Introduction
The UKCA mark (UK Conformity Assessment) was brought in by the UK government to replace the CE mark post Brexit. However, with pushback from industry and ongoing consultation with business owners, the government has delayed and delayed the enforcement of its implementation.
As of 1st August 2023, the government has laid out its intentions to extend recognition of the CE marking for placing goods on the market in Great Britain, indefinitely, beyond the last deadline of December 2024. Does this therefore signify the end of the UKCA mark?
A brief history of CE marking recognition in the UK
- 22nd July 1993
- CE marking came into effect.
- 1st January 2021
- UKCA mark came into force. Intending to become mandatory for most products from 1st January 2023, during this period use of the CE mark was still to be recognised.
- 14th November 2022
- Recognition of the CE mark was extended to 31st December 2024.
- 1st August 2023
- Recognition of the CE mark was extended indefinitely beyond to December 2024 for particular products.
UKCA vs CE, what's the difference?
As of August 2023, there are only minor differences between the CE and UKCA conformity assessments. The initial implementation has focused on the rebranding of conformity assessments; affixing the UKCA mark to products placed on the Great Britain market, rather than the CE mark.
However, there are differences in the conformity assessment requirements for particular products. These include:
- Medical devices.
- Construction products.
- Cable ways.
- Transportable pressure equipment.
- Unmanned aircraft systems.
- Rail products.
- Marine equipment.
- Eco-design.
UKCA or CE mark flowchart
Cenheard has created the below flowchart as a simple guide to help manufacturers determine whether a CE mark or UKCA conformity assessment should be completed, depending on which market the product is going to be placed:
UKCA and Northern Ireland
Northern Ireland is the only country in Great Britain which shares a border with an EU member state; the republic of Ireland. This has been a major sticking point for Brexit negotiators. As a result, a special certification has been created to try and bridge the gaps between the two economies – the UKNI mark.
On 1st January 2021, the Northern Ireland protocol came into effect. This allows Northern Ireland to align with all relevant EU rules relating to placing products on their market. The UKNI mark is for products placed on the Northern Ireland market which have undergone a mandatory third-party conformity assessment, completed by a body based in the UK.
While the UKCA mark is in turbulent times, it’s likely the CE and UKNI mark will still be seen side by side for the majority of products placed on the Northern Ireland market.
The future of UKCA marking
At the time of writing, the UK government is laying out a plan for the implementation of future regulations. Their focus being the re-writing of, or total removal of, EU led legislation in UK law.
Transition arrangements are being put into place, along with post-market surveillance requirements to enforce new / amended legislation.
The picture is still unclear, however this is to be expected; EU led legislation has been embedded into UK law for over 40 years. The changes that are required are not be underestimated. If done with a steadfast British attitude, there are numerous opportunities. How the changes may alienate the British economy are yet to be seen, and so too are the global opportunities.
How such post-Brexit changes will impact the British economy will be closely observed by the entire world, this could go either way – will Britain exemplify itself once again as shining example of doing things properly, or will this all come crashing down. Watch this space as we wish for the best outcome for all.