Attention: In our newsletter of 27 August 2021 we informed you about the changes (as of 24.08.2021) regarding the transition period. Changes have been marked with * in the text.

The UKCA mark (UKCA = UK Conformity Assessed) is the new UK product marking required for certain products placed on the market in the UK (England, Wales and Scotland). It affects most products that previously required CE marking.

For more detailed consideration, the UK also provides guides specifically for certain products that describe all the changes in detail. Here you can find this for the Machinery Directive, for example. As of January 1, 2023* (Update status: 24.08.2021), CE marking is no longer allowed in the United Kingdom (UK) and only UKCA marking may be used.

Below we have prepared the most important information for you:

Guidelines

The table below provides an overview of the UK legislation that transposes EU directives:

EU legislation

UK legislation

Simple Pressure Vessels – Directive 2014/29/EU

Simple Pressure Vessels (Safety) Regulations 2016

Pressure equipment – Directive 2014/68/EU

Pressure Equipment (Safety) Regulations 2016

Electromagnetic Compatibility – Directive 2014/30/EU

Electromagnetic Compatibility Regulations 2016

Low Voltage Directive 2014/35/EU

Electrical Equipment (Safety) Regulations 2016

ATEX manufacturer directive 2014/34/EU

Equipment and Protective Systems Intended for use in Potentially Explosive Atmospheres Regulations 2016

Personal protective equipment – Regulation (EU) 2016/425

Regulation 2016/425 on personal protective equipment as brought into UK law and amended

Machinery Directive 2006/42/EC

Supply of Machinery (Safety) Regulations 2008

source: https://www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-great-britain

The above UK Regulations have been amended by the Product Safety and Metrology (Amendment etc.) (EU Exit) Regulations 2019 to apply solely to the UK.

Validity of harmonized standards

Great Britain adopts the principle of presumption of conformity and, like the EU, publishes corresponding lists of harmonised standards. These harmonised standards, as we know them, are called "designated standards" in Great Britain. All harmonised standards (as of 31.12.2020) that confer a presumption of conformity with EU law have been published as "designated standards". These can be used for the presumption of conformity with the UK Regulations. Of course, the list of designated standards will be extended in the future. The designated standards for machinery can be found here. Annex II of the list of designated standards also contains a list of standards that will no longer be harmonised in the future (with exact date).

Responsible person/authorised representative

The UK does not recognize an EU-based responsible person or authorized representative. The manufacturer's authorized representative or the responsible person for a product placed on the UK market must therefore be based in the UK.

Notified bodies

The same requirements and procedures for conformity assessment apply as for CE marking. If a notified body is required for CE marking, a UK Approved Body is also required for UKCA. A list of "UK Market Conformity Assessment Bodies" for the UK can be found here.

Transitional provisions until the end of 2022* (Update status: 24.08.2021)

The UK (England, Wales and Scotland) had adopted the EU Directives/Regulations into national law and amended them through the Product Safety and Metrology (Amendment etc.) (EU Exit) Regulations 2019 to apply exclusively to the UK market.

In short, any reference to the EU directives will be removed from the legislation and the CE marking will be replaced by UKCA marking. For this reason, it will still be possible to market products with a CE marking in the UK (England, Wales and Scotland) until the end of 2022* (Update status: 24.08.2021).

However, there are some exceptions for certain products, such as medical devices, construction products, marine equipment, transportable pressure equipment and rail products. There is a good general guide for this.

source: https://www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-...

ATTENTION: For products placed on the market in Northern Ireland, CE marking continues to apply in the "self-declaration" assessment procedure by the manufacturer and, if necessary, with the involvement of an EU Notified Body.

In the future, deviations between EU and UK regulations are possible. The UK as well as the EU can introduce new directives/regulations or change the existing ones.

You want to know more? Then visit our UKCA training >> here! We also offer these individually tailored to your needs online or on site!

 

We will be happy to provide you with further advice on the subject of placing products on the market in Great Britain!