The quality and certification team at leading power supply and battery charger manufacturer Mascot, examines the effects of Brexit on international quality standards, and the actions that manufacturers and agents must take to ensure conformity.
After many months of debate and much seemingly last-minute wrangling, December saw the UK and EU finally secure a post-Brexit trade deal, more than four years after the UK’s electors voted narrowly to leave the EU.
It is a deal which neither side will probably say is perfect, but it does at least provide a degree of clarity and an operational framework for the thousands of businesses that trade between the UK and EU. A ‘no deal’ scenario would have likely been a nightmare for all sides when it came to standards – but with broad agreement having been reached, both importers and exporters can look towards a more secure future.
That is not to say, of course, that everything will remain the same when it comes to ensuring conformity with the regulatory regime for the electrotechnical product sector.
One aspect where it is clear that there will be significant change is in the usage of the European recognised CE marking for products.
In particular, the CE marking scheme in the UK has been replaced from 1st January 2021 by a new national conformity system, which is equivalent to the CE scheme, but is known as the UKCA (UK Conformity Assessed) mark. The UK Government is urging businesses to be ready to use this new standard as soon as possible. It applies to all goods entering England, Scotland or Wales.
However, the UKCA marking will not be recognised in the EU market, and any products that currently need a CE marking to be sold in the EU, will continue to do so.
Furthermore, the UKCA marking on its own cannot be used for goods entering the Northern Ireland market. These will require either CE marking or UKNI marking.
The legislation is relevant to all products previously bound by CE marking. Any goods which were placed on the UK market before January 2021 can continue to circulate. Manufacturers of electrotechnical products may apply UKCA marking as well as CE marking provided it does not affect the visibility of the CE marking.
To allow businesses sufficient time to get up to speed with the changing requirements, CE marking will be accepted in the UK in parallel for a transitional period, which is 12 months from 1st January 2021, assuming that the requirements for the EU and UK legislation remain the same.
The UKCA symbol should be at least 5mm in height (unless a different size is required in specific regulation), and should not be distorted or used in different proportions. UKCA labels should be easily visible and legible. Notably, as of 23 January 2023 the marking must also be permanent.
UKCA markings must only be placed on a product by the manufacturer or their authorised representative, and manufacturers take full responsibility for their product’s conformity with the requirements of the relevant legislation. The UKCA marking can only be used to show product conformity with the relevant UK legislation and should not be placed on products unless there is a specific legal requirement to do so.
Meanwhile, no marking or sign should be placed on a product which might misconstrue the meaning or form of the UKCA marking to third parties or which might impact the visibility, legibility or meaning of the UKCA marking.
Additionally, all Declaration of Conformity documents must be updated by 1st January 2022 with details of relevant UK legislation (rather than EU legislation) and of UK designated standards, rather than standards cited in the Official Journal of the European Union.
The information required on the Declaration of Conformity will be broadly similar to what was required on an EU Declaration of Conformity. In this document, the manufacturer or their authorised representative, will need to declare that the product is in conformity with the relevant statutory requirements applicable to that product.
Required information is likely to include the name and address of the manufacturer (or authorised representative); the product’s serial number, model or type identification; a statement, stating you take full responsibility for compliance; details of the approved body which undertook the conformity assessment procedure (if applicable); the relevant legislation with which the product complies; your name and signature; the date of the declaration; and any other relevant information.
Unfortunately, the burden of administration has grown slightly weightier in the wake of Brexit, but with clear parallels and consistencies between the new standards in the UK and EU, compliance should remain sufficiently straightforward for manufacturers and their representatives.
For further information on the Mascot range of CE and UKCA products, or to learn more about compliance, visit www.mascot.no.