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ukca mark

UKCA Mark Updates

Because of the United Kingdom leaving the EU, the CE Mark will no longer be recognised as demonstrating conformity with UK legislation.

Instead the CE Mark will be replaced by the UKCA mark (UK Conformity Assessed) which will be required to sell your products in the UK. This mark can coexist with the CE mark on the same label.

The transition period starts this coming January 2021 and UKCA marks become mandatory for the UK on 1 Jan 2022.

Whilst it sounds like a year in enough time to get everything in order think back to university and how much time you had to finish your dissertation – am I right? Start sooner rather than later, especially if you have multiple products.

unit 3 compliance ce mark to ukca mark transition

This applies to goods sold (“placed on the market” to use the correct term) in England, Scotland and Wales. Northern Ireland will still require CE marking due to the Irish border.

 

Action Stations for UKCA

You will need to create a new “UK Declaration of Conformity” similar to the EU Declaration of Conformity (which you will still need for CE marking). Contact me if you need a template. If you’ve been a customer and we’ve performed CE marking testing for you then we’ll be sending out UK DoC templates for your products before the end of this year.

The EU Technical Documentation that I’m sure you keep up to date for all your products will need an additional section with references to the UK Statutory Instruments (equivalent to the Directives) and Designated Standards. Let me know if you need some help with this.

Add the UKCA mark to your product label. You can find image files on the gov.uk website. It must be at least 5mm high.

It can be applied as a temporary label until 1 January 2023 after which it must be “permanently attached” in the same fashion as you currently apply the CE mark.

The product, or documentation where this is not possible, must have the manufacturer’s name and UK address shown. If the manufacturer is outside the UK, this must be the importer’s address.

 

UK Manufacturers Selling to EU

You are now a “3rd country” and will need an EU Sales Office (assuming you don’t already have one) whose address and contact details will need to go on the EU Declaration of Conformity. Various companies offer an “EU Authorised Representative Service” which can be found with a little searching.

If you use a UK based Notified Body, they will probably have already been in touch to discuss what is happening with your compliance certification. If not, get in touch with them sharpish and ask about your compliance status.

 

Key Dates

1st January 2021

UKCA becomes valid and can be placed on electrical / electronic products to demonstrate conformity with UK legislation.

CE mark enters transition period but is still valid for 12 months.

This transition period applies if you currently self declare CE compliance using an EU Declaration of Conformity (the vast majority of products do this).

 

1st January 2022

CE mark ceases to be valid in the UK.

UKCA mark becomes mandatory.

 

Legal Eagles

The EU directives relating to CE marking are already UK law. SI 2019 No. 696 will modify the below SIs (and more) to add UKCA marking and change the terminology. All compliance documentation must refer to these Statutory Instruments instead of the EU Directives.

Notified Bodies become Approved Bodies.

Harmonised Standards become Designated Standards and use the BS prefix (e.g. BS EN, BS ETSI EN). No list of Designated Standards is available yet, this is likely going to be published around 1 Jan 2021 where the list gets transposed from existing standards.

Most standards change at a slow pace so we’ll have to wait and see how quickly changes to the IEC, CENELEC and ETSI standards filter through to the UK standards list. Certainly no massive changes in technical requirements will happen overnight.

 

References

Guidance: Placing manufactured goods on the market in Great Britain from 1 January 2021 (Gov.uk)

Guidance: Guidance Using the UKCA mark from 1 January 2021 (Gov.uk)

UKCA information from the clever chaps over at Conformance.co.uk

 

 

EMC Certification is not just a rubber stamp by the test lab!

“Do You Do Certification?”

“Do you do certification or just pre-testing?”
“Can you certify our products?”
“Can you do EMC testing even though you aren’t accredited?”

The concept of “certification” is an interesting and, judging by these real customer enquiries that we’ve received, a confusing aspect of EMC testing.

