UKCA mark - CE marking UK product post-BREXIT

[fcb]

Lovely. 

Yesterday the British Gov withdrew the UKCA mark guidance paper. https://www.gov.uk/guidance/prepare-to-use-the-ukca-mark-after-brexit

[GromBeestje]

That's what I've been expecting

[AndyC_772]

It's the uncertainty that's so damaging 

I don't recall anyone suggesting that the CE marking regime was, or is, broken. Common technical standards and markings are in everyone's best interests, especially when there's nothing in them that's politically charged or controversial.

[Monkeh]

It's the uncertainty that's so damaging 

I don't recall anyone suggesting that the CE marking regime was, or is, broken. Common technical standards and markings are in everyone's best interests, especially when there's nothing in them that's politically charged or controversial.

Self-certification with little to no verification is pretty broken. But UKCA is.. exactly the same bollocks and just another logo to try and jam on a label. Despite all attempts to claim to the contrary, the same standards will be applicable to goods post-brexit.

[m98]

Self-certification with little to no verification is pretty broken.

Don't beg for even more bureaucracy than there already is.
And don't think that any amount of regulation is going to affect the anonymous chinese companies who ship their dangerous shit via their european warehouses.

[fcb]

The weird or perhaps wonderful (if you're a testing lab), is that the UKCA is/was only applicable if ALL of the following is required:

1. is for the UK market
2. requires mandatory third-party conformity assessment
3. conformity assessment has been carried out by a UK conformity assessment body (a UK based notified body, recognised third party organisations or user inspectorate - referred to collectively as UK notified bodies)

Which makes it either a bit FCC (but without the magic number for verification), but defintley not the equivalent of the CE.  So one wonders if the idea is to force everything through UKCA (never going to happen) OR have some lesser style of mark (UKCE?) OR just keep alignment with the EU and use CE (without any input from the UK into EU rules).

Oh well. I didn't vote to leave the EU, and come 2300hrs tonight I'll be well oiled on a bottle or two of some excellent European produce to mark this moment of collective UK stupidity.

[Monkeh]

The weird or perhaps wonderful (if you're a testing lab), is that the UKCA is/was only applicable if ALL of the following is required:

1. is for the UK market
2. requires mandatory third-party conformity assessment
3. conformity assessment has been carried out by a UK conformity assessment body (a UK based notified body, recognised third party organisations or user inspectorate - referred to collectively as UK notified bodies)

Which makes it either a bit FCC (but without the magic number for verification), but defintley not the equivalent of the CE.  So one wonders if the idea is to force everything through UKCA (never going to happen) OR have some lesser style of mark (UKCE?) OR just keep alignment with the EU and use CE (without any input from the UK into EU rules).

Oh, mandatory third party.. so basically we'd end up without any conformity marking at all in many cases?

This whole situation is just depressing.

[Mangozac]

Self-certification with little to no verification is pretty broken.

Don't beg for even more bureaucracy than there already is.
And don't think that any amount of regulation is going to affect the anonymous chinese companies who ship their dangerous shit via their european warehouses.

Yeah here in Australia pretty much all household electrical items need to be certified by a notifying body after testing by an approved lab. This is an extremely expensive process and mostly just penalises honest local manufacturers. There is still so much of the low quality, unsafe Chinese stuff coming in, especially through eBay. I remember once "educating" a friend as to why it might not be a good idea to buy a $1(delivered!) charger for their $1000 iPhone!

[nuclearcat]

I think it is worth to bring old topic, since there is update in podcast from Macrofab:
https://macrofab.com/blog/mep-ep247-to-bake-an-apple-pie/?utm_campaign=Podcasts&utm_content=143518515&utm_medium=social&utm_source=twitter&hss_channel=tw-1890756841

New regulatory mark to make things easier…
Goes into affect 1 January 2021
The UKCA marking can be used from 1 January 2021. However, to allow businesses time to adjust to the new requirements, you will still be able to use the CE marking until 1 January 2022 in most cases.
The UKCA marking alone cannot be used for goods placed on the Northern Ireland market, which require the CE marking or UK(NI) marking.

https://www.gov.uk/guidance/using-the-ukca-mark-from-1-january-2021

When to use the UKCA marking
You will need to use the new UKCA marking immediately after 1 January 2021 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 and you haven’t transferred your conformity assessment files from your UK body to an EU recognised body before 1 January 2021
This does not apply to existing stock, for example if your good was fully manufactured and ready to place on the market before 1 January 2021. 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.

From all i am reading, it might be major issue for many UK businesses.

[48X24X48X]

Few months back was trying to get a product UKCA certified but the testing lab said they don't have any rules and guidance on it yet. So, only CE is available. So, we went on with CE instead. That was lucky.

[fcb]

Finishing a 'consumer' orientated product at the moment for launch in mid-Nov, we've just opted to put both UKCA and CE on the bottom label.

I suspect that any UK based firm likely to read this forum would do the same unless you only sell to the UK or only sell to the EU.

CE and UKCA rules are unlikely to deviate when it comes to things that matter to us.

[TimCambridge]

Go UKCA - the UK Cinema Association needs your support while the virus rages.

[themadhippy]

Am i reading this correct that you need to transfer your files that were carried out by a uk body to an eu body to comply with the ukca or get a retest?

conformity assessment has been carried out by a UK conformity assessment body and you haven’t transferred your conformity assessment files from your UK body to an EU recognised body before 1 January 2021

and the point of brexit again?

