Understanding the use of the UKCA Mark for UK markets
Understanding the use of the UKCA Mark for UK markets
The new UKCA Mark
Due to the UK leaving the EU, the UKCA (UK Conformity Assessed) marking is a new UK product marking regulation that will be used in place of the CE mark for goods being placed in the UK market. CSA Group’s Sira Certification Service (No. 0518) will be recognized as an UK approved body on 1 January 2021, allowing us to perform conformity assessments for UKCA markings for those products.Starting 1 January 2021, the UKCA mark will be the conformity assessment marking for goods entering the UK market that are currently subject to CE marking. However, to allow time for adjustments to the new requirements, businesses will still be able to use the CE marking until 1 January 2022.
Businesses should be ready to use the UKCA marking from 1 January 2022 at the latest, although they should look to use the UKCA marking as soon as possible
Using the UKCA Mark
From 1 January 2021 businesses can apply the UKCA marking to their product or to the packaging. In some cases, it may be placed on the manuals or on other supporting literature. This will vary depending on the specific regulations that apply to the product.
The following general rules apply using UKCA markings:
- UKCA markings must only be placed on a product by the manufacturer or authorized representative (where allowed for in the relevant legislation)
- When attaching the UKCA marking, businesses take full responsibility for their product’s conformity with the requirements of the relevant legislation
- Businesses must only use the UKCA marking to show product conformity with the relevant UK legislation
- Businesses must not place any marking or sign that may misconstrue the meaning or form of the UKCA marking to third parties
- Businesses must not attach other markings on the product which affect the visibility, legibility or meaning of the UKCA marking
- The UKCA marking cannot be placed on products unless there is a specific requirement to do so in the legislation
UK Declaration of Conformity
The UK Declaration of Conformity is a document which must be drawn up for most products lawfully bearing a UKCA marking.
In the document businesses, or an authorized representative (where allowed for in the relevant legislation), should:
- Declare that the product is in conformity with the relevant statutory requirements applicable to the specific product
- Make sure the document has the name and address of the manufacturer (or an authorized representative) together with information about the product and the conformity assessment body (where relevant)
The UK Declaration of Conformity should be available to market surveillance authorities on request.
The information required on the Declaration of Conformity will be largely the same as what is currently required on an EU Declaration of Conformity. This can vary depending on the application legislation but generally should include:
- Business name and full business address or that of an authorized representative
- The product’s serial number, model or type identification
- A statement, stating the business takes full responsibility for the product’s compliance
- The details of the approved body which carried out the conformity assessment procedure (if applicable)
- The relevant legislation with which the product complies
- Business’s representative’s name and signature
- The date the declaration was issued
- Supplementary information (if applicable)
You will need to list:
- Relevant UK legislation instead of EU legislation
- UK designated standards rather than standards cited in the Official Journal of the European Union
Continuing use of the CE Mark
The CE marking will be accepted in the UK until 1 January 2022 for some products like products with a certificate of conformity from an EU-recognized notified body or pre-existing stock. Pre-existing stock of a product that would normally need the UKCA marking but was fully manufactured before 31 December 2020 and covered by a UK certificate of conformity can still be placed in the UK market after 1 January 2021 with CE marking.
Businesses will be able to use the CE marking until 31 December 2021 if any of the following apply:
- The business currently applies the CE marking to their goods on the basis of self-declaration
- Any mandatory third-party conformity assessment was carried out by an EU-recognized notified body (including a body in a country with which the EU has a relevant mutual recognition agreement)
- The certificate of conformity previously held by a UK approved body has been transferred to an EU-recognized notified body
Conformity assessment for the EU market
Starting 1 January 2021 any mandatory third-party conformity assessment for the EU market will need to be carried out by an EU-recognized conformity assessment body.
Very few Testing, Inspection and Certification (TIC) providers have the physical presence and notified body status in both the EU and UK to meet the requirements and issue the CE and UKCA marks.
Using both the CE and UKCA marking
Goods can carry both the CE and UKCA markings so long as they are fully compliant with both UK and EU regulations. CSA Group maintains both an EU-27 Notified Body (CSA Group Netherlands B.V, Notified Body number 2813), and an UK Approved Body (Sira Certification Service No. 0518) ensuring we can offer UKCA and CE services in a seamless and efficient manner.
Frequently Asked Questions about Brexit and the new UKCA marking
1. What is the UKCA?
The UKCA (UK Conformity Assessed) marking is a new UK product marking regulation that will be used in place of the CE mark in the UK market.
2. What is the current status with the implementation of the UKCA mark?
The UK has left the EU and the current transition period after Brexit comes to an end on 31st December 2020. From 1st January 2021, the UKCA mark can be used on products placed on the UK market. The UKCA marking will apply to most goods that are currently subject to CE marking.
Whilst the UKCA mark becomes available from 1st January 2021 (whereby manufacturers will be permitted to mark their products with UKCA marking (subject to the relevant assessment being conducted)), to allow businesses time to adjust, CE marked goods in scope of UKCA, that meet EU requirements, can continue to be placed on the GB market until 1st January 2022, whereby EU and UK requirements remain the same. This will include, for example, products certified by an EU Notified Body.
The transition period is strictly time limited and the advice is for businesses to be ready for full implementation of the new UK regime as soon as possible after 1st January 2021, including (where applicable) engaging the services of a UK approved body.
Another transitional measure being introduced allows for the UKCA mark to be affixed to an accompanying document (in lieu of the actual product) until 1st January 2023 (after which the UKCA mark must be affixed directly to the product) to ease any potential burden on product labelling changes.