The short answer to the questions above is “no, you do, in a way, most of the time, for most things” but like most short answers it isn’t particularly helpful.

To help clear this up, lets have a quick look at declaration vs certification for EMC testing to CE marking (EMCD & RED) and “FCC” CFR 47 Part 15B, lab accreditation and the operating philosophy of Unit 3 Compliance.

In summary:

  1. Unit 3 Compliance test results are valid for a wide range of regulatory approvals, including CE marking and FCC
  2. In the context of the CE Mark, there is no such thing as a ‘CE certificate’ or a ‘CE certification’ process
  3. You (the manufacturer) “self certifies”; or rather you legally Declare your product to be compliant with the EU Directives
  4. For the USA (FCC) certification does exist but it depends on the product. Many products are exempt from certification.

 

Unit 3 Compliance Test Results Validity

Regulatory Regime

Product Type

Unit 3 Compliance can be used for testing?

CE Marking

EMC or Radio Equipment Directive

Yes

FCC

Unintentional Radiators (Part 15B)

Yes

FCC Unintentional Radiators with FCC Approved Radio Module

Yes

FCC

Intentional Radiators (Part 15C)

Pre-compliance only.

Accredited laboratory required for final test

 

 

CE Marking

When CE marking for selling products in the EU, most electronic products are going to be covered by either the EMC Directive (2014/30/EU) or the Radio Equipment Directive (2014/53/EU). The latter refers to the wording of the EMC Directive anyway.

In all cases, the manufacturer “self certifies” by assessing the product (usually to a Harmonised Standard) and then producing and signing a Declaration of Conformity (a legal document) to confirm that their product meets the Essential Requirements of the Directives in question.

Note that the directive requires the manufacturer to “assess” the product. It doesn’t specifically require testing of a product. However, by testing the product to Harmonised Standards, you gain a “Presumption of Conformity” to the requirements of the Directive.

However, testing is the best way to determine performance; EMC behaviour is largely dictated by parasitic components that are not generally present on the design documents.

It is then up to the manufacturer to ensure that all future products remain compliant through control of production.

Try searching either of these Directives for the following:

  • certificate
  • certification
  • accredited
  • accreditation

and you will find that these words are only used in relation to a Notified Body (NB) or an EU Type Examination Certificate provided by such a body. This approach is only mandatory for a narrow range of products or applications (e.g. where no Harmonised Standard exists for the Radio part of the equipment).

Similarly, there is no requirement to use an ISO 17025 accredited laboratory for any of the assessment activities. Accreditation is managed in the UK by UKAS and as such are sometimes referred to as “UKAS accredited laboratories”. This also includes testing submitted to a Notified Body to support an EU Type Examination Certificate process.

In summary:

  • There is no “certification” of products for CE marking
  • Using an accredited laboratory is not mandatory for CE marking
  • Whilst not strictly required, testing is definitely the best way to determine EMC performance

 

 

FCC

When seeking to comply with the “FCC” requirements of CFR 47 Part 15 for sale of products into the USA, we need to consider the type of product we are making and fit it into one of these categories.

  • Unintentional Radiators are products that can generate RF energy but are not designed to radiate it. Essentially, a product that does not contain a radio (like Bluetooth or Wi-Fi). Examples would be a power supply, a desktop PC, etc. (defined in 15.13 (z))
  • Intentional Radiators (defined in 15.13 (o)) are products that intentionally emit RF (e.g. mobile phone, Wi-Fi router)

A complicating factor are Radio modules that have undergone a Modular Approval process (15.212). This is an easy way to add radio functionality to your product. These have already been reviewed by a Telecommunications Certification Body (TCB) and approved by the FCC.

Provided an approved module is installed into your equipment in line with the OEM instructions then your responsibilities as manufacturer are to verify that the combination of Unintentional Radiator and Radio Module do not infringe any radiated emissions limits.

15.101 shows the paths available (SDoC or Certification) for different types of Unintentional Radiator.

