UKCA / UKNI Markings

The UKCA (UK Conformity Assessed) marking is a new UK product marking used for certain goods being placed on the market in Great Britain (England, Wales and Scotland). It is being introduced in place of CE Marking. An additional mark, UKNI, may be used in Northern Ireland.

The BBA aims to provide the latest information with regards to these markings.

As an Approved Body for UKCA Marking Conformity, the BBA can help guide you through the marking process.

Updated 18th January 2021. 

BREXIT; CE and UKCA/UKNI Markings – What you need to know

If you are a manufacturer or distributor based in the UK or situated in the EU and you want to continue to trade within the UK and/or the EU on and after 1st January 2021, you need to understand these changes as they may affect your trading capabilities

The BBA can support and guide you through these changes to product compliance for both the UK and EU markets. 

These changes are centered around the changes to CE Marking and the introduction for UKCA and UKNI Marking. 

To make sure we are serving all BBA clients with the most up to date information we are keeping up to date with all UK Government, EU and industry guidance, continuing our strong relationship with the key players within the construction industry.  

We will continue to inform you and refresh the information found on the BBA website in line with the latest communication and regulatory updates. 

IMPORTANT NOTICES:

The BBA has decided to accept existing reports (data from EU Notified Bodies, as well as other accredited laboratories) for UKCA and UK ETAs, in addition to continuing to do so for BBA Certification. If either of these is essential to your business, get in touch with the BBA to discuss your requirements and develop a product roadmap for 2021.

BBA Agrément and HAPAS Certificates are unaffected by BREXIT. The BBA will also continue its wide range of activities that are independent of the UK’s status within the EU. 

Dec 31st 2021 Deadline: Contact the BBA now for help with your CE, UKCA and UKNI Markings
Click Here

What is CE Marking?

CE-logo

By placing the CE Marking on a product a manufacturer is declaring conformity with all of the legal requirements to achieve CE Marking.

  • Mandatory for ALL applicable products placed on the EU market. This does not change.
  • Existing CE Marking will be recognised in the UK until 1st January 2022.
  • UKCA Marking will replace CE marking for products placed on the GB market.
  • UKNI may be used for products placed on the Northern Ireland market, although CE Marking may be used as an alternative there.
  • The UKCA Marking will not be recognised on the EU market.
  • UKNI Marking will be accepted in Eire, but not within the rest of the EU.

www.gov.uk/guidance/construction-products-regulation-from-1-january-2021

What is UKCA Marking?

ukca-logo

UKCA Marking will replace CE Marking for any applicable products that are or will be placed in the GB market.

  • Mandatory for NEW applicable products placed on the GB market from 1st January 2021.
  • Mandatory for ALL applicable products placed on the GB market from 1st January 2022.
  • Existing CE Marking will be recognised in the GB until 1st January 2022.

Note: Conformity tasks must be carried out by a UK Approved Body.

www.gov.uk/guidance/construction-products-regulation-from-1-january-2021

What is UKNI Marking?

UKNI Marking will supplement, but not replace CE Marking for any products that are or will be placed in the Northern Ireland market.

  • CE Marking will continue to be recognised in Northern Ireland and, if based on Certification by an EU based body, is sufficient to place a product on the market there.
  • Where conformity tasks are carried out by a UK Approved Body, the CE Mark must be accompanied by the UKNI Mark.
  • The UKNI Marking can never be used in isolation – it must accompany CE Marking

For further information, please see link below.

www.gov.uk/guidance/construction-products-regulation-from-1-january-2021

Routes to UKCA and UKNI Marking 

As for CE Marking, there are two routes to UKCA and UKNI Marking. The UK Government has published the adopted Construction Products Regulation and The Construction Products (Amendment etc.) (EU Exit) Regulations 2019. The latter came into force on 1st January 2021 and provides a parallel Regulatory system to that previously operated by the EU relating to CE Marking.

The first route applies where a product is covered by a UK Designated Standard. These documents have the same text as previously used harmonised European Standards. Up until the end of 2020, it was mandatory to CE Mark products covered by one of these Standards. CE Marking will continue to be accepted until the end of 2021 in Great Britain, but thereafter this must be replaced by UKCA Marking.

UKCA Marking is mandatory for all new products being placed on the GB market for the first time from 1st January 2021.

