Introduction

The UK’s exit from the EU Customs Union and European Single Market on 1st January 2021 will have massive implications for many trading partners. In addition to the increased documentation and control effort due to the new customs regulations for exports and imports, this primarily affects manufacturers with regard to product safety regulations.

Within the EU Single Market, all products that comply with harmonised product safety directives bear the CE marking (Conformité Européenne). Since then, the “European Conformity” marking has ensured that a technical product or medical device complies with all specified product safety standards within the EU and can therefore be freely traded in the participating states of the European Economic Area (EEA).

In recent years, the EU has devised a detailed system for how manufacturers, distributors and importers can circulate products with a CE marking. Although this marking requirement involves a certain amount of organisational effort, it greatly simplifies cross-border trade in electronic and medical devices throughout Europe.

Since Brexit, the UK left this system on 1st January 2021. The British government has put its own solution in place of the CE marking, namely the UKCA marking. For companies from the EU, this means that in the future they will have to familiarise themselves not only with CE certification but also with the British model of UKCA marking if they want to offer products covered by this standard on the British market.

In this guide, we explain what the deadlines are for this transition, what is different from the old CE marking, how UKCA certification works for the UK and how to use themarking.

The Certification Process

What is the expected economic impact of UKCA implementation?

In a survey conducted by the consultancy firm KPMG in the spring of 2021, many German and British companies stated that they have an even more negative

assessment of the consequences of Brexit after the first three months than they did before. The introduction of UKCA marking is just one more negative factor in the mounting administrative and logistics workload that is hindering German-British trade as a result of Brexit.

German companies trading with the UK see themselves at a disadvantage compared to domestic competitors due to the newly added regulations. According to the KPMG study, one in six companies plans to cease foreign trade with the UK.

When should manufacturers start UKCA certification?

As UKCA certification is already valid, companies should start as early as possible to initiate the certification process to UKCA standards for all products to be exported in the UK. In our experience, once all the necessary documents are in place, certification is relatively quick in most cases. However, you should keep in mind that a lot of companies currently need to have their products certified for the UK. Therefore, you should expect delays at the relevant offices due to these special circumstances.

The UKCA Marking

What does the UKCA marking look like?



Where and how must the UKCA marking be placed?

If possible, the UKCA marking should be placed directly on the product or – if this isn’t possible – on the packaging. If not, it can also be printed in a manual or other

accompanying documentation in exceptional cases. More detailed provisions may be governed by the relevant product regulations.

*The minimum height of the UKCA marking is 5mm. Other minimum sizes may apply to individual product types. When changing the size of the UKCA marking, the proportions of the letters to each other must always be maintained. The marking must be applied legibly, but can be changed graphically, e.g. the colour.

What other information must be provided?

Most products with a UKCA marking require an accompanying “UK Declaration of Conformity”, in which the manufacturer or an authorised representative states that their product complies with the respective applicable legal standards. Depending on the product, the exact requirements for the Declaration of Conformity may vary. In general, however, the document should contain the following:

• Name and address of the manufacturer or their authorised representative

• Serial number, model or type designation of the product

• Declaration of Conformity of the product

• The Assessment Body that carried out the process

• The new British regulations and standards that apply to the product

• Signature with name and date.

Case Study | How FRIWO Implements UKCA Requirements

Since the announcement of the new standard, FRIWO has been working closely with the German Electrical and Electronic Manufacturers’ Association (ZVEI) and has prepared a UKCA Declaration of Conformity in good time.

FRIWO was one of the first companies in the German electrical industry to approach the approval authorities and work closely with the ZVEI. Since then, there has been a constructive exchange to understand all requirements in detail and prepare for implementation.

FRIWO’s goal is to become a pioneer in marking. The company has already implemented many requirements, even if they’re not currently required. This way, the company wants to guarantee its customers and sales partners continuity for business in the UK and seamless implementation of the UKCA requirements.

From 1st January 2023, the UKCA marking must be visible on the device, in accompanying documents or on the folding box. From 1st January 2024 at the latest,

the UKCA marking must be present directly on the device.

FRIWO exceeds these requirements and has already started marking its devices. The UKCA marking is applied directly to the devices by laser printing, so various products from the manufacturer already meet the requirements that will apply from 2024. We expect to successfully mark our entire portfolio with the respective markings in the near future.

How to Navigate the UKCA Certification Process

Before you start the certification process for the UKCA marking, you should first determine whether you’ve compiled all the necessary information. In the following,

FRIWO provides you with the most important information with further sources for the UKCA marking.

Before you start the certification process for the UKCA marking, you should first determine whether you’ve compiled all the necessary information. In the following,

FRIWO provides you with the most important information with further sources for the UKCA marking.