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UKCA: More Time for Business

PM has covered the new UKCA marking previously and we’re back with a reminder after the Government has recognised that businesses may not be ready for the change. The 2022 deadline has been extended to 1 January 2023. However, the BPMA is still encouraging the industry to keep on track with it’s UKCA marking plans.

WHAT IS THE UKCA MARK?
Now the UK has left the EU, CE marking no longer applies to UK-made goods. As a result, there are changes to how businesses place manufactured goods on the market. The UKCA (UK Conformity Assessed) marking is a new product marking for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods which previously required the CE marking and demonstrates that all the requirements of the legislation have been met.

WHAT DOES THE NEW DEADLINE MEAN?
Businesses placing goods on the market must be ready to use UKCA marking from 1 January 2023 for most goods and the industry is encouraged to start using UKCA as soon as possible. The Government will introduce legislation so that the UKCA marking can be placed on a label affixed to the product or on a document accompanying the product until 1 January 2024.

WHAT DO BUSINESSES NEED TODO NOW?
Step 1: Check whether your product needs the UKCA mark. If it was previously CE marked or used the reverse epsilon marking, you will need to use the UKCA mark.
Step 2: Check the appropriate route for conformity assessment. There is guidance available to help you work out if you can self-declare or need to use a third party conformity assessment. Again, if you previously used a CE mark, you should follow the same rules to choose your method of conformity
assessment.
Step 3: If you are using a third party for your conformity assessment, you must identify an appropriate body. There is a database called the UK market conformity bodies (UKMCAB), at gov.uk/uk-market-conformity-assessment-bodies
Step 4: Draft the technical documentation and declaration of conformity which shows the manufacturer or authorised representatives have ensured the safety of the product.
Step 5: Affix the UKCA marking. As the manufacturer, you must place the UKCA marking on the product itself or where the rules allow it, on the packaging or on accompanying documentation. You may appoint an authorised representative to do this.

EXISTING STOCK AND OTHER AREAS WHERE THE MARK APPLIES
Are there areas where other rules to UKCA marking apply?
It is mandatory to use the UKCA marking in most cases from 1 January 2023, except for medical devices, which must use the UKCA marking by 1 July 2023.
What is the status of existing CE stock that has not been placed on the market before 2023 in Great Britain?
Government legislation allows products bearing the CE mark to continue to be placed on the market until 1 January 2023.

Define ‘Placing a good on the market’?
A product is placed on the market when there is an offer or an agreement, verbal or written for the transfer of the ownership, possession or any other kind of right, excluding intellectual property rights, concerning the product. It applies to each individual good. For more details on this, search ‘Placing manufactured goods on the market in GB’ on Gov.uk.

What about Northern Ireland and the UKNI mark?
The UKNI marking is a new conformity marking for products placed on the market in Northern Ireland (NI) which came into force on 1 January 2021. You need to use it on your products, alongside the CE marking, if they have undergone mandatory third-party conformity assessment by a UK-based
body.

When should the UKNI mark be used?
Third-party conformity assessment: If you are using a UK Notified Body, you need to apply both a UKNI marking and the CE marking. If you use an EU recognised Notified Body, you only need to apply the
CE marking.

Self-declaration: If you self-declare, you should continue using the CE marking when placing goods on the market in NI and you must not add the UKNI marking.

Will UKCA marked goods be accepted on the NI market without the UKNI marking?
No. The valid markings for placing goods on the NI market will be the CE marking or the CE+UKNI markings. The UKCA marking can appear alongside the CE or the CE+UKNI markings if you are planning on selling your good on the GB and NI market and both sets of relevant rules have been met.

Can you sell CE+UKNI marked goods in the EU?
No. If your product requires mandatory third-party conformity assessment, you will need to use an EU Notified Body and then can CE mark your products. Under unfettered access, qualifying NI goods that are CE marked from an EU notified body can be placed on the GB market without any requirements.

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