Is your product compliance up to date? Get ready for the UKCA Mark & make sure your CE marking is correct
As you may be aware, on 24th August 2021, the UK Government announced a 12-month extension to the date ending the recognition of the CE Mark for the GB market.
With this extension in place, goods that are CE marked can now continue to be placed on the GB market until the 1st January 2023. The exception for medical devices remains in place, with CE marked products being accepted until the 1st July 2023.
From the 1st January 2023, the UKCA mark will become mandatory. It’s also important to note that the CE Mark will only continue to be valid for the GB market whilst UK and EU rules remain the same. If the rules do diverge, CE marking will no longer be valid. It’s not clear what would happen in this situation, so it is essential that your products are UKCA marked at the earliest opportunity.
UKCA marking has sometimes appeared to be shrouded in a bit of mystery aided by some clumsy early official statements written by someone who didn’t understand the difference between Notified (Approved) Bodies and test laboratories, and that not all EU Directives (UK Regulations) needed the use of the former.
In fact, for the vast majority of products, the manufacturer makes the Declaration of Conformity themselves, often based on the results obtained from a test laboratory. This point has been lost in some recent media coverage, which has focussed on the lack of availability of UK Approved Bodies as the basis for the extension.
What’s the future for the UKCA mark?
The UK Government has stated that it remains committed to the UKCA Mark and that business should transition to the UKCA mark as soon as possible, ensuring they have enough time to complete the process before the new 2023 deadline.
This date is described as “…the final deadline…” and so if you have already started the process of UKCA marking your products, we’d recommend that you continue to do so.
If you’ve not started the process of UKCA marking your products, now is the time to review your current product certification, ensure that it is up-to-date and correct and start the work towards adding the UKCA mark to your product.
If you’re going to use CE marking as the basis for your UKCA mark, is it all correct and up-to-date?
Given that there is alignment between EU Directives and UK Regulations and we are using the same standards, then the act of adding UKCA Marking for a product where the manufacturer can make the declaration of conformity without third-party assessment should be very straight forwards.
Essentially take the EU DoC, change the references and hey presto!
But those manufacturers who have scratched a little more below the compliance surface have, in many cases, found themselves opening Pandora’s Box.
Having started with the assumption that the product was properly CE Marked, and therefore adding the UKCA mark was a paperwork exercise, this presumption often quickly unravels.
In many cases that we’ve seen, the EU DoC is incorrect, it doesn’t have the correct information, the product isn’t correctly described, and the standards are out of date. Now transferring that information to a UK DoC adds another invalid DoC for the product.
Why is this important? The increased market surveillance introduced with the implementation of the EU Goods Package will mean that there is even more scrutiny on product compliance, especially for products placed on the EU market from third countries.
It’s also essential to be able to provide accurate and correct information to importers or authorised representatives or distributors (whoever is placing your product onto the market) as they are taking on the responsibility that those roles demand, one of which is ensuring that the product meets the requirements of any relevant EU Directives or UK Legislation. The Declaration of Conformity and supporting Technical File are vital parts of this and so must be correct.
How Eurofins E&E can help
To help you ensure that your product is compliant, both technically and in terms of the administrative part (the bit that is most often wrong!), we’ve introduced our Compliance Support service.
Delivered by the Expert Services team within Eurofins E&E UK, this service can encompass almost any aspect of product compliance, including:
- Compliance reviews for existing products
- Gap analysis when you add new functions, such as wireless capability, to an existing product
- Documentation reviews including CE DoC’s, Technical Files etc
- Standards monitoring so you’re always up-to-date
- Compliance strategies for your future products
- On-going compliance support
This service can be built around what you need and can be as simple as a review of a DoC through to an in-depth review of an entire product range, covering both the technical and administrative aspects of product compliance. Whatever you need, Compliance Support can help.
To find out more about Compliance Support, click here.
Download our updated UKCA guide
We’ve updated our UKCA guide to version 1.6 to reflect these changes, and we will shortly be holding a webinar to cover these changes and others, such as the introduction of the EU Goods Package.
Do you have any questions about the UKCA Mark or product complance?
If you need any more information or assistance with any aspects of product testing, certification or compliance, get in touch and we can help you get your products to market, on-time and on-budget.