The Locksmith Journal Jul/Aug 2022 - Issue 81 | Page 26

HARDWARE & SECURITY

CE to UKCA Marking Transition

Key information from the GAI

» THE DEADLINE OF 1ST JANUARY 2023 for construction products with only the CE marking no longer being accepted in Great Britain ( England , Scotland and Wales ) is fast approaching , therefore Guild of Architectural Ironmongers ’ ( GAI ) Technical Manager , Douglas Masterson , has prepared a list of frequently asked questions ( FAQs ) to help you navigate the transition .
The 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 ( England , Wales and Scotland ). It covers most goods which previously required the CE marking .
The UKCA marking cannot be used for goods placed on the Northern Ireland market , which require the CE marking or UKNI marking which must be accompanied by the CE Mark .
Your product will need UKCA Certification from 1st January 2023 onwards under the following conditions :
• It is for the market in Great Britain ( therefore not Northern Ireland )
• It is covered by legislation which requires the UKCA marking such as the UK Construction Product Regulation 2020 or European Machinery Directive through Supply of Machinery ( Safety ) Regulations 2008
• It requires mandatory third-party conformity assessment
• It is within the scope of a UK designated standard
Who can issue UKCA Certification ?
UKCA Marking can only be issued using a UK-recognised “ Approved Body ” for third party conformity assessment . The guidelines outlining how to meet UKCA Certification requirements can be seen in the relevant designated standard for that product group . What responsibilities must be met by the manufacturer , and the necessary level of involvement from an Approved Body , depends on the level of Attestation and Constancy of Performance ( AVCP ) the product complies with .
Under AVCP System 1 , which is the most common level in the hardware industry , a UK Approved Body must take responsibility for inspecting and ensuring continued compliance with satisfactory Factory Production Controls . The fire test data may come from either an EU Notified or UK Approved Body . However , the acceptance of this data for UKCA Certification will be dependent on the decision by the UK Approved Body which will be issuing the UKCA Certification .
Will the recent UK Government announcement on relaxations to UKCA Marking affect construction products ?
The UK Government recently announced it is making changes and relaxations to the rules on UKCA marking but be aware that this announcement does not specifically refer to construction products . It relates primarily to UKCA marked products covered under the Assessment and Verification of Constancy of Performance ( AVCP ) system 3 , such as radiators , sealants , and tile adhesives . It ’ s also important to note , products using the CE / UKCA marking in the ironmongery and security sector are within the scope of harmonised / designated standards and fall within AVCP system 1 . This means they require approval from a UK body , and the existing guidance will continue to apply .
All this means this Government announcement is unfortunately largely irrelevant to the ironmongery and security
industry . So , as it currently stands CE marking will no longer be accepted in Great Britain from 1st January 2023 , unless the goods have already been placed on the market prior to that date . After this the product will require UKCA marking .
What are the rules and regulations regarding branding of products for UKCA and CE marking ?
The labelling of the product necessary to meet UKCA & CE Marking schemes is outlined in the applicable harmonised and designated standards . If both CE & UKCA Marking is being applied , then separate labels with a full set of information on each label must be included .
In addition , separate Declaration of Conformity and Declaration of Performance documents must be supplied for UKCA & CE Marking respectively . Specific DoP Templates for both are available for GAI members on the GAI website .
When attaching UKCA labels and markings the relevant UK legislation must be referenced .
• UKCA markings 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 UKCA marking , the manufacturer takes full responsibility for your product ’ s conformity with the requirements of the relevant legislation
Can I still use CE marked products in Great Britain ?
From 1 January 2023 , CE marking will not be recognised in Great Britain . However , a product bearing the CE
‘ The UKCA marking cannot be used for goods placed on the Northern Ireland market ’
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