Hot Spot UKCA Marking without a UK Approved Body now Permitted for up to 5 years

What is it?

Hot Spot BV002526 informed members of easements to the introduction of the UKCA marking scheme announced by the UK Government during June 2022. Further details have now been published in the revised Statutory Guidance for the Pressure Equipment (Safety) Regulations which can be found at Pressure Equipment (Safety) Regulations 2016: Great Britain - GOV.UK ( In section 10 more details of the scope of the easements is now given as follows:

On 20 June 2022, the Government announced it intends to introduce legislation which will allow completed conformity assessment activities carried out under EU requirements (including existing testing, certification, and contractual arrangements relating to the quality control or auditing of existing certificates) undertaken by non-UK conformity assessment bodies (CABs) (accredited by their national accreditation body) for CE certification before 1 January 2023 to be used by manufacturers to declare existing product types as compliant with UKCA. Products must still bear UKCA marking. For ongoing production, they will need to undergo conformity assessment with a UK Approved Body once any of the relevant CE certification has expired, or after 5 years (31 December 2027), whichever is sooner.

This will allow manufacturers to apply the UKCA mark without the need for any UK-recognised CAB involvement and continue to place their goods on the GB market, on the basis of an existing CE type examination completed before 31 December 2022, for the lifetime of the certificate issued, or until 31 December 2027 (whichever is sooner).

These measures are aimed at easing requirements relating to the process of introduction of the UKCA mark however, it is still mandatory to mark applicable products with the UKCA mark from 01/01/2023. To ensure a complete understanding of the requirements, it is strongly recommended that members read the new PE(S)R statutory guidance in full.

Why is it Important?

The revised statutory PE(S)R guidelines bring further clarity to the previous announcement regarding “re-testing costs”. It is now clear that the scope of the easement includes not just type approval testing, but also certification and quality control auditing to the PED by EU Notified Bodies.

This means that any members who are manufacturers and have not yet engaged the services of a UK Approved Body to UKCA mark their products, potentially have a further 5 years before this is necessary. For example, any member who uses PED module D, D1, H or H1 for their products with NB approval validity after 31/12/2022 may now apply the UKCA mark to products falling in category II and higher without using a UK Approved Body until 31/12/2027, or the date that their current CE certification expires.

This Hot Spot has been issued to alert members to this important change, the existing BVAA UKCA guidelines will be updated over the coming days in order to fully 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 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

Published: 15th September 2022

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