Preliminary Guidance on UKCA mark

Preliminary Guidance on UKCA mark

Last update: January 2021

Preliminary Guidance on UKCA mark

 

This paper provides initial guidance on the introduction of the UKCA mark in the United Kingdom, and of the UKNI mark in Northern Ireland. These 2 new markings came into effect on 1st January 2021 for construction products as for many other products.

A transition period is foreseen until 1st January 2022. During 2021, products placed on the Great Britain market can be marked with either the UKCA or the CE mark, or both. The recognition of CE marking in Great Britain will end on the 1st January 2022. As of this date, products placed on the Great Britain market must carry the UKCA mark. Businesses willing to sell their products in Great Britain and to affix the UKCA marking will have to use a UK-recognized “approved body” by 1st January 2022.

As legal basis, the UK Government has published an amendment to the Construction Product Regulation (CPR):

Further guidance by the UK Government is available under to following links:

 

While many details of the new procedure are still open, the framework is fixed:

  • UK “notified bodies” will automatically become UK “approved bodies”
  • All existing Harmonized European standards will become Designated UK standards, see https://www.gov.uk/uk-market-conformity-assessment-bodies?page=3
  • UK notified body CE certificates for type testing can be used by the manufacturer to support UKCA marking (but must be maintained)
  • UK notified body certificates cannot be used to support CE marking after the 1st January 2021
  • CE marks affixed after the 1st January 2021 must be supported by an EU27 notified body certificate (AVCP 1, 1+ and 2+)
  • EU27 notified body certificates cannot be used to support UKCA marking
  • Products legitimately CE marked and circulating on the EU28 market prior to 1st January 2021 can continue to circulate, but the distributor or importer must be able to demonstrate that they were placed on the market prior to 1st January 2021.
  • A UK distributor of an EU27 product will become an importer
  • UK manufacturers that export to the EU27 will need to appoint an importer in the EU27
  • In Northern Ireland, the UKNI mark and the CE mark need to be affixed.

The marking requirements and logos are given below:

Country

Relevant mark

England, Scotland, and Wales

UK CA

Northern Ireland

UK NI
or
UK NI and CE

Ireland

CE

Other EU member states

CE

 

 

For further information, please check the Glass and Glazing Federation’s (GGF) presentation below (link):

 Several questions remain unanswered:

  • Will an abbreviated/simplified UK CA Mark and UK NI Mark be acceptable as we have seen for CE Marking (reference Glass for Europe guide to CE Marking)?
  • What happens if no UK Approved Bodies can carry out Type Testing? Will it be acceptable to continue to use an EU27 Notified Body provided the Type Tested referenced in the hEN and corresponding UK designated standard are the same?
  • For a manufacturer supplying all countries in the UK as well as Ireland, is it acceptable to supply a product affixed with all three marks – UK CA, UK NI and CE? (We have heard that products affixed with UK CA Mark in addition to CE Marking may not be acceptable in EU27 – but there has been no formal confirmation of this from any of the EU institutions, e.g. European Commission).
  • It is the Commission services’ view that the UK marking (as any third country marking) can be affixed to a product which bears the CE marking, provided that such marking does not create confusion with the CE marking. This confusion may either refer to the meaning or the form of CE marking (see Article 30(5) of Regulation 765/2008). Therefore, the UK marking as well as any other information concerning UK legislation must be separate from the CE marking and information concerning EU legislation. This applies also to the Declaration of Performance/Conformity. The DoP drawn for the purposes of compliance with EU legislation should not be used for the purposes of UK legislation.
  • If the UK CA Mark in GB (and UK NI Mark in Northern Ireland) only needs to be affixed when the product is placed on the market, is it acceptable for a product imported into the UK from EU27 to have the CE Marking affixed at point of entry into the UK (i.e. customs) provided it is subsequently relabeled with UK CA or UK NI Mark in UK before being placed on the market?

 

More detailed guidance will be provided by Glass for Europe once more details are known.