UKCA for electrical appliances done right

Q: Do products that are only covered by the Low Voltage and EMC Directive now have to bear the UKCA mark when sold in the UK, or will the CE mark continue to be recognised in this case?

Yes, electrical devices covered by EMC directives and low-voltage devices must be marked with an UKCA mark and generally do not require the approved body as for the CE marking. All products can be declared themselves, except for radios for which there is no standard for regulation or for which manufacturers have not applied. Radio equipment therefore requires the approved notified body for the UKCA marking. CE marking of products will be accepted in the UK until the end of 2021. As of January 1, 2021, the UKCA marking will replace the CE marking on products marketed in the UK (UK) such as Wales, England and Scotland. The UKCA marking is required for goods such as EMC, low voltage and radio equipment that are subject to similar legislation on the UK market to EU regulations/directives requiring CE marking. In addition, the UK-based notified EU bodies lost their status on 1 January 2021. The EU certificates issued by these notified bodies will be transferred to the notified body of the EU-27 on 31 December 2020 to ensure their continued validity.

What are the requirements for marking electronic products? Do CE and UKCA marks and addresses have to be indicated on a label or separately?

In the UK, only UKCA marking is required. With a double CE and UKCA marking, the company takes responsibility for the goods in all markets in the EU and UK to ensure that the marking is clearly displayed. The rules for the physical affixing of the UKCA mark are initially the same as for affixing the CE mark. The UKCA mark must be affixed to the label found on the electrical appliance or in the documents supplied with the appliance. It is possible to apply the CE and UKCA marks on the same device as long as the requirements of the UK and the EU remain the same. When selling in the EU, only the CE mark is required.

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Authorized representatives or manufacturers must follow the instructions below.

They ensure that electrical devices must have a type designation, a serial number (batch number) or other identification features. On electrical equipment, the name of the manufacturer, registered trade names, registered trademarks and postal address must be indicated for contact. If this information cannot be affixed to the device, it may be affixed to the product packaging or accompanying document. It must be readable and easy to understand by the end user and the supervisory authority. All this information must be in English in the UK. UKCA marks can be affixed to packaging, equipment, manuals or warranty certificates. The UKCA mark is a declaration that the electronic devices comply with the regulations.

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Which EU directives/regulations will be affected by the UKCA?

The UKCA regulations are technically similar to the CE marking, but differ in terminology and in some procedures (for example, involving a notified body, not self-declaration of the product by the manufacturer itself). All applicable EU directives or regulations will be replaced by new UK regulations requiring the UKCA mark. For electrical equipment, EMC and low voltage directive are required to meet the Electrical Equipment Regulation 2016. The regulation applies to electronic devices intended for connection to domestic power supply as well as to industrial devices. Electrical equipment components are also covered by the regulation if sold separately.

Hier finden Sie die einschlägigen britischen und EU-Rechtsvorschriften:

EU Directives (CE)	Equivalent UK Regulation (UKCA)	Delta between the regulations
Electromagnetic compatibility (EMC) Directives 2014/30/EU	Ordinance on Electromagnetic Compatibility 2016	No notified body is required for all products declared by the manufacturer. On the other hand, the EU directives require a third party for the conformity assessment of all products
Low Voltage Directives (LVD) 2014/35	Ordinance on Electrical Equipment (Safety) 2016	All products can be declared by yourself
Safety of toys - Directives 2009/48/EC	Regulation on toys (safety) 2011	Products for which all essential requirements are covered by defined standards and the manufacturers have applied these standards can be declared themselves.
Radio equipment - Directives 2014/53/EU	Radio equipment regulation 2017	All products can be declared by themselves, unless the standard referred to in Rule 6(2) does not exist or has not been applied by the manufacturers.
Restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS) - Directive 2002/95/EC	The 2012 regulation restricting the use of certain hazardous substances in electrical and electronic equipment	All products can be declared by yourself
Machinery Directives 2006/42/EC	Regulation on the supply of machinery (safety) 2008	Any machine that is not listed in List 2, Part 4 of the Regulation can be declared by itself. Each machine listed in List 2, Part 4, which meets all the requirements of the notified standards, can be registered by itself.
Pressure equipment - Directives 2014/68/EU	Pressure equipment (safety) Regulation 2016	Category I pressure equipment can be declared
Noise outside Directive 2000/14/EC	Noise emissions in the environment from equipment and machinery for outdoor use Regulation 2001	A notified body is required for the conformity assessment of the products.
Measuring equipment - Directive 2014/32/EU	Measuring Instruments Regulation 2016	Required representative for the conformity assessment declaration.
Personal Protective Equipment (PPE) - Regulation (EU) 2016/425	Regulation on Personal Protective Equipment (PPE) (Regulation (EU) 2016/425, which has been adopted and amended in UK law)	Personal equipment and protective equipment of category I are declared by the manufacturer himself.
Gas appliance - Regulation (EU) 2016/426	Ordinance on Gas Consumption Equipment (Product Safety and Metrology, etc. (Amendments (EU Exit) 2019)	The authorised representative is required for the UKCA marking.
Directives 92/42/EEC Hot water boilers AND Ecodesign Directives 2009/125/EC	The regulation on the ecodesign of energy-related products and energy information (changes) (EU exit) 2019	Representative required for conformity assessment
ATEX - Directives 2014/34/EU	Regulation on devices and protection systems for use in hazardous areas 2016	Products of device group II and device category 3 can be declared by the user.
Lift - Directive 2014/33/EU	Elevator Regulation 2016	Required Notified body for conformity assessment
Non-automatic scale - Directives 2014/31/ EU	Ordinance on non-automatic scales 2016	Authorized representative required for the conformity assessment of the products.
Simple pressure vessel - Directives 2014/29/EU	Regulation on simple pressure vessels (safety) 2016	Category I pressure equipment can be declared

