UKCA Marking FAQ2021-06-24T07:49:51+00:00

UKCA FAQ: Your Questions Answered

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

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Note: Information updated as of 23rd June 2021.

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

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.
 

 

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Is everything changing?2021-06-23T20:42:05+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 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?2021-06-23T20:45:03+00:00

UKCA Marking came into force on 1st January 2021.

As things stand, CE Marking will continue to be recognised in the UK until the end of 2021, although it is possible that this timescale could change

Currently, only products with UKCA Marking will be accepted in England, Scotland and Wales from 1st January 2022

 

 

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What products does the UKCA Marking apply to?2021-11-30T10:16:31+00:00

Most products that currently require CE Marking will need UKCA Marking before 2023.

The BBA can work with you to make the necessary changes.

 

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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?2021-06-23T20:46:56+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.

The BBA, together with the other UKTABs, are meeting with MHCLG  and 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.

 

 

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1.Are the fee schedules available yet from BBA and other UK notified bodies for UKCA and UKNI Marking?2021-06-23T20:49:01+00:00

Yes, please contact us for a specific quote.

 

 

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Are the BBA still waiting for UKAS accreditation in order to start carrying out UK assessment for UKCA Marking?2021-06-23T20:50:01+00:00

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.

Those Standards that were previously accredited under the CPR in support of CE marking have already been transferred to support the UKCA marking process.

We are in discussions with UKAS to agree the most efficient processes for adding new documents to our existing scope of accreditation.

 

 

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If a harmonised-standard changes, will the UK automatically follow the changes in the UK Designated Standards?2021-06-23T20:51:01+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 CEN, 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?2021-07-22T14:25:30+00:00

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 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 to get this in place for materials already on the market, as CE Marking will continue to be valid in the UK, but will be replaced by UKCA Marking in the future.

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 apply 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?2021-06-23T20:54:30+00:00

For UKCA Marking, the UKCA Mark product will continue to whatever the current UK Designated standards 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?2021-06-23T20:55:12+00:00

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

 

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What defines a new product? Will formulation tweaks be considered a new product?2021-06-23T20:56:16+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.

 

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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

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.

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
 

 

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Can the UKCA Marking just be mentioned on a relevant page on the website?2021-06-23T21:14:28+00:00

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?2021-06-23T21:15:33+00:00

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

 

 

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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?2021-06-23T21:17:07+00:00

Yes.

 

 

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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?2021-06-23T21:17:58+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?2021-06-24T07:46:11+00:00

Yes. Any UK AB can 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?2021-07-22T14:31:00+00:00

CE Marking will not be recognised in GB once the transition date for the UKCA Marking to supercede this has been confirmed 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-transition.

 

 

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For clarification, to continue to use CE Marking we don’t need to do anything?2021-07-22T14:11:51+00:00

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 until the transition to UKCA Marking is mandatory. For new products covered by a UK Designated Standard, new marking will be required with immediate effect.

 

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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?2021-06-23T20:24:21+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?2021-06-23T20:25:33+00:00

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 AVCP 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?2021-06-23T20:27:08+00:00

If you have a CE mark from an EU Notified Body and you’re selling in Northern Ireland, you only need to CE Mark.

 

 

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In terms of European Assessment Document (EAD), will they be transferred to UKAD?2021-06-23T20:31:31+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, the EC, EOTA and the UKTABs. It is anticipated that MHCLG will Designate the EADs as UKADs in due course.

 

 

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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?2021-06-23T20:33:57+00:00

No, all UK based ETAs must be withdrawn.

The technical work carried out prior to the issue of the ETA can be used as the basis of a UKTA, if requested.

 

 

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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?2021-06-23T20:35:42+00:00

Yes.

The Withdrawal Agreement makes it clear that both the EC and the UK are keen that operators do not have to duplicate their efforts.

The BBA can work with you and our EU TAB partners 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?2021-06-23T20:36:51+00:00

If you sell into the EU, for products covered by a harmonised European Standard, you must continue to apply CE Marking, including using an EU based Notified Body for conformity activities. .

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

The BBA has arrangements in place with European partners 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 partners. 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?2021-06-23T21:00:21+00:00

UKCA and UKNI Marks require that third party conformity 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 EU Notified Bodies to prevent any duplication of activity and to facilitate an efficient process for our clients.

 

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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?2021-06-23T21:02:10+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 from the 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?2021-06-23T21:03:13+00:00

If you are selling within the UK and wish to update your CE Marking to UKCA Marking, you can use this existing report.

