United Kingdom
What is UKCA Marking?
The UKCA (UK Conformity Assessed) marking is a new UK product marking that is used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods which previously required the CE marking including industrial Machinery. It is required for products manufactured anywhere in the world that are then marketed in the Great Britain.
The CE Mark is mandatory in Europe, as UCKA will be mandatory in GB from 1st January 2023. In Europe the UCKA will be not recognized.
Is UKCA Marking Mandatory?
The UKCA marking came into effect on 1 January 2021. However, to allow businesses people to adjust to the new requirements, you will still be able to use the CE marking until 1 January 2023 in most cases.
Machinery lawfully placed on the market with a CE marking until 31 December 2022 can continue to circulate on the GB market after this date.
If before 31.12.2022 EU changes its rules and the manufacturer puts the CE mark on its product on the basis of those new rules, the producer or its distributor will not be able to use the CE marking to sell the product in Great Britain.
In other words, products with CE mark due on the basis of the applicable safety requirements and the law in force at this time, can be placed on the GB market and can circulate, otherwise it is not possible.
From 1st January 2023 UCKA Marking will be mandatory.
Machinery lawfully placed on the market with a CE marking until 31 December 2022 can continue to circulate on the GB market after this date.
If before 31.12.2022 EU changes its rules and the manufacturer puts the CE mark on its product on the basis of those new rules, the producer or its distributor will not be able to use the CE marking to sell the product in Great Britain.
In other words, products with CE mark due on the basis of the applicable safety requirements and the law in force at this time, can be placed on the GB market and can circulate, otherwise it is not possible.
From 1st January 2023 UCKA Marking will be mandatory.
How to Obtain UKCA Marking?
As foreseen by Supply of Machinery (Safety) Regulations 2008, the manufacturer of the machinery or the manufacturer’s authorized representative is the sole responsible person’ and this means that he:
- Cannot place machinery on the GB market or put it into service unless it is safe
- Must ensure that the essential health and safety requirements are satisfied
- Must ensure that the technical file is compiled
- Must provide the necessary information to operate safely
- Must ensure that the relevant conformity assessment procedure is carried out
- Draw up a UK Declaration of Conformity and make sure that a copy of this accompanies the machinery
- Must affix the relevant conformity marking to the machinery
- For partly completed machinery, he must also ensure that assembly instructions are prepared, and a declaration of incorporation is drawn up and that both accompany the partly completed machinery until it is incorporated into machinery
What is the UK Declaration of Conformity?
Any machine which is not in Schedule 2, Part 4 of The Supply of Machinery (Safety) Regulations 2008; or any machine that is in but where the requirements of all relevant designated standards have been applied in full and where those standards cover the applicable essential requirements can be self-declared by the manufacturer.
In the UK Declaration the manufacturer should:
In the UK Declaration the manufacturer should:
- Declare that the product is in conformity with the relevant statutory applicable requirements
- Make sure that in the document there is its name and address (or of its authorized representative) together with information about the product
As per CE Declaration of Conformity, also the UK Declaration should be available to market surveillance authorities on its request.
The information required on the UK Declaration of Conformity is largely the same as what was required on an EU Declaration of Conformity but need to list relevant UK legislation (rather than EU legislation) and UK designated standards (rather than standards cited in the Official Journal of the European Union).
The information required on the UK Declaration of Conformity is largely the same as what was required on an EU Declaration of Conformity but need to list relevant UK legislation (rather than EU legislation) and UK designated standards (rather than standards cited in the Official Journal of the European Union).
Which are the Main Standards to Respect?
| EU Legislation | UK legislation |
| Electromagnetic Compatibility – Directive 2014/30/EU | Electromagnetic Compatibility Regulations 2016 |
| ATEX – Directive 2014/34/EU | Equipment and Protective Systems Intended for use in Potentially Explosive Atmospheres Regulations 2016 |
| Pressure Equipment – Directive 2014/68/EU | Pressure Equipment (Safety) Regulations 2016 |
| Machinery – Directive 2006/42/EC | Supply of Machinery (Safety) Regulations 2008 |
| Low Voltage - Directive 2014/35/EU | The Electrical Equipment (Safety) Regulations 2016 |
At the following link it is possible find the designated standard that must be respected and mentioned on the documents of the machinery. CLICK HERE
The list of standard has been published by Great Britain; the purpose of this standards is the same of UE harmonized standards and which will guarantee presumption of conformity with the English regulation.
The list of standard has been published by Great Britain; the purpose of this standards is the same of UE harmonized standards and which will guarantee presumption of conformity with the English regulation.
Main Differences Between Machinery Directive and the Machinery safety Regulation?
Follow, the relevant differences between the two documents:- From the formal point of view all the references to the European standards and European Union approach have been removed by the Regulation;
- All information on the machinery must be in English
- The manual and instruction of use of the machinery must be in English
- The UKCA is the unique mark recognized
- It is necessary the UK Declaration of the machinery
- Only UK standards must be cited and not the European ones.
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