The UKCA (UK Conformity Assessed) marking ─ a new UK product marking for goods being placed on the GB market ─ covers most goods previously requiring CE marking
UKCA mark requirements delayed for third time due to 'difficult economic conditions' ─ [15/11/2022 update]
The government has given businesses two additional years to prepare for a new deadline of 31 December 2024, at which point the UKCA mark will be legally required for affected goods placed in the UK market.
The UK will continue to recognise the CE mark for this period, with the EU certificate remaining valid until the end of 2027.
The UKCA (UK Conformity Assessed) marking is a new UK product marking that is used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods which previously required the CE marking.
Selling goods in Great Britain
The UKCA marking applies to most goods previously subject to the CE marking. It also applies to aerosol products that previously required the ‘reverse epsilon’ marking.
The technical requirements (‘essential requirements’) you must meet – and the conformity assessment processes and standards that can be used to demonstrate conformity – are largely the same as they were for the CE marking.
The UKCA marking came into effect on 1 January 2021. However, to allow businesses time to adjust to the new requirements, you will still be able to use the CE marking until 1 January 2022 in most cases.
In some cases, you need to apply the new UKCA marking to goods being sold in Great Britain immediately from 1 January 2021.
The CE marking is only valid in Great Britain for areas where GB and EU rules remain the same. If the EU changes its rules and you CE mark your product on the basis of those new rules you will not be able to use the CE marking to sell in Great Britain, even before 31 December 2021.
What you need to do to comply with regulations on manufactured goods you place on the GB market.
Selling goods in the EU
The UKCA marking is not recognised on the EU market. Products need a CE marking for sale in the EU
When to use the UKCA marking
You only need to use the new UKCA marking before 1 January 2022 if all of the following apply. Your product:
- is for the market in Great Britain
- is covered by legislation which requires the UKCA marking
- requires mandatory third-party conformity assessment
- conformity assessment has been carried out by a UK conformity assessment body
This does not apply to existing stock, for example if your good was fully manufactured, CE marked and ready to place on the market before 1 January 2021. In these cases, your good can still be sold in Great Britain with a CE marking even if covered by a certificate of conformity issued by a UK body before 1 January 2021.
How to use the UKCA marking
Placing the UKCA marking
In most cases, you must apply the UKCA marking to the product itself 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:
- UKCA markings must only be placed on a product by you as the manufacturer or your authorised representative (where allowed for in the relevant legislation)
- when attaching the UKCA marking, you take full responsibility for your product’s conformity with the requirements of the relevant legislation
- you must only use the UKCA marking to show product conformity with the relevant UK legislation
- you must not place any marking or sign that may misconstrue the meaning or form of the UKCA marking to third parties
- you 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
Rules for using the UKCA image
You must make sure that:
- if you reduce or enlarge the size of your marking, the letters forming the UKCA marking must be in proportion to the version set out below
- the UKCA marking is at least 5mm in height – unless a different minimum dimension is specified in the relevant legislation
- the UKCA marking is easily visible, legible (from 1 January 2023 it must be permanently attached)
Technical documentation
Record keeping
You, or your authorised representative (where allowed for in the relevant legislation), must keep documentation to demonstrate that your product conforms with the regulatory requirements. This must be kept for up to 10 years after the product is placed on the market.
This information can be requested at any time by market surveillance or enforcement authorities to check that your product conforms with the statutory requirements.
The information you must keep will vary depending on the specific legislation relevant to your product. You must keep general records of:
- how the product is designed and manufactured
- how the product has been shown to conform to the relevant requirements
- the addresses of the manufacturer and any storage facilities
You should keep the information in the form of a technical file which can be supplied if requested by a market surveillance authority.
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 you as the manufacturer, or your authorised 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 your authorised 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 is largely the same as what was required on an EU Declaration of Conformity. This can vary depending on the application legislation but generally should include:
- your name and full business address or that of your authorised representative
- the product’s serial number, model or type identification
- a statement, stating you take 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
- your name and signature
- the date the declaration was issued
- supplementary information (if applicable)
You will need to list:
- relevant UK legislation (rather than EU legislation) (ODS, 5.08KB)
- UK designated standards rather than standards cited in the Official Journal of the European Union
The UK standards are currently the same in substance and with the same reference as the standards used in the EU.
"WATCH POINT! ─ Construction products, medical devices, interoperability of the rail system and transportable pressure equipment ─ ARE covered by the UKCA marking, however ─ the TRANSITIONAL MEASURES ARE NOT APPLICABLE!"
David Jones - ICM Director
Transitional measures relating to the UKCA marking
For many product types (listed above), the following transitional measures apply.
Until 1 January 2023, for most goods (other than those subject to special rules) you have the option to affix the UKCA marking on a label affixed to the product or on an accompanying document. The economic operators (whether manufacturer, importer or distributor) should take reasonable steps to ensure the UKCA marking remains in place. Products that require the UKCA marking cannot be made available without it (other than where the CE marking is being used before 1 January 2022).
From 1 January 2023, the UKCA marking must, in most cases, be affixed directly to the product. You should start building this into your design process ready for this date.
"the Construction Sector will also need to appropriately address statutory compliance to Building Regulation 7─(1)
David Jones - ICM Director
Brexit, Building Regulation 7, cdm, CE Marking, competence, product marking, UK Declaration of Conformity, UKCA Marking
David Jones
The UK government made a general announcement yesterday (14Nov22) that the deadline for when businesses across the wider economy need to use the UKCA mark has been extended until
31 December 2024.
The CPA warns however that construction products fall under different regulations that have not yet been amended. The government’s announcement stated: “There will be different rules for medical devices, construction products, cableways, transportable pressure equipment, unmanned aircraft systems, rail products, and marine equipment. Government departments responsible for these sectors are making sector-specific arrangements….”
Therefore, yesterday’s general announcement does not apply to our sector. We have raised this with government and are pushing for further clarity, particularly from the Department for Levelling Up, Housing and Communities, which is the government department responsible for our sector. We have also asked that the Department for Business, Energy, and Industrial Strategy to make this distinction with the general announcement on its website.
Peter Caplehorn, CPA Chief Executive, said: “We are not out of the woods yet. The status quo is not certain, and for construction product manufacturers and the wider construction industry to prepare for any impending policy changes, the government must expedite its decision on this critical issue for our sector. The year-end is fast approaching, and Parliament will recess on 21 December, leaving very little time for government to enact the necessary legislation to make the policy and its deadline a reality. It also leaves the industry to face the increasingly difficult process through next year to re-test and re-certify new products where few or no UK facilities exist to achieve this.”
“With the longer term in mind, we must also ask government ministers to re-consider the usefulness of the CA Mark policy, and whether a more reasonable, practical solution exists to help achieve the right aims but avoid further and unnecessary loss of time, money and resources. This continues to have a significant impact on investment, innovation, and growth of the sector.”