Building bridges for uncomplicated market access in the UK after Brexit
Important news: UKCA labeling is temporarily suspended!
Great Britain has left the EU and is therefore no longer part of the European domestic market.
The original plan was that, instead of the CE mark, British and European manufacturers of construction products would have to mark their products with the UKCA mark (after a further delay) from June 30, 2025, to ensure market access in the United Kingdom.
On September 2, 2024, however, the British Ministry of Housing, Communities & Local Government announced in a statement that the further implementation of the British conformity procedure "UKCA" for construction products would be suspended for an indefinite period.
If it is made mandatory for imports, a coexistence period of two years is also planned.
This means that construction products from the EU can continue to be placed on the UK market with the CE mark even after the original deadline of July 1, 2025.
However, the UKCA mark remains valid in the UK market.
The manufacturer is free to choose which of the two marks he wishes to use to indicate the conformity of his construction product, in accordance with the relevant rules.
At present, the verification criteria are still the same. How to proceed in the event of a difference in the rules in the future (e.g. different versions of a test standard) is a matter for the relevant authority in the UK to define.
For tests as a basis for the UKCA mark, Approved Bodies in the UK must be involved. As a Notified Body in the EU, ift Rosenheim therefore works with its cooperation partners UL, BSI and 4ward Testing, which are Approved Bodies in the Great Britain.
However, ift Rosenheim and its partners continue to offer the opportunity to provide the basis for a UKCA marking.
Die Voraussetzungen sind wie folgt:
- For tests as a basis for the UKCA mark, Approved Bodies in the UK must be involved. As a Notified Body in the EU, ift Rosenheim therefore works together with the cooperation partners UL, BSI and 4ward Testing, which are Approved Bodies in the UK.
- We will help you to confirm the compliance of your products with the UKCA mark.
Possible paths to the UKCA mark
- The procedure for the UKCA mark is similar to that for the CE mark
- The basis for the tests are (currently) still EN standards as they apply to the CE mark
- Only products for which a CE mark is mandatory (currently) require a UKCA mark
- However, rules in the UK can change independently of the rules in the EU
Recognition of „historical“ test data
Extrapolation and translation of existing test reports and verifications as well as implementation of any necessary audit visits by ift Rosenheim together with the cooperation partners.
Possible for:
- Test results & certifications in AVCP system 1
- Possibility of recognition of historical test results for AVCP system 3 is currently not possible. Necessary verification for the UKCA mark can be provided by ift Rosenheim in cooperation with the British partners
Good to know:
Through mutual recognition, ift Rosenheim can use existing test results of the cooperation partners that were obtained before Brexit (February 1, 2020) as a basis for the CE mark.
New tests for the UK and the EU
Carrying out new tests as well as any necessary audit visits as a basis for CE and UKCA marking by ift Rosenheim together with the cooperation partners.
Possible for:
- Test results & certifications in AVCP system 1
- Test results in AVCP system 3
Good to know:
As with the CE mark, the UKCA mark is currently based on EN standards. Due to the mutual recognition of ift Rosenheim and its partners, only one inspection is therefore necessary in many cases. In addition, optimisation is possible if monitoring is required.
