On 1 September 2020, the Department for Business, Energy and Industrial Strategy issued guidance on the use of the UKCA logo. From 1 January 2021, the UKCA certification mark will be used on products marketed in the Great Britain Region (" GB ", including England, Wales and Scotland, excluding Northern Ireland). However, in order to allow more time for the market to adapt to the new requirements, the CE marking on most products can still be accepted before January 1, 2022.
The UKCA mark will come into effect on 1 January 2021, however, in order to give businesses time to adapt to the new requirements, the UK market (Great Britain) will accept the CE mark for products until 1 January 2022.
In order for the same new product to be able to enter the EU market, it is also necessary to obtain the CE mark. Eu authorities will not accept the UKCA logo.
At present, products entering Northern Ireland will continue to use the CE mark or UK(NI) mark in accordance with the special treatment agreement, and it is expected that after the 2024 referendum, Northern Ireland will make new adjustments.
1. Attach the UKCA logo
Until 1 January 2023, for most products (except those subject to special rules), the UKCA mark may be affixed to the product's label or accompanying documentation. From 1 January 2023, in most cases, the UKCA logo must be affixed directly to the product. Therefore, companies should start preparing for this.
Here are the general rules:
- The UKCA logo may only be affixed to the product by the manufacturer or its UK authorised representative (where permitted by law)
- When the UKCA mark is affixed, the manufacturer assumes full responsibility for whether the product complies with the requirements of the relevant regulations
- Only the UKCA mark can be used to demonstrate that the product complies with the relevant UK law
- Any mark or mark which may misinterpret the meaning or form of the UKCA mark shall not be made available to third parties
- No other mark shall be affixed to the product which affects the visibility, legibility or meaning of the UKCA mark
- The UKCA logo must not be affixed to products unless expressly required by law
2. Rules for using the UKCA mark
Manufacturers must ensure that:
- If the size of the logo is reduced or enlarged, the relevant proportion of the letters of the UKCA logo shall be observed
- The height of the UKCA mark shall be at least 5 mm unless a different minimum size is specified in the relevant regulations
- The UKCA logo must be clearly visible
The requirements of the UK regulations on product scope, standards, conformity assessment procedures, etc. are basically consistent with the EU directives. However, the relevant regulations in the UK are updated from time to time, such as the No. 8 Ecodesign and Energy Information for Energy-Related Products (Amendment) Regulation 2019, which has amended relevant terms and expressions, and added provisions for the transition period from the EU to prepare for the use of the UKCA mark.
The UKCA mark will cover most products currently subject to CE marking as well as aerosol products:
1. Toys are safe
2. Leisure boats and private boats
3. Simple pressure vessel
4. Electromagnetic compatibility
5. Non-automatic weighing device
6. Measuring instruments
7. Elevators and lifting equipment
8. Explosion-proof products
9. Radio equipment
10. Pressure equipment
11. Personal Protective equipment
12. Gas appliances
13. Machinery
14. Outdoor noise
15. Ecological design
16. Aerosols
17. Low voltage electrical appliances
18. Restriction of hazardous substances
UKCA marks covered products, but there are some special rules:
Medical equipment
Railway interoperability
Building product
1. Record keeping
The manufacturer or its authorized representative (where permitted by law) must maintain documentation that the product complies with regulatory requirements. Products must be kept for 10 years after they are placed on the market.
The documents retained will depend on the specific regulations relevant to the product, but a general record of the following must be kept:
- How to design and manufacture products
- How to prove that the product meets the relevant requirements
The address of the manufacturer and any storage facility
This information may be requested at any time by the UK market surveillance or law enforcement authorities to check whether the product complies with statutory requirements.
A UK DoC is a document that must be drawn up for most compliant products bearing the UKCA mark.
In the document, the manufacturer or its UK authorised representative (where permitted by law) shall:
- Declare that the product complies with the relevant statutory requirements applicable to the particular product
- Ensure the name and address of the manufacturer (or an authorised representative in the UK), as well as information about the product and the conformity assessment body (where relevant), are on the document
Manufacturers are required to provide the UK DoC to the market watchdog upon request.
The information required for the declaration of conformity will be substantially the same as that currently required for the EU declaration of conformity and may vary depending on the applicable regulation, but should generally include:
- Name and full business address of the manufacturer or its authorized representative
- Product serial number, model number or model identification
- Declaration (Full responsibility for product compliance)
- Details of the authority to carry out the conformity assessment procedure (if applicable)
- Product compliance with relevant regulations
- The name and signature of the UKCA DoC signatory
- The date the statement was issued
- Additional information (if applicable)
In addition, it will be necessary to list:
- UK regulations, not EU regulations
- Criteria specified by the UK (BS), rather than those quoted in the EU Gazette
From 1 January 2021, the substance and reference standards of UK standards will be the same as those used in the EU, but the prefix "BS" will be used to indicate that they are those adopted by the British Standards Institute (BSI) as the UK's national standards body.
Yes, the UK government has said that goods can carry both CE and UKCA marks as long as they are fully compliant with UK and EU regulations (which remain the same). Therefore, affected businesses may consider using both trademarks in order to sell the same product/model in the EU and GB market. Again, this may mean changes to product design, packaging and labeling.
Can the CE certification of the UK Certification body still be used?
If you have obtained a certificate of conformity from a certification body in the UK and have applied the CE marking to your product on this basis (and wish to continue to sell the product on the EU market), you will need to apply for a new certificate from a notified body in the EU (as UK bodies are no longer recognised), some UK designated bodies have established branches in the EU, and some UK designated bodies have established branches in the EU. This is part of its preparations for Brexit.
UKCA certification body
PPTS is a professional UK UKCA certification and EU CE certification technical service agency, with many UK and EU certification bodies have a long-term cooperative relationship, can provide one-stop UKCA certification and CE certification services, welcome technical exchanges.
