UKCA Marking Guide for Post-Brexit Shipping to Great Britain
Overview of UKCA Marking
The UKCA (UK Conformity Assessed) marking is a mandatory conformity mark for goods sold in Great Britain (England, Scotland, and Wales) post-Brexit. It indicates that a product meets UK regulations. Below is a detailed guide to help businesses comply with UKCA marking requirements.
UKCA Marking Dimensions and Placement Requirements
- Minimum Size: The UKCA marking must be at least 5mm in height unless specific legislation specifies a different minimum dimension.
- Visibility and Legibility: The marking must be clear, visible, and legible. It cannot be obscured or distorted by other markings.
- Placement: Ideally, the UKCA marking should be affixed directly to the product. If the product is too small, it can be placed on the packaging or accompanying documentation. However, the marking must be permanently attached to the product in accordance with relevant legislative requirements starting January 1, 2023.
- Prohibited Uses: The UKCA marking cannot be used on products intended for sale in the EU. Additionally, no other markings or signs that may mislead third parties about the meaning or form of the UKCA marking should be placed on the product.
Transition Period Compliance Solutions (Before 2025)
- Extended Transitional Measures: Until December 31, 2025, businesses can continue to use the CE marking for goods sold in Great Britain. However, the UKCA marking is mandatory for certain high-risk products.
- Labeling Flexibility: Until January 1, 2023, the UKCA marking could be placed on a label attached to the product or on accompanying documentation. Starting January 1, 2023, for most goods, the marking must be permanently attached to the product. However, the UK government plans to extend this deadline to December 31, 2025.
Steps to Obtain UKCA Certification
- Identify Applicable Regulations: Determine the UK regulations and standards applicable to your product. These largely reflect pre-Brexit EU directives and regulations, though some UK-specific changes may apply.
- Conduct Conformity Assessment: Depending on the product type, conformity assessments may involve testing by a UK-approved notified body. Manufacturers can self-declare conformity for many products, but high-risk items (e.g., medical devices) require third-party assessment.
- Prepare Technical Documentation: Compile a technical file containing evidence that the product meets UK regulations. This typically includes product design and manufacturing details, risk assessments, conformity test results, certificates, test reports (if applicable), instructions, and safety information.
- Create a UK Declaration of Conformity (DoC): Issue a UK DoC stating that the product complies with relevant regulations and standards. The DoC must include the manufacturer’s (or authorized representative’s) name and address, product identification details, a statement of responsibility for compliance, information about the conformity assessment body (if applicable), and the relevant legislation.
- Affix the UKCA Marking: Once conformity is confirmed, apply the UKCA marking to the product, packaging, or documentation as required.
Roles and Responsibilities of Importers and Sellers
- Importer Responsibilities: Importers must ensure that imported products comply with UKCA requirements. This includes verifying that the products bear the UKCA marking, reviewing technical documentation and conformity declarations, and confirming that the manufacturer has appointed a UK-based authorized representative (if required).
- Seller Responsibilities: Sellers must ensure that products on the market meet UKCA requirements. They must also retain relevant documentation, such as conformity declarations and technical files, for at least 10 years.
Key Dates for UKCA Compliance
- January 1, 2021: The UKCA marking became effective. However, businesses were permitted to use the CE marking for most products until December 31, 2024.
- January 1, 2023: For most goods, the UKCA marking must be permanently attached to the product.
- January 1, 2025: After this date, only the UKCA marking will be accepted for products sold in Great Britain. The CE marking will no longer be recognized.
North Ireland Special Requirements
- Continued Use of CE Marking: Products sold in North Ireland must continue to comply with EU regulations and bear the CE marking. The address on the CE marking must be that of an EU, EEA, or North Ireland entity.
- CE&UKNI Marking Option: For products requiring third-party conformity assessments, businesses can choose to use the CE&UKNI marking. However, the CE&UKNI marking is not valid in the EU.
UKCA Certification Process Checklist
- Determine Applicable Regulations: Check which UK regulations apply to your product.
- Prepare Technical Documentation: Compile all necessary technical files.
- Select a UK Notified Body: If third-party conformity assessment is required, choose a UK-approved notified body from the UKMCAB database.
- Draft the UK Declaration of Conformity: Ensure the DoC includes all required information.
- Affix the UKCA Marking: Apply the marking to the product, packaging, or documentation as specified.