UKCA Marking FAQ2021-04-19T14:27:53+00:00

UKCA FAQ: Your Questions Answered

The latest frequently asked questions around
UKCA legislation, standards and marking conformity

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

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Note: Information updated as of 1st February 2021.

Could the information here change?2021-04-08T13:36:00+00:00


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.


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Is everything changing?2021-04-08T13:36:11+00:00

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 and the elements that directly affect your case.

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When does UKCA Marking start to become a requirement?2021-04-08T13:36:19+00:00

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.


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What products does the UKCA Marking apply to?2021-04-08T13:36:27+00:00

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.


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Will BBA test data continue to be recognised in the EU?2021-04-07T14:13:08+00:00

We are currently working with the Government on this. A definitive position will be made clear in the future.


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What organisations will be created within the UK to help with the transition?2021-04-07T14:13:25+00:00

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).


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Are the fee schedules available yet from BBA and other UK notified bodies for UKCA and UKNI Marking?2021-04-07T14:13:44+00:00

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.


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Are the BBA still waiting for UKAS accreditation in order to start carrying out UK assessment for UKCA Marking?2021-04-07T14:13:59+00:00

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.


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If a harmonised-standard changes, will the UK automatically follow the changes in the UK Designated Standards?2021-04-07T14:14:12+00:00

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.


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Can we have clarification on what new responsibilities distributors (as opposed to manufacturers or merchants) of EU imported goods will have?2021-04-07T14:14:25+00:00

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

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 a 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.


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Do you have a draft available for the UKCA and UKNI Declarations of Performance?2021-04-07T14:14:37+00:00

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


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When is a product considered to be a new product on the market and therefore UKCA marked as from 2020 / January 2021?2021-04-07T14:14:54+00:00

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.


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In the future when UK standards may deviate from the harmonised European Norms, will this be done through BSI standards? Would there be a new British Standard issued with a new number if UK wishes to deviate from EN?2021-04-07T14:15:07+00:00

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.


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If a product is assessed to a harmonised standard, but that standard changes in EU, will the UKCA marked product continue to the old standard? Or will the UK automatically follow the changes of the end standard?2021-04-07T14:15:19+00:00

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.


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If I am importing goods onto the GB market, what do I need to do?2021-04-07T14:15:37+00:00

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.


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What defines a new product? Will formulation tweaks be considered a new product?2021-04-07T13:58:25+00:00

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.


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What technical information must accompany the UKCA Marking?2021-04-07T13:58:16+00:00

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.


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Does the UKCA Marking have to be on a product or its wrapping?2021-04-07T13:58:04+00:00


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.

Northern Ireland Information: Construction Products Regulation in Northern Ireland – GOV.UK (

UK information:


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Can the UKCA Marking just be mentioned on a relevant page on the website?2021-04-07T13:58:02+00:00

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


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Will UKCA Marking apply in the Channel Islands and Isle of Man?2021-04-07T13:58:00+00:00

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.


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Will tests carried out in an EU Member State be acceptable for UKCA Marking?2021-04-07T13:57:57+00:00

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

The BBA will accept suitably notified/accredited test data irrespective of the country of origin, providing that MHCLG allow us to do so.

In all instances, please check with the BBA to confirm the acceptability of test data.


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Where there is no harmonised standard and CE Marking is voluntary in the UK, will this still be the case with the UKCA Marking?2021-04-07T13:57:56+00:00

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.


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Do I need to use the UKCA Marking on any existing stock?2021-04-07T13:57:53+00:00

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.


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Can I place both CE and UKCA Markings on a product?2021-04-07T13:57:51+00:00

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


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How is the situation different for companies based in Northern Ireland?2021-04-07T13:57:48+00:00

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.


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Can UK Approved Bodies approve UKNI Marking?2021-04-07T13:57:46+00:00

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


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If you are Northern Ireland business, can you use UKCA, UKNI and CE Marking, to continue to sell your products in the GB Market. Does a CE Marking for NI businesses continue to be recognised post 1st January 2022?2021-04-07T13:57:44+00:00

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.


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For clarification, to continue to CE Marking we don’t need to do anything?2021-04-07T13:57:43+00:00

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

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.


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Can a product destined to the EU have both the CE Marking and UKCA Marking (and UKNI Marking) alongside each other?2021-04-07T13:57:40+00:00

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 Northern Ireland but not in Eire (or in the rest of the EU).


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We currently have CE Marking through an EU NB (Notified Body) or TAB (Technical Assessment Body) – can the BBA carry out the conformity assessment tasks to support UKCA Marking?2021-04-07T13:57:38+00:00


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.


