Insight

Earlier this year the UK government announced an extension to the CE Marking deadline so that it would continue to be accepted in Great Britain until the end of 2022, at which point products will require UKCA Marking. Here, Alex Lubbock, global construction practice director at BSI (The British Standards Institution) discusses everything fastener manufacturers need to know about UKCA Marking.

The UKCA Mark, which has been valid since 1^st January 2021, will be the only route to market for regulated products in Great Britain (England, Wales and Scotland) from the 1^st January 2023. The UKCA Marks placed into the Great British market will act much like their predecessors, the CE Marks. The UKCA Mark indicates conformity with legislative requirements and is placed on products to declare they are safe and comply with essential health and safety characteristics. It’s objective is to ensure there is no reduction in product safety, accuracy, or consumer protections, due to BREXIT and aims to ensure the effectiveness of the current legislative framework is maintained. 

Manufacturers should take steps now and prioritise the application of this legislative requirement. From 1^st January 2023, the CE Mark will no longer be recognised by the Great British market and manufacturers will need to apply the UKCA Mark to any products they intend to place on the market.

This may seem like an adequate length of time before manufacturers need to approach Approved Bodies and apply for the UKCA Mark. However, there are significantly less Approved Bodies for UKCA Marking and this increases the risk of long lead times and delays in 2022. 

This year we have all experienced backlog and disruption to transport and supply routes due to Covid-19, the Suez Canal shipping incident and leaving the EU. These issues have resulted in difficulty reaching clearance at UK borders and this is something BSI is keen to help the industry avoid next year. We strongly advise manufacturers and importers to get prepared early for UKCA by speaking to BSI to avoid disruption to supply chains and loss of confidence amongst consumers.

There are over four hundred and forty designated standards under the Construction Product Regulation alone to which UKCA applies. Determining how to apply UKCA Marking is also very important. The intended purpose of the product and the annex to the standard you wish to test or certify against hold the key. Products such as construction materials, toys, personal protective equipment, gas appliances, and pressure vessels, all have their standards reviewed regularly, as a result of regulations in these areas. 

The BSI website and Gov.UK are great sources of information to find out whether your product falls under regulation or outside it. With the Building Safety Bill being put before the UK parliament in 2022, there is likely to be an increasing requirement on manufacturers to demonstrate conformity and accuracy of what is placed on the market. 

Having knowledge of compliance and making Declarations of Conformity will help protect from disruption. Proper training courses can also help navigate the relevant rules and regulations. As an Approved Body, BSI can support organisations and ensure that appropriate testing and certification is provided. 

Applying for UKCA certification

To apply for UKCA certification and for it to be processed without delays, an application must contain all of the necessary documents. If you do not already have CE certification with BSI, you will need to supply a technical file containing a contents list; revision history; product description – such as GA drawings, component drawings; materials and intended use; details of the organisation; risk assessment/compliance with Essential Safety Requirements (ESR); product type test reports; as well as user information. 

It is also beneficial to include product marking and draft Declaration of Conformity. We also ask our clients to complete an application form to ensure that the scope of our certification will be right from the outset. Clear guidance documents are provided to clients with each application to make the process smoother.

Failure to supply complete documentation can lead to considerable delays. Approved Bodies may be unable to make a positive UKCA certification recommendation without a complete set of documents demonstrating conformity. The volume of applications and work for UKCA will likely result in a lead time for manufacturers, so the earlier documents are submitted, the better. BSI helps manufacturers avoid applications being delayed and this is why we are sharing this information. 

To make this easier, we’ve provided guidance documents showing new applicants how to put together a technical file. We have a quick and simple process for our existing CE certificate holders to gain UKCA certification, so they won’t have to worry about resubmitting a technical file.

What about the EU market?

BSI is well placed to assist manufacturers who require CE Marking, as well as a number of other global market access marks. BSI will continue to offer CE Marking services for EU27 market access via our Netherlands Notified Body (2797), as well as many other global market access solutions.

However, time is very short and there are examples, such as insulated glass unit testing, which is taking up to five months. Therefore, any delay in conducting testing could result in products being placed on the market without the required supporting documents or even not being placed on the market at all, which could lead to negative consequences for both consumers and manufacturers.

We have seen a lot of interest from European manufacturers who appear to be taking appropriate action and having their products tested ready for the end of the deadline next year. However, UK manufacturers who have previously worked with EU Notified Bodies are perhaps not fully aware of the consequences.

As one of the UK’s leading Approved Bodies, BSI can guide manufacturers through the process to achieve UKCA Marking, explain the new requirements and provide solutions. We can also help with the complexities of supplying to and from Northern Ireland where there are further nuances related to the changes coming into force.

UKCA is also not the only option for conformity within the UK. Where a product falls outside of the designated standards under the Construction Product Regulation, you might wish to consider a global voluntary mark like Kitemark™. The BSI Kitemark™ is the most recognisable mark of its kind in the UK and working with the BSI Kitemark brand brings more than access, it is also a differentiation as a manufacturer to customers who trust in the BSI brand.