Understanding the use of the UKCA Mark for UK markets
Placing products onto the market in Great Britain
Due to the UK leaving the EU, the UK Department of Business and Trade (DBT) has laid out its plans for manufacturers placing products into Great Britain.
The DBT announced in August 2023 that legislation will be introduced to extend recognition of the CE marking for placing a wide range of goods on the market in Great Britain. This will continue to allow recognition of goods that meet EU requirements, using the EU conformity marking (including the CE marking) in England, Scotland and Wales.
The CE marking is already recognised in Northern Ireland. Businesses there will continue to enjoy unfettered access to the GB market and the EU single market.
As such, the CE marking will be an acceptable method of demonstrating compliance for a wide range of goods on the UK market, covering the following products and regulations:
- recreational craft and personal watercraft
- electromagnetic compatibility
- non-automatic weighing instruments
- measuring instruments
- measuring container bottles
- equipment for potentially explosive atmospheres (UKEX)
- radio equipment
- pressure equipment
- simple pressure vessels
- personal protective equipment (PPE)
- gas appliances
- equipment for use outdoors
- low voltage electrical equipment
Links to UK Government announcements can be found here:
This approach will provide flexibility for businesses to use either the CE or UKCA marking.
The UKCA Mark
Should manufacturers wish to use the UKCA mark on their products, the UKCA regulations apply.
Using the UKCA Mark
The following general rules apply using UKCA markings:
- UKCA markings must only be placed on a product by the manufacturer or authorized representative (where allowed for in the relevant legislation)
- When attaching the UKCA marking, businesses take full responsibility for their product’s conformity with the requirements of the relevant legislation
- Businesses must only use the UKCA marking to show product conformity with the relevant UK legislation
- Businesses must not place any marking or sign that may misconstrue the meaning or form of the UKCA marking to third parties
- Businesses must not attach other markings on the product which affect the visibility, legibility or meaning of the UKCA marking
- The UKCA marking cannot be placed on products unless there is a specific requirement to do so in the legislation
UK Declaration of Conformity
The UK Declaration of Conformity is a document which must be drawn up for most products lawfully bearing a UKCA marking.
In the document businesses, or an authorized representative (where allowed for in the relevant legislation), should:
- Declare that the product is in conformity with the relevant statutory requirements applicable to the specific product
- Make sure the document has the name and address of the manufacturer (or an authorized representative) together with information about the product and the conformity assessment body (where relevant)
The UK Declaration of Conformity should be available to market surveillance authorities on request.
The information required on the Declaration of Conformity will be largely the same as what is currently required on an EU Declaration of Conformity. This can vary depending on the application legislation but generally should include:
- Business name and full business address or that of an authorized representative
- The product’s serial number, model or type identification
- A statement, stating the business takes full responsibility for the product’s compliance
- The details of the approved body which carried out the conformity assessment procedure (if applicable)
- The relevant legislation with which the product complies
- Business representative’s name and signature
- The date the declaration was issued
- Supplementary information (if applicable)
You will need to list:
- Relevant UK legislation instead of EU legislation
- UK designated standards rather than standards cited in the Official Journal of the European Union
Using both the CE and UKCA marking
Goods can carry both the CE and UKCA markings so long as they are fully compliant with both UK and EU regulations. CSA Group maintains both an EU-27 Notified Body (CSA Group Netherlands B.V, Notified Body number 2813), and a UK Approved Body ( CSA Group Testing UK Ltd No. 0518) status and can offer UKCA and CE services in a seamless and efficient manner.
Frequently Asked Questions about Brexit and the new UKCA marking
1. What is the UKCA?
The UKCA (UK Conformity Assessed) marking is a UK product marking regulation that can be used in place of the CE mark in the GB market.
2. Based on the above, will the UK accept CE marked goods?
Yes, the DBT announced in August 2023 its intention to introduce legislation to allow indefinitely the acceptance of CE marked products placed on the market in Great Britian.
