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UKCA mark and UKCA Declaration of Conformity

On September 1, 2020, the United Kingdom has left the European Union. On January 1, 2021, it will officially start to use the United Kingdom Conformity Assessment (UKCA) certification mark. At the end of this year, the transition period for the use of the product mark after Brexit will end.

The UKCA mark is a new British product mark that will be used for products sold in the UK (England, Wales and Scotland) market. It covers most of the goods that previously required the CE mark. Note: The UKCA mark does not apply to goods sold on the Northern Irish market.

After the UKCA mark is implemented, products that originally only require CE mark will require CE and UKCA certification for export to the European Union and the United Kingdom. This may have a significant impact on the cost of the seller’s products and requires great attention.

What products need to use the new UKCA mark?

1. Products sold in the UK

The UKCA mark will apply to most goods currently using the CE mark. From January 1, 2021, the technical requirements, conformity assessment process and standards that products must meet will be basically the same as they are now. In some cases, it will be necessary to apply the new UKCA mark to goods sold in the UK. The UK encourages companies to prepare to use the UKCA logo as soon as possible before this date.

Although the UKCA mark will be used from January 1, 2021, to allow companies enough time to adapt to the new requirements, in most cases, the CE mark can still be used until January 1, 2022. The CE mark is only valid in areas where the current UK and EU rules are still consistent. If the EU changes its rules and the product CE marking meets the new EU rules, then the product will not be able to use the CE marking to be sold in the UK, even before December 31, 2021.

2. Products sold in the EU still use the CE mark

The CE mark is still required to sell goods in the EU, and the UKCA mark will not be recognized by the EU market. From January 1, 2021, products that currently require CE marking are still required to apply for CE certification for sales in the EU.

When to use the UKCA mark?

After January 1, 2021, products that meet all the following conditions need to immediately use the new UKCA mark.

1. Products manufactured for the British market;

2. The law requires the use of the UKCA mark;

3. Products that need to be compulsory for third-party conformity assessment;

4. The product has been assessed by the British Conformity Assessment Agency. And before January 1, 2021, the conformity assessment documents have not been transferred from the UK agency to the EU recognized agency. If the transfer is successful, it will be regarded as equivalent to the CE certification and the CE mark can be used and the products can continue to be sold in the UK market, without the need to use the UKCA mark.

These regulations do not apply to existing inventory. For example, if the product has been fully produced and is ready to be placed on the market before January 1, 2021. In this case, even if it is a certificate of conformity issued by a British institution, products with the CE mark can still be sold in the UK.

From January 1, 2022, the United Kingdom will not recognize the CE mark. However, if the product also has the UKCA mark and complies with the relevant British rules, products with the CE mark can still be sold in the UK. There are separate applicable rules for medical devices.

How to use the UKCA mark

1. How to place the UKCA mark

In most cases, the UKCA mark must be used on the product itself or on the packaging. In some cases, it may be placed on manuals or other supporting documents. This will vary according to the specific regulations that apply to the product.

General applicable rules:

The UKCA mark can only be placed on the product by the manufacturer or authorized representative (when permitted by relevant laws);

When the UKCA mark is affixed, the manufacturer or authorized representative shall be fully responsible for the product’s compliance with the requirements of relevant laws;

Only the UKCA mark can be used to show that the product complies with relevant British laws;

The manufacturer or authorized representative must not place any mark or label on the product that may misinterpret the meaning or form of the UKCA mark to a third party;

Do not attach other marks that affect the visibility, legibility or meaning of the UKCA mark on the product;

Unless required by law, the UKCA mark cannot be used on products.

2. Rules for using UKCA pictures

It must be ensured that when downsizing or zooming the logo, the UKCA mark composed of letters must be in the same proportions. The height of the UKCA mark is at least 5mm unless relevant laws provide for a different minimum size. The UKCA mark must be clearly visible. It must be permanently attached to the product from January 1, 2023.

3. Transitional measures for the use of the UKCA mark

For general products covered by the UKCA mark, the following transitional measures apply. Before January 1, 2023, for most goods (except those subject to special rules), you can choose to stick the UKCA mark on the label with the product or accompanying documents. The operator (whether it is a manufacturer, importer, or distributor) should take reasonable measures to ensure that the UKCA mark remains effective. Products that require the UKCA mark cannot be provided without it (unless the CE mark is used before January 1, 2022).

From January 1, 2023, the UKCA mark must be printed directly on products in most cases, and manufacturers should incorporate this date into the product design process.

The transitional measures for the UKCA mark do not apply to products with special regulations such as construction products, medical equipment, interoperability equipment for railway systems, and transportable pressure equipment.

4. UKCA certification application process and matters that need attention

The UKCA mark is in principle not different from the CE mark. The manufacturer is responsible for ensuring that the product complies with the standards stipulated by the regulation. And after self-declaration in accordance with the prescribed procedures, the corresponding mark can be put on the product.

Manufacturers can seek testing by qualified third-party laboratories to prove that the product meets the relevant standards, issue a qualified test report, and issue a Attestation of Compliance(AoC), and use this as the basis for the manufacturer’s UK declaration of conformity(DoC).

The DoC needs to include key parameter information such as the manufacturer’s name and address, and the product model.

What is the UK Declaration of Conformity(DoC)?

The UK Declaration of Conformity is a document drafted for most products legally bearing the UKCA mark. In the document, you, as the manufacturer or authorized representative (if permitted by relevant regulations), shall:

▪ Declare that the product complies with relevant regulatory requirements.

▪ Ensure that the name and address of the manufacturer (or your authorized representative), as well as information about the product and conformity assessment body (if relevant) are on the file.

▪ The UK declaration of conformity should be provided to the market surveillance agency.

What information is required for the UK Declaration of Conformity?

The information required for the UK Declaration of Conformity is basically not different from that required for the current EU declaration of conformity. Different regulations may have different requirements, but they should generally include:

▪ Name and full office address of you or your authorized representative

▪ Product serial number, model or model identification

▪ Declare that you are fully responsible for the compliance of the product.

▪ Details of the accreditation body performing the conformity assessment procedure (if applicable)

▪ The relevant laws and regulations that the product complies with

▪ Your name and signature

▪ The date of the statement

▪ Supplementary information (if applicable)

What standards do you need to list in the UK Declaration of Conformity?

You need to list in the UK Declaration of Conformity:

▪ Related UK directives (non-EU directives)

▪ Relevant UK standards (standards not quoted in the Official Journal of the European Union)

Note: On January 1, 2021, the British Standards will be the same as those used by the European Union in terms of substance and reference. However, they will use the prefix “BS” to indicate that they are standards adopted by the British Standards Institution, the British National Standards Agency.