[olkipukki]

I suspect that any UK based firm likely to read this forum would do the same unless you only sell to the UK or only sell to the EU.

UK is not GB  , so you need both (CE & UKCA)* anyway for UK 

UKCA (UK Conformity Assessed) marking is a new UK product marking that will be used for goods being placed on the market in Great Britain

The UKCA marking alone cannot be used for goods placed on the Northern Ireland market, which require the CE marking or UK(NI) marking

*edit: or special UK(NI) 

[fcb]

Am i reading this correct that you need to transfer your files that were carried out by a uk body to an eu body to comply with the ukca or get a retest?

conformity assessment has been carried out by a UK conformity assessment body and you haven’t transferred your conformity assessment files from your UK body to an EU recognised body before 1 January 2021

and the point of brexit again?

Of course this is a cluster-f**k - however everyone I've spoken to this is being pragmatic and just carrying on as normal. It'll only get resolved properly when there's a court-case in XX years time.

No comment Olkipukki on the UK/GB+NI differences 

[coppice]

It's the uncertainty that's so damaging 
I don't recall anyone suggesting that the CE marking regime was, or is, broken. Common technical standards and markings are in everyone's best interests, especially when there's nothing in them that's politically charged or controversial.

Self-certification with little to no verification is pretty broken. But UKCA is.. exactly the same bollocks and just another logo to try and jam on a label. Despite all attempts to claim to the contrary, the same standards will be applicable to goods post-brexit.

Yep, CE is a farce. People want the CE mark on their final products, so it goes into the design at the earliest prototype stage, and every single thing they ever make carries that mark. It means nothing in practice.

[langwadt]

Self-certification with little to no verification is pretty broken.

Don't beg for even more bureaucracy than there already is.
And don't think that any amount of regulation is going to affect the anonymous chinese companies who ship their dangerous shit via their european warehouses.

sure the big European companies would love if they could keep the anonymous chinese companies out with tax paid enforcement and at the same time
bury any small upcoming european companies in bureaucracy

[Smallsmt]

The UKCA marking will not be recognised on the EU market. Products currently requiring a CE marking will still need a CE marking for sale in the EU from 1 January 2021.

The british government is crazy this will prevent a lot of EU manufacturers to sell on UK market.

But how do they deal with automotive testing for newly developed cars that could not be sold in the EU without technical approval.
Even medical products need a new approval!

On 1 January 2021 the UK standards will be the same in substance and with the same reference as the standards used in the EU. However, they will use the prefix ‘BS’ to indicate that they are standards adopted by the British Standards Institution as the UK’s national standards body.

Why have they not accepted the parallel CE approval.

It will rise development costs.

This reminds me of another person "Make UK great again!" 

The hope that everything will come to a good end has unfortunately not been confirmed and our English friends will still feel the effects of this.
Unfortunately only after it is too late.
We hope the best for Uk people.

[wilhe_jo]

Accepting CE includes accepting all CE directives... i guess that would not really support the idea of the brexit.

73

[Mangozac]

"Let's force our manufacturing industry to have to apply yet another certification system and bear all of the costs that go with it. That will really show those EU punks who is superior!"

[fcb]

Likely that the UK will only diverge from the EU CE standards in only a few places where it makes sense to have different standards.

I don't think any of these are will affect electronic goods that 'we' are likely to involved with, with the possible exception of automotive (EV charging installation? also we drive on the opposite side to the bulk of the EU).

From what I heard the other day the big differences will be to do with agriculture, fishing, animal welfare and similar. Stuff like banning catches caught by electro-fishing, free-range labelling, import/export of live animals, etc.. Radio4 mentioned that fishing is 0.1% of the UK economy, but 1% of the EU's - and the UK has way more that 1% of the fishable waters - so reckon that'll be good for a few dust-ups.

Certainly EU manufacturers will eventually have to add the UKCA mark on their products if they want to export to the UK - someone will make a couple of quid out of printing UKCA stickers as a stop gap.

[Neilm]

Likely that the UK will only diverge from the EU CE standards in only a few places where it makes sense to have different standards.

I am guessing the UK will adopt IEC standards soon after they are published. The EU has decided to run all the new standards through some lawyers who are making an absolute fortune. From what I hear, they come back with loads of changes to the standard that are going to renderthey pretty usless.  I know that there are parts of 61010 that are waiting for publication for over 2 years now.

[Mangozac]

From what I hear, they come back with loads of changes to the standard that are going to renderthey pretty usless.  I know that there are parts of 61010 that are waiting for publication for over 2 years now.

Or as with the Australian versions of IEC standards they come back with just one small change that still requires half of the testing to be repeated. As I've alluded to earlier, all this does is penalise responsible manufacturers and importers.

[fcb]

"The nice thing about standards is that you have so many to choose from." - Andrew S. Tanenbaum

The rest of the quote is darkly applicable in this case as well: "The nice thing about standards is that there are so many of them. If you don't like one, just wait for next years model."

[olkipukki]

No comment Olkipukki on the UK/GB+NI differences 

No worries, but would suggest to start the reading of "Market Surveillance Regulation (EU) 2019/1020" if you still want to sell your CE marked products directly in EU