The Locksmith Journal Jul/Aug 2022 - Issue 81 | Page 27

HARDWARE & SECURITY marking would still be valid for sale in the UK so long as it was also UKCA marked and complied with the relevant UK rules . Products currently requiring a CE marking will still need a CE marking for sale in the EU from 1 January 2021 .
Is UKCA Certification recognised in the EU ?
No . The UKCA marking is not recognised on the EU market . Products need a CE marking for sale in the EU .
Is CE Certification still recognised in the UK ?
CE Certification is still recognised within the UK until the 1st January 2023 . After this CE Certification will hold no validity in Great Britain , however , will still be recognised in Northern Ireland .
Is dual conformity marking permitted ?
Dual marking is permitted ; therefore , a product can be placed on any of the relevant markets providing the relevant mark is affixed . The only exception to this is the combination of CE and CE + UKNI marking . Each marking will require its own DoP , certificate of Assessment of Performance as applicable ) and supporting documentation .
Do I need to test twice to gain CE & UKCA Certification ?
If you require both CE and UKCA Certification then you will need to follow the appropriate guidance in the harmonised and designated standards which outlines the appropriate tests required .
Should you be Certificating under AVCP System 3 then you will need to obtain test reports from an EU Notified Body for CE Marking and test reports from a UK Approved Body for UKCA and / or CE + UKNI Marking .
Can we sell our products into Northern Ireland with the UKCA mark ?
No – the two options are CE or CE + UKNI .
If the product is only marketed into the EU and Northern Ireland , then CE Marking will be sufficient . CE marking will still be acceptable in NI as under the Northern Ireland Protocol , NI currently remains part of the European Single market .
If the product is only marketed into Great Britain and Northern Ireland , then UKCA and CE + UKNI Marking will be necessary , and CE will not .
What is a UK designated standard ?
UK designated standard is the UK equivalent of a EN harmonised standard . This is developed by consensus , which is designated by Secretary of State and is recognised by government in part or in full by publishing its reference on www . gov . uk in a formal notice of publication . At present both harmonised and designated standards are identical but there remains the possibility for divergence at a further stage .
What is an Approved Body ?
From 1 January 2021 , UK notified bodies operating under the EU Construction Products Regulation 2011 and based in the UK have been granted new UK ‘ approved body ’ status and listed on a new UK database . Approved bodies will be able to undertake conformity assessment activity for UK designated standards . Where an approved body has undertaken the assessment , the manufacturer ( or their authorised representative ) must affix the UK marking . Rules around affixing the new UK marking will be equivalent to current CE marking .
I have CE Certification with a European Body ; how do I get UKCA Marking to market into the UK ?
You will need to contact a UK Approved Body and submit an application form for UKCA Marking if your product falls under System 1 . You may then present the existing documentation to support your CE Marking and the Certification Body can determine what additional steps are needed .
I am a distributor with existing stocks of CE marked product with no UKCA marking – will I still be able to sell these after 1st January 2023 ?
Yes – these items will be deemed to have already been placed on the market therefore will still be able to be sold .
What is meant by “ placing on the market ” in Great Britain ?
The UK Government website defines placing on the market as follows :
A fully manufactured good is ‘ placed on the market ’ when a written or verbal agreement ( or offer of an agreement ) to transfer ownership or possession or other property rights in the product is exchanged . ‘ Placing a good on the market ’ means each individual good , not a type of good . It does not require the physical transfer of the good .
You can usually provide proof of placing on the market on the basis of any relevant document ordinarily used in business transactions , including :
• contracts of sale concerning goods which have already been manufactured and meet the legal requirements
• invoices
• documents concerning the shipping of goods for distribution
The relevant economic operator ( whether manufacturer , importer or distributor ) bears the burden of proof for demonstrating that the good was placed on the market before 1 January 2021 .
www . gai . org . uk
JUL / AUG 2022
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