UKCA – Impact of UK Legislation on Market Access

Worldwide approvals and access to international markets

Currently the UKCA scheme very closely resembles the CE scheme, so in almost all cases wherever you are required to affix a CE mark for the EU market you will be required to affix a UKCA mark for the UK market. This is mostly on the product and often on the packaging also (in a few instances accompanying documentation is also accepted). This will be defined in the legislation applicable to your product.

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June 20, 2022: UK government announced changes to simplify application of new product conformity markings for most products placed on the market in England, Scotland and Wales.

Most important information at a glance:
All conformity assessment activities carried out by EU bodies before the end of 2022 will be taken into account as the basis for UKCA marking next year.

Related legislation will be enacted before the end of the year, allowing manufacturers to place the UKCA mark on these products without the need for re-testing and re-certification. This includes both products manufactured and imported into the UK by the end of 2022 and also spare parts that meet the same requirements.

In addition, legislation will be introduced to extend the current labeling easement, allowing key information and other UKCA markings to be placed on products by means of a sticky label or accompanying document until 31 December 2025.

For more information, please see the UK government website.

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EU vs UK Market Requirements

We have already been recognized by UKAS, the national accreditation body for Great Britain, to perform certifications according to UK guidelines for several product groups.

EU Regulation	UK Regulation
ATEX - Directive 2014/34/EU	Equipment and Protective Systems Intended for use in Potentially Explosive Atmospheres Regulations 2016
Electromagnetic Compatibility - Directive 2014/30/EU	Electromagnetic Compatibility Regulations 2016
Lifts - Directive 2014/33/EU	Lifts Regulations 2016
Low Voltage - Directive 2014/35	Electrical Equipment (Safety) Regulations 2016
Machinery - Directive 2006/42/EC	Supply of Machinery (Safety) Regulations 2008
Outdoor Noise - Directive 2000/14/EC	Noise Emission in the Environment by Equipment for use Outdoors Regulations 2001
Personal Protective Equipment Regulation - 2016/425 (PPE)	Regulation 2016/425 on Personal Protective Equipment as brought into UK law and amended
Pressure Equipment - Directive 2014/68/EU	Pressure Equipment (Safety) Regulations 2016
Radio Equipment - Directive 2014/53/EU	Radio Equipment Regulations 2017
Simple Pressure Vessels - Directive 2014/29/EU	Simple Pressure Vessels (Safety) Regulations 2016
Toy Safety - Directive 2009/48/EC	Toys (Safety) Regulations 2011

EU Regulation	UK Regulation (UKAS and MHRA)
Medical Devices Regulation - 2017/745 (MDR) In Vitro Diagnostics Regulation - 2017/746 (IVDR)	Medical Devices Regulations 2002 (The following EU Directives are given effect in UK law through the MDR 2002: Directive 93/42/EEC (medical devices), Directive 90/385/EEC (active implantable), and Directive 98/79/EC (in vitro diagnostics))