2.906 Self Declaration of Conformity can take place in any test laboratory whereas 2.907 Certification has to take place in an FCC registered laboratory (must me nationally accredited to ISO 17025). In all cases the provisions of 2.948 measurement facilities apply.

 

 

Accreditation

Accreditation of laboratories is a slightly different subject. Accreditation is a method by which the test procedures of a test laboratory are verified by an independent 3rd party (e.g. UKAS in the UK) to be compliant with ISO 17025.

Similar to ISO 9001, ISO 17025 is a quality management system that demonstrates a laboratory is operated to a certain standard. 17025 also extends this quality system to the tests being carried out where the individual test procedures and personnel are checked by an external assessor.

This is useful to demonstrate competence of the lab to their customers. It also demonstrates (but does not guarantee) the quality of test results have met a certain agreed basic standard. Some manufacturers choose to always use accredited laboratories for their testing for a variety of reasons e.g. their quality policy might dictate it.

 

At Unit 3 Compliance, we choose not to be an accredited laboratory.

Accreditation costs a lot of time and money in fees, inspections and internal paperwork. This cost ultimately gets passed on to the customer. By remaining un-accredited we can keep our fees around 33% less than an accredited laboratory.

Many accredited labs subscribe to a business model of employing multiple technicians to perform the day to day testing whilst retaining a couple of engineers for consultancy and compliance paperwork. The operation can end up as a bit of a sausage factory – seeking to have a full calendar of testing and turning the handle as quickly as possible.

The fallout from this is that test reports often take a a back seat and are delivered weeks after the testing has been completed and in the event of problems you might not have time in the relevant test area to perform diagnosis of the problem before you are hurried out for the next customers’ scheduled test to take place.

Most people at the test lab have been working in that environment for most of their working lives. This makes them very capable at performing the tests but their lack of experience with product design means the staff are frequently not as capable of

You might get informal suggestions of “try and improve the shielding” or “you need a ferrite on that” but beyond that the likelihood of getting good quality problem solving advice is low.

I certainly don’t want to tar all accredited labs with the same brush. There are good labs and good engineers out there. However with some labs it can be pot luck whether you get Technician A (interested, helpful, keen, knowledgeable) or Technician B (uninterested, jobsworth, clock watching).

Whilst many accredited labs do have experienced personnel on site, getting access to them in a time or cost sensitive manner is often hard. Because of the requirements of accreditation and the need for impartiality, many labs run their consultancy services as a separate division within the company. Sometimes they aren’t even in the same building as the test lab! Inevitably these services have to be accessed outside of the test cycle leading to delays.

 

comparison of emc lab capabilities

 

How we operate

 

Unit 3 Compliance is not a sausage factory. Our motivation is doing interesting work and solving challenging problems for people who care about their products.

We are significantly cheaper than an accredited lab, putting EMC testing within the budget of startups and smaller businesses. It also makes it more economical for medium to larger companies to run ongoing quality control checks, product cost down exercises and experiments.

We have a strong product design background, particularly in design for EMC. We can suggest, trial and optimise EMC fixes during the test process rather than send you back to base to figure it out for yourself. These fixes take into account the nature, volume and cost of the product – there’s not one fix that is suitable for all applications.

First time EMC pass rates are generally low. Of all the products that I’ve tested, less than 20% have passed first time. Many of those passed because we reviewed their design first from an EMC perspective and made suggestions for improving the design.

Because we have a strong background in fixing EMC problems and not just testing, we can resolve your EMC problems faster than anyone else. This is not an idle boast but something we genuinely believe. Every problem we fix makes us faster and better next time and this compounding experience is available to you.

We turn every test session into a miniature EMC class, explaining the tests, why we perform things the way we do and how it sits into the larger framework of standards, directives and compliance. We work hard to acquire our experience and love to share it with our customers.

If you’d like to benefit from this then get in touch.

 

 

 

References