As the deadline for transition from CE to UKCA marking approaches, and in response to continuous industry pressure over capacity and capability, there has been an announcement from the Government regarding some provisions that have been agreed to simplify UKCA marking for products in England, Scotland and Wales.
The full guidance from the Government can be found here, but the principal changes of interest as they relate to construction products are summarised below.
Spares – The UK will continue to accept spares onto the GB market to repair, replace and maintain products to the same conformity requirements in place at the time the original product or system was placed on the GB market.
- Businesses will need documentary evidence to demonstrate the intended use of a product as a spare part.
- This applies to products in stock as spares before the deadline. FIS is seeking further clarity on whether any nuance exists for construction products after the deadline.
Imported Goods – Existing CE marked stock imported into GB under contract before the end of 2022 will not need re-testing and re-marking.
- Products imported into GB for further manufacture or processing, will not be considered as placed on the market.
- FIS is seeking further clarity on the definition of “further manufacture or processing”.
Re-Testing Costs – Manufacturers whose products are tested under AVCP System 3 by an EU notified body before 31 December 2022 can use this evidence to obtain a UKCA mark without having to retest through a UK approved body.
- All new testing after this date must be done through a UK approved body.
Reduce Re-Testing Costs – The UK will allow certificates provided by non-UK conformity assessment bodies (CABs) issued before the end of this year to be used as a basis for UKCA marking certification.
- The goods must still bear the UKCA marking, and will need to undergo conformity assessment with a UK Approved Body at the expiry of the certificate or after 5 years (whichever is sooner).
There is no clarification at this time if the EU intends to mirror any of these simplification measures, so it is assumed that there are no relaxations on the use of EU notified bodies and/or CE marking goods that are being sent to the EU.
Please take some time to review how this will impact your businesses and let us know what outstanding questions or inconsistencies remain so that we can feed these back to Government.
FIS has created how-to guidance for its members which can be Conformity Marking – how-to guidance.