Hot Spot UK Government Announces Measures to Ease the Introduction of UKCA Marking Requirements

What is it?

The UK Government have announced changes attempting to make it simpler for members to apply UKCA marking to valve and actuator products placed on the market in England, Scotland and Wales. These measures are aimed at easing requirements relating to the introduction of the UKCA mark on 01/01/2023, but the mandatory implementation date remains unchanged.

The details of the announcement can be found at Government to make it simpler for businesses to apply new product safety markings - GOV.UK (www.gov.uk) and are summarised below. It is important to note that the legislation enacting these changes has not yet been published, so the information in this Hot Spot relies solely on the announcement and further information supplied by UK Government in recent webinars and a consultation meeting between BEIS and BVAA to discuss the effect of these measures.

1. Reducing re-testing costs
Conformity assessment activities undertaken by EU bodies before 01/01/2023 may be used as the basis for UKCA marking products until 12/12/2027 or when these certificates expire, whichever is the sooner. This will be the subject of legislation to be put into place later in this year however, it has been indicated that the following activities fall within the scope of “re-testing”
▪ CAB Type approval testing and design examinations
▪ Certification of NDT personnel
▪ Certification of permanent joining personnel and joining (welding) procedures
▪ Certification of material manufacturers’ QA systems

2. Removing the need to re-test existing imported stock
Existing products which are CE marked and have been imported into the UK before 01/01/2023 may be sold after this date without re-testing and applying a UKCA mark.
This does not apply to products where further manufacturing or processing is conducted in UK after 01/01/2023.

3. Continuing to accept spare parts onto the GB market
Spare parts will continue to be accepted into the GB market which comply with the same requirements that were in place when the original pressure equipment was manufactured or supplied.

4. Extending labelling measures
The original interim arrangement to allow a sticky label or accompanying document to satisfy the UKCA marking requirements is to be extended until 31/12/2025 through legislation to be introduced this year. This change is intended to reduce cost and ease logistics issues associated with managing existing stock. This requirement includes importer details as well as the UKCA marking.

5. Recognising historic testing on some construction products
Any member’s products that fall under AVCP system 3 of the construction products directive and are tested by an EU Notified Body before 01/01/2023 will be able to be UKCA marked without having to retest through a UK Approved Body.

Why is it Important?

The announcement made by the UK Government is a general announcement and so needed some further clarification of its applicability to BVAA members. The measures regarding removing the need to re-test existing imported stock and continuing acceptance of spare parts onto the GB market, in the context of BVAA members, simply confirm the current situation already widely understood in the industry. Point 5 is also welcome but is likely to have limited impact on most members activities.

The most significant elements of this announcement for the majority of BVAA members will be points 1 and 4 covering existing EU CAB certifications and labelling requirements:

Allowing the 4 types of certifications listed under reduced re-testing costs will allow members to continue to use existing certification issued by an EU CAB until it expires, or for the next 5 years if sooner or no expiry date is given on the current certificate. This easement represents an important concession to any members or their suppliers who have not yet completed the transition to dual certification for product testing and type approval, NDT or welding activities.

However, the most significant aspect for members is likely to be the acceptance of existing material suppliers QMS approval certificates accredited by EU CABs. According to the OPSS’s slide deck issued 27/06/22, this will allow these suppliers’ material to be used for main pressure-bearing parts after 01/01/2023, without the need for dual certification until the expiry of their current EU QMS certificate or 12/12/27. It is hoped that this will help to ease the potential material supply issues that many members are now facing. It should be noted that material suppliers will still be required to obtain QMS system approval accredited by a UKCAB upon the expiration of their existing certificates.

The two year extension until 31/12/2025 of the period that a sticky label or accompanying document is permitted to be used to satisfy the UKCA marking requirements will also serve to ease logistics and labelling costs. However, it should be noted that the legislation to allow this still needs to be amended and that the accompanying document must stay with each product until it reaches the end user.

This Hot Spot is issued to provide members with a prompt awareness of this important change. The BVAA will update existing guidelines on UKCA over the coming days in order to reflect these changes.

Continuous Improvement - Did we miss anything?

Hot Spots are intended to alert members and provide a brief overview of new standards, activities or procedures that are being introduced in the industry. If there is key information missing that would be helpful, please let us know so that we can improve our future service.

Please Note: This Hotspot is for information purposes, and we invite comments from BVAA members only. Please also note that at time of publication ballots may be closed. For more information, please contact the Secretariat.

BVAA Members: Did you know we have a hotspot tab on the BVAA website? Head over to www.bvaa.org.uk/login-here.asp and log into the member only area. You then need to select ‘Hotspots’ for the latest. For information on how to access the member only area of the website please contact jane@bvaa.org.uk


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