Which harmonised standards must be applied in the context of the UKCA labelling of electrical products? Are these different than before?

For the EU, the term harmonised standard is used and for the United Kingdom the term named standard. The Government of the United Kingdom (UK) has drawn up a list of designated standards. The designated standard is adopted by the State Secretary and published by the BSI (British Standards Institution). If all electrical equipment complies with a certain standard, it is considered safe for use by the end user. The content of the standards will remain the same in the foreseeable future as for the CE marking. The GB/UK standards will be identical in terms of content and reference. However, they will use the prefix "BS" to show that they are standards adopted by the UK Standards Institute, the UK National Standards Body. In terms of content, the standards designated by the UKCA are currently equivalent to the harmonized standards. However, the government has stated that it can change the name or restrict its use to ensure that the standards best meet the needs of the UK.

The following prefixes are used for named standards

BS
EN ISO
EN
EN IEC

While the important legal requirements in the UK (UK) remain the same as the law of the European Union (EU), they will be converted as soon as the essential legal requirements change in the UK. The following table contains some standards, for a complete analysis of the desired standards, you can view this list.

EMC (electromagnetic compatibility)

Legislative References	Named reference	Title of the named references
S.I. 2016 Nr. 1091	EN ISO 14982:2009	Agricultural and forestry machinery, EMC (electromagnetic compatibility), test methods and acceptance criteria (ISO 14982:1998)
S.I. 2016 Nr. 1091	EN IEC 61058-1:2018	Switch for device
S.I. 2016 Nr. 1091	EN IEC 60947-9-1:2019	Low voltage switchgear and ballasts and arc extinguisher
S.I. 2016 Nr. 1091	EN 50557:2011	Requirements for Automatic Reclosing Devices (ARDs) for Household and Similar Applications
S.I. 2016 Nr. 1091	EN 62606:2013	General requirements for arc fault detection devices
S.I. 2016 Nr. 1091	EN 62586-2:2014	Power quality measurements in power supply systems - functional testing and uncertainty requirements
S.I. 2016 Nr. 1091	EN 50148:1995	Electronic taximeter
S.I. 2016 Nr. 1091	Electronic taximeter	Resistors Welding Equipment - EMC Requirement
S.I. 2016 Nr. 1091	EN 50121-3-2:2016	Railway Applications - EMC Vehicles Equipment
S.I. 2016 Nr. 1091	EN 50130-4:2011	Alarm systems - EMC - Product family standards: Immunity requirements for components of fire alarm, burglar alarm, intrusion alarm, CCTV, access control and social alarm systems

Low voltage devices (LVD)

Legislative References	Named reference	Title of the named references
S.I. 2016 Nr. 1101	EN ISO 11252:2013	Lasers and laser systems - Laser devices - Minimum documentation requirements (ISO 11252:2013)
S.I. 2016 Nr. 1101	EN 13637:2015	Construction fittings - Electrically controlled exit systems for use on escape routes - Requirements and test methods
S.I. 2016 Nr. 1101	HD 308 S2:2001	Identification of wires in cables and flexible lines
S.I. 2016 Nr. 1101	HD 361 S3:1999, HD 361 S3:1999/A1:2006, HD 361 S3:1999/AC:1999	Systems for cable designations
S.I. 2016 Nr. 1101	EN 50178:1997	Electronic equipment for use in power plants
S.I. 2016 Nr. 1101	EN 50214:2006, EN 50214:2006/AC:2007	Flexible flat cable with polyvinyl chloride coating
S.I. 2016 Nr. 1101	HD 368 S1:1978	Direct-acting records of electrical measuring instruments and their accessories
S.I. 2016 Nr. 1101	HD 605 S2:2008, HD 605 S2:2008/AC:2010	Electrical cable - Additional test method
S.I. 2016 Nr. 1101	HD 549 S1:1989	Conference system - electrical and audio equipment
S.I. 2016 Nr. 1101	EN 50117-3-1:2002	Coaxial cables - Specification for cables for telecommunications applications - Miniaturized cables for digital communication systems

