Compliance inSight Consulting Inc.

Since the UK left the EU on 2020-12-31, CE Mark­ing machines head­ing for instal­la­tion in the UK is in clos­ing days. For the dura­tion of 2021, machine builders can either CE Mark, or they can use the new UKCA Mark­ing (UKNI for prod­ucts going to North­ern Ire­land). The UKCA Mark­ing applies in Wales, Eng­land and Scotland. 

UKCA Marking, Compliance inSight Consulting Inc.
The UKCA Mark

The UKCA mark­ing applies to most goods pre­vi­ous­ly sub­ject to the CE mark­ing. It also applies to aerosol prod­ucts that pre­vi­ous­ly required the ‘reverse epsilon’ marking.

The tech­ni­cal require­ments (‘essen­tial require­ments’) you must meet – and the con­for­mi­ty assess­ment process­es and stan­dards that can be used to demon­strate con­for­mi­ty – are large­ly the same as they were for the CE marking.

The cir­cum­stances in which you can use self-dec­la­ra­tion of con­for­mi­ty for UKCA mark­ing are the same as for CE mark­ing. Check the list of areas where self-dec­la­ra­tion is per­mit­ted.

The UKCA mark­ing came into effect on 2021-01-01. How­ev­er, to allow busi­ness­es time to adjust to the new require­ments, you will still be able to use the CE mark­ing until 2022-01-01 in most cases.

In some cas­es, you need to apply the new UKCA mark­ing to goods being sold in Great Britain imme­di­ate­ly from 2021-01-01.

The CE mark­ing is only valid in Great Britain for areas where GB and EU rules remain the same. If the EU changes its rules and you CE mark your prod­uct on the basis of those new rules you will not be able to use the CE mark­ing to sell in Great Britain, even before 2021-12-31.

You only need to use the new UKCA mark­ing before 2022-01-01 if all of the fol­low­ing apply. Your product:

  • is for the mar­ket in Great Britain
  • is cov­ered by leg­is­la­tion which requires the UKCA marking
  • requires manda­to­ry third-par­ty con­for­mi­ty assessment
  • con­for­mi­ty assess­ment has been car­ried out by a UK con­for­mi­ty assess­ment body

This does not apply to exist­ing stock, for exam­ple, if your good was ful­ly man­u­fac­tured, CE marked and ready to place on the mar­ket before 2021-01-01. In these cas­es, your good can still be sold in Great Britain with a CE mark­ing even if cov­ered by a cer­tifi­cate of con­for­mi­ty issued by a UK body before 2021-01-01.

The UKCA Mark can­not be used for prod­ucts for sale in North­ern Ire­land. This is because the UK signed the North­ern Ire­land Pro­to­col with the EU so that North­ern Ire­land can con­tin­ue to be aligned with the EU in accor­dance with the Good Fri­day Agree­ment, and also with the UK.

Northern Ireland

The North­ern Ire­land Pro­to­col came into force on 2021-01-01. For as long as it is in force, North­ern Ire­land will align with rel­e­vant EU rules relat­ing to the plac­ing on the mar­ket of man­u­fac­tured goods.

Placing goods on the market in Northern Ireland

You need to use a con­for­mi­ty mark­ing if you are plac­ing cer­tain goods on the mar­ket to show they meet the rel­e­vant rules.

In North­ern Ire­land, EU con­for­mi­ty mark­ings con­tin­ue to be used to show goods meet EU rules. For most man­u­fac­tured goods, this is the CE mark­ing, but there are some oth­er mark­ings for spe­cif­ic products.

If you are using a UK body to car­ry out manda­to­ry third-par­ty con­for­mi­ty assess­ment you also need to apply a UKNI marking.

You nev­er apply the UKNI mark­ing on its own — it always accom­pa­nies an EU con­for­mi­ty marking.

The UK Mar­ket Con­for­mi­ty Assess­ment Bod­ies (UKMCAB) data­base lists all bod­ies which can pro­vide con­for­mi­ty assess­ment for the UK market.

Machin­ery is a new approach prod­uct, cov­ered by at least the fol­low­ing leg­is­la­tion. Addi­tion­al Directives/Regulations may apply.

Euro­pean UnionNorth­ern Ireland
Elec­tro­mag­net­ic Com­pat­i­bil­i­ty — Direc­tive 2014/30/EUElec­tro­mag­net­ic Com­pat­i­bil­i­ty Reg­u­la­tions 2016
Low Volt­age Direc­tive 2014/35Elec­tri­cal Equip­ment (Safe­ty) Reg­u­la­tions 2016
Safe­ty of Machin­ery 2006/42/ECSup­ply of Machin­ery (Safe­ty) Reg­u­la­tions 2008

Using the UKNI Mark

You need to use the UKNI mark­ing if all of the fol­low­ing apply:

  • you are plac­ing cer­tain goods (most­ly those goods sub­ject to the CE mark­ing) on the North­ern Ire­land market
  • your goods require manda­to­ry third-par­ty con­for­mi­ty assessment
  • you are plan­ning to use a UK body to car­ry out those con­for­mi­ty assessments

You will not be able to use the UKNI mark­ing if either of the fol­low­ing apply:

  • you are plac­ing goods on the mar­ket in the EU
  • you are plan­ning to use an EU body to car­ry out con­for­mi­ty assessments

If you are a man­u­fac­tur­er based in North­ern Ire­land (or the manufacturer’s autho­rised rep­re­sen­ta­tive) and you cur­rent­ly mark your goods on the basis of a supplier’s dec­la­ra­tion of con­for­mi­ty, you do not need to make any changes. Your goods con­tin­ue to be valid on the UK and EU mar­kets using the rel­e­vant con­for­mi­ty markings.

How to use the UKNI marking

Placing the UKNI marking

In most cas­es, you must apply the UKNI mark­ing to the prod­uct itself or to the pack­ag­ing. In some cas­es, it may be placed on the man­u­als or on oth­er sup­port­ing doc­u­ments. This will vary depend­ing on the spe­cif­ic reg­u­la­tions that apply to the product.

The fol­low­ing gen­er­al rules apply:

  • the UKNI mark­ing must only be placed on a prod­uct by you as the man­u­fac­tur­er or your autho­rised rep­re­sen­ta­tive (where allowed for in the rel­e­vant legislation)
  • when attach­ing the UKNI mark­ing to accom­pa­ny anoth­er con­for­mi­ty mark­ing, you take full respon­si­bil­i­ty for your product’s con­for­mi­ty with the require­ments of the rel­e­vant legislation
  • you must not place any mark­ing or sign that may mis­con­strue the mean­ing or form of the UKNI mark­ing to third parties
  • you must not attach oth­er mark­ings on the prod­uct which affect the vis­i­bil­i­ty, leg­i­bil­i­ty or mean­ing of the UKNI marking
  • the UKNI mark­ing can­not be placed on prod­ucts unless there is a spe­cif­ic require­ment to do so in the legislation
  • the UKNI mark­ing must accom­pa­ny anoth­er con­for­mi­ty mark­ing; it nev­er appears on a prod­uct alone

Rules for using the UKNI marking

You must make sure that:

  • if you reduce or enlarge the size of your mark­ing the let­ters form­ing the UKNI mark­ing must be in pro­por­tion to the ver­sion set out below
  • the UKNI mark­ing is at least 5mm in height – unless a dif­fer­ent min­i­mum dimen­sion is spec­i­fied in the rel­e­vant legislation
  • the UKNI mark­ing is eas­i­ly vis­i­ble, leg­i­ble, and per­ma­nent­ly attached
UKCA Marking, Compliance inSight Consulting Inc.

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