UKCA Update November 2022
Following the end of the Brexit transition period on 31st December 2020, the UK Government announced a one-year transition for CE marked goods to be placed on the market in Great Britain (England, Scotland and Wales). Once this period was over, goods which were CE marked would need to have a UKCA mark, and where necessary, certification from a UK Approved Body. In August 2021 this was extended by a year, with the deadline set to the end of 2022.
UKCA marking with CE certification
In June 2022 a new ‘easement’ was announced by the UK Government, intended to reduce retesting and recertification costs. The details varied across different legislation. For PPE, this meant that the UKCA mark could be applied using valid CE certification, only needing new UKCA approvals when the CE certificate expired.
For Construction Products, the only easement was for System 3 products, where a UKCA mark could be applied using a valid EU notified laboratory test report (Initial Type Test) issued before 31st December 2022. No changes for Systems 1+ / 1 / 2+ were announced.
UKCA marking extension November 2022
The UK government have just announced a further 2-year extension for the transition of CE to UKCA marking. This applies to a wide range of product legislation, but does not currently include construction products.
CE marked PPE
There is a 2-year extension for CE marked PPE. Products can be placed on the GB market until 31st December 2024. The PPE items must be properly CE marked, with valid certification and a CE Declaration of Conformity. Once placed on the GB market, it can continue to be circulated indefinitely.
UKCA marking PPE using CE certification
The date of validity for using CE certification to apply the UKCA mark has also been extended by two years, but the final deadline remains the same.
- The PPE must have a valid module B certificate from an EU notified body, issued up until 31st December 2024.
- For Category III PPE, the Module C2 or D must be provided by an EU notified body, with the EU body’s number beside the UKCA mark.
- From 1st January 2025, if the Module B CE certificate expires, it must be replaced by a UK issued Module B certificate.
- For Category III PPE, when the Module B is replaced by a UK certificate, the Module C2 or D must be replaced with a UK approval.
- In any case, the PPE must have certification from a UK approved body from 1st January 2028.
Marine Equipment deadline unchanged
There is no extension for marine equipment, and this has been confirmed to UK approved bodies by the Maritime and Coastguard Agency (MCA). The transition from Wheelmark to UK Red Ensign was already two years.
Construction products deadline unchanged
There has been no announcement of an extension for construction products. At present, all construction products placed on the GB market from 1st January 2023 must be UKCA marked. The easement for System 3 is still in place to use existing EU notified laboratory testing, but all other products must have UKCA approval from a UK approved body.
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® can 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 1st 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.
If you have any questions regarding UKCA marking, please contact our UK certification team at certification@bttg.co.uk