA mark to a product and placing it on the UK market, the manufacturer of that product is stating that the product meets the UK Regulations as defined in the relevant Statutory Instruments.

When will the new mark be required on products?

The UKCA mark came into force on the 1st January 2021, which marked the end of the transition period. To allow manufacturers to catch up though, the CE mark will continue to be accepted until the 1st January 2022.

Can CASS Industries perform the required testing to UKCA Specifications?

Yes. There is little change in the actual testing, and all the standards are the same as before. We at CASS Industries are able to test to both UKCA & CE marking systems, and are able to offer advice & support to customers requiring either, or both technical documentation files as required.

Can I still Self-Certify Compliance?

Yes. The principle of self-certification & 3rd party assessment remains unchanged at this time.

Placing Products on the British Market

The UKCA mark can be used to demonstrate conformity with UK regulations for products placed on the market after the 1st January 2021. As mentioned above, the CE mark can continue to be used until the 31st December 2021.
If the all the following conditions apply, then the UKCA mark must be used immediately from the 1st January 2021:

  • The product is covered by legislation which requires the UKCA mark
  • The product requires mandatory 3rd party assessment
  • The 3rd party assessment has been carried out by an EU Notified Body located in the UK & the files have not been transferred to an EU27 Notified Body
  • The product is intended for sale on the GB market.

This does not apply to existing stock, if that stock was fully manufactured & ready for market before the 1st January 2021. In these cases, the goods can still be sold in Britain with CE marking even if covered by a Declaration of Conformity issued by a UK Body.

  • From the 1st January 2022, all products to be available on the British market must be UKCA marked unless special arrangements are in place.
  • CE Marking for Medical Devices will still be recognised in Britain until 30 June 2023 assuming that British & EU rules maintain synergy.
  • Any product that is currently CE marked on the basis of an EU Notified Body assessment are required from the 1st January 2022 to be assessed by a UK Approved Body before they can be placed on the British market.
  • For businesses based in Northern Ireland, products which qualify can be placed on the British market with an EU CE marking after the 31st December 2021.

I want to place a product on the EU market. What assessment is required?

  • For goods using self-certification, no further action is required.
  • For goods having 3rd party assessment by an EU27 notified body, no further action is required.
  • For goods that have a 3rd party assessment made by an EU Notified Body located in the UK, the files will need to have been passed on to an EU27 Notified Body before 1st January 2021, or a new assessment needs to be completed by an EU27 Notified Body.

I want to place a product on the Northern Ireland market. What assessment is required?

  • Any new & existing goods that are CE marked can be placed on the market with no changes at all.
  • The UKCA mark is not recognised in Northern Ireland.
  • Any goods that require a 3rd party assessment can be placed on the Northern Ireland market using either an EU27 Notified Body and affixed with the CE mark, or a UK Approved Body and affixed with both the CE & UKNI marks. Products marked with both marks cannot be sold into the EU market, as UK Approved Bodies are not recognised within the EU.
  • Any existing 3rd party assessment from an EU27 Notified Body will continue to be accepted by Northern Ireland.

UKCA Mark – Making the Transition

As we all know, the UK has left the EU. As a result of this the CE Mark will no longer be recognised as demonstrating conformity within UK legislation after the transition period has ended.

Instead, the UK has created it’s own conformity mark, the UKCA Mark:

The transition period is closer than you think! It begins on the 1st January 2021, and the UKCA mark will become mandatory on the 1st January 2022. This mark applies to any goods placed on the market in England, Scotland & Wales. Northern Ireland will retain the CE mark.

So what’s required?

The transition to the new UKCA mark is mainly a paperwork exercise. You’ll need to create a new UK Declaration of Conformity which is very similar to the CE Declaration (and these are still required to show CE mark compliance).

The Technical File you should be keeping well up to date for your product portfolio will need some additional information, with references the UK Statutory Instruments and Designated Standards. We can assist with these changes, if you require help, just let us know!

Once you’ve sorted out the technical file, the UKCA mark then needs to be applied to your products. The image files can be found in the zip files located below:

Until 1st January 2023, it can be applied as a label, and after this it must be “permanently attached”, as is currently done with the current CE Mark – normally by printing it directly onto the product labeling. The height of the mark must be at least 5mm.

As with the CE Mark, the product, or documentation where the product does not provide enough room, must have the manufacturer’s name & UK Address shown. If the manufacturer is outside the UK, this must be the importer’s Name & Address.

Still selling to the EU?

Unfortunately, you’re now classed as a “3rd Country”, and to be able to sell products into the EU, an EU Sales Office is required, assuming you don’t currently have a presence in the EU. The contact details of this office will need to be placed on the products for sale in the EU. There are various companies that offer an EU Authorised Representative Service, and these can be found through your favourite search engine.

Key Dates

1st January 2021The UKCA Mark becomes valid & can be placed on your electrical or electronic products to demonstrate conformity with UK Legislation At this point the CE mark enters the 12 month transition period, and is still valid for this time.
1st January 2022The CE mark ceases to be valid in the UK, and the UKCA mark becomes mandatory to demonstrate compliance.

