Export these products please note! The UK will open the UKCA certification mark to replace the CE mark!
Export these products please note! The UK will open the UKCA certification mark to replace the CE mark!
Toys, aerosols, personal protective equipment, machinery, low-voltage electrical equipment ...... etc. are on the list.
September 1, 2020, the British government officially announced that the United Kingdom has left the European Union, January 1, 2021 officially began to use the United Kingdom Conformity Assessment (UKCA) certification mark, the end of this year will end the transition period for the use of product marking in the United Kingdom after Brexit.
The majority of products currently under the control of CE marking will be required to bear the UKCA mark if they are to be exported to the UK market (England, Wales and Scotland) in the future, and UKCA will be used as a mandatory access mark for the UK market. All products must comply with the British Standards beginning with "BS".
The implementation of the UKCA mark, the original only need to CE certification of products exported to the EU and the UK will need to CE and UKCA certification, which may have a significant impact on the cost of the enterprise products, the need for a high degree of attention.
For UKCA a lot of foreign trade people still have some questions, today we will be a little bit of these issues, I hope to help you.
01
When will the use of the UKCA mark become mandatory?
After January 1, 2021, products that meet all of the following criteria will need to use the new UKCA mark immediately.
Products manufactured for the UK market;
Products for which the use of the UKCA Mark is mandatory by law;
Products that require mandatory third party conformity assessment;
Products that have been conformity assessed with a UK conformity assessment body.
and the conformity assessment documentation has not been transferred from a UK body to an EU-recognized body by January 1, 2021 (if the transfer is successful it is considered to be equivalent to CE marking and can be used to continue to be sold in the UK market without the mandatory use of the UKCA mark).
Additional? -? New UKCA Marking Exemptions
These provisions do not apply to existing stock, for example, if the product has been fully manufactured and is ready to be placed on the market by January 1, 2021. In this case, products bearing the CE marking can still be sold in the UK, even if a certificate of conformity has been issued by a UK body.
From January 1, 2022, the CE marking will not be recognized in the UK. However, products bearing the CE mark can still be sold in the UK as long as they also bear the UKCA mark and comply with the relevant UK rules. There are separate rules applicable to medical devices.
Important reminder:
To give companies time to adapt to the new requirements, the CE marking can still be used in most cases until January 1, 2022.The CE marking will only be valid in the areas where the current UK and EU rules remain consistent. If the EU changes its rules and the product CE marking meets the new EU rules, then the product will not be able to be sold in the UK using the CE marking, not even until December 31, 2021.
02
What are the products that will need to use the new UKCA mark?
Mainly for products sold in the U.K. The UKCA mark will apply to most goods that currently use the CE mark. The UK is encouraging companies to be ready to use the UKCA mark as soon as possible before this date.
The following are the specific product areas covered by the UKCA Mark:
Toy safety
Recreational craft and personal watercraft Recreational craft and personal vessels
Simple pressure vessels Simple Simple pressure vessels
Electromagnetic compatibility
Non-automatic weighing instruments?
Measuring instruments? Lifts
ATEX ATEX
Radio equipment Radio equipment
Pressure equipment Pressure equipment
Personal protective equipment Personal protective equipment
Gas appliances Gas appliances
Measuring instruments? appliances Gas appliances
Machinery machinery
Outdoor noise Outdoor noise
Ecodesign
Aerosols
Low voltage electrical equipment Low voltage electrical equipment
Restriction of hazardous substances
Products covered by the UKCA mark but with some special rules:
medical devices Medical devices
railway interoperability? rail interoperability?
construction products Construction products
civil explosives Civil explosives
03
How do I use the UKCA Mark? How do I place it?
In most cases, the UKCA mark must be used on the product itself or on the packaging. In some cases it may be placed on manuals or other supporting documentation. This will vary depending on the specific regulations that apply to the product.
General rules apply:
a. the UKCA Mark may only be placed on the product by the manufacturer or an authorized representative (where permitted by the relevant legislation);
b. when the UKCA Mark is affixed, the manufacturer or authorized representative becomes solely responsible for the product's compliance with the requirements of the relevant legislation;
c. the UKCA Mark may only be used to show that the product complies with the relevant UK legislation;
d. the manufacturer or authorized representative must not place on the product any mark or logo which could cause a misunderstanding of the meaning or form of the UKCA mark to a third party;
e. no other marking may be affixed to the product which affects the visibility, legibility or meaning of the UKCA mark;
f. except where required by law, the The UKCA Mark must not be used on the Products.
Specifications for the UKCA Mark:
The letters in the UKCA Mark must be scaled in proportion to the official logo.
The height of the UKCA mark is a minimum of 5mm, unless the relevant legislation specifies a different minimum size.
The UKCA mark must be clearly visible (from January 1, 2023 it must be permanently attached to the product).
For general products covered by the UKCA mark, the following transitional measures apply:
Before January 1, 2023, for most goods (except those subject to special rules), there is an option to attach the UKCA mark to a label affixed to the product or accompanying documentation.
