UK | General Product Compliance
New UKCA Implementation Guidance published
New implementation guidelines for the UKCA marking has just been published
The Guidance has been much awaited by market participants because there was a lot of confusion about the UKCA marking. Fortunately, the document answers at least some of the open questions.
Basically, the Guidance provides information on the following topics:
- Placing goods on the market in Great Britain
- Circulation of goods on the market
- UKCA labelling easement
- Prototypes and testing
- Leasing and hiring
- Economic operator responsibilities
One of the issues that has now been clarified is the UKCA marking on the accompanying documentation. Until now it wasn’t certain what was meant by this term. BEIS (Department of Business, Energy and Industrial Standards) stated that they are not overly prescriptive about what constitutes an accompanying document. The important thing is that the accompanying document must reach its end user to indicate that the good is compliant (however, it doesn’t have to accompany every single product if products are delivered in a batch).
Another open issue was the applicability of UKCA marking to components. In the Guidance it was stated that a good must be compliant with all applicable legislation when placed on the GB market. This may include a requirement for components to be individually conformity assessed and marked. However, for many goods, a single marking covering the overall good is sufficient. Manufacturers should check whether components require individual marking under the legislation.
Two examples for a vehicle radio were given:
- A radio fitted in a vehicle would require the UKCA marking if the vehicle (inclusive of the radio) is placed on the GB market after 31 December 2022.
- A radio imported for assembly into a vehicle, will need to bear the UKCA marking if the vehicle (and therefore the radio) is placed on the GB market after 31 December 2022.
Nevertheless, one must remember that the examples provided throughout the Guidance are only indicative. They do not apply to all products but are provided to help interpret the individual regulations.
Importantly, it is stated in the Guidance that it represents BEIS’s interpretation of the legislative framework and does not have legal force.
This guidance will be regularly updated, and we will provide further guidance on spare parts shortly.
If you would like to find out more about the content of the Guidance, please do not hesitate to contact our EFS Product Compliance Team.