3. Based on the above, will the UK accept CE marked goods?
Yes, for a time-limited period. Until 1st January 2022, CE marked goods will be accepted on the UK market. Third-party approved products bearing the CE mark must be issued from an EU Notified Body.
4. Can the same body assess and certify products for entry into both the UK and EU?
No, however, CSA Group is one of only a few organizations that can provide solutions for entry into both Europe and the UK, specifically for products used in ‘Ex’ explosive atmospheres (hazardous locations), due to our position as a leading testing, inspection and certification company. UKCA assessment and certification must be conducted by a UK Approved Body located in the UK. For entry into the EU, certification must be conducted by an EU Notified Body. Under CSA Group we maintain both an EU ATEX Notified Body (CSA Group Netherlands B.V, Notified Body number 2813), and an UK Approved Body (Sira Certification Service (No. 0518). On 1 January 2021, Sira Certification Service will be automatically appointed a UK approved body. This ensures we can offer both ATEX and UKCA services in a seamless and efficient manner.
5. Will CSA Group be automatically accredited as a UK Approved Body on 1st January 2021?
Yes. CSA Group’s UK-based body, Sira Certification Service, will be automatically appointed a UK Approved Body on 1st January 2021 and will be able to conduct third-party approval services for UKCA from this date onwards.
6. What will the actual assessment and certification process look like?
While we await clear guidance from the UK authorities on this, we anticipate the assessment and certification process will operate in a very similar manner to what is currently provided for ATEX for the EU market.
7. Can I use the assessment data in my CSA Group ATEX file in support of the issue of a UKCA certificate?
Yes. As the legislation for UKCA for ‘Ex’ products is broadly similar when compared to ATEX Directive 2014/34/EU, our certification team will base their assessment of UKCA on this existing data.
8. Can existing ATEX certificates issued by other test bodies be used as supporting documentation for CSA Group (Sira Certification Service) to issue certification for UKCA?
Yes, and CSA Group will provide any additional evaluation needed to support the issue of a UKCA mark certificate.
9. Which documents are needed for the assessment?
Documentation that is used in the assessment process will emulate that of the CE mark in the EU market so the documents for CE mark should be sufficient, with appropriate amendment to include the UKCA marking.
10. How long will such an assessment take?
Timing will be based on the review of the application data, and the availability of such data. Please contact CSA Group for more details.
11. I have an ATEX certificate issued by CSA Group’s Sira Certification Service, Notified Body 0518. What will happen to my certificate on 1st January 2021?
The process, with client permission, would be to have the ATEX file transferred to our EU Notified Body, CSA Group Netherlands (Notified Body 2813). If this is not done before 1st January 2021, the ATEX file would be invalid and could not be used to place product on the EU marketplace. Nor could it be used to place product on the UK market.
12. I have an ATEX certificate issued by CSA Group Netherlands, Notified Body 2813. What will happen to my certificate on 1st January 2021?
Your certificate will continue to remain valid when placing product on the EU marketplace. For UK entry, the UK Government published guidance on 1st September which explains that CE-marked products will continue to be accepted into the UK until 1st January 2022, allowing for a 1-year transition period. Products will have to be UKCA-approved by this time to enter the UK. However, the UK Government’s advice is to ensure you implement UKCA as soon as possible in 2021. CSA Group is here to support you in gaining UKCA approval; please contact us for more details.
13. Can or should I mark my product as UKCA compliant now?
The UKCA mark cannot be used or placed on products until 1st January 2021. However, CSA Group can carry out assessments and certification prior to this date, so that your product can be marked as UKCA compliant from 1st January 2021.
14. Is the UKCA mark accepted within the EU?
No. Products currently requiring CE marking will still need a CE mark for sale in the EU from 1st January 2021.
15. I have CE marked product in stock. Am I able to place this product on the UK market without a UKCA mark?
Yes, subject to any third-party approval that supported the affixing of the CE mark being based in an EU member country. Further, this stock would have to be placed on the market prior to the end of the January 2022 transition period.
16. How do I affix the UKCA mark to my product?
In most cases, UKCA marks need to be affixed to the product itself. As mentioned above, some provision has been made for the UKCA mark to be added to accompanying documentation instead of the product until 1st January 2023, after which, UKCA marking must be affixed to the product. Guidance on this link provides further information on affixing the UKCA mark https://www.gov.uk/guidance/using-the-ukca-mark-from-1-january-2021
17. Will I need a separate quality audit in addition to my QAN?
Where allowable, we would expect to use existing quality audit data and carryout combined UKCA/ATEX audits where possible.
18. How can CSA Group help me obtain UKCA approval?
CSA Group is one of only a few organizations able to issue UKCA (from 1st January 2021) for products used within ‘Ex’ explosive atmospheres (hazardous locations) in the UK. Our body, Sira Certification Service, will be able to issue UKCA, amongst many other complimentary services offered within the CSA Group, such as ATEX, IECEx, entry to North American hazardous locations and many more internal marketplaces. Our team is here to support and guide on the requirements and provide cost effective and efficient solutions for your needs. Contact us today to learn more.
For more information about the UKCA mark please contact the CSA Group UK office
CSA Group Testing UK Ltd. (Hawarden)
Unit 6, Hawarden Industrial Park
Hawarden, Deeside, CH5 3US
+44 1244 670 900
Conformity assessment bodies: change of status from 1 January 2021.
Using the UKCA mark from 1 January 2021.
Placing manufactured goods on the EU market from 1 January 2021.
Placing manufactured goods on the market in Great Britain from 1 January 2021.
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