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 an Approved Body, such as the BBA.

Such reports 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?2021-06-23T21:04:41+00:00

It has now been made clear that separate Declarations of Performance will be required for the EU and the UK markets.

 

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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?2021-06-23T21:05:57+00:00

You need take no action; the existing surveillance and Certification arrangements can continue to be used in support of UKCA marking.

If you wish to do so, we can re-issue your certification from the BBA as a UK Approved Body

 

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I am an FPC 2+ client selling into the EU market – what is the status after January 1st 2021?2021-06-23T21:08:01+00:00

You will continue to require CE Marking. We will work in contract with you and our European partners 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 advise on individual circumstances.

 

 

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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?2021-06-23T21:09:28+00:00

You will possibly need both CE Marking and 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, you will be able to choose whether to UKCA mark or not.

 

 

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Where is the application form for the BBA to help start the process of transferring from ETA to UKTA?2021-06-23T20:12:08+00:00

We can accept applications NOW. You can use the formal application form, which 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?2021-06-23T20:13:27+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 CE Marking (if applicable). If you don’t CE mark you must use the UKNI Mark, in combination with the CE mark.
  • More than one mark can be used if you are selling to multiple markets.
  • However, the UKNI mark must not be used on goods intended for the EU market (including the Republic of Ireland).
  • 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?2021-06-23T20:14:51+00:00
  • BSI will keep the same numbering system for European Standards carried over as UK Designated Standards.
  • A 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 designation of a Standard.

 

 

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What are the lead times for the UKCA Marking process? What happens if a company has not completed the process by the end of 2021?2021-06-07T12:50:19+00:00

The lead time will depend on the nature of the work; for example we undertake to convert an existing ETA to a UKTA within two months, but other processes will of course have their own timescales. We would be pleased to quote for any specific work that you have in mind. If is product covered by a Designated Standard is not UKCA marked by the beginning of 2021, it would currently be illegal to place it on the market unless the transition period for CE marking is extended.

 

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If you have a BBA System Certification is UKCA Marking still required?2021-06-07T12:59:39+00:00

UKCA Marking for products covered by a Designated Standard is mandatory from 1st January 22 unless the transition period is extended and this is unaffected by the presence or otherwise of a BBA Certificate. Work carried out to produce a BBA Certificate may well be used towards UKCA marking, but this will depend on the individual Standard. UKCA Marking via the voluntary route is, of course, optional.

 

 

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We have an ETA from a European Body and therefore still have a CE Marking in place. Will this now suffice going forward?2021-07-22T14:16:51+00:00

We can convert an ETA to a UKTA but UKTAs are voluntory and so it is your choice whether or not to apply for one.

 

 

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What are the requirements in the case of an EU manufacturer exporting goods into UK, but UK partner will not use the goods on the local market, but will export them to other markets?2021-06-07T12:58:45+00:00

UKCA Marking is only required for goods being placed on the market in the UK.

 

 

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Can we use self-assessment documentation from an EU country that was used for CE Marking to enable us to use UKCA Marking on the same product?2021-06-07T13:00:51+00:00

If this relates to an AVCP System 4 Standard then yes. If any EU Notified Body was involved, then the same work will have to be carried out by a UK Approved Body.

 

 

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What is the definition of a “new product”? If the product with CE certification exists in the EU and is introduced to the UK, is that “new”?2021-06-07T13:01:51+00:00

New means the first time that it is offered for sale on the UK market – it does not matter that it has previously been sold elsewhere. We suggest confirming the specifics with MHLG if this poses an issue.

 

 

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Can you ‘carry’ the UKCA Mark on paperwork going into NI alongside the CE Mark, which will be the mark actually referred to for that market?2021-06-07T13:02:47+00:00

Yes, this is acceptable, provided that the rules for placing the product on both markets have been met.

 

 

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If we have a BBA Agrement Certificate and CE certificate (by an EU Body) do we need to get UKCA for sales in UK?2021-07-22T14:09:24+00:00

UKCA marking for products covered by a Designated Standard will be mandatory, unless the transition period is extended and this is unaffected by the presence or otherwise of a BBA Certificate. Work carried out to produce a BBA Certificate may well be used towards UKCA Marking, but this will depend on the individual Standard. UKCA Marking via the voluntary route is, of course, optional.

 

 

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Will tests undertaken to a european norm EN 13501-1 in Europe be accepted going forward to support our UKCA DoC?2021-06-07T13:05:02+00:00

This is currently unclear. There is currently no mutual recognition of test reports between the EU and the UK and potentially it might be necessary to retest. MHCLG are aware and are looking for a resolution to the issue.

