Before Brexit in 2020, regulations on product safety and performance in the United Kingdom had been aligned with the European Union since 1974.
Emblematic of that alignment was use of the traditional CE mark on a variety of manufactured goods throughout the European Union, including the UK.
Along with Brexit came the need to create a UK-only mark that served a similar purpose to the customary CE mark.
Transitioning to the new mark
Formation of the UKCA mark followed, indicating conformity with the applicable requirements for products sold in Great Britain.
As of Jan. 1, 2023, new products sold in the United Kingdom must use the new UKCA mark However, transitioning to the new mark has not been easy, and the government has delayed the deadline four times on the path to implementation. Economic issues and the global pandemic were among the factors contributing to the delays.
In the HVAC market, any new electrical products, electric heating equipment, heat pumps, and gas appliances require the UKCA mark. As it stands now, as of Jan. 1, 2023, new products sold in the United Kingdom must use the new UKCA mark.
Existing products have five more years to complete the transition, by 2027.
New framework of standards and regulations
Along with the new UKCA mark comes a new framework of standards and regulations on hundreds of products. Initially, the new framework is almost identical to the EU regulations relating to the CE mark.
However, as time passes, the two marks will represent diverging paths reflecting the differing priorities in the EU and the UK.
For example, the EU will focus more on environmental issues and sustainability, while the UK will shift its focus to fire safety, driven by changing trends after the Grenfell Tower disaster.
Factor slowing the implementation
A factor slowing implementation of the UKCA mark has been fewer “approved bodies,” companies that can evaluate products and manufacturers and award the mark.
Currently there are only four approved bodies in the United Kingdom, far fewer than the 48 “notified bodies” previously available to award the CE mark. The lower capacity could cause bottlenecks as the 2023 deadline approaches.
HVAC market
EU standards are designed to accommodate the range of climate differences in the EU
In terms of energy labeling and performance in the HVAC market, the divergence from EU to UKCA standards will likely occur quickly.
EU standards are designed to accommodate the range of climate differences in the EU – from cold Norway to sunny Greece. However, there is less climate variation within the UK, and climate rules do not have to be as robust.
OPSS enforces the use of the UKCA mark
The UK’s Office for Product Safety and Standards (OPSS) enforces the use of the UKCA mark. Enforcement is not particularly aggressive and is mostly driven by complaints. Legal repercussions of non-compliance generally amount to a fine.
The OPSS rarely takes enforcement action against a company that makes a genuine mistake. The emphasis is to provide education about the benefits of the mark.
Big rush before the first deadline
McKay admits that some companies have delayed pursuing the required UKCA certificates
“It’s difficult to know how many companies still need to get the mark, although thousands of UKCA certificates have been issued,” says Graham McKay, Global Head of Energy Products for BSI Group.
“Companies like certainty, and many of them are taking the approach to get the certificate. We had a very big rush before the first deadline, less by the second and third (following postponements). There have been no big spikes as the new deadline approaches.”
McKay admits that some companies have delayed pursuing the required UKCA certificates because they “hope it might all go away.” But he reiterates that the reality is that it is not going to go away and therefore, companies need “to be planning for and taking the necessary steps to obtain the mark for their products”.
“The easiest solution is to get the piece of paper certifying your product,” says McKay.
BSI Group
BSI Group is a business improvement and standards company that enables organizations to turn standards of best practice into habits of excellence. They are an “approved body” for issuing UKCA certificates.
BSI is a notified body in the Netherlands and can provide both UKCA and CE certificates in a single “package” based product
BSI has driven best practices in organizations around the world, working with over 77,500 clients across 195 countries. They have assessors in 90-plus countries to evaluate products.
The company operates both inside and outside the European Union. For example, they are a “notified body” in the Netherlands and can provide a company both UKCA and CE certificates in a single “package” based on one product evaluation and factory inspection. Whether a product receives the CE or the UKCA mark depends on where they want to sell their products.
Mutual recognition
British Standards Institution (BSI) is the national standards body of the United Kingdom. BSI produces technical standards on a range of products and services and supplies certification and standards-related services to businesses.
For companies that do not want to have their products retested for the UKCA mark, BSI proactively has made “mutual recognition” agreements with similar organizations, including IMQ Group in Italy and DVGW in Germany. The move helps to minimize the need for duplicate or repeat testing.
