Update to UKCA marking of PPE products

Explaining the revised UKCA conformity assessment for personal protective equipment being placed on the UK market.

Image © iStockPhoto.com | kadmy

The United Kingdom (UK) left the European Union (EU) on 31st January 2020, and was in a transition phase where EU legislation still applied until the end of December 2020. Since that time, the UK has adopted its own legislation with regard to placing personal protective equipment (PPE) goods onto the market in Great Britain (GB – consisting of England, Scotland and Wales). The PPE Regulation (EU) 2016/425 has been brought into UK law to become ‘Regulation 2016/425 on personal protective equipment, as amended to apply in GB’.

Figure 1: The UKCA mark

The UK legislation involves the use of a new UKCA mark (shown in figure 1), which needs to be affixed to the product as a means of showing conformity with applicable UK legislation.

This means that to place PPE on the market in Europe (that is, the UK and EU member states), a manufacturer will need to affix both the UKCA and CE marks – although, as explained below, UKCA marking will not be mandatory for products placed on the GB market before 31st December 2024.

For Category II and Category III PPE, the manufacturer must work with a Conformity Assessment Body (CAB), which for the EU is a ‘Notified Body’ and for the UK is an ‘Approved Body’. SATRA Technology Centre Limited in the UK became UK Approved Body Number 0321 on 1st January 2021, so can issue UKCA certification. SATRA is also still able to offer CE marking services through SATRA Technology Europe Limited, which remains a Notified Body (number 2777) based in Ireland (an EU member state).

In terms of UKCA marking, there is a transitional phase which allows EU type-examination certificates and Module C2 or Module D decisions under Regulation (EU)2016/425 from an EU Notified Body such as SATRA Technology Europe Limited, to be used as the basis of UKCA marking. For this legislative ‘easement’ to apply, the Notified Body certification must be in place on 1st January 2025 and it will only last until that certificate expires or until 31st December 2027 – whichever comes sooner. At that time, a UKCA certificate from a UK Approved Body (for instance, SATRA Technology Centre Limited) will be necessary. 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 service for all our customers.

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

To summarise the transition to the new UKCA marking system for the GB market (that is, the UK excluding Northern Ireland), there are notable phases which are described below. In each case, it is important to note that these transition dates refer to the specific point in time when the individual product is ‘placed on the market’.

Until 31st December 2024

it is possible to place on the GB market products carrying either the UKCA mark or a CE mark
for Category II and Category III PPE, UKCA marking can be made following the issuing of CE certificates by EU Notified Bodies (therefore no requirement for a UKCA certificate from a UK-based Approved Body)
the UKCA mark and importer information can be affixed to a document accompanying the PPE, such as the packaging, instead of having to mark the product itself.

1st January 2025 to 31st December 2027

it will only be possible to place on the GB market products carrying the UKCA mark – CE marking alone will no longer be accepted
for Category II and Category III PPE, the UKCA marking can be on the basis of CE certificates issued by EU Notified Bodies (hence no need for a UKCA certification from a UK-based Approved Body). However, for this to apply, the CE certification must have been in place on 1st January 2025 and, when this EU Notified Body certificate expires or from 31st December 2027 (whichever comes sooner), a UKCA certification from a UK Approved Body will be necessary
the UKCA mark and importer information can be affixed to a document accompanying the PPE, such as the packaging, instead of having to mark the product itself.

From 1st January 2028

it will only be possible to place on the GB market products carrying the UKCA mark – CE marking alone will not be accepted
to UKCA mark Category II and Category III PPE, a UKCA certification from a UK-based Approved Body will be required (that is, UKCA marking can no longer be based on an EU Notified Body certification)
the UKCA mark must be affixed to the PPE itself (see figure 2) unless this is not practicable to do (for instance single-use gloves and earplugs). In these cases, the UKCA mark must be affixed to the smallest commercially-available packaging. This latter situation is very unlikely to be applicable to PPE footwear.

Figure 2: The UKCA mark must be affixed to the PPE itself unless this is not practicable to do

It is important to note that the UK’s withdrawal from the EU did 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’. The UKAS organisation, along with other European Accreditation Bodies, is a signatory of the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Agreement.

In conclusion

SATRA is world-renowned for its testing and certification services in the field of personal protective equipment (PPE). 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 member state), thus enabling the CE mark to be affixed to products. SATRA is also able to conduct conformity assessment work and issue UKCA certifications from its Approved Body in the UK.

How can we help?

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

Publishing Data

This article was originally published on page 26 of the January 2023 issue of SATRA Bulletin.