 

 

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Which fire classes for UKCA – Euroclass or do we need new fire tests according to BS standard?2021-06-23T21:19:09+00:00

UKCA Marking is done against the existing UK Designated Standard and as such the test requirements remain unchanged to those required for CE Marking. The difference is that for UKCA Marking these tests will need to have been supported by a UK Approved Test facility.

 

 

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Do you need to keep the DoP (according to the EN) as well as a DoC according to the UKCA process?2021-06-23T21:19:57+00:00

A Declaration of Conformity is required for the UK market in addition to a separate Declaration of Performance for the EU.

 

 

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If a product is covered by both an ETA and a hEN, is UKCA mandatory?2021-06-23T21:21:02+00:00

In the EU, a product will be assessed under an ETA or a hEN but not both. The same principle applies for UKCA marking.

If covered by a UK Designated Standard, UKCA Marking is mandatory; the UKTA route is voluntary.

 

 

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If products were covered by ETA and CE was voluntarily applied, does the product then need UKCA Marking because of the CE Mark?2021-06-23T20:38:50+00:00

Since 2013 it has been mandatory for any product with an ETA to be CE Marked. It is not mandatory that an ETA is converted into a UKTA but as the ETA is not recognised in the UK you cannot UKCA Mark without a UKTA, the UK equivalent)..

 

 

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In addition to UKCA, does a manufacturer not based in the UK need a representative based in the UK to put a construction product in the UK market?2021-06-07T13:14:43+00:00

No, many overseas companies sell directly into the UK; there is no reason relating to UKCA Marking that would affect this.

 

 

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Our product is Zinc based and we did not require CE Marking. Will we now require UKCA Marking for a zinc product in the UK?2021-06-23T21:11:30+00:00

If you didn’t previously CE Mark then it is unlikely that you would need to UKCA Mark – UKCA Marking mirrors the requirements of CE Marking. Unless you are covered by a Harmonised Standard (or have produced an ETA) then you would not have been required to CE Mark. If your product falls outside of this and you need a robust way to demonstrate performance and durability to satisfy specifiers, insurance and warranty providers then  please talk to us about BBA Agrément Certificates and how this could help your product.

 

 

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Do MHCLG have juristiction across the whole of the UK with regard to the UKCPR?2021-06-07T13:17:03+00:00
Will the Reissue of Test Report for System 3 apply to reports obtained from an EU Based Notified Body (Test Laboratory) after the 1st Jan 2021?2021-06-07T13:17:58+00:00

This is still with MHCLG to decide and announce what will be acceptable.

 

 

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Will the EU accept the information in reverse to ETA/UKTA, so that where a UKTA has been created then a ETA can be applied for?2021-06-07T13:20:15+00:00

It is down to the individual EU TAB whether or not to use data generated by a UK Approved Body as part of the issue of an ETA. If the applicant wishes to have an ETA based on a UKTA and the supporting technical assessment, then the BBA can speak directly to an appropriate EU TAB, preferably at the time of contract preparation to ensure the suitability/acceptance of data.

 

 

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Will there be a GB equivalent to the Construction Products Regulations?2021-06-23T21:12:24+00:00

Yes, the Construction Products (Amendment etc) (EU Exit) Regulations.

 

 

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Will UKCA cover be the same as UKNI or will additional testing approvals be needed?2021-07-22T14:31:58+00:00

The technical requirements for UKCA and UKNI marking are identical. CE marking will still be accepted in the NI market after the GB transition to UKCA Marking.

 

 

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If I have an ETA and thus CE Marking, am I obligated to have an UKTA, if there is no designated standard?2021-06-23T20:40:44+00:00

UKCA marking for non-harmonised products are voluntary in the UK, therefore you are not obliged to have a UKTA.

 

 

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What is the legislation in place in the UK for the ETA conversion into UKTA?2021-06-10T16:14:01+00:00

There is no separate legislation for this, it comes under the UK version of the CPR, along with everything else. You can check this out: https://www.gov.uk/guidance/construction-products-regulation-in-great-britain

If we have a BBA Agrément Certificate, do we still need UKCA Marking?2021-06-23T20:17:30+00:00

Possibly – UKCA is compulsory for products falling under UK Designated Standards (formerly harmonised Standards). Otherwise, it is possible via the voluntary route, but this is optional. BBA Agrément is a voluntary approval but this goes into far greater depth and provides greater validation of a products ‘fit for use’ in terms of performance, longevity, durability etc.

