Whether your business is ready or not, the UKCA deadline of 31st December 2022 is looming. In this post we discuss what actions your business needs to take to ensure compliance.
What is UKCA marking?
Most of us are familiar with the CE mark – the European Union conformity mark. After Brexit, for most products, the CE mark will cease to be valid in Great Britain and will be replaced by the UKCA mark. If your product requires a UKCA mark, you will not be able to place your product on the GB market without it. The UKCA is already in place as a valid conformity mark and has already been implemented by major brands.
The CE Mark continues to be valid for products placed on the European market. Therefore if your products are available in both markets, the CE mark and the UKCA mark may co-exist on the same product provided one does not obscure the other and the requirements of both have been met.
In Northern Ireland, because of the Northern Ireland Protocol, the CE Mark can continue to be used for self-assessed goods and for goods which are conformity assessed by an EU Notified Body. An additional mark, the CE UKNI mark, exists for products which are conformity assessed by a UK Notified Body and placed on the Northern Ireland Market.
The UKCA mark must be at least 5mm in height, must be easily visible and legible. Resizing should not distort the width-to-height ratio.
Full information on using the UKCA marking can be found on the UK Government website: https://www.gov.uk/guidance/using-the-ukca-marking
Does UKCA marking apply to my product?
Before embarking on the process of UKCA marking, it is worthwhile to consider if the marking is required for your product. The UKCA marking cannot be placed on products unless there is a specific requirement to do so in the legislation. As a rule, all products which required CE marking will require UKCA marking. This includes (but is not limited to) toys, PPE, gas appliances, machinery, aerosols (where it also replaces the reverse epsilon), outdoor equipment, and others. There are special additional rules for some products, such as medical devices, construction products, marine equipment, and others.
What actions should I take and when?
The UKCA mark is already recognised and can be used now. Ultimately, the legislation states that the UKCA Mark needs to be applied to all qualifying products on the GB market, and that the mark should be applied directly to the product itself, if feasible. However, there has been an easement up to the 31st of December 2025, which allows the UKCA mark to be applied as a sticky label or on the product documentation accompanying the product, rather than on the product itself.
- For products that already have a CE mark and have already been imported under contract into the UK before 11pm on the 31st of December 2022, you do not need to do anything. There is no need to re-test or remark these products, they can continue to sell through to the end user on the GB market, without a UKCA mark.
- Any certificates provided by non-UK conformity assessment bodies, testing to EU requirements, issued before the 31st of December 2022 can be used as a basis for UKCA marking Certification
- For products that are placed on the GB market after the 31st of December 2022 and before the 31st of December 2025, the UKCA mark is mandatory for qualifying products, and can be applied as a sticky label to the product or by adding to the accompanying product documentation. The accompanying document must stay with the product until it reaches the end user.
- For products placed on the GB market after 11pm on the 31st December 2025, the UKCA mark and the importer details should be applied directly onto the product itself, if feasible
- The UKCA mark is already recognised and can be used now. If you are already prepared, there is no reason not to apply the mark directly to your product now, in preparation for future deadlines.
If you need assistance in this complex and changing landscape, reach out to PerformanSC, your specialists in supply chain.
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