It is time to prepare for changes in construction products, as there is only one year remaining until CE marking (which stands for Conformité Européenne) will no longer be recognised as the compliance mark for installations in Great Britain, and instead the UKCA marking (which stands for UK Conformity Assessment) will be needed. Construction product manufacturers, designers, importers and distributors that are supplying goods with the CE mark, should take steps to convert to the UKCA mark without delay, and as the compliance mark cannot be relied upon until the applicable standards have been identified, tested and assessed as compliant by the testing house or accredited organisations, a year is a relatively short period of time to prepare.
The continued recognition of the CE marking as the compliance mark for GB, has been due to an extension to the original Brexit transition period to allow businesses time to transition to the new standards for the last few years. However, as there is divergence between the EU and the UK as regards safety and environmental standards for construction products, the expectation is that the same EU pre-Brexit standards should not continue to be the applicable standards in GB.
The time has come for conversion to the GB applicable laws. So, from this time next year, and specifically after 30 June 2025, only the UKCA marking can be affixed for construction products placed on the market in Great Britain. Therefore, rather than being certified to the harmonised standards, it is the new designated standards that UK approved bodies operating under EU Construction Products Regulation 2011 (EU Regulation No. 305/2011) and based in the UK will be assessing for safety.
It is important to note the following when putting these changes in place:
- Businesses must ensure that they are using UK approved bodies for testing and certification for products supplied to the GB market.
- Where a UK notified body which became a UK approved body had carried out tasks or issued certification in relation to the Assessment and Verification of Performance (AVCP) for a product before 1 January 2021, then those tasks and/or that certification may be used to support affixing of the UK marking, if the product is supplied to the GB market after this date.
- The UKCA marking will not be valid in the EU and therefore dual marking of products placed on both markets will be necessary. This will require testing to the GB standards, as well as the EU standards.
- The UKCA will need to be applied to the product or its packaging from 1 January 2028, but until then it can be added to documentation that accompanies the product in transportation, or a label that can be added to the product. This is a further transition period agreed by the Office of Product Safety and Standards.
- There appears to be some time to prepare, however the timeline in the legislation states that the compliance mark cannot be affixed to products until the applicable standards have been identified, tested to, and certified. This includes assessment of the applicable standards, passing the testing procedures for safety and potentially environmental compliance, and that the requisite certifications are also in existence. Our recommendation is that this time is utilised. This will avoid delays and ensure that goods placed on the market from that date are compliant and competitive for GB sales.
- Note: This guidance does not cover goods supplied to the Northern Ireland market or goods supplied to the GB market from Northern Ireland.
If you would like further information on how these changes might affect you and your business, please don’t hesitate to get in touch.
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