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UKCA marking of PPE products

SATRA offers both CE and UKCA marking of PPE for the European and UK markets.

by Peter Doughty

Image © Dmytro Gilitukha | Dreamstime.com

SATRA is world-renowned for its testing and certification services in the field of personal protective equipment (PPE) such as safety footwear. Manufacturers of PPE can certify their products for sale in the European Union (EU) by working with SATRA’s notified body in Ireland (an EU 27 member state), thus enabling them to CE mark their products. SATRA should soon be able to conduct conformity assessment work for manufacturers who want to mark their products as meeting the new ‘United Kingdom Conformity Assessment’ (UKCA) for sale in the UK after 1st January 2021.

The UK has left the EU, and is in a transition phase where EU legislation still applies until the end of December 2020. It is almost certain that after this date the UK will adopt its own legislation with regard to placing PPE goods onto the UK market. The European PPE Regulation (EU) 2016/425 will be brought into UK law to become the UK PPE Regulations. For category II and III PPE (such as safety footwear), third-party certification will be required and all categories of PPE will need to be marked with a new UKCA mark. The process will be very similar to that currently used for CE marking which will require the manufacturer to work with a UK ‘Approved Body’ for categories II and III. SATRA will have Approved Body status in the UK from 1st January 2021 and can already carry out conformity assessment work in preparation for UKCA marking.

Figure 1: The UKCA mark

Starting from 1st January 2021, the UK is expected to adopt its own PPE legislation. While in the first instance this will be a copy of EU law, it is expected that over time there will be a gradual divergence away from such rulings. The UK legislation will involve the use of a new UKCA mark (shown in figure 1), which will need to be placed on products as a means of showing conformance with applicable UK legislation. At this time, SATRA Technology Centre Limited in the UK will become a UK Approved Body with the reference AB0321 – the prefix ‘AB’ denoting ‘Approved Body’. SATRA will still be able to offer CE marking services through SATRA Technology Europe Limited, which will remain a Notified Body (number 2777) based in Ireland (an EU 27 member state).

The UK’s equivalent of the CE mark will be the previously-mentioned UKCA mark. This means that to sell category II and III PPE in both the UK and EU 27 member states, a manufacturer will need an EU type-examination certificate under Regulation (EU) 2016/425 from an EU Notified Body such as SATRA Technology Europe Limited, plus a UKCA certificate from a UK Approved Body – for instance, SATRA Technology Centre Limited. Hence, SATRA is well placed to provide both certifications in the most efficient manner, and our staff in both Ireland and the UK will be able to organise this for our customers.

Although it is part of the UK, products being sold into Northern Ireland will still require CE marking, and not the new UKCA mark.

In terms of the transition to the new UKCA marking system for the UK market (excluding Northern Ireland), there are several notable phases.

1st January to 31st December 2021

During this time, it will be possible to place on the UK market either products carrying the UKCA mark or a CE mark. However, where that CE mark needs to be supported by certification from a Notified Body (that is, for category II and III PPE), that Body must be based in an EU 27 member state. It will no longer be possible to place CE-marked products on the UK or EU market where the supporting CE certification is from a UK-based Notified Body. Effectively, all CE certifications issued by UK Notified Bodies will expire on 31st December 2020. During this time, the manufacturer can affix the UKCA mark to the packaging instead of the product.

1st January to 31st December 2022

During 2022, it will only be possible to place on the UK market products carrying the UKCA mark. It will no longer be possible to place on the UK market products that only carry a CE mark. During this time, the manufacturer can affix the UKCA mark to the packaging instead of the product.

From 1st January 2023

After 1st January 2023, it will only be possible to place on the UK market products carrying the UKCA mark. The UKCA mark must ordinarily be affixed to the product. However, if this is not possible (for instance, due to the characteristics of the product), the UKCA mark can be placed on the packaging instead of the product.

It is important to note that the UK’s withdrawal from the EU will not affect the validity of existing or future test reports issued by SATRA’s testing facilities in the UK. These test reports will continue to be accepted for certification purposes by SATRA Technology Europe Limited and other PPE Notified Bodies. This is because testing that supports PPE certification does not need to be carried out in the EU.

The testing laboratories at SATRA are accredited by the United Kingdom Accreditation Service (UKAS) to the internationally-recognised standard ISO/IEC 17025:2017 – ‘General requirements for the competence of testing and calibration laboratories’. UKAS, along with other European Accreditation Bodies, is a signatory of the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Agreement.

Elena Luria | Dreamstime.com

The UKCA mark is expected to cover a variety of PPE products, including motorcyclists' footwear

In conclusion

The withdrawal of the UK from the European Union has required new national legislation which, initially, will mirror that of the EU. This will require PPE being placed on the UK market, excluding Northern Ireland, to carry a new UKCA mark. This legislation becomes effective on 1st January 2021 and, depending on circumstances, will apply to PPE either on that date or 12 months later on 1st January 2022. SATRA is now in a position to certify PPE products for both CE marking and UKCA marking, enabling manufacturers to continue to supply PPE into both the European and UK markets.

How can we help?

Please email ppe@satra.com for further information on testing and certification of PPE for the European and UK markets.

Publishing Data

This article was originally published on page 30 of the November 2020 issue of SATRA Bulletin.

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