BREXIT

Introduction

On 31 December 2020, the United Kingdom (England, Scotland and Wales) left the European Union, creating a new political context for the free movement of goods and the regulations in force.

Northern Ireland has a specific status (see below).

As of 1 January 2021, the UKCA (UK Conformity Assessed), Rho and the Red Ensign marking came into force to replace the CE, Pi and wheel marking for products intended for the UK market.

Those new markings will be required for products subject to UK legislation equivalent to all EU directives/regulations that required CE, Pi and wheel marking. This refer to directives like the Pressure Equipment Directive, the Simple Pressure Vessels, the Transportable Pressure Equipment Directive and the Marine Equipment Directive.

To allow companies to adapt to the new requirements, there is a transition period where :

The Pi and wheel marking will be accepted until 1 January 2023.

The CE marking will be accepted till the 1 January 2025 and even later for some specific products (CPR).

If you are a European company wishing to export your products to the UK or if you are a UK company wishing to put your products on the UK market,  you will need to apply the new UKCA marking as soon as possible to continue your activities with peace of mind.

What are the differences between the UKCA, Rho and Red Ensign marking and the CE, Pi and Wheel marking ?

There are currently very few technical differences between the two types of marking.

The UKCA marking applies to items that require a CE marking.

The Rho marking applies to items that require a Pi marking.

The Red Ensign marking applies to items that require a Wheel mark.

It can only be affixed if the products have been assessed by bodies approved by the UK authorities.

Bodies can obtain temporary approval while awaiting accreditation by UKAS.

The UKCA, Rho and Red Ensign marks will not be recognised on the EU market.

Self-declared CE manufacturers can also do so for the UKCA marking.

Double marking is possible (CE and UKCA or Pi and Rho or Wheel & Red Ensign) for products destined for both the EU and UK markets.

The UKCA marking cannot be used for the Northern Ireland market, which requires CE marking or UK-NI marking.

How to get the UKCA, PI or Red Ensign ?

Companies must prepare for the end of CE, PI and Wheel mark recognition in the UK and affix the UK mark by using an "Approved body" recognised in the UK.

Prior to this, manufacturers wishing to access the UK market must take into account the new UK legislations applicable to their products and adapt their existing EU technical documents.

Apragaz Asbl and its subsidiary Apragaz Ltd. can assist you in your UK marking procedures (as well as your EU marking).

Last publication from UK Gov regarding the placing of manufactured goods on the UK market

https://www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-great-britain