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After Jan 1 2022, your LED product needs a UKCA mark for selling in the UK

 

Find out what the UKCA is and why it’s important to you

 

What is CE?

CE, or Conformité Européene, is a company’s declaration that a product is safe, compliant and meets all regulations.

Don’t want to do your compliance in-house? You can use third-party conformity assessment bodies like The British Standards Institute (BSI). They’ll test your product, you’ll pay them a license and you can apply their compliance mark to your products.

 

Using CE

Before placing goods on the European Market, you MUST make a Declaration that the product is safe and compliant with all applicable regulations. 

This Declaration of Conformity must be available in writing for all products, with a technical file of evidence used in support.  The evidence can be internal test validation or external third party tests.

Placing the CE mark on the product is making the declaration. A market surveillance framework that reviews and samples products across the market enforces the legislation. It will assess the supporting evidence and product to confirm the declaration made is correct. 

If incorrect, action is taken with the signatory of the declaration and the legal entity at the declared address on the product. Depending on the severity of the non conformity this can be an instruction recall from the market - or to correct and introduce actions to avoid a recurrence in the future.

A declaration without evidence of ‘who’ is making the declaration is not valid. So BEWARE: a CE mark placed on a product without a brand name is immediate and obvious non compliance.

At Integral LED, we test all our products internally to validate performance. We also hold third party supporting evidence as a best practice before declaring them compliant. Better safe than sorry.

 

So what happens with Brexit?

If you’ve (somewhat) followed the news, you’ll know that the UK has decided to leave Europe. And set up its own market.

This means you can’t tell customers your product “conforms to European standards” anymore. 

Now, Customers want us to say we’re meeting UK standards.

 

How does this change in practice?

It doesn’t. Not really. UK and European lighting regulations are very much aligned. For now. 

They’re both tested to international standards (IEC) with small amendments to accommodate specific issues at country level and accepted in many markets, except the USA. So there’s very little local variation.

BUT!

We still need to say on our packaging that our products comply with the UK regulatory framework. This involves a slight change in paperwork, saying all our products comply with all relevant UK regulations.

An example:

What used to be labeled (LVD) (2014/35/EU) is now an English Statutory Legislation Document 18374. They’re basically the same document - BUT... Your compliance declaration now has to be under the latter, and not the former.

 

Transition period

UKCA came into effect as of 1st January 2021. And is now applicable to the market.

BUT

Because we are transitioning, we can still sell products with the ‘CE’ mark on them.

UNTIL

1st January 2022. When we MUST have the UKCA mark on our products. Meaning we’ll have two marks: CE and UKCA.

ALSO

Part of the regulations require you to declare a legal entity for market surveillance to go to and make an arrest in the event of non-compliance. And since a UK address no longer supports a ‘CE’ mark, you’ll need TWO addresses on your packaging:

A European address to support the CE mark. 2) A UK address to support the UKCA mark.

So yes, if you buy an Amazon product made in China with a ‘CE’ mark on it. But NO brand name. It doesn’t have a legal entity behind it - meaning it’s not legally compliant. And could even be dangerous because there’s nobody accountable for it.

 

About the UKCA mark

  • Applied to product and packaging. Can be applied to manuals/supporting literature
  • Only the manufacturer or authorised representative can apply the mark to products
  • Manufacturer takes full responsibility for product’s conformity
  • Only used to show conformity with UK legislation
  • Don’t put any other markings or signs that can distort the meaning or form of the UKCA marking
  • UKCA marking is at least 5mm in height - unless otherwise specified in relevant legislation
  • Easily visible (displayed permanently from 1 January 2023)

 

For Northern Ireland

  • Only the manufacturer or authorised representative can apply the mark to product
  • MUST accompany another conformity marking, such as CE
  • When accompanying another conformity marking, you must take full responsibility for your product’s conformity with the requirements of the relevant legislation
  • Don’t put any other markings or signs that can distort the meaning or form of the UKNI marking
  • Do not place on product unless stated in legislation

 

Summarising UKCA, UK(NI) and CE

Watch this space as we keep you posted on conformity regulations!

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