The situation in Northern Ireland is different. Marking of the product is mandatory for product covered by a Designated Standard, but this can be by either CE marking alone or by a combination of both CE Marking and UKNI Marking, depending on the location of the Certification body, as described above. UKNI is never used in isolation.

The second route is a voluntary process, where the product is not covered by a Designated Standard. This will require the issue of a UK Technical Assessment Document by a UK Certification Body, such as the BBA. If you are interested in this option, pleas get in touch, as the details of the process are still being decided by the Government.

The new bodies, documents and numbering systems mirror those previously used for CE Marking and are summarised below.

Up to 1st January 2021 Equivalent to From 1st January 2021
CPR = UK CPR
Harmonised European Standards = UK Designated Standards (Shown as EN XXXXX)
CE Marking in the GB Market = UKCA Marking
CE Marking in the NI Market = CE or CE & UKNI Marking
Technical Assessment Body (TAB) = UK Technical Assessment Body
Notified Body (NB) = UK Approved Body
Notified Body Number XXXX = UK Notified Body Number XXXX
European Approval Document (EAD) = UK Approval Document (UKAD)
European Technical Assessment (ETA) = UK Technical Assessment (UKTA)
NANDO Database = UKMCAB (UK Market Approved Body Database)

Things you need to consider

Moving to UKCA and UKNI Marking will take different forms depending on factors that affect you such as: 

  • The nation in which your company is based 
  • The markets you sell into 
  • Whether your product is covered by a UK Designated Standard or not 
  • Your AVCP level (where applicable) 
  • Whether your third-party conformity tasks are carried out by a UK or EU notified body 
  • Whether your ETA was issued by a UK or EU TAB (Technical Approval Body) 
  • Whether it is an existing product or a new product (i.e. whether it was already CE Marked at the end of 2020)
Marketplace Type of goods (see list of product areas below) Accepted marking or combination of markings*
Placing goods on the market in Northern Ireland Manufactured goods being placed on the market in NI using an EU conformity assessment body


Manufactured goods being placed on the market in NI using a UK-based body

CE


CE and UKNI

Placing goods on the market in Great Britain Manufactured goods being placed on the GB market until the end of 2021


Manufactured goods placed on the GB market from 1 Jan 2022

UKCA or CE


UKCA

Placing qualifying Northern Ireland goods on the market in Great Britain (unfettered access) Qualifying Northern Ireland goods being placed on the GB market under unfettered access CE

or

CE and UKNI

Placing goods on the EU market Manufactured goods being placed on the EU market CE
Dec 31st 2021 Deadline: Contact the BBA now for help with your CE, UKCA and UKNI Markings
Click Here

Frequently Asked Questions – Online Webinar 

Partnering with SPRA and LRWA, we recently presented an online workshop about the UKCA & CE Markings.

The online webinar explains in detail about the current status of the marking, along with potential outcomes following a Brexit No Deal or Deal.

The questions submitted in this webinar, can also be found in the next section, under Frequently Asked Questions.

Frequently Asked Questions

If your question hasn’t been answered in the FAQ section, please contact us below:

Note: Information updated as of 18th January 2021. 

General

Yes.

We are keeping up to date with UK Government, EU and industry guidance, but these do change over time, and we will continue to update our information in line with that.

The BBA Agrément Certificates will be unaffected and remain the same as they are, outside of the CPR (Construction Products Regulation) regime. The same is true of the BBA’s standard accredited testing and inspection activities. The BBA is accredited and covered by UKAS, which is still a signatory to all of the relevant International mutual recognition schemes.

The only areas which may be affected are the CPR activities themselves. The complexity of this lies in a number of factors, including (but not limited to):

  • the country you are based in
  • the markets you sell into
  • whether you’re using a harmonised European Standard route or an ETA (European Technical Assessment)
  • the AVCP (Assessment and Verification of Constancy of Performance) level
  • whether you currently have your third-party conformity tasks carried out by a UK or EU body
  • where your ETA was issued
  • whether your product is an existing or new product,
  • whether it’s been altered in any way

Due to the complexities around this, we’re advising that if you are in any doubt whatsoever, you contact the BBA to gain clarity on this directly affects your case specifically me format as those currently used as part of CE marking.