3. Can the same body assess and certify products for entry into both the UK and EU?
No, however, CSA Group is one of only a few organizations that can provide solutions for entry into both Europe and the UK, specifically for products used in ‘Ex’ explosive atmospheres (hazardous locations), due to our position as a leading testing, inspection and certification company. UKCA assessment and certification must be conducted by a UK Approved Body located in the UK. For entry into the EU, certification must be conducted by an EU Notified Body. Under CSA Group we maintain status as both an EU ATEX Notified Body (CSA Group Netherlands B.V, Notified Body number 2813), and a UK Approved Body (CSA Group Testing UK Ltd (No. 0518). This ensures we can offer both ATEX and UKCA services in a seamless and efficient manner.
4. Is CSA Group accredited as a UK Approved Body?
Yes. CSA Group’s UK-based body, CSA Group Testing UK Ltd is a UKAS-accredited, UKCA Approved Body (Approved Body Number 0518).
5. What will the actual assessment and certification process look like?
UKCA denotes a number of “Designated Standards” that products must be in compliance with (see here for the list of Designated Standards for equipment for explosive atmospheres: https://www.gov.uk/government/publications/designated-standards-atex); these Designated Standards largely mirror the EN standards found within the European Journal. Further, the fundamental principles of UKCA for hazardous locations follow closes those of ATEX (for example, definition of hazardous area zones, categories of equipment and conformity assessment procedures).
In practice, therefore, if there is an existing ATEX or IECEx certification file for the products that also require UKCA, CSA will aim to utilize this existing data in support of UKCA approval. Where further assessment may be required (for example, if the ATEX file was certified to EN standards that are no longer harmonized standards and therefore do not meet the latest technical requirements of the corresponding UKCA Designated Standards), CSA will conduct any necessary assessment required to ascertain if the product can demonstrate compliance to the Designated Standards.
In the majority of cases, a UKCA Quality Assurance Notification (QAN) will be required, and the requirements of this are also very similar to ATEX QANs. CSA will aim to conduct a desk-based review of any existing QAN data in support of issue of a UKCA QAN.
For non-electrical equipment used in an explosive atmosphere (for Zone 1/21), a product assessment using the EN ISO 80079-36 and -37 standards can be carried out by the manufacturer with the documentation in the form of a technical file being lodged with a UKCA Approved Body.
6. Can I use the assessment data in my CSA Group ATEX file in support of the issue of a UKCA certificate?
Yes. As the legislation for UKCA for ‘Ex’ products is broadly similar when compared to ATEX Directive 2014/34/EU, our certification team will base their assessment of UKCA on this existing data. We will check submitted ATEX files for compliance against UKCA Designated Standards, and review any third-party component incorporated into the design against UKCA requirements. Should additional assessment be needed to issue a UKCA approval, this will be communicated following our review.
7. Can existing ATEX certificates issued by other test bodies be used as supporting documentation for CSA Group ( CSA Group Testing UK Ltd) to issue certification for UKCA?
Yes, and CSA Group will provide any additional evaluation needed to support the issue of a UKCA certificate.
8. Which documents are needed for the assessment?
Documentation that is used in the assessment process will emulate that of the CE mark in the EU market so the documents for CE mark should be sufficient, with appropriate amendment to include the UKCA marking.
9. How long will such an assessment take?
Timing will be based on the review of the application data, and the availability of such data. Please contact CSA Group for more details.
10. I have an ATEX certificate issued by CSA Group Netherlands, Notified Body 2813. What will happen to my certificate?
Your certificate will continue to remain valid when placing product on the EU marketplace. For UK entry; in August 2023 the UK Government published guidance which explained that CE-marked equipment will be recognized in the UK indefinitely for many types of products.
11. Is the UKCA mark accepted within the EU?
No. Products currently requiring CE marking will still need a CE mark for sale in the EU.
12. Will I need a separate quality audit in addition to my QAN?
Where allowable, we would expect to use existing quality audit data and carryout combined UKCA/ATEX audits where possible.
13. How can CSA Group help me obtain UKCA approval?
CSA Group is one of only a few organizations able to issue UKCA for products used within ‘Ex’ explosive atmospheres (hazardous locations) in the UK. Our body, CSA Group Testing UK Ltd, will be able to issue UKCA, amongst many other complimentary services offered within the CSA Group, such as ATEX, IECEx, entry to North American hazardous locations and many more international marketplaces. Our team is here to support and guide on the requirements and provide cost effective and efficient solutions for your needs.
Learn more about ATEX certification and approval and our Industrial & Hazardous Locations Equipment solutions.
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