UKCA and UKCA MED (AKA Red Ensign) has been introduced as a result of Britain’s withdrawal from the European Economic Area (EEA), commonly referred to as Brexit. Due to Crowcon product label size and logo size for UKCA and CE, products for UK and European markets will have separate labels and therefore, part numbers.
What is UKCA Marking?
“UKCA” stands for “UK Conformity Assessed” marking is a new UK product marking that is used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods that previously required the CE marking. The UKCA marking came into effect on 1st January 2021, where goods placed on the market in Great Britain for the first time must be UKCA marked. However, to allow businesses time to adjust to the new requirements, business have still been able to use the CE marking but this is only until 31st December 2024.
Due to the ongoing economic negotiations that surround the Northern Ireland Protocol, the UKCA mark may not be used on its own for marking of products for sale. The existing CE mark will continue to be accepted in NI and there is no requirement for Crowcon to use a UKNI marking. The UKNI mark is only required for certain situations for example if using a 3rd party UK notified body to carry out a mandatory conformity assessment.
What do I need to know today?
A result of Brexit, from 1st January 2023, MED approved products to be used on UK flagged ships must have the UKCA MED marking, Red Ensign (however any product manufactured with a CE mark before the 31st December 2022 can still be placed onboard a vessel with a UK registered flag). The affected products and new part numbers are below:
Product | EU | UKCA MED |
T4 | T4-HOCA-MD T4-ZOCA-MD T4-HOZA-MD T4-ZOZA-MD T4-HOCA-MD-CRD T4-ZOCA-MD-CRD T4-HOZA-MD-CRD T4-ZOZA-MD-CRD | T4-HOCA-UM T4-ZOCA-UM T4-HOZA-UM T4-ZOZA-UM T4-HOCA-UM-CRD T4-ZOCA-UM-CRD T4-HOZA-UM-CRD T4-ZOZA-UM-CRD |
Gas-Pro | GPPE8ABC-DADBZZFDOC GPPE8ABA-DADBZZFDOC | GPPU0ABC-DADBZZFDOC GPPU0ABC-ACZZFDOCZZ GPPU0ABC-ALZZFDOCZZ GPPU0ABC-ZZZZFDOCZZ GPPU0ABA-DADBZZFDOC GPPU0ABA-ACZZFDOCZZ GPPU0ABA-ALZZFDOCZZ GPPU0ABA-ZZZZFDOCZZ |
Gas-Pro TK | GTPE8AAC-ZZDADBRGOC GTPE8AAA-ZZDADBRGOC | GTPU0AAC-ZZDADBRGOC GTPU0AAA-ZZDADBRGOC GTPU0AAA-ALZZRGOCZZ |
Products used on European ships will continue to be certified with the MED wheel marking and existing product codes.
From 1st January 2024, products sold within the UK (exports are unaffected) which carried the CE mark, will now carry a UKCA mark. This has been amended in November 2022 by the UK government, as it was originally supposed to come into effect in January 2023. As in the past with the CE mark, this guarantees to the consumer that all relevant health and safety regulations and applicable standards for the product have been met by the manufacturer and that it’s safe and legal to use. The UKCA mark covers much the same range of products that were previously marked with the CE mark, such as electrical items, radio equipment, PPE and toys, plus the new addition to the list of aerosol products.
The previous but still applicable initials CE stand for the French Conformité Européenne, or “European Conformity” and indicate that any product carrying this mark conforms with all applicable EU Directives.
Any product sold in the UK which formerly carried a CE mark will carry a UKCA mark from 1st January 2024.
What about the CE Marking?
The “CE” marking will continue to be acceptable in the EU and UK until the end of 2024 (with the exception for marine approved products). However, from 1st January 2024, products will require the UKCA marking, while where the rules for the UK and EU stay the same, the CE marking will still be valid until then. Although, if the EU chooses to alter its rules for CE marking, there may still be a change to products with based on those new rules, this will disqualify you from selling them in the UK.
Summary
The UKCA marking system is a revision of the system we used when we were part of the European Economic Area and now will follow UK legislation rather than that issued by the European Union. The products that require the conformity assessment are almost the same as previously but now with the inclusion of aerosol products.
Manufacturers will still have the same responsibilities for assessing and declaring their products’ conformity. The main difference in the new legislation is that it doesn’t currently cover Northern Ireland, and there will be some cross-over between CE marking and UKCA marking until this situation is resolved.
For more information about UKCA certification changes, read our white paper here.