UKCA Marking will come into force on 1st January 2021.
CE Marking will continue to be recognised in the UK until the end of 2021*
Only products with UKCA Marking will be accepted in England, Scotland and Wales from 1st January 2022

* As long as on deal is agreed and UK and EU regulations remain aligned to the same standards.

Most products that currently require a CE Marking will need a UKCA Marking before 2022. The BBA can work with you to make sure that all the products that require this or any other marking conform to future regulations.

The UK Government has stressed the need for TABs (Technical Assessment Body) and NBs (Notified Bodies) to work together, to minimise as far as possible the cost and inconvenience to clients in operating these parallel processes.

It is hoped that a UK organisation similar to EOTA will be set up by the UK Government and that the two bodies will liaise to align procedures, so that the dual Certification can be based on the same requirements, initially the existing EADs (European Assessment Document).

The BBA can currently give guidance on costs on an ad-hoc basis.

Any costs are caveated by the fact that a lot of questions still remain unanswered and other elements cannot be controlled.

If there are significant changes made by the UK Government, the EU costs and processes will need to be reassessed.

No. The BBA continues to be covered by the existing accreditation arrangements. These will be automatically transferred to allow the BBA to carry out the same functions in support of UKCA / UK(NI) Marking.

No. It is likely that EU and UK standards will diverge at some point in the future. We’re anticipating that the UK will still be involved with CE, feeding into the development of standards to the EU. But it is likely, particularly with building safety changes, that we will see some divergence.

For a full description and clarification on this topic, please use the link below:

https://www.gov.uk/guidance/construction-products-regulation-from-1-january-2021

Distributors will be classified as importers, mostly bringing in products to the UK from a third country. This means that there are changes and obligations on distributors.

Distributors will need to take more responsibility for the products, and for ensuring that the assessments and AVCP requirements have been carried out, and that the correct conformity marking and labelling is correct on that product. This will naturally depend on exactly what your position is as distributor, where the product is manufactured and where you intend to distribute it.

There will be no additional responsibilities to a Distributor if someone has already placed a good on the UK or EU market before you sell it in Great Britain.

Note: Distributors will have until 2022 to get this in place as CE Marking in the UK market will continue to be valid throughout 2021 for products that were already CE marked.

If you are distributing a new product covered by a UK Designated Standard that is being placed in the UK market for the first time, you will have to undergo UKCA Marking.

No, but they are expected to follow the same format as those currently used as part of CE Marking.

References in the GB regime to ‘the market’ will mean the Great Britain market, rather than meaning the EU market. Apart from that, these definitions will be unchanged and so operators do not need to change their approach in this regard. See Article 2 in Regulation (EU) No 305/2011 for more information.

‘Placing on the market’ means the first making available of a construction product on the GB market.

‘Making available on the market’ means any supply of a construction product for distribution or use on the GB market in the course of a commercial activity, whether in return for payment or free of charge.

The BSI will issue and maintain the UK versions of European Standards and initially will be aligned. Over time, there is likely to be some divergence.

For UKCA Marking, the UKCA Mark product will continue to whatever the current UK designated standard is. So if the EU version of the standard changes and the UK version doesn’t, then the UKCA Marking stays the same.

You will still need to take action to ensure you comply with new importer responsibilities if you are placing a product on the GB market from the EU market.

The lines are blurred here but, in the opinion of the BBA, a good rule of thumb would be the declaration of performance (DoP). If you are making changes that affect this, that would constitute a new product. If these changes are minor formulation changes that do not affect the performance of the product, this may not be substantial enough to be classed as a new product.

Please contact the BBA for further information on any bespoke product changes in the first instance.

UKCA Marking

A Declaration of Performance (DoP) must be made for UKCA Marking, as for CE Marking. These could hold the same information and duplication of this information will be required and this will remain as such, unless the requirements for either Marking differ.

Yes. It should be visible on the product, unless the size or nature of the product makes this impossible. The UKCA marking needs to be affixed visibly, legibly and indelibly to the construction product or to a label attached to it. Where this is not possible or not warranted on account of the nature of the product, it shall be affixed to the packaging or to the accompanying documents.

No. It needs to be on the product unless the size or nature of the product makes this impossible.

Yes. It is expected that they will, but at the moment we don’t have a definite answer.

