UKCA (UK Conformity Assessed) 英国合规性评估
According to the announcement issued by the British government, from January 1, 2021, the UKCA logo will be officially used on products. In the future, most products within the scope of CE control will need to supplement the UKCA mark when entering the UK. is a new British product mark for goods placed on the market in the United Kingdom (England, Wales and Scotland). It covers most goods that previously required CE marking, known as "New Approach" goods.
During the transition period from 2019 to 2020, the UK government has issued guidance to UK manufacturers on putting their products on the UK market and on the EU market if the UK leaves the EU without a deal.
The government has issued similar recommendations for medical devices and construction products.
What are the differences between CE marking and UKCA marking?
First of all, we need to know the basis of Brexit and what is UKCA?
UKCA（英国合规性评估）标志将是新的英国产品标识，如果英国在没有脱欧协议的情况下退出欧盟，仍然可以在投放英国市场的产品上使用 CE 标志。
If the UK leaves the EU without a deal in most cases you will still be able to use the CE marking for products being placed on the UK market.
It will not be recognised in the EU market.Products that need CE mark still need CE mark before they can be sold in the EU.
After Brexit, the EU's main product standards will be replaced by a new UK equivalent (UKCA logo), and travel and trade will continue during the transition without additional fees or cheques. However, at the end of the transition period, the UK will leave the EU market and customs union. The new UK Conformity Assessment (UKCA) legislation is expected to replace the European CE certification framework. The new product label used for goods sold in the UK market is the UKCA label.
In the future, trade between the UK and the EU will still exist, and the two will continue to trade as partners
After the launch of the official UKCA logo scheme on 1 January 2020, using a UK approved body (equivalent to the EU certification body in the UK), and only wishing to launch their products in the UK market will require registration of the UKCA logo.CE certificate in the UK will need to be replaced by UKCA before it can be imported into the UK market
Will the UKCA registration terms be similar to CE in the future?
Yes, the UKCA will accept the EN standard in the future.
In general, the registration process still depends on the CE system.
It should be noted that chemicals, pharmaceuticals, cosmetics and foods do not have the CE mark and may not need the UKCA mark in the future - these types of goods are covered by separate labelling requirements.
(Pay attention to Headway's official account to accept the latest information of testing certification in a timely manner)
There are some important differences between the UKCA and CE marks to note.
In the event of a no Deal Brexit, a copy of the statutory instrument amending the UK's product compliance regulations can be found here.
And products on the UK market can still use the CE mark.
The advice would only apply if The UK left the EU without a deal.
The provisions of any withdrawal agreement or future relationship shall be governed by these agreements.
It is still up to the future government to decide
Manufacturers using the UKCA should contact the BODY as soon as possible to find out about their post-Brexit plans or whether they are indeed better suited to using the UKCA mark
Manufacturers distributing through the EU supply chain should be aware that the economic operator status of that supply chain will change, which may require a change in packaging.
Machinery makers have also been warned that if they intend to launch their products on the EU market after a "no agreement Brexit", they should nominate someone responsible for preparing the technical documentation, which must be within the EU.
What should manufacturers pay attention to after Brexit?
After March 29, 2019, the following products will no longer be allowed to use eu norms and compliance marks in the UK market:
Automobile (Vehicle type certification);
Aerospace (Aviation safety);
Pharmaceutical products (batch test drugs;Drugs, medical devices and clinical trials;Further specification of drugs, medical devices and clinical trials;
5、 Regulatory information of medical products with price increases); Medical devices (drugs, medical devices and clinical trials; Submit regulatory information on medical products);
Chemicals (chemicals to be managed, classification, labelling and packaging of chemicals);
Articles controlled by national laws and regulations (non-coordinated articles).
The UKCA logo USES the following general rules:
The UKCA mark may only be affixed to the product as a manufacturer or its authorized representative (where permitted by applicable law);
When the UKCA logo is affixed, the manufacturer is fully responsible for compliance with the relevant regulatory requirements;
Manufacturers must use only the UKCA mark to demonstrate compliance with the relevant UK regulations;
The manufacturer shall not place any marks on third parties which may misunderstand the meaning or form of the UKCA mark;
The manufacturer shall not attach to the product other marks that affect the visibility, readability or meaning of the UKCA mark;
The UKCA logo cannot be placed on a product unless a specific requirement is made in legislation.
