From CE to UKCA markings
What is the UKCA?
Following the UK’s departure from the EU, the UK government has introduced a new safety labelling scheme for use in England, Wales and Scotland. The UK Conformity Assessment (UKCA) replaces the CE mark for use within British markets. The label is an indicator that products meet specified technical or essential requirements.
What are the rules for Northern Ireland?
Northern Ireland is in a different position. The Northern Ireland protocol, agreed as part of the Brexit deal with the EU, means that Northern Ireland remains within the single market. Consequently, Northern Ireland continues to recognise the EU’s CE marking for goods sold in Northern Ireland. However, relevant goods produced in Northern Ireland for the British market will need to use a UKNI mark, and goods will need to be tested by an approved UKCA body.
What marking is required for products to be sold to the EU?
The UKCA label is not recognised by the EU, so UK companies will need to continue to apply the CE safety mark for products to be sold in EU markets. The UKCA marking is the labelling specific to the UK.
What are the timescales for introducing the UKCA?
The UKCA scheme was launched on 1st January 2021. The original deadline was for all changes to safety markings to be implemented by 1st January 2022. However, due to the upheaval that businesses have faced in recent years as a result of Brexit and the pandemic, the decision has been made to delay the deadline to 1st January 2025. In the meantime, the CE marking is permitted for use in the UK. From 11pm on 31st December 2024, the CE marking will no longer be recognised for use in Great Britain.
What products require the UKCA marking?
Most goods that were previously required to display the CE marking will need to feature the UKCA mark when sold in Great Britain. UKCA marking is also required on aerosol products, which were previously required to display the reversed epsilon label.
What is the benefit of the UKCA labelling scheme?
The UKCA label assures customers that products have been made to an approved technical specification. This means that substandard products can be avoided, as they will not display the UKCA marking.
Who can issue certification for the UKCA scheme?
UKCA certification can be provided by one of the UK Approved Bodies, such as the British Standards Institution (BSI). An Approved Body will work with a company to go through the necessary conformity assessment procedures to move from CE to UKCA markings.
Who can help with CE marking?
To access EU markets, your products will need to have proof of conformity with EU standards, indicated by the use of the CE mark. To get certification for CE marking, you need to work with a Notified Body. Notified Bodies are organisations approved by the EU for the provision of CE certification services. You can get further details of EU Notified Bodies here. BSI Netherlands can help with CE marking as well as UKCA marking.
Why is there not an automatic transfer of CE to UKCA marking?
The Approved Body is responsible for assessing the evidence of compliance with required standards. The Approved Body will need to review CE documents and evidence of conformity from the Notified Body you have worked with. If these are satisfactory, the UKCA certification can be issued. In some cases, further evidence or testing may be required. However, if the CE marking was previously issued by the Approved Body, the transfer process can be shorter.
What is the impact on health and safety products?
This is particularly important for health and safety products, which people need to be able to rely on for quality and suitability. Personal protective equipment (PPE) is an obvious example of how important it is for safety products to meet the required standards. During 2020, in response to the COVID-19 crisis, the UK government wasted hundreds of millions of pounds on PPE that was poor quality and not fit for purpose. Under one contract, millions of face masks were purchased, but none of them could be used because the fixing was not the correct type. The House of Commons Public Accounts Committee noted that “stocks ran perilously low, single use items were reused, some were not fit for purpose – including reports of expired, substandard, deficient… supplies” (as reported in the British Medical Journal).
Due to these failings, some health workers had to resort to using substandard PPE as there was nothing else available, while other health workers ran out of PPE when it was not distributed because of not meeting the required standards. As a result, some key workers contracted COVID-19. Some of these cases were fatal.
Safety standards
At Seton, we are proud to be members of the British Safety Industry Federation (BSIF) – the trade association representing the PPE industry. The BSIF has established a Registered Safety Supplier Scheme (RSSS). Under this scheme, companies that wish to display the RSSS logo on their products must sign a binding declaration to give assurances that the safety products they offer meet suitable standards, are compliant with PPE regulations, and are marked with the CE or UKCA labelling.