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If we have a CE Marking via an EU Notified Body do we still need a UKNI Mark as well as the UKCA Mark?2021-04-07T13:57:35+00:00

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.

If a UK company already has a product on the market, CE marked, can you confirm you don’t have to do anything to continue to sell that product on the UK Market, until January 2022.
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.

If a UK company already has a product on the market, CE marked, can you confirm you don’t have to do anything to continue to sell that product on the EU Market, until January 2022.
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 coordinate wherever possible and so to minimise duplication of such activities.


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In terms of European Assessment Document (EAD), will they be transferred to UKAD?2021-04-07T13:57:31+00:00

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.


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Will an ETA (European Technical Assessment) issued by a UK TAB (Technical Assessment Body) prior to the 31st December 2020 continue to be valid after 1st January 2021?2021-04-07T13:57:28+00:00

They will continue to be valid for UKCA Marking.

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


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My ETA is issued by a Technical Assessment Body (TAB) in the EU. Can I use my existing technical file to support UKCA Marking?2021-04-07T13:57:26+00:00


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.


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What happens for sales to the EU market if we have an ETA?2021-04-07T13:57:19+00:00

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.


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Do you have to have different notified bodies for the CE and UKCA Marks?2021-04-07T13:38:46+00:00

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.


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Is there an equivalent to EOTA (European Organisation for Technical Assessment) under the new system?2021-04-07T13:39:09+00:00

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.


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Where a UK Notified Body has carried out tasks or issued certification in relation to the AVCP (Assessment or Verification of Performance) for a product before 1st January 2021, can that approval be used to support affixing a UKCA Mark?2021-04-07T13:39:30+00:00

Yes, this existing Certification is acceptable and no further action is necessary.


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Will testing carried out by a UK Notified Body which was EU Notified at the time of testing, still be accepted in support of CE Marking by an EU Notified Body?2021-04-07T13:39:49+00:00

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.


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Will EU and UK notified bodies cooperate?2021-04-07T13:40:07+00:00

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.


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Will any Notified Bodies in Europe be able to be UK approved? Or do the UK Approved Bodies need to be based in the UK?2021-04-07T13:40:26+00:00

The UK Approved Bodies need to be based in the UK.


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I have a Notified Body test report or thermal report from the BBA – what is the status?2021-04-07T13:40:45+00:00

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 a further agreement is reached, retesting will be necessary.


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What are the requirements when it comes to the Declaration of Performance (DoP) and the duplication of this content if the requirements for CE Marking and UKCA Marking are the same?2021-04-07T13:41:00+00:00

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).


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How do these changes effect trading with other commonwealth countries?2021-04-07T13:41:15+00:00

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).


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I am an FPC 2+ BBA client selling into the UK market – what is the status after January 1st 2021?2021-04-07T13:41:31+00:00

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.


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I am an FPC 2+ client selling into the EU market – what is the status after January 1st 2021?2021-04-07T13:41:46+00:00

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.


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I am an FPC 2+ client selling into the UK and EU markets – what is the status after January 1st 2021?2021-04-07T13:42:02+00:00

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.


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Will it be legal to sell products, for which the UKCA mark is voluntary, only the with CE mark in the UK?2021-04-07T13:42:19+00:00

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 from 1st January 2021.


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Where is the application form for the BBA to help start the process of transferring from ETA to UKTA?2021-04-07T13:42:33+00:00

We can accept applications NOW. You can use the formal application form can be downloaded here


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Will the BBA keep the same notified body number?2021-04-07T13:42:50+00:00

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


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Will the BBA be testing and assessing on behalf of an EU TAB?2021-04-07T13:43:05+00:00

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


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Does the BBA have adequate capacity to deal with the volume of correspondence plan for the execution of data transfers to EU partners?2021-04-07T13:43:20+00:00

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.


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My Agrément (including HAPAS) product requires CE Marking / UKCA Marking – where can I sell it?2021-04-07T13:43:41+00:00

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.


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With Agrément (including HAPAS) what is the status of this product from January 1st 2021?2021-04-07T13:23:01+00:00

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.


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Does BBA revise all certificates because of new numbers for the harmonised European norms/Standards carried?2021-04-07T13:20:07+00:00

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 a defined application is not going to change as a result of changing 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.



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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) 

APPLY HERE: Application form for UKCA (UK Conformity Assessed) Marking Support and UK Technical Assessment

Application Form
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