The only territory we have specific rules for is Northern Ireland but it is expected they will follow something similar under a different framework.

The UK Government has indicated that this will be down to the discretion of individual UK TAB / Abs.

The BBA will accept suitably Notified / accredited test data irrespective of the country of origin.

Yes, at the moment this is what is expected.

UK assessment documents are to be created which would be the basis for a UK technical assessment in order to support UKCA Marking on a voluntary basis.

No, this does not apply to existing stock. For example, if your good was fully manufactured and ready to place on the market before 1st January 2021, you do not need to use the UKCA Marking. The following does apply however;

  • Only on the GB market
  • Only until 31 December 2021
  • From 1st January 2022, you will need to use the UKCA Marking where CE marking was previously required

Yes, but both logos should be placed so that neither impedes the visibility of the other.

UKNI Marking

Companies who are based in Northern Ireland are in a unique position. Products may be placed on the market with CE marking only, if an EU based Notified Body was used. Alternatively, the use of a UK Approved Body could allow the use of the  CE / UKNI combined Mark.

Yes. Any UK AB can re-assess Northern Ireland products for the Northern Ireland market.

From the 1st January 2022, CE Marking will not be recognised in GB, but will continue to be recognised in NI.

To sell a product into the NI market,  you will need either a CE Marking (from an EU Notified Body) or a CE and UKNI Marking (from a UK Approved Body).

The Government intends to pass legislation to allow goods manufactured in Northern Ireland to be placed on the GB market on the basis of CE Marking post 2022.

CE Marking

For a full description and clarification on this topic, please use the link below:

https://www.gov.uk/guidance/placing-manufactured-goods-on-the-eu-market-from-1-january-2021

If you’ve already placed your goods on the market, in an EU country, or in the UK before 1st January 2021, you do not need to do anything if you use an EU Notified Body.

For products already placed on the market, CE marking will continue to be recognised in the UK market for one year. For new products or newly-marked products, covered by a UK Designated Standard,  new marking will be required.

We believe that it is permissible for a label to feature both CE Marking and the UKCA Mark.

The situation in Northern Ireland however is more complex. Products bearing CE Marking and UKNI Marking may be placed on the market in both Northern Ireland and Eire. However, the UKNI Mark may not be used on products being exported to the rest of the EU.

Yes.

The BBA has been designated as both a UK Technical Assessment Body (equivalent to an EU TAB) for a wide range of construction products, and also as a UK Approved Body (equivalent to an EU Notified Body) for FPC (Factory Production Control) Certification and system three testing.

If you have a CE mark from an EU Notified Body and you’re selling in Northern Ireland, you only need a CE Marking which will continue to be acceptable in Northern Ireland only.

Yes that’s the case, provided that it is an EU body supporting the certification, CE Marking will be acceptable. UK based organisations can no longer be used in support of CE Marking.

This will depend on whether a UK based Notified Body was used to support the CE Marking. If this is the case, this is no longer acceptable and the tasks must be transferred to an EU based Notified Body.

Conversely, only UK based Approved Bodies can be used  in support of UKCA Marking.

The BBA is committed to working with partners in the EU to co-ordinate wherever possible and so to minimise duplication of such activities.

Thank you for your message. It has been sent.
There was an error trying to send your message. Please try again later.

ETA (European Technical Assessment)

The BBA has been appointed as a UK Technical Assessment Body (UKTAB) by the UK Government, so this is something that the BBA are able to do. The full details of the mechanism for achieving this are currently the subject of negotiations between the UK Government, EOTA and the UKTABs.

They will continue to be valid for UKCA Marking.

They will not, however be valid for CE Marking, unless further agreement between the UK and EU is reached.

Yes.

The Withdrawal Agreement makes it clear that both the EU and the UK are keen that operator do not have to double their efforts.

The BBA can work with you and our EU TAB partner to transfer technical file information so that the process of moving to a UK TAB and having a UKTA issued is as smooth as possible.

If you sell into the EU, you must have a CE Marking. Note that UK Government guidance states ‘If you’ve already placed your goods on the market in an EU country (or in the UK) before 1 January 2021, you do not need to do anything.’ Although you may need to change to a EU NB (Notified Body).

For the future, if you are placing new goods on the market in the EU and the UK, you may choose to have both CE Marking and UKCA Marking.

