UKCA and UK RoHS
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UKCA Replacing CE Marking in the UK
On February 2nd, 2019, the Department for Business, Energy & Industrial Strategy of the government of the UK drafted UKCA guidance in this regard which was updated on September 1st, 2020. Here is a simplified summary of what we learn from this official publication and what it entails in terms of RoHS compliance.
What is the UKCA Marking?
The UKCA mark is a label that should supplant the CE logo on your products to be placed into the UK's market, under certain conditions. UKCA stands for United Kingdom Conformity Assessed.
Why Replacing the European CE Mark?
Due to the Brexit, the UK Parliament has adopted a UK marking, called UKCA. The UKCA marking enables the UK to diverge from the European CE marking requirements.
Where does the UKCA Marking Apply?
In the UK, of course! To be more specific, if a product is placed into the market of Great Britain - England, Wales, and Scotland - it must bear a UKCA conformity label.
Products sold in the European Union must still be labeled with the CE marking, according to the Blue Guide on CE marking.
The CE or UK(NI) marks still apply in Northern Ireland.
Does UKCA apply to Electronic Equipment?
Basically, yes. A list of in-scope European regulations and products is provided at the very end of the UKCA Guidance. The UKCA marking affects the products under the EU RoHS or the ecodesign ErP directives and special UKCA rules apply to medical devices.
For information purposes, the UK law on Ecodesign is the 'The Ecodesign for Energy-Related Products and Energy Information (Amendment) (EU Exit) Regulations 2019', and the UK RoHS regulation is the 'The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012'.
Is the CE Marking still Accepted in the UK?
To label my product with the CE or the UKCA symbol? That is the question.
The UKCA applies from January 1st, 2021. Still, manufacturers and importers of certain products benefit from a one-year grace period for the transition. After January 1st, 2022, the UKCA will be the only recognized mark in the UK. However, until January 1st, 2023, it is possible to label the packaging or documents accompanying the device, and not mark directly the products with UKCA. After Januray 1st, 2023, the product must directly be UKCA marked.
Additionally, the UKCA marking won't be recognized in the EU. As a result, equipment sold in the European Union and the UK will typically bear both the CE and the UKCA markings.
What is the Game Plan for UKCA Marking?
If you manufacture or import electronic products in the UK:
1 - Build a Robust Technical File for EU RoHS and Ecodesign
Fortunately, the assessment rules on RoHS and ecodesign remain the same as the European Union. You need to perform due diligence, follow recognized standards, and build solid technical files with proofs of compliance. Your products must remain in conformity, considering the regulatory changes and the modifications in your designs, supply-chains, etc.
The record-keeping of your technical file is 10 years after the last product unit is placed into the UK market.
2 - Draft the UKCA Declaration of Conformity
Once a product is deemed fully compliant, you can draft a UKCA declaration of conformity (DoC). Your UKCA DoC will have to include all the applicable requirements, such as UK RoHS. Enviropass recommends that you provide the RoHS exemption status on your UKCA DoC.
For the time being, the standards are the same as the EU ones, with the addition of the prefix 'BS' for British Standards Institution approval. Therefore the IEC 63000 Standard for RoHS assessment - Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances - becomes BS EN IEC 63000:2018 in the UK.
3 - Label your Product with the UKCA
The labeling rules are still essentially the same as the CE marking ones. Like the CE marking, the minimum size is 5mm height. The UKCA marking must normally be affixed on the product itself, on a visible and permanent surface. However, it is possible to provide the UKCA label on an accompanying document until January 1st, 2023.
Note that specific UKCA requirements also apply to medical devices.
Should you have any questions about UKCA and UK RoHS, don't hesitate to contact Enviropass.