Countdown to implementation
Grace Period
When does this new standard come into action?
The UKCA mark can be applied to products sold in the UK from 1st January 2021.
There will be a grace period of 1 year to allow manufacturers to update existing product labels accordingly.
During this grace period, it will be acceptable for products that are sold in the UK to only bear the CE mark.
From 01 January 2022, all products sold in the UK will be required to carry the UKCA mark.
Additionally, products sold in Northern Ireland requiring a UKCA mark one year later, on 1 January 2023.
In some cases you will need to apply the new UKCA marking to goods being sold in Great Britain immediately from 1 January 2021.**
You are encouraged to be ready to adopt the UKCA marking as soon as possible!
The CE marking will only be 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
When to use the UKCA Marking?
**You will need to use the new UKCA marking immediately after 1 January 2021 if all of the following apply. Your product:
This does not apply to existing stock, for example if your good was fully manufactured 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.
Where to apply 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:
Rules for using the UKCA image
You must make sure that:
Product areas covered by the UKCA marking
Products covered by the UKCA marking but have some special rules:
What are the differences between UKCA and CE marking?
Many of the differences between the two systems are administrative in nature and reflect that UKCA only applies in the UK and only requires information in English. This simplifies some aspects, such as where the technical information must be kept and which language applies.
Other differences relate to the separation of UK conformity assessment bodies from the EU Notified Body System.
What aspects are not changing?
Many facets are the same; the scope of products covered, technical requirements (essential requirements, standards) and conformity assessment procedures will all initially be alike. If your product is sold in both the EU and the UK, the technical file to show that it meets these requirements will also be the same.
What is the specific UK legislation that needs to be followed?
To implement the new regime, the UK government has issued several Statutory Instruments to amend current legislation.
The main regulations are The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019, which runs to 659 pages.
These regulations amend most of the UK CE marking regulations for products placed on the UK market and stipulate the UKCA mark.
Where a directive required CE marking and UK regulations were already detailed, the amendments are limited to:
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