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.
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.
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.
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.
- 2014/30/EU “EMC Directive” >> SI 2016 No. 1091 “The Electromagnetic Compatibility Regulations 2016”
- 2014/53/EU “Radio Equipment Directive aka RED” >> SI 2017 No. 1206 “The Radio Equipment Regulations 2017”
- 2014/35/EU “Low Voltage Directive” >> SI 2016 No. 1101 “The Electrical Equipment (Safety) Regulations 2016”
- 2011/65/EU “RoHS” >> SI 2012 No. 3032 “The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012”
- 2014/34/EU “ATEX” >> SI 2016 No. 1107 “The Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres Regulations 2016”
- 2006/42/EC “Machinery” >> SI 2008 No. 1597 “The Supply of Machinery (Safety) Regulations 2008”
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.
UKCA information from the clever chaps over at Conformance.co.uk