Last edited 09 Jul 2021

UKCA mark transition extension for construction products requested

1 Introduction
2 UKCA Mark transition issues
3 Deadline extension to avoid supply chain disruptions
4 Reactions
5 Related articles on Designing Buildings Wiki

[edit] Introduction

On 16 June 2021, the engineering services body Actuate UK issued a warning about serious consequences for businesses, the public and commercial projects as well as domestic customers if - by December 2021 - a major issue regarding product compliance and standard marking is not resolved. It has asked for an extension of the transition time to the new arrangements to avoid delays and allow all products to be tested and accredited.

[edit] UKCA Mark transition issues

Under the current arrangement, the Government plans to move CE marking for construction products to UKCA marking during 2021 so that from January 2022, only products approved and tested to UKCA can be placed onto the market in Great Britain.

The new rules for UKCA marking do not apply to Northern Ireland, where the CE mark will continue to be the product compliance mark. The United Kingdom Northern Ireland (UKNI mark) will be needed in addition to the CE mark for products whose conformity tasks are carried out by a UK Approved Body.

The aim of both CE and UKCA marking is to show that products comply with essential health, safety and environmental protection legislation. However, the problem with the limited transition period is being exacerbated by the lack of UKCA Approved Bodies and available capacity in current certification bodies and product testing facilities to reliably verify that existing or new products meet the UKCA criteria.

[edit] Deadline extension to avoid supply chain disruptions

The issue affects a vast swathe of installed engineering products for both the domestic and commercial sectors, and it could lead to an array of installation cancellations, delays and contractual problems for the supply chain and its customers. Actuate UK members cover the whole process of planning for, testing and installing these products and they are concerned that this could bring the industry to a standstill, while it is still recovering from the pandemic.

To avoid the looming crisis and help with a sensible transition to UKCA marking, Actuate UK is working with others across the construction sector to request that the Government continues to recognise the CE mark until at least the end of 2022.

[edit] Reactions

Tom Garrigan, Technical Director for Building Services Research and Information Association (BSRIA) shared examples related to specific products. He explained, “One of the 21 directives covering products being placed on the market is the Construction Products Regulation (CPR), which is split into five AVCP (Assessment and Verification of Constancy of Performance) systems. There are particular issues surrounding AVCP system 3, as the assessment of products is handled differently to other systems due to the EU Notified Body or UK Approved Body being a test laboratory. The current arrangements require all products with an existing CE mark where testing has been carried out in the EU to be retested by a UK Approved Body by 31 December 2021, assuming there is one with the relevant accreditations.

“As an example, there are eight Notified Bodies in Europe testing heat emitters for CE marking purposes, and if we assume our European counterparts have a similar annual throughput of samples as ourselves, it’s estimated there is 64 years’ worth of retesting required in less than seven months. A clear and urgent decision relating to the application of the UKCA mark to products is required to give manufacturers and UK Approved Bodies much needed time to prepare and comply.”

CEO of Federation of Environmental Trade Associations (FETA) Russell Beattie added, “This is not simply a question of manufacturers failing to prepare for a deadline and is inextricably linked with capacity within the still developing UKCA Approved Body cohort. Nor is this problem limited to our sector. At a time when businesses are trying to rebuild after the COVID-19 challenges, the Government is urged to take the pragmatic step of extending the transition period. It is our understanding this has been done in the case of medical devices, so there is sensible precedent for this.”

Nick Mellor, Managing Director of Lift and Escalator Industry association (LEIA) said, “Under the new arrangements, a wide range of equipment placed on the Great Britain market from 1 January 2022 would need to be UKCA marked. In many cases, where approved bodies are needed as part of the conformity process in place of EU Notified Bodies, there is a critical shortage of Approved Body capacity to deliver re-certification to UKCA rules by the end of 2021. For lifts (and safety components for lifts), there is currently only one UK Approved Body able to undertake such certification, yet we have thousands of such components which we need to be able to use.”