Brexit Motiv

UK Conformity Assesed Kennzeichnung

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2021-01-05

UKCA Mark

The UK government has decided that UKCA mark is mandatory for the UK market. An explanation of the UKCA mark, as well as an overview of the time and further information such as technical data can be found below.

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Dr.-Ing. Klaus Kreß

What is the UKCA mark?

UKCA Mark
GOV.UK

The UKCA (UK Conformity Assessed marking) is a British product marking that was created to replace the CE marking following Brexit. Products that are to be placed on the market in Great Britain (England, Wales and Scotland) require this marking since 01.01.2021.

Notified bodies in the UK are no longer permitted to issue statutory certificates for the EU and existing UK certificates no longer apply in the EU. Manufacturers who have previously used statutory certificates (such as EU type-examination certificates) issued by a notified body in the UK must transfer them to a body in the EU or apply for a new one. Conversely, for certificates to be used in the UK, they must be issued by a UK notified authority.

In place of EU Directives and Regulations, the applicable UK legislation requiring UKCA marking is to be applied.

The UKCA marking is not recognised on the European market. For products that are to be placed on the EU market, the CE marking is still required. 

When is UKCA marking required?

The UKCA mark has been mandatory in Great Britain since January 1st, 2021.

Up to 31.12.2021, manufacturers are still permitted to bring products exclusively carrying the CE mark onto the British market. As well as the EU declaration of conformity, there will also be a UKCA declaration of conformity for the British market, which will reference British law instead of EU guidelines/regulations and use British standards (BS) as normative reference. The BS indicates that this standard approved by the British Standards Institution, the UK’s national standards organization.

The CE mark, the EU declaration of conformity and the EU type approval test are considered equal alternatives to the corresponding UK elements until the end of 2021 at the latest. There is therefore a one-year transition period from 01.01.2021 to 31.12.2021. Afterwards, the UKCA mark must be used and related requirements implemented.
If there are related changes to EU or UK law from 01.01.2021, the UKCA label will immediately be mandatory for affected products from 31.12.2021. The same also applies to interim changes to UK law. The transition period also correspondingly applies to products that require a confirmation from a notary. 

The UK government has released guidelines on UKCA labeling.

To the guidelines

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We are here to help

We support you in researching EU / UKCA guidelines with regard to a possible EU / UKCA declaration of conformity. 

Contact us!

Rules for affixing the UKCA marking

Up to the end of 2022, manufacturers are allowed to “provisionally” use the UKCA label on their products. This can be implemented by adding the relevant mark to the operating manual, an additional label or similar. From 01.01.2023, the UKCA label must be firmly applied to the product itself under a similar regulation to which the CE mark is subject.

  • It may only be applied to the product by the manufacturer or an authorized representative, insofar as this is permissible within the relevant legal guidelines.
  • The manufacturer (or its authorized representative) takes full responsibility for the conformity of its product with the applicable legal requirements.
  • This declares the conformity of the product with the applicable legal requirements.
  • The foundation for the application of the UKCA mark is a UKCA declaration of conformity.
  • No further marks or symbols can be applied to the product alongside the UKCA mark that would impact the readability or meaning of the UKCA label.


Further information on technical documentation:

  • The manufacturer (or its authorized representative) must create technical documentation. It must clearly state that the product complies with statutory requirements.
  • This information can be requested by the market’s supervisory authorities or law enforcement bodies.

In general:
It must be clear...

...how the product has been constructed and manufactured.
...how the manufacturer has fulfilled the statutory regulations for its product.
...the address of the manufacturer and any warehousing.

Further information complies with the requirements of the EU declaration of conformity.  


The following products are mandatory for UKCA labeling:

  • Toy safety
  • Recreational craft and personal watercraft
  • Simple pressure vessels
  • Electromagnetic compatibility
  • Non-automatic weighing instruments
  • Measuring instruments
  • Lifts
  • ATEX
  • Radio equipment
  • Pressure equipment
  • Personal protective equipment
  • Gas appliances
  • Machinery
  • Outdoor noise
  • Ecodesign
  • Aerosols
  • Low voltage electrical equipment
  • Restriction of hazardous substances

How can the VDE Institute support you in the implementation?

We are happy to assist you to make the implementation easier. Right from the start, we will support you in identifying the applicable Statutory Instrument (SI) for the individual product as well as in preparing a draft UK Declaration of Conformity (DOC). The testing we carry out on your product will allow you to demonstrate compliance with the BS standards and continue to place your products on the UK market. Additional relevant information will be added to the test report as well as in the certificate. 

Disclaimer

This information has been taken from publications of the British government on Brexit. We accept no liability for its correctness or implementation.