Actuate UK requests more time on UKCA Mark transition

June 25, 2021

The engineering services alliance highlights the important issue

Actuate UK, which SNIPEF is part of, has issued a warning about serious consequences for businesses, public and commercial projects as well as domestic customers in only six months if a major issue regarding product compliance and standard marking is not resolved. It asks for an extension of the transition time to the new arrangements to avoid delays and allow all products to be tested and accredited.      

The Government plans for the new ‘UKCA’ Mark to entirely replace the established EU ‘CE’ product Mark across the country by the end of this year.  The aim of both CE and UKCA marking is to show that products meet 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.

As such, if any UK manufactured or imported engineering services product that needs to show these essential features cannot display a UKCA mark by the end of 2021 this will leave manufacturers and installers, clients and the public dealing with serious quality and contractual issues. In some product categories, industry is estimating that 64 years’ worth of retesting will be required, and we currently only have 7 months. 

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 and services industries and requesting that the government continues to recognise the CE mark until at least the end of 2022. Actuate UK adds that during this this time, products used in Great Britain should be allowed to bear either or both marks.     

CEO of Federation of Environmental Trade Associations (FETA) Russell Beattie explained:

“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) added on how the issue is impacting the sector:

“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 this year.  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.”

Tom Garrigan, Technical Director for Building Services Research and Information Association (BSRIA) raises similar issues for other products:

“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 21, assuming there is one with the relevant accreditations.  

As an example, there are 8 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 7 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.”

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