The UKCA marking – a new UK conformity assessment marking
On 31 January 2020 it was time. The UK left the EU and thus the European Single Market and the European Customs Union following the agreed transition period. As a result, EU laws and regulation or directives are no longer applicable in the UK, and are now replaced by UK laws, regulation, markings, etc. One example of this is the UKCA marking, which now applies to construction products in the construction sector. The German Ü mark for conformity that labels construction products complying with the Model Administrative Regulation on Technical Building Regulations (MVV TB) can be considered a model for the UKCA marking.
The MVV TB – a basis for the UKCA marking?
In Germany, the MVV TB is used for the technical regulation of construction products that do not have the CE marking and is implemented by the individual states as an administrative regulation. When the MVV TB was introduced in 2017, it replaced the Building Rule Lists A, B, and C and the list of Technical Building Regulations. With what is known as the Ü marking according to MVV TB, manufacturers confirm that their products comply with the technical regulations and that they observed the requirements of MVV TB which are necessary for manufacturers to make a declaration of conformity when producing their products. There are three options for making such a declaration of conformity:
- Manufacturer’s declaration of conformity (ÜH)
- Manufacturer’s declaration of conformity after prior inspection of the construction product by a recognized inspection body (ÜHP)
- Certificate of conformity from a recognized certification body (ÜZ)
In addition to the MVV TB, there are several other administrative regulations: e.g. the ordinance on building regulations for construction products and types of construction in North Rhine-Westphalia (Bauprodukte- und Bauartenverordnung - BauPAVO NRW). This regulation specifies, e.g. that welding work for producing load-bearing steel or aluminum components, reinforced concrete components, etc. may be carried out only by designated specialists with the appropriate equipment, which must also be verified by an examination body recognized in accordance with the NRW building code.
The Ü mark according to MVV TB is thus equivalent to a CE marking with declaration of performance. Unlike MVV TB, the UKCA marking is not a regulation for cases for which there are no harmonized technical rules, but a separate regulation with marking that applies to all construction products to be placed on the UK market
The UKCA marking – from the CE marking to the “UK marking”
The introduction of UKCA marking as a British standard brings several changes for manufacturers:
- Products for the construction industry must have the new UKCA marking in the future.
- The evaluation and verification of consistent performance are now carried out by a “UK approved body” (not equivalent to a notified body under EU law)
- “UK approved bodies” are listed in a separate UK list.
- Manufacturers of products according to EN 1090 ff must be certified by a "UK approved body" as of 1 January 2023. Products without UKCA marking are considered to be non-compliant products, which are to be removed from the UK market in the course of increased market surveillance.
- Technical documentation serves as proof that a product complies with the regulatory requirements and must be submitted to the market surveillance authorities upon request. In addition, a retention period of 10 years applies.
- In terms of content, the specific requirements placed on the product must be taken into consideration. This always applies to any documentation of how the product was measured, designed and manufactured, how the product was proven to comply with the relevant requirements, and the address of the manufacturer and any storage facilities.
- Before the UKCA marking may be attached to the product, a “UK Declaration of Conformity” must be issued. The UK government recommends a separate EU Declaration of Performance to be issued as well.
- There is a separate provision for products that are imported from Northern Ireland to Great Britain.
- The shape, appearance, and dimensions of the UKCA marking are defined as follows:
* Source: www.gov.uk/guidance/using-the-ukca-marking
For construction products, there is a transition period for these regulations until 1 January 2023. The following table provides information on the required labelling of products during and after this period.
Construction products according to EN 1090-1 and the UKCA marking
Manufacturers of construction products according to EN 1090-1 can place their goods on the market of the United Kingdom only on the basis of a valid UKCA certification with a UKCA marking. Manufacturers/distributors can obtain this certification only from the bodies that have been recognized by the UK government. One of these recognized “UK conformity assessment bodies” is TWI Ltd. (The Welding Institute). Thanks to the cooperation with TWI Ltd., there is a special option of applying for additional UKCA certification based on certification of the factory production control according to DIN EN 1090-1 by DVS ZERT GmbH. In addition to compliance with the specifications of the DVS Zert certification body, the following additional requirements must always be met for successful certification:
- All audit documents must be available in English
- The records of a successful audit carried out according to DIN EN 1090-1 by the auditor from GSI – Gesellschaft für Schweißtechnik International mbH must be available
- There must be a valid contract between the customer and TWI for the DVS Zert
Any questions about the UKCA marking? Our experts in the relevant locations would be happy to help: https://www.gsi-slv.de/dienstleistungen/audits/
For further information, see the website of the DVS Zert certification body:
about autor
Jörg Mährlein
Stellv. Niederlassungsleiter SLV Duisburg
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