As we have already seen in this article, the UKCA (United Kingdom Conformity Assessed) is the new marking of the United Kingdom after leaving the European Union, and will replace the CE marking starting from 1 January 2023 required on goods placed on the market in Great Britain (England, Wales and Scotland).
The United Kingdom’s exit from the European Union, in fact, has imposed new ways of selling products and the import and export of goods, to ensure the safety of manufacturers and end users.
The mandatory conformity assessment, in fact, will also be required for products with the UKCA marking, as was already the case for products with the CE marking. The UKCA directives applied to Fandis products allow self-declaration: a third party conformity assessment is therefore not necessary, but in other cases mandatory.
But what are the steps to be taken to adapt to this new marking?
UKCA step by step
Determine the applicable legislation in the two markets
First of all, it is necessary to check which EC directives the respective UKCA correspond to: for Fandis products, for example, these are summarized in the table below.
Instead, the reference standards are the same for the CE marking, i.e. the UKCA marking has implemented the European harmonized standards EN for the time being.
|2006/42/EC Machinery Directive (MD)||S.I. 2008 No. 1597 Supply of Machinery (Safety) Regulations|
|2011/65/EU Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Directive (RoHS)||S.I. 2012 No. 3032 Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations|
|2014/30/EU Electromagnetic Compatibility Directive (EMC)||S.I. 2016 No.1091 Electromagnetic Compatibility Regulations|
|2014/35/EU Low Voltage Directive (LVD)||S.I. 2016 No. 1101 Electrical Equipment (Safety) Regulations|
Carry out a risk analysis
This operation is recommended by the guides on the subject, but since the UKCA reference standards are the transposition of the European ones for the CE marking, it is not necessary to carry out a further risk analysis, in all those cases in which it has already been done for CE marking.
If applicable legislation requires third party intervention during the UKCA compliance process, identify a Notified Body / UK Approved Body
The list of UK Approved Bodies is available at this link. However, even in this case, but only for certain product categories, a third party is not required to verify their compliance, but a self-certification process by the company itself is sufficient, as is the case with Fandis.
Identify the applicable standards for your product for the EU / designated standards for the United Kingdom
The UKCA reference standards are the same as those of the CE marking, but will be called designated standards.
Designed standards can be standards adopted by any of the recognized standardization bodies British Standards Institution (BSI), European Committee for Standardization (CEN), European Committee for Electrotechnical Standardization (CENELEC) and the European Telecommunication Standards Institute (ETSI) or by international standardization bodies (including the International Organization for Standardization (ISO), the International Electrotechnical Commission (IEC) and the International Telecommunications Union (ITU). For Fandis case they will be IEC, CEN, CENELEC and ISO.
Draw up the technical file which must contain the reports of the tests carried out on the product suitable for demonstrating its conformity to UKCA
Also in this case, the technical file has already been drawn up, as it coincides with that of the CE marking of the product, for the reasons referred to in the previous point. We only remind you that the file must be kept by the manufacturer or authorized representative (if permitted by law) for ten years following the placing of the product on the market.
Draw up two separate declarations of conformity, one for the EU and one for the UK
In this case, the two distinct declarations will be similar, they will differ in the references to the mark and to the directives (as shown above for the correspondences between EU and UK directives), while the references to the harmonized standards will be the same. Fandis intends to complete the drafting of the declarations of conformity on time, before January 2023.
Ensure mass production compliance and UKCA marking the product
The UKCA marking of the product must be consecutive to the preparation of the UKCA declarations of conformity for the product itself.
The UKCA marking came into effect on 1st January 2021, however, to allow businesses time to adjust to the new requirements, you will still be able to use the CE marking until 1st January 2023 in most cases. From 1st January 2023, on the other hand, it will become mandatory to affix the UKCA mark directly on the product. The labels of Fandis products, therefore, starting from January 2023, will show the UKCA mark along with the CE mark (in addition to the other marks, if any).