The Legal Stuff

All the EU Directives relating to CE marking are already in UK law as Statutory Instruments. SI2019 No.696 (The Product Safety & Metrology etc Regulations 2019) modifies the below table of Statutory Instruments, along with many others to add the UKCA mark & alter some terminology used. As mentioned above, all compliance documentation in your technical file must refer to these SI’s instead of the EU Directives.

EU DirectiveUK Statutory InstrumentInformation
2014/30/EUSI 2016 No.1091The Electromagnetic Compatibility Regulations 2016 (EMC)
2014/53/EUSI 2017 No.1206The Radio Equipment Directive (RED)
2014/35/EUSI 2016 No.1101The Electrical Equipment (Safety) Regulations 2016 (LVD)
2011/65/EUSI 2012 No.3032The Restriction on Use of Hazardous Substances Regulations 2012 (RoHS)
2014/34/EUSI 2016 No.1107The Equipment & Protective Systems Intended For Use In Potentially Explosive Atmospheres Regulations 2016 (ATEX)
2006/42/EUSI 2008 No.1597The Supply of Machinery (Safety) Regulations 2008 (Machinery Directive)

Other changes include Notified Bodies are becoming Approved Bodies, and the EU Harmonised Standards will become Designated Standards. Unfortunately there’s no list of Desginated Standards yet available, but we’ll keep you up to date with what’s going on!

Test Equipment Upcycling – Variable Attenuator Module

A while back we found ourselves in the need of an adjustable RF attenuator capable of high-GHz operation. As luck would have it we had an old Spectrum analyser on the shelf, which we had retired quite some time ago. Here at CASS, we don’t like to see useful equipment or parts of equipment to to waste, so it’s time for some repurposing!

Spectrum analysers being quite capable test instruments, I knew that the input attenuation would be done with a standalone module that we could recover for reuse without too much trouble.

The attenuator module

Here’s the module itself, with the factory drive PCB removed from the bottom, showing the solenoids that operate the RF switches. There are test wires attached to them here to work out which solenoid switches which attenuation stage. In the case of this module, there are switches for the following:

  • Input select switch
  • AC/DC coupling
  • -5dB
  • -10dB
  • -20dB
  • -40dB

For us this means we have up to -75dB attenuation in 5dB steps, with optional switchable A-B input & either AC or DC coupling.

Drive is easy, requiring a pulse on the solenoid coil to switch over, the polarity depending on which way the switch is going.

Building a Control Board

Now we’d identified that the module was reusable, it was time to spin up a board to integrate all the features we needed:

  • Onboard battery power
  • Pushbutton operation
  • Indication of current attenuation level

The partially populated board is shown at right, with an Arduino microcontroller for main control, 18650 battery socket on the right, and control buttons in the centre. The OLED display module for showing the current attenuation level & battery voltage level is missing at the moment, but it’s clear where this goes.

As there weren’t enough GPIO pins for everything on the Arduino, a Microchip MC23017 16-Bit I/O expander, which is controlled via an I²C bus. This is convenient since I’m already using I²C for the onboard display.

Driving the Solenoids

A closer view of the board shows the trip of dual H-Bridge drivers on the board, which will soon be hidden underneath the attenuator block. These are LB1836M parts from ON Semiconductor. Each chip drives a pair of solenoids.

Power Supplies

The bottom of the board has all the power control circuitry, which are modularised for ease of production. There’s a Lithium charge & protection module for the 18650 onboard cell, along with a boost converter to give the ~9v rail required to operate the attenuator solenoids. While they would switch at 5v, the results were not reliable.

Finishing off

A bit more time later, some suitable firmware has been written for the Arduino, and the attenuator block is fitted onto the PCB. The onboard OLED nicely shows the current attenuation level, battery level & which input is selected.

Fire In The Hole!

To the right is a clip from one of our tests, where the cell was intentionally overcharged, demonstrating what can occur when no overcharge protection is included in Lithium Battery Packs.

As the cell reaches full charge, continued application of charging power causes the lithium ions in solution to plate out on the anode in elemental metallic form, rendering the cell highly reactive & unstable.

As the charge is continued, more lithium plates out, and the cell heats up. This heat, along with the reaction of the now metallic lithium with the flammable electrolyte causes further heating. At this point the delithiated cathode is also beginning to react with the electrolyte, releasing various gases. Both chemical processes are extremely exothermic, and the cell ruptures from the combination of heat damage & internal gas pressure.

As the electrode material breakdown continues, driven by thermal runaway & the continuing charge current, the cell vents the resulting breakdown products. Further heating as a result of the combination of chemical/electrochemical processes eventually reaches the autoignition point, and the cell explodes, spewing flames.

Welcome to the CASS Industries Blog!

Welcome to our new blog! We’ll be posting content here monthly, on a variety of subjects from general EMC and Electrical Safety, to electronic design tips & problem solving!
In the meantime, please see the other sections of our site for assistance with your product compliance needs.