 

 

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If a BS EN Standard has been published, but does not yet appear on the UK Designated Standards list, or been listed in the OJEU, can you UKCA or CE Mark against it?2021-06-10T16:16:17+00:00
For EN14782, general attestation is level 4 but fire declarations are level 3. I already have fire classification documents from an EU Notified Body. Do I need to re-do this through a UK Approved Body?2021-06-10T16:17:33+00:00

As of 10th June 21, this is unclear; MHCLG is working on a solution but has yet to make a decision.

As things stand, while the Government is encouraging mutual recognition in principle and the BBA would like to be able to accept existing EU NB test reports towards supporting UKCA marking, this is not allowed.

At present, duplicate testing will be necessary; we await MHCLG’s final decision.

PLEASE NOTE: This is correct at the time of publishing and may have changed. Contact the BBA for further updates before proceeding with any decisions.

 

 

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Can the UKCA and CE Mark logos be put side by side on the label?2021-06-10T16:18:30+00:00

Yes, but please see: Using the UKCA marking – GOV.UK (https://www.gov.uk/guidance/using-the-ukca-marking) for the advice from the Government on how to use the mark.

 

 

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Can a BBA test report issued in 2020 to a BS EN standard be used for UKCA without BBA re-issuing as an Approved Body?2021-06-23T20:19:03+00:00

Yes, if a test was issued by a UK Approved Body (or Notified Body at the time) such as the BBA then this is suitable for UKCA Marking.

However, if CE marking is also required, test reports from a UK Notified Body are no longer acceptable and, as things stand, the product must be retested.

 

 

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Can you market the product without UKCA Marking if a European supplier has BBA Certificate for that product?2021-06-10T16:20:34+00:00

The company that is responsible for putting the product on the UK market takes responsibility for marking that product, not necessarily the EU manufacturer.

There is no requirement to UKCA Mark, unless the product is covered by a UK Designated Standard (equivalent to a harmonised European Standard) in which case it is mandatory, as for CE marking.

 

 

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When will the UKNI Mark be required and why it would not be covered by dual certification CE and UKCA Marking?2021-06-24T07:47:30+00:00

If a product is covered by CE Marking, backed up where appropriate by an EU based Conformity Body, this is sufficient to place the product on the market in NI.

UKNI Marking would be applied if a UK rather than EU Conformity Body was supporting the marking. In this case, it would be appropriate to apply both CE and UKNI Marking – the UKNI Mark is never applied in isolation.

 

 

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Must we apply for UKCA Marking & produce our own Declarations of Conformity for CE Marked white labelled products from UK manufacturers or importers from Europe, if they are already obtaining UKCA Marking for those goods?2021-06-10T16:22:40+00:00

Yes. For products subject to harmonised standards each company placing the product on the UK market must have it’s own Declaration of Conformity and UKCA mark. If this has been obtained by the 3rd party manufacture then it can be used to support the UKCA marking by others with their permission.

 

 

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What is current situation regarding potential need for re-testing specifically for AVCP 3 products?2021-06-10T16:23:58+00:00

The BBA is seeking to rebrand notified body test reports where possible, but advice and clarification by MHCLG is awaited.

As things stand, while the Government is encouraging mutual recognition in principle and the BBA would like to be able to accept existing EU NB test reports towards supporting UKCA marking, this is not allowed.

At present, duplicate testing will be necessary; we await MHCLG’s final decision.

PLEASE NOTE: This is correct at the time of publishing and may have changed. Contact the BBA for further updates before proceeding with any decisions.

 

 

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What marking do I need to import into Northern Ireland?2021-06-24T07:48:25+00:00

Currently, CE marking for products subject to harmonised standards.

If a product is covered by CE Marking, backed up where appropriate by an EU based Conformity Body, this is sufficient to place the product on the market in NI.

UKNI Marking would be applied if a UK rather than EU Conformity Body was supporting the marking. In this case, it would be appropriate to apply both CE and UKNI Marking – the UKNI Mark is never applied in isolation.

 

 

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When should you revise ITT? If the product has not been changed is the ITT acceptable?2021-06-10T16:25:43+00:00

The requirements will be defined in the relevant product Standard, on a case by case basis.

 

 

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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 the transition to UKCA Marking occurs?.2021-07-22T14:14:28+00:00

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 based Notified Body was used to support the CE Marking, 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 conformity activities

 

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UK Government Sources

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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