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.
|1st January 2021||The 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 2022||The 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 Directive||UK Statutory Instrument||Information|
|2014/30/EU||SI 2016 No.1091||The Electromagnetic Compatibility Regulations 2016 (EMC)|
|2014/53/EU||SI 2017 No.1206||The Radio Equipment Directive (RED)|
|2014/35/EU||SI 2016 No.1101||The Electrical Equipment (Safety) Regulations 2016 (LVD)|
|2011/65/EU||SI 2012 No.3032||The Restriction on Use of Hazardous Substances Regulations 2012 (RoHS)|
|2014/34/EU||SI 2016 No.1107||The Equipment & Protective Systems Intended For Use In Potentially Explosive Atmospheres Regulations 2016 (ATEX)|
|2006/42/EU||SI 2008 No.1597||The 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!