Rules for attaching UKCA logo images
1. The UKCA mark must be reduced or enlarged to a specified scale;
2. The height of the UKCA mark shall be at least 5mm, unless otherwise specified by relevant regulations;
3. The UKCA logo must be easy to recognize, clearly visible and of high durability.
Manufacturers or their authorized representatives must maintain technical documentation to prove that their products comply with regulatory requirements. Market surveillance or law enforcement agencies may request this information from the manufacturer at any time.
It can be supplied up to 10 years after the product is put on the market.
Record keeping requirements will vary according to the specific regulations applicable to the product and will generally be maintained as follows:
1. Product design and manufacturing records;
2. How to prove that the product meets the relevant requirements;
3. Address of manufacturer and any storage facilities.
The information shall be stored in a technical document which may be made available to the market watchdog.
UK declaration of conformity
The UK Statement of Compliance is a document developed for most products that legally use the UKCA logo.
In that document, the manufacturer or its authorized representative shall:
1. Declare that the product complies with the requirements of the relevant regulations applicable to the specific product;
2. Ensure that documents contain the name and address of the manufacturer or its authorized representative, as well as information about the product and conformity assessment body.
3. The manufacturer must provide the market watchdog with a STATEMENT of UK compliance upon request.
4. When using the CE mark, the manufacturer shall also prepare a declaration of COMPLIANCE with the EU.
My product has been sold in The UK and I have the CE certificate. How should I operate after that?
You will need to choose the path which meets your organization’s needs and you will need to choose one of these two options;
However, if your product requires a third party conformity assessment service to be provided by a notified body and the service is performed by a UK certification body, your CE mark will no longer be valid in the case of a "no trade".This is because UK certification bodies will no longer be recognised by the EU.
The IMPLEMENTATION of UKCA certification after Brexit
The IMPLEMENTATION of UKCA certification after Brexit
(1) The transfer of certification from a third-party designated institution of the 27 EU countries or from a third-party designated institution of the UK must be completed before the end of the Brexit transition period.
(2) Tests carried out by third-party designations in eu27 may be submitted to UK accreditation bodies for UKCA certification.
(3) In accordance with the UK Government's current guidelines, if your product applies to any of the following, then your product may still use the CE mark in the UK market for a limited period, which has not yet been determined, but the UK Government will give positive notice of the termination of this period.
(4) Details of the test requirements have not been specified, but it is expected that the test requirements will reflect or be very similar to the current CE mark test requirements.
Both the CE mark test and the UKCA mark test (EN standard) can be performed, and the EN standard will apply to the UKCA mark.
(5) As the UK has not enacted legislation to implement the UKCA logo before its formal withdrawal from the EU on 31 December 2020, the UKCA logo cannot be used or placed on products before 1 January 2021.
Products bearing the CE mark will be recognised in the UK market for a limited period from 1 January 2021.
Once the UK leaves the EU, manufacturers will be told they have an obligation to put the UKCA mark on their products and that the CE mark will be recognised for a limited period.
(6) The same product can display more than one conformity mark (including CE and UKCA), so as to enter the global market.
It is common for the same product to be labeled with multiple compliance marks for different markets.
(7) Just like THE CE mark, once the UKCA mark is enacted and implemented in the UK, relevant detailed rules need to be observed to add the mark of conformity on the product label, packaging and in the instruction manual.
(8) The United Kingdom is a recognized IECEE/IECEx CB reporting and certification country/accreditation country. Therefore, CB certification is not affected by Brexit.
(9) As of 2016, all products conforming to low voltage instruction (LVD) are self-declared products.
The UK has adopted the directive and the directive will apply to the UK market.
The only difference is that the UKCA mark for UK market access will be used instead of the CE mark for the European market.
The UK will recognise the CE mark for a limited period of time after it formally leaves the EU on 1 January 2021.
(10) Test reports of LVD, EMC, RoHS and WEEE that have been CE certified do not need to be re-tested or reviewed.
For products that have already made their own declaration, the manufacturer will need to draw up a declaration of compliance before marking the UKCA logo.
(11) The same technical document may be used simultaneously to obtain the UKCA bid