PPE for the Great Britain market - ‘Indefinite’ CE mark recognition beyond 2024 deadline

On 1^st August, the UK’s Department for Business and Trade announced an indefinite extension to the use of CE marking for businesses. This applies to the 18 regulations that fall under the Department for Business and Trade (DBT), which includes personal protective equipment (PPE).

 Effect of the indefinite extension

Manufacturers and Importers of PPE can place CE marked PPE on the Great Britain market (England, Scotland and Wales) indefinitely, with no deadline or need to transition to UKCA (UK Conformity Assessment) marking.

The UK’s PPE Regulations will still be in place, including the UK PPE Enforcement Regulations. PPE must still comply with the requirements of the UK regulations, even if it is CE marked.

• PPE must have a valid CE mark, and where necessary, valid CE certification.
• The PPE must be accompanied by, or have a link to, a valid EU Declaration of Conformity.
• Category III PPE must have Module C2 or Module D controlled by an EU notified body.
• If the EU PPE Regulation deviates from the UK regulations in the future, the UK requirements must still be met.
• If the PPE is certified to an EU harmonised standard which is different to the UK designated standard, the assessment of the PPE may be affected.
• If a UK designated standard has a restriction which the equivalent EU harmonised standard does not, the Manufacturer or Importer will need to address the restriction before placing PPE on the GB market.

UKCA marking of PPE

The UK PPE Regulations will still be in force. It will still be possible to apply to a UK Approved Body and receive UKCA certification, in order to apply the UKCA mark, for those manufacturers who only wish to sell their PPE in Great Britain.

UKCA ‘Easement’

The UK introduced a CE extension in 2022, with a 2024 deadline. This 2022 extension also introduced an ‘easement’, which enabled manufacturers to apply the UKCA mark to their PPE, using valid CE certificates.

We have no information on the future of the easement. The announcement of the indefinite CE extension is a general announcement covering a range of legislation and products, and we await publication of PPE specific guidance from the UK Government to confirm the status of the easement.

CONSTRUCTION PRODUCTS

The announcement does not cover the UK Construction Products Regulations. This legislation is the responsibility of a different department of the UK Government, the Department for Levelling Up, Housing and Communities, and we have had no information regarding a possible extension for CE marked construction products. At present, the deadline for CE marked products is still 31^st June 2025, with UKCA marking required after that date.

MARINE EQUIPMENT

There is no further extension for marine equipment. The deadline for Wheelmarked marine equipment was 31^st December 2022. The UK’s Maritime & Coastguard Agency have confirmed that there will be no change to the UK’s regulations.

Any relevant marine equipment newly placed on board a UK registered ship must have UK issued certification, and bear the Red Ensign mark.

What effect does this have on Certification and Auditing?

Shirley Technologies Limited, trading as BTTG®, became UK Approved Body number 0338 on 1st January 2021. BTTG® will continue to offer UKCA approval for the UK PPE Regulations, the UK Merchant Shipping (Marine Equipment) Regulations, and the UK version of the Construction Products Regulation 305/2011.

Through our sister company, Shirley® (Europe) who are EU notified body number 2895, we can also offer CE marking to the PPE Regulation (EU) 2016/425 and Construction Products Regulation (EU) No 305/2011, and Wheelmarking to the Marine Equipment Directive 2014/90/EU.

PPE and MED Module B certificates and PPE Module C2 approvals can be issued for both CE and UKCA based on one technical assessment, and where Module D visits are required, our auditors can cover both CE and UKCA requirements during one audit, so enabling our clients to use both marks.

Where construction product FPC visits are required, our auditors can cover both CE and UKCA requirements during one audit, meaning our clients can use both marks.

BTTG® is also cooperating with other EU notified bodies for UKCA approval of CE marked products, including the use of EU notified body auditors for construction products FPC audits.

Placing product on the market in Northern Ireland

Northern Ireland has different rules to Great Britain (the mainland UK). From 1^st January 2021, products can be placed on the Northern Ireland market with either the CE mark, using CE certification held by an EU notified body, or with CE+UKNI marking using certification from a UK Notified Body. BTTG® can issue the relevant certification.

If you have any questions regarding UKCA marking, or CE marking for Great Britain, please contact our UK certification team at certification@bttg.co.uk