Also online at: www.dijonline.co.uk 24 THE door industry journal summer 2022 Industry News Stop Press: UKCA Marking Update Since the Brexit transition period ended on 31 December 2020, the rules for UK conformity assessment and marking have changed. In late 2020 it was announced that CE marking in GB would be replaced by UKCA marking by the end of 2021. This was later deferred to the end of 2022 to give manufacturers more time to make the necessary adjustments. The shift from CE to UKCA marking comes with new requirements for documentation and, in certain circumstances (explained below), conformity testing and certification. Products covered by the Supply of Machinery (Safety) Regulations, such as powered doors, gates and barriers, will need their Declaration of Conformity to be altered to refer to the appropriate UK Regulations rather than the EU Directives when manufacturers make the change from CE to UKCA. UKCA marked products covered by the Construction Products Regulations such as industrial doors, garage doors, external pedestrian doorsets, and some building hardware products are required to have their AVCP system 3 characteristics tested by a UK-approved test body and certification of their AVCP system 1 characteristic to be provided by a UK approved certification body. As many products that circulate on the GB market have their origins in the EU, currently many are relying on testing and/or certification from EU notified bodies, which presents a need for re-testing and re-certification. Throughout 2021 and 2022 it has become obvious that there would not be time or capacity within UK-approved assessment bodies to facilitate the required re-testing. dhf and many other construction-related trade bodies have been lobbying UK Government, both via the UK Construction Products Association (CPA) and independently, to provide a solution for the approaching logjam. One dhf member even instigated a parliamentary question by their local MP, and dhf wrote to the appropriate Government ministers in the search for a solution. Thankfully, the UK government has now (20th June 2022) announced that it will put in place additional measures to assist GB market operators, and the situation relating to construction products is now as follows: 1. Existing AVCP system 3 type-test reports from an EU-notified test body that are dated up to 31st December 2022 will be permitted to support UKCA marking. This change will affect industrial doors, garage doors, and external pedestrian doorsets. It is not yet clear whether there will be a time limit after which EU test evidence will cease to be acceptable for AVCP system 3 products. 2. UK-approved test bodies are permitted to subcontract testing work to other providers in the UK, EU or elsewhere, but they must be approved by UKAS for the testing work they sub-contract and any test report that is issued must be from the UK assessment body concerned, not the sub-contractor. 3. For certification under AVCP system 1, the certificate of constancy of performance must be issued by a UK-approved certification body which is free to subcontract the testing to both UK and non-UK bodies, on the basis that the UK certification body remains fully responsible for the work done. This affects the fire and smoke resistance characteristics of industrial doors and external pedestrian doorsets; also affected are relevant building hardware products and emergency exit doorsets. This situation has not changed as a result of the latest government announcements. 4. CE marked products that are already in stock with GB distributors at the end of 2022 are regarded as having been placed on the GB market before the deadline and can continue to circulate on the market after this date. Records should be kept to demonstrate that the product was placed on the GB market before the end of 2022. Some EU certification bodies have set up UK subsidiaries to facilitate the transfer of EU certification to a UK body for UKCA marking. The Declaration of Performance for a UKCA marked construction product must include the following text: “This Declaration of Performance is issued, in accordance with Regulation (EU) No 305/2011 as it has effect in the United Kingdom, under the sole responsibility of the manufacturer identified.” In Northern Ireland, recognition of CE marking continues under the Northern Ireland Protocol; UKCA marking is not recognised in NI. If the CE marking is dependent upon mandatory third-party conformity assessment, and this is provided by a UK body, then the CE marking must be accompanied by the UKNI marking. Note that the CE plus UKNI marking is not recognised outside NI (except where “unfettered access” applies - see below) and that the UKNI marking is never used separately from the CE marking. Under the ‘unfettered access’ provisions granted by the UK government, businesses in NI are permitted to place qualifying products on the GB market bearing any marking which is valid in NI (CE, or CE plus UKNI); it will not be necessary to apply the UKCA marking for this purpose. dhf will continue to monitor developments and keep the industry informed via our Technical Standards and training. www.dhfonline.org.uk
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