The BBA has arrangements in place with a European partner so that ETA technical files can be transferred between bodies to minimise duplication of conformity assessment. If this is necessary, you will enter a contract between you, the BBA and our European partner. The European TAB will then be able to reissue your ETA. Your CE Marking label will need to change to identify the new TAB.

NB (Notified Bodies)

UKCA and UKNI Marks require that third party assessment activities carried out are done by a UK Approved Body, while CE Marking assessment activities need to be carried out by an EU Notified  Body. The BBA has formed a partnership with an EU Notified Body to prevent any duplication of activity and to facilitate an efficient process for our clients.

At the moment no there isn’t, but this is under discussion. The BBA has been asked whether they we would be prepared to stay as an observer on EOTA, which we’ve agreed to, but would hope for a more active role.

It is likely that there will be a UK equivalent to EOTA and the BBA are, together with other UK TABS, engaging with MHCLG to progress this, but there has been no official UK guidance as yet.

Both the UK and the EU wish to minimise duplication of efforts and costs by the manufacturers.

At present it does appear that the EU will refuse to accept such testing and that retesting by an EU Notified Body will be required.  There is some reason to believe that this position may change as a result of the negotiated Agreement, but the details are unclear and require interpretation. We are waiting for further guidance for UK Government.

As soon as we have additional clarity around this topic, we will confirm the situation.

There are differences of opinion, but essentially yes, as far as is possible.

The Agreement allows the use of subcontracting by Notified Bodies, including organisations in the ‘other Party’s territory’. Again the practical meaning of this has yet to be defined.

In Government guidance it states that EU Notified Bodies are required to share information with UK Approved Bodies, when requested by a certificate holder. The UK approved body should do the same with EU Notified Bodies.

This will help facilitate the issue of new certificates of conformity were needed, without the need to repeat the entire certification process.

If you are selling within the UK and wish to update your CE Marking to UKCA Marking, the BBA will be able to reissue your report under its UK Notified Body number. The BBA will be able to do this from January 1st 2021. If your product changes in the future, and you wish to continue selling on the UK Market, you will need to have the product reassessed by the BBA.

The report will not be accepted by the EU in support of CE marking and, unless further agreement is reached, retesting will be necessary.

Other Information

It has now been made clear that separate Declarations of Performance will be required for the EU and the UK markets (ie duplication of the information is required at the moment and this will remain, unless the requirements for either Marking differ).

The situation with goods being imported to the UK from Commonwealth countries to the EU is unchanged. For importing into the UK however, the same rules apply as for countries within the EU (i.e the UKCA rules will also apply).

We will re-issue your certification from the BBA as a UK Approved Body as soon as possible after the year starts for a nominal fee so that your UKCA Marking can be put in place in plenty of time before CE Marking stops being recognised in the UK. Note that if you sell on the Northern Ireland market as well as in the GB, you will need to display UK(NI) marking as well as UKCA Marking.

You will continue to require CE Marking. We will work in contract with you and our European partner and if possible to transfer your files to them so that your CE Marking is supported by a Notified Body in an EU member state. In many cases, we may be able to continue to carry out the factory inspections for continuity.

In some cases, this may not be possible and you will need to source a new Notified Body in the EU. The BBA can in individual circumstances and will be notifying BBA client.

You will need both CE Marking and possibly UKCA Marking, depending on whether your CE marking is based on the mandatory route (via harmonised Standards) or the voluntary option (vie ETAs) . If the latter, it is likely that you will be able to choose whether to UKCA mark or not.

If appropriate, we will re-issue your certification from the BBA as a UK Approved Body as soon as possible after the year starts for a nominal fee so that your UKCA Marking can be put in place in plenty of time before CE Marking stops being recognised in the UK. Note that if you sell on the Northern Ireland market as well as in the GB, you will need to display UK(NI) marking as well as UKCA Marking.

We will also work with you and our European partners to transfer your files to them so that your CE Marking is supported by a Notified Body in an EU member state. In many cases, we may be able to continue to carry out the factory inspections for continuity.

Further details of this process will be released later in the year, once there is more definitive information on whether a UK / EU trade deal has been negotiated. An application form will be available at that time for you to provide us with the necessary information.

