UK CA Marking is a new UK product marking that is used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods which previously required CE Marking, including glass in building.
England, Wales and Scotland, i.e. Great Britain. Special procedures apply in Northern Ireland.
UK CA Marking cannot be used for products placed on the Northern Ireland market, which requires either CE Marking alone or UK NI Marking together with CE Marking.
UK CA Marking came into effect on 1st January 2021. To allow businesses time to adjust to the new requirements, it was originally still possible to use CE Marking until 1st January 2023 in most cases.
However, the UK Government updated its guidance on UK CA Marking on 9th December 2022, announcing that CE marking of construction products, including glass, will continue to be recognised for another 2.5 years for products placed on the GB market (England, Scotland and Wales), to allow businesses until 30th June 2025 to prepare for UK CA Marking.
Most of the content of the Declaration of Performance (DoP) for the UK CA Mark will be identical to the DoP for CE Marking. However, there may be small, but important, differences between the two. For example, the references to the relevant legislation will be different. Regulation 67 of The Construction Products (Amendment etc.) (EU Exit) Regulations 2019 specifies exactly how the wording should be on the DoP for the UK CA Mark, and amends it to state at point 8:
‘This declaration of performance is issued, in accordance with Regulation (EU) No 305/2011, as it has effect in the United Kingdom under the sole responsibility of the manufacturer identified above.’
On 26th January 2022, United Kingdom Accreditation Service (UKAS) issued an updated technical bulletin to clarify the outsourcing requirements relating to the UK Construction Product Regulations and UK Approved Laboratories. It applies to new testing, including Type Testing undertaken in connection with Assessment and Verification of Constancy of Performance (AVCP) System 3.
Key guidance in the technical bulletin includes the following:
- It is permissible under the UK CA System for Approved Laboratories to outsource required testing activities to external providers
- The UK Approved Laboratory should be competent to review the resulting test reports and must hold UKAS accreditation for the scope of testing concerned
- Testing laboratories that have an agreement in place with a UK Approved Laboratory to carry out testing are not required to themselves be UK Approved Laboratories
- There is no requirement for testing laboratories sub-contracted to conduct testing to be based in the UK
On the basis of the above, it is possible for a UK Approved Body to sub-contract Type Testing to an EU Notified Body in support of UK CA marking.
No, UK CA Marking is not recognised on the EU market. Products need to be affixed with CE Marking for sale in the EU.
It stands for Conformity Assessed.
As for CE Marking, the UK CA Marking shall be affixed visibly, legibly and indelibly to the construction product or to a label attached to it.
Where this is not possible or not warranted on account of the nature of the product, it shall be affixed to the packaging or to the accompanying documents.
As for CE Marking, there may be additional information that accompanies the UK CA Marking. Please check the relevant legislation for more details, for example the Construction Products Regulation.
Manufacturers must not place any mark or sign that may misconstrue the meaning or form of UK CA Marking to third parties. They must not attach other marks on the product which affect the visibility, legibility or meaning of UK CA Marking.
Manufacturers must make sure that, if they reduce or enlarge the size of the mark, the letters forming the UK CA Marking must be in proportion to the official image. In addition, the UK CA Marking should be at least 5mm in height for the whole logo, not individual letters. In all cases, the UK CA Marking must be easily visible and legible.
The same rules apply also for the UK NI Marking for Northern Ireland.
From 1st January 2023, it was originally proposed that CE Marking would not be recognised in Great Britain for construction products and the UK CA Marking would need to be affixed instead. However, a product bearing CE Marking would still be valid for sale in the UK, so long as it was also affixed with the UK CA Marking and complied with the relevant UK rules.
The UK Government updated its guidance on UK CA Marking on 9th December 2022, announcing that CE marking of construction products, including glass, will continue to be recognised for another 2.5 years for products placed on the GB market (England, Scotland and Wales), to allow businesses until 30th June 2025 to prepare for UK CA Marking.
As for CE Marking, there may be additional information that accompanies the UK CA Marking. Please check the relevant legislation for more details, for example the Construction Products Regulation.
Although the UK CA Mark is not recognised in the EU, the view of European Commission Services is as follows. The UK CA Marking (as any third country marking) can be affixed to a product which bears the CE Marking, provided that such marking does not create confusion with CE Marking. This confusion may either refer to the meaning or the form of CE Marking (see Article 30(5) of Regulation 765/2008). Therefore, the UK CA Marking, as well as any other information concerning UK legislation, must be separate from the CE Marking and information concerning EU legislation. This applies also to the Declaration of Performance (DoP). The DoP drawn for the purposes of compliance with EU legislation should not be used for the purposes of UK legislation.
All existing harmonised European Norms (hENs) have become UK-designated standards. This will mean that immediately after the end of the transition period hENs and UK-designated standards will be identical. It is possible that deviations could occur in the future.
The UK government has introduced changes to the way standards are referenced in regulation. Therefore, BSI has added a National Foreword to new standards that might be designated to inform users how text in the BS EN standard can be read in relation to UK law for Great Britain and Northern Ireland. Current standards that have already been designated will not have this new foreword.
The UK government will maintain a list of UK-designated standards on a UK Database. To access the database, please click here.
UK-designated standards should be referenced as EN rather than BS EN related to the UK CA Marking and Declaration of Performance (DoP).
The designation of EN rather than BS EN is to make sure all identical nationally-adopted versions of the standard receive the same legal effect.
Products originating from another EU Member State being transported via the UK to Ireland do not have to carry the UK CA Marking as the product is only 'in transit' and not being placed on the Great Britain market. Only CE Marking is necessary for such products.
The UK will have powers to carry out market surveillance and enforcement to ensure that non-compliant products can be removed from the UK market. This will be through Trading Standards in Great Britain and Environmental Health Officers in Northern Ireland.
Since 1st January 2021, UK Notified Bodies operating under the EU Construction Products Regulation 2011 (EU Regulation No. 305/2011) and based in the UK have been granted new UK ‘Approved Body’ status and listed on a new UK database. An Approved Body may also be referred to as a Conformity Assessment Body (CAB).
To access the database of UK Approved Bodies, please click here.
Yes, but only under specific conditions.
On 20th June 2022, 'Construction Products Regulation in Great Britain - Guidance providing practical information for placing construction products on the GB market' on the gov.uk website was amended to reflect the government's intention to recognise historic test certificates for products under Assessment and Verification of Constancy of Performance (AVCP) System 3, which captures much of the Type Testing for glass products.
The new guidance states the following:
'For products subject to AVCP System 3 testing, the UK mark may be affixed on the basis of testing conducted by an EU recognised notified body for the purpose of CE Marking where this testing was done before 31st December 2022.'
The above now allows a manufacturer to commence UK CA marking of their products – which may have been established on the GB market for many years - on the basis of existing Type Testing reports issued by EU Notified Bodies.
For testing carried out under AVCP Systems 1+, 1 and 2, it has been possible for a competent UK Approved Body to accept the testing of a third party (e.g. an EU Notified Body) under a formal agreement and to provide the necessary documentation in support of UK CA Marking.