With the Brexit story still developing, and other events taking the focus from the impending deadline on January 1st, we thought we’d share an update on what’s happening with the new UKCA markings.
What is the UKCA marking?
The UKCA (UK Conformity Assessed) marking is a new product certification marking that will be used for certain types of goods placed on the UK market.
The CE (Conformité Européenne) marking currently used in the European Union will only be accepted in the UK for a limited period of time (until 1 January 2022). However, for some goods, the UKCA marking will need to be applied immediately (1 January 2021).
The UKCA marking will not be recognised in the European Union. Products currently requiring a CE marking will still need a CE marking for sale in the EU from 1 January 2021.
See the gov.uk website for the latest details.
Will my product need the UKCA mark labels?
If your products currently require the CE marking, and if you want to continue selling them on the UK market after Brexit, you’ll need to obtain the UKCA marking for them.
As a rough guide, goods that will need the UKCA marking will meet all of the following four conditions:
- They are for the UK market
- They are covered by legislation which requires the UKCA marking
- They require mandatory third-party conformity assessment
- A conformity assessment has been carried out by a UK conformity assessment body and you haven’t transferred your conformity assessment files from your UK body to an EU recognised body before 1 January 2021
The exact regulations you need to meet depend on your business sector and product type. For more details, see this gov.uk page.
UKCA marking and technical documentation
To sell your products in the UK, merely obtaining the UKCA mark labels is not enough. You will also need to consider your technical documentation.
For each of your products, the technical documentation must demonstrate that the product meets the regulatory requirements. You need to keep the documentation for up to 10 years after the product first enters the UK market.
So what should your product documentation consist of? This depends on the specific legislation related to the particular type of product. However, you should always ensure there is documentation that covers the following:
- The product design and manufacturing process
- The process of declaring the product’s conformity with the relevant requirements
- The address of the manufacturer and storage facilities
Your technical documentation should always be “in the form of a technical file which can be requested by a market surveillance authority”.
EU, US, and UK technical documentation standards
Do the new UKCA requirements mean that you need to completely re-design your product’s technical documentation? Well, it largely depends on your current documentation quality.
If your product documentation is compliant with the current EU regulations, chances are that you won’t need to make any major changes. As the documentation standards in the USA are not drastically different from EU ones, the same may apply to products certified in the USA.
However, it’s worth mentioning that UKCA marking is not used or recognised in either the EU or the USA.
Good documentation helps, whatever the regulations
Be it the EU, the USA or the UK, regulations are there to make our lives safer and easier. In the case of technical documentation, it means that most documentation standards and regulations share similar, good-practice technical communication values, such as:
- Consistent terminology
- Document versioning
- Persistent, easy-to-find warnings and cautions
- Easy-to-read text
- A well-explained guide on how to properly use the product
Of course, Brexit or no Brexit, there will always be some disparities between compliance systems. But, if your existing documentation is well written already, chances are you’ll only need to polish a few details.
Unfortunately, due to the nature of the situation, the exact rules of the new UKCA markings are subject to change. In light of this, we will share any changes and updates that we believe may impact your documentation.
If you need assistance updating your documentation, contact us here.