UKCA Replaces CE in the United Kingdom

UKCA certification will become mandatory in the UK from January 1, 2022, with the end of the Brexit transition period.

What is UKCA?

UKCA (UK Conformity Assessment) is the product brand that replaces the CE (Conformitè Europëenne) mark for products to be exported to the United Kingdom (England, Scotland, Wales) with Brexit.

The UKCA mark, which started to be applied on January 1, 2021, will become mandatory for the United Kingdom (UK) from January 1, 2022, after the transition period. During the transition period, the CE marking will continue to be accepted by the UK. However, as of January 1, 2022, these two applications will be completely separated from each other. Products not carrying the UKCA mark will not be able to enter the UK market.

From January 1, 2022, products for both the EU and UK markets must meet CE and UKCA standards.

Manufacturers wishing to export their products to the UK must complete their UKCA certification process within the transition period.

Which Products Should UKCA Have?

Almost all products covered by the current CE marking regulation are covered by the UKCA mark. From January 1, 2021, the UKCA mark will be used if all of the following are valid:

• If the product is to be placed on the UK market,
• If the product is within the scope of legislation requiring UKCA mark,
• 3rd party conformity assessment of the product is required,
• The UK approved assessment body has carried out the product conformity assessment. The conformity file was not transferred to a notified body established in the EU before 1 January 2021.

How to Get a UKCA Mark?

The UKCA mark is awarded by assessment bodies approved by the UK authorities. Most organizations that provide CE certification based in the UK have this status. The UK Accreditation Service (UKAS) will continue to operate as the national accreditation service. You can access the information of approved authorities from the UKMCAB (UK Market Conformity Assessment Bodies) database.

From 1 January 2021, the exporter must appoint a representative or responsible person. For the UK market, all authorized representatives must be based in the UK. If the product is not manufactured in the UK, the UK-based importer’s information and address should be included in the product documentation.

Preparation for the UKCA Certification Process

The process will work differently for manufacturers with CE marking and manufacturers without CE marking. Those with the CE mark will complete the process faster, as the requirements largely overlap.

Manufacturers who do not have the CE mark yet will take longer and more intensively with the necessary arrangements to provide the conditions required in this process.

Some Important Issues in UKCA Mark Application:

• Products with the existing CE mark within the harmonization process will be sold in the UK market until January 1, 2022.
• Manufacturers that have placed their products on the EU or UK markets before January 1, 2021, do not need to do anything additional with these products.
• This CE mark can be used in the UK market until January 1, 2022, even if the CE certificates issued by EU-approved institutions are obtained after January 1, 2021.
• As of January 1, 2021, products that are found to be non-compliant with UK standards by UK-approved institutions must receive the UKCA mark.
• Within 24 months from January 1, 2021, the UKCA mark can be added to most CE-marked products.
• All UK-based EU-approved assessment bodies become UK-approved assessment bodies as of January 1, 2021.
• From January 1, 2021, assessments by the UK approved the EU will not accept bodies unless mutual recognition agreements indicate otherwise. Likewise, evaluations made by EU-approved institutions will not be carried by the UK.
• The product will use both marks if it meets both CE and UKCA standards and is produced for both markets.
• The UKCA mark can be affixed to a product label or accompanying document until January 1, 2023, for most products.
• The UKCA mark must be affixed directly to most products on or after January 1, 2023.

Use of UKCA Mark in Machinery Export

The product groups covered by the UKCA mark include superficial pressure vessels, electromagnetic compatibility, non-automatic weighing instruments, measuring instruments, lifts, radio equipment, pressure equipment, containment of harmful substances, and machinery.

Medical equipment, collaborations in rail products, construction materials, and civil explosives are also within legislation but have specific rules.

The Supply of Machinery Safety Regulations 2008 UKCA marking is in the legal area where the declaration of conformity is allowed. Manually operated machines (other than those used for lifting), tools, and ladders do not fall under legislation.

UKCA compliance is not required in most cases of machine modifications. However, the Work Equipment Regulations (PUWER-Provision and Use of Work Equipment Regulations) and product health requirements must be met. Depending on the change to be made, advice may be sought from the product manufacturer, and you may need engineering expertise depending on the transition to be made.

However, the change to be made on the machine;

• If it is extensive enough to make the product a new machine,
• The product affects security systems or functions, or
• If the product brings a significant risk increase not included in its original form (such as making a manual machine computer-controlled), the modified machine must meet the conformity assessment criteria, and the product must be given a new UKCA mark.