For the Holz-Zentralblatt (issue 32 / 2021 of 13 August 2021), Dr Vera Steckel reported on our online seminar, which took place on 22 June 2021 on the topic: “Brexit changed import rules for building materials in Great Britain: How to deal with the UKCA and CE marking”.
With the kind permission of the Holz-Zentralblatt, we may present the text here. Go to the online issue 32/2021, where the article was published on 13 August 2021.
UKCA instead of CE: Still many ambiguities
Chris Miles from UL International UK explains the background at a seminar organised by the eco-INSTITUT
Due to the UK’s withdrawal from the EU, the CE mark is to lose its validity for the British market from 1.1.2022. It will be replaced by UKCA, short for United Kingdom Conformity Assessed, a newly developed conformity mark.
In the online seminar offered by the Eco-Institut, Chris Miles of UL (formerly Underwriters Laboratories) International (UK) explained what will change for manufacturers of construction products with the new mark. Miles heads UL International’s UKCA Approved Body, one of the government-approved certification bodies created in the UK analogous to the EU’s Notified Bodies. In response to a recent inquiry, Miles confirmed that there have been no notable changes since the June 22 event.
The UKCA mark declares that the product in question complies with all applicable requirements under UK law and that all necessary conformity assessment procedures have been successfully completed. The new mark must be applied to all products to which so-called Designated Standards apply. All harmonized EU standards on which presumptions of conformity are based have been incorporated into UK law as Designated Standards and therefore offer conformity for this jurisdiction as well.
As things stand today, the tests and procedures required for construction products are thus essentially the same as for CE marking. However, for the UKCA mark, only British institutions are to be consulted for the necessary inspections and tests. This aspect is still unclear, however, and the concrete formulation of several points is being discussed again by the British government, Miles emphasized. For example, for products that are classified under CE in systems 3 or 2+ of the Attestation of conformity (AoC), it is still unclear whether duplicate tests are required if the products are to bear both the CE and the UKCA mark. For products that are to be assigned to AoC system 1, a UKCA body must be involved. This body can accept from EU-notified bodies as long as they take the responsibility for that testing and it is within their accreditation scope. The systems for the assessment and verification of constancy of performance of construction products (1+, 1, 2+, 3 and 4) are regulated in Annex V of the Construction Products Regulation. Depending on which system a construction product is classified in, there are requirements of different scope that have to be fulfilled by the manufacturer or the notified body.
In order to be allowed to offer construction products on the British market, EU manufacturers will need a company or legal entity based in Great Britain in conjunction with the UKCA mark. This economic operator can be, for example, a subsidiary or an authorized representative of the manufacturer. According to Miles, for many EU manufacturers, the economic operator will be classified as an importer. Requirements for importers include labeling products with their name and address and ensuring that assessment and verification of constancy of performance (AVCP) has been performed by the manufacturer. In general, the economic operator, as the person or entity placing the product on the market, is responsible for the product. This means, among other things, ensuring that there is a declaration of conformity or performance and a technical documentation, as well as keeping the corresponding documents available.
There is a coexistence period of UKCA and CE mark until 31.12.2021. However, given the unresolved issues, it is questionable whether the UKCA mark will gain sole validity in the UK market from Jan. 1, 2022, as planned. Miles expressed the suspicion that this could possibly be delayed at least until much later in 2022. In the online seminars of the Eco-Institut, regularly up-to-date information on national and international requirements for building products and furniture are presented. The Eco-Institut cooperates with various testing and certification bodies in Germany and abroad. (www.eco-institut.de).
Text: Dr. Vera Steckel for Holz-Zentralblatt | Image: Karin Roth