On January 31, 2020, the UK/EU Brexit Agreement was approved and officially entered into force. The UK has entered a transitional period of "Brexit", during which consultations will be held with the European Commission. The transition period is scheduled to end on December 31, 2020. When the United Kingdom leaves the European Union on December 31, 2020, the UKCA (UK Certification of Conformity) mark will become the new British product mark.

The following are key messages:

The transfer of certification from a third-party designated agency in the EU-27 or from a third-party designated agency in the United Kingdom must be implemented before the end of the Brexit transition period.

Tests implemented by third-party designated agencies in the 27 EU countries can be submitted to the UK accreditation body for the issuance of UKCA certification

According to the current guidelines of the British government, if any of the following applies to your product, your product can still use the CE mark in the British market for a limited period of time. This period has not yet been determined, but the British government will A positive notice will be given before the expiration of this period.

• The CE mark that your existing goods currently have is based on self-certification

• A third-party designated agency recognized by the 27 EU countries has implemented a mandatory third-party conformity assessment
• The previous conformity certification held by the British institution has been transferred to a designated third-party institution recognized by the EU 27 countries

The detailed information about the test requirements has not been listed, but it is expected that the test requirements will reflect or be very similar to the current CE marking test requirements. CE marking test and UKCA marking test (EN standard) can be carried out at the same time, and the EN standard will apply to the UKCA mark.

As the UK has not yet promulgated a law to implement the UKCA mark before it officially leaves the European Union on December 31, 2020, the UKCA mark cannot be used or placed on products before January 1, 2021. Starting from January 1, 2021, the UK market will approve CE-marked products for a limited period of time. Once the UK leaves the European Union, manufacturers will be informed that they are obliged to add the UKCA mark on their products, and the CE mark will be recognized during the limited recognition period

The same product can display multiple conformity marks (including CE and UKCA) in order to enter the global market. It is common for the same product to mark multiple conformity marks to apply to different markets.

Like the CE mark, once the UK enacts a law to implement the UKCA mark, it needs to comply with the relevant detailed rules and add the conformity mark on the product label, package and in the instruction manual.

The United Kingdom is recognized as the country of issuing/recognizing IECEE/IECEx CB reports and certifications. Therefore, CB certification is not affected by Brexit.

As of 2016, all products that comply with the Low Voltage Directive (LVD) are self-declared products. The UK has adopted the directive, and the directive will apply to the British market. The only difference is that the UKCA mark, which is applicable to the UK market, will be adopted instead of the CE mark applicable to the European market. After the UK officially leaves the European Union on January 1, 2021, it will recognize the CE mark for a limited period of time.

The LVD, EMC, RoHS, WEEE test reports that have already had CE certification, do not need to re-test, and do not need to conduct document review. For products that have already issued their own declarations, the manufacturer must draft a declaration of conformity before marking the UKCA mark.

The same technical document can be used to obtain the UKCA mark and CE mark at the same time

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