The UKCA marking came into effect on 1 January 2021 with a requirement for all sectors (apart from medical devices which has until 30 June 2023), to display the new UKCA marking from 1 January 2022. However, recognising the impact of the pandemic on businesses, the deadline for implementation has been extended for a further 12 months.
This means that recognition of the CE mark will end on 31 December 2022 and businesses must take action to ensure they are ready to apply UK Conformity Assessment (UKCA) marking by the final deadline. This applies to all goods where businesses were due to begin using the UKCA marking by the end of this year (2021).
With the 12 month extension in place, manufacturers and importers can continue to apply to EU Notified Bodies for EU Certificates of Conformity allowing them to use the CE mark in the UK until 31 December 2022. The BMTA recognises the benefit this extension provides manufacturers and importers. However it remains concerned this is eroding the UK Conformity Assessment market, with some former UK Notified Bodies having already ceased their UK based operations as they have lost business. Some of them have closed down altogether, while others have migrated operations to the EU to retain their status as EU Notified Bodies, in order to take advantage of what they see as better business opportunities. This has led to a net reduction in UK coverage, capacity and capability for Conformity Assessment.
The BMTA remains concerned about the timing of the introduction of the UKCA mark and the lack of detailed supporting guidance.
The BMTA also notes concern at the introduction of Easements which recognise tests carried out by EU Notified Bodies as having UKCA equivalence. This is in direct contradiction to the objectives of the legislation. Whilst we recognise that it is expedient to adopt this approach it again mitigates against UK Approved Bodies (ABs) extending or expanding their capability to deliver this service in the UK.
The BMTA believes that ABs need clarity on what the regulatory requirements for UKCA marking are, as well as clarity on the timing of their introduction. This lack of clarity has failed to encourage UK ABs to come forward and develop their capabilities and capacities.