Operators (whether manufacturers, importers or distributors) should take reasonable steps to ensure that the UKCA mark remains valid.
Products requiring the UKCA mark cannot be supplied without it (unless the CE marking is used before January 1, 2022)
From January 1, 2023, the UKCA mark must be printed directly on the product in most cases, and manufacturers should incorporate this date into the product design process.
The UKCA Mark transitional measures do not apply to specially specified products such as construction products, medical devices, interoperability equipment for railroad systems and transportable pressure equipment.
04
Will the UKCA Mark be recognized in the EU?
No. The UKCA marking will not be recognized in the EU market after the transition period. Products that currently require CE marking will continue to require CE marking to be sold in the EU. In order to continue to sell products in the EU, UK-based manufacturers will need an authorized representative to do so.
05
Will the CE mark still be used after the UK leaves the EU?
There has been no official notice from the UK government yet, but the UK government has promised companies that there will be a consultation period followed by a notification period before CE is completely phased out.
Industry insiders say the timing of the transition period may depend on the UK's exit negotiations in the coming months. Any manufacturer selling to both the EU and the UK is advised to be prepared to add both quality marks to their goods at least by the end of the year.
It is worth noting that chemicals, pharmaceuticals, cosmetics and food products do not have CE marking and may not need UKCA marking in the future - these types of goods are covered by separate labeling requirements.
06
What are the implications for domestic exporters and how should they respond?
The official implementation of the UKCA marking in the UK, products exported from China to the EU that require CE marking will require UKCA marking if they are exported to the UK, increasing the cost of certification.
From the statistics of recent years, China's main exports to the United Kingdom product categories for mechanical and electrical products, furniture and toys, textiles and raw materials, in addition, light metals and products, plastics and rubber and chemical products are also important commodities imported by the United Kingdom from China, which electromechanical products, toys, products are the main scope of coverage of the UKCA mark.
So the related products export enterprises need to pay attention to, timely access to trade on the relevant product certification requirements, prepare certification materials in advance, as soon as possible to complete the product certification, in order to prevent unnecessary losses caused by this.
Important additions? The impact of Brexit on exporters and freight forwarders and their response
There are less than 2 months to go before the end of the transition period for the UK's formal exit from the EU. As a result, exporters and freight forwarders are bound to face tariff changes, lengthy customs clearance procedures, and freight congestion. A study by the Organization for Economic Cooperation and Development (OECD) found that Brexit would increase freight transaction costs by up to 24 percent of the value of goods.
The possible impacts of Brexit are as follows:
1.? No longer applying EU custom tariffs
The EU's regional integration has the nature of a customs union, setting ****same tariffs externally and liberalizing trade internally. This means that member states cede tariff-setting powers to the EU and cannot independently negotiate trade agreements with other countries outside the union.
After Brexit, China-UK trade trade will operate according to World Trade Organization (WTO) rules, and the UK will make certain adjustments to China-UK trade policy according to its own situation.
2.? Customs clearance of goods in and out of the EU and the UK becomes complicated
Originally, under the EU's unified customs system, goods entering and leaving the EU do not need to undergo repeated customs clearance and taxation procedures. After Brexit, the UK and the EU will operate as separate customs systems. The original EU harmonized HS system is bound to change, and the customs clearance procedures for goods entering and leaving the country through both sides will be much more complicated than before.
3. China Customs and the EU's AEO mutual recognition is affected
After Brexit, even if the UK extends the EU and China's AEO mutual recognition, the two countries will still have to carry out a separate mutual recognition signing, which is the most ideal result. If there are differences between UK Customs and Chinese Customs consultations, then the two sides will have to restart negotiations, resulting in the disappearance of the previous customs dividend.
4.?EORI number to expire in EU
The EORI number is a necessary registration number for any enterprise with economic activities, especially import and export business, in the EU countries, and is used to identify every import and export trade declared by an enterprise, trader or individual. The number is common throughout the European Union as long as it is registered with the customs authorities of the country where the enterprise is located.
5. UK ports will see massive delays in port congestion
After Brexit, UK truckers will be subject to the 1968 Vienna Convention on Road Traffic, and transport capacity will be greatly reduced, leading to higher road transport prices.
How should exporters and forwarders respond?
1. Keep an eye on the latest news and adjust the freight arrangement in time
2. Apply for the EORI of EU countries as soon as possible
Many exporters used to solve the whole European customs clearance problem by an EORI starting with GB.
Many exporters used to solve the whole European customs clearance problem with one EORI beginning with GB. The EORI number of EU countries is common and unique, but GB is not working now, so we need to apply for the EORI of EU countries as soon as possible.
For example, if the market of Germany is relatively large, we suggest to apply for the EORI of Germany, which is the EORI beginning with DE, and of course, each enterprise has its own focus, and it can apply for the EORI of which country it chooses by itself.
Finally, to remind the British customers of the foreign trade, timely access to relevant product certification requirements, as soon as possible to complete the product certification, in order to prevent unnecessary losses.
(This article is reprinted in focusvision)