The UKCA Marking is mandatory from 1st January 2022 for products covered by a UK Designated Standard (existing CE Marking is acceptable for products until then). The UKCA Marking is also mandatory for all new products covered by such Standards form 1st January 2021.

BBA Specific

We can accept registrations of interest immediately. These should be sent to marketing@bbacerts.co.uk. A formal application form will be made available shortly.

Yes. The BBA will keep the same notified body number but with an additional prefix ie: UK 0836.

No – unless things change, the EU will not accept UK Approved Bodies for work in support of CE marking, except in Northern Ireland.

Yes. The BBA is working hard to make sure all of its clients are properly informed and serviced to conform with transitional dates and deadlines by having the adequate capacity, knowledge and understanding into this topic.

To sell on the EU market, you will need to continue to CE Mark your product.

To sell on the GB market, you will need to UKCA Mark your product.

To sell in Northern Ireland, you will need a CE Marking (if applicable). If you don’t you must use the UKNI Mark.

More than one mark can be used if you are selling to multiple markets.

The BBA can provide you with the third-party Certification that you need for your UKCA Marking.

There is no change in the status of your BBA Agrément Certificate. The BBA Agrément Certificate remains the most robust and comprehensive approval in the UK for construction products and systems, both for innovative products and more established ones. As the UK moves away from the CE Marking scheme, independent UK third-party verification of the performance of products is likely to become increasingly important to specifiers and end-users.

BSI will keep the same numbering system for European Standards carried over, but with a new prefix.

The BBA certificate is an independent statement of fitness for purpose. The adequacy of the product for defined application is not going to change as a result of changing a the prefix of a Standard.

The default position would be to update the Standard number at the next review and reissue of the certificates.

The BBA isn’t imposing additional costs on certificate holders to revise the certificates purely to update harmonised standard numbers or prefixes.

If individual clients feel it’s important that their certificate should reflect the current standards, the BBA can do this.

What can we do to help?

To help with this transition BBA will be able to:  

  • Carry out a range of accredited and Approved testing in support of UKCA and UKNI Marking or other certification, such as Agrément and HAPAS certification or Certificates of Conformity in the UK 
  • Provide UK Approved Body test reports in support of UKCA and UKNI Marking 
  • Offer Factory Production Control certification if you need third-party inspection 
  • Prepare UK Assessment Documents, and issue UK Technical Assessment Certificates, if you choose to voluntarily UKCA and/or UKNI Mark a product that is not associated with a Designated Standard.
  • Liaise with our European partners to mirror your UKCA and UKNI Marking needs into support for CE Marking 
  • Combine activities to save you time and money – for example, by combining Agrément factory production control visits with FPC 2+ visits and management systems certification (ISO 9001, ISO 14001, ISO 45001)

There is additional information for all our clients that currently hold a BBA product, in a post that was issued 28th September 2020 – The Impact of BREXIT on Your BBA Products 

The UK Government sources below can help if you require any further detailed information that is not provided on the BBA website. You can also ask us directly using the FAQ section or get in touch with us using brexit@bbacerts.co.uk and we will try to provide the information you need. 

The EU Construction Products Regulation 

UK adoption of CPR as a ‘designated standard’ 

UK Government guidance on the CPR from 1-1-2021 

UK Government – placing goods on the UK market 

UK Government – using the UKCA mark 

Product Labelling:

Northern Ireland Information: Construction Products Regulation in Northern Ireland – GOV.UK (www.gov.uk)

UK information: https://www.gov.uk/guidance/using-the-ukca-mark-from-1-january-2021

Dec 31st 2021 Deadline: Contact the BBA now for help with your CE, UKCA and UKNI Markings
Click Here

AVCP (Assessment and Verification of Constancy of Performance) 

CPR (Construction Products Regulation) 

DoP (Declaration of Performance) 

EAD (European Assessment Document) 

ETA (European Technical Assessment) 

EU (European Union) 

hEN (harmonised European Standard 

TAB (Technical Assessment Body) 

The impact of Brexit on your BBA products

The UK has left the European Union, and at the end of 2020, the transition period is due to end. At this point, the UK may no longer be working to European Union systems, particularly if a trade deal is not negotiated. The UK Government has issued several guidance updates recently, and we have therefore updated our information to clients. Please use the options below to find the information for your BBA product.

Read more
Download our latest Industry Voices bulletin here.