Guidance on UKCA marks post-Brexit were recently updated by the Office for Product Safety and Standards for clarity.
UKCA is marking used for products being placed on the market or into service for the first time in England, Scotland and Wales, demonstrating conformity with UK regulations.
The UKCA marking applies to most goods previously subject to the CE marking, and has been in place after the end of the Brexit transition period on 1 January 2021.
CE marking is still valid and will continue to satisfy UK product legislation until 31 December 2022. However, it is recommended that UKCA marking is sought as soon as possible, and by 1 January 2023 at the latest, when it becomes compulsory in the UK.
Those responsible for ensuring the accuracy of the markings include those who import machinery, make products for their own use, and those who modify existing products already in use to such an extent that they are considered ‘new’.
For much work equipment and machinery, the UKCA markings can be affixed to products within the business, provided there is access to the necessary engineering expertise.
Before affixing the UKCA marking to products, a conformity assessment needs to be applied for, which requires a risk assessment and consideration of essential requirements.
UKCA marking is needed for machinery, lifts, cableways, pressure equipment, gas appliances, personal protective equipment, low-voltage electrical equipment, equipment for use in potentially explosive atmospheres.
Assembly lines require UKCA unless valid CE marking is being affixed instead – at least until 31 December 2022. This must be done for the whole assembly line, even if each individual machine has its own CE or UKCA marking.
Work equipment made by businesses for their own use must have UKCA marking if it comes within the scope of the Supply of Machinery (Safety) Regulations 2008. All other essential health and safety requirements must also be met, even if there is no intention to supply the equipment to third parties.
Most modified machinery will not need a UKCA conformity mark, but it must be safe and continue to meet the requirements of the Provision and Use of Work Equipment Regulations. The machinery will, however, need full conformity assessment and a new UKCA mark where the modification means it could be considered a new machine, affects safety devices or systems, or introduces significant hazards.
Products that do not fall under any of the legislation requiring the UKCA marking - such as manually powered machinery (except those used for lifting), tools and ladders - must not bear the UKCA marking, but if for use at work these products will still be subject to Section 6 of the Health and Safety at Work etc Act 1974.