The UK government has published updated guidance regarding the UK domestic regime for manufactured goods which comes into force on 1 January 2021 and it appears to be good news (or at least as good as we can expect in the context of Brexit).
In summary, for most goods which currently have to carry the CE mark for sale in the UK, this will continue to be recognised for a further 12 months - that is throughout 2021. For the following year (2022), while the UKCA mark will be required, it can be in the form of a label fixed to the product or an accompanying document and the economic operator responsible for placing the product on the UK market should take reasonable steps to ensure the UKCA marking remains in place.
Companies are encouraged to make reasonable efforts to switch to using the UKCA mark for goods placed on the UK market ahead of the deadline of 31st December 2021 and this certainly applies to any design process that takes place for new products.
The technical requirements for these goods will be the same on 1 January 2021 as they are now but there will be certain changes, including the introduction of the UKCA marking and a system of third-party conformity assessment by UK-recognised approved bodies, in place of the current EU system of notified bodies. An important point is that this only applies where the EU requirements continue to match UK requirements - it is implied that this would only change if the EU were to amend the requirements for the CE mark but it could also apply if the UK were to change its regulations.
There are four links to specific guidance which we would suggest you explore - we will try over the next couple of weeks to look for any possible anomalies in this guidance and to highlight any specific points for MTA members:
- Placing UKCA and CE marked goods on the GB market from 1st January 2021: www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-great-britain-from-1-january-2021
- Placing manufactured goods on the EU market from 1st January 2021: www.gov.uk/guidance/placing-manufactured-goods-on-the-eu-market-from-1-january-2021
- Prepare to use the UKCA marking from 1st January 2021: www.gov.uk/guidance/using-the-ukca-mark-from-1-january-2021
- Conformity assessment bodies: status from 1st January 2021: www.gov.uk/guidance/conformity-assessment-bodies-change-of-status-from-1-january-2021
There are different requirements for certain goods including medical devices, pressure vessels and construction products.
One final point - despite using UKCA as the new mark, the regulations in Northern Ireland (where the CE mark will remain valid) are different; again, we will return to this in the coming weeks but there is a sub-link from the reference at point 1 above as well.