radio equipment

Legislative References	Named reference	Title of the named references
S.I. 2017 Nr. 1206	EN 50360:2017	These standards describe the conformity of wireless communication devices with the general restrictions and limits for human exposure to electromagnetic fields in the frequency range from 300 MHz to 6 GHz: Devices used near the ear
S.I. 2017 Nr. 1206	EN 50401:2017	The standards describe the conformity of base stations with the exposure limit for radio frequency electromagnetic fields from 110 MHz to 100 GHz when put into operation.
S.I. 2017 Nr. 1206	EN 50385:2017	The standards describe the conformity of base stations with the exposure limit for radio frequency electromagnetic fields from 110 MHz to 100 GHz when placed on the market.
S.I. 2017 Nr. 1206	EN 55035:2017	EMC (electromagnetic compatibility) of multimedia devices - interference resistance requirements
S.I. 2017 Nr. 1206	EN 50401:2017	The standards describe the conformity of base stations with the exposure limit for radio frequency electromagnetic fields from 110 MHz to 100 GHz when put into operation.
S.I. 2017 Nr. 1206	EN 300 224 V2.1.1	Mobile terrestrial radio service; radio equipment for radio call service in the frequency range (25 MHz - 470 MHz); harmonised standards comply with the essential requirements of Directive 2014/53/EU
S.I. 2017 Nr. 1206	EN 302 077-2 V1.1.1	EMC (Electromagnetic Compatibility) and ERM (Radio spectrum Matter); navigation radars for inland navigation; harmonized ENs covering important requirements of R&TTE directives
S.I. 2017 Nr. 1206	EN 302 194-2 V1.1.2	EMC (Electromagnetic Compatibility) and ERM (Radio Spectrum Matter); navigation radar for inland navigation; harmonized ENs covering the necessary requirements of the R&TTE directives
S.I. 2017 Nr. 1206	EN 302 480 V2.1.2	Mobile Communication on Board Aircraft (MCOBA) System; Harmonisierte Normen, die notwendigen Anforderungen abdecken Richtlinien 2014/53/EU
S.I. 2017 Nr. 1206	EN 302 609 V2.1.1	SRD (Short Range Device); radios for the Euroloop railway system; harmonised standards covering the necessary requirements of Directives 2014/53/EU

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Do products that are only covered by the Low Voltage and EMC Directive now have to bear the UKCA mark when sold in the UK, or will the CE mark continue to be recognised in this case?

Yes, electrical equipment that falls under the scope of EMC directives and low voltage equipment must be UKCA marked and generally does not require the approved body as with CE marking. All products can be self-declared, with the exception of radio equipment for which there is no standard for regulation or which has not been applied by manufacturers. Radio equipment therefore requires the approved Notified Body for UKCA marking. CE marking of products will continue to be accepted in the UK indefinitely due to the currently suspended deadline. From 1 January 2021, the UKCA marking will replace the CE marking on products placed on the market in GB (Great Britain) such as Wales, England and Scotland. UKCA marking is required for goods such as EMC, low voltage and radio equipment that are subject to similar legislation in the UK market as EU regulations/directives that require CE marking. In addition, EU Notified Bodies based in the UK lost their status on 1 January 2021. The EU certificates issued by these notified bodies were transferred to the EU-27 notified body on 31 December 2020 to ensure their continued validity.

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Are the regulations for UKCA for electronic products stricter than for CE?

The regulations for UKCA are technically similar to CE and differ in terminology and some procedures. All goods covered by the Low Voltage Directive (LVD) and the Electromagnetic Compatibility Directive (EMC) are labelled by the manufacturer in the same way as the CE marking, which is the declaration of conformity. The only difference is that the UKCA mark is used for the UK market and the CE mark for Europe. For low-voltage and EMC products, the assessment by the notified body of the EU27 is not required, they are declared by the manufacturer himself. Low-voltage and EMC devices that already have test reports and CE certificates must be retested for the UKCA marking or the documentation checked.

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When is an authorized representative required to sign the UKCA Declaration of Conformity?

As the UK is no longer part of the EU market, a UK product now requires an agent in the EU. Third party conformity assessment was required for CE marked products, so it is also required for UKCA marked products. Cross-border trade in products requires an authorised representative who declares that the products comply with the legal requirements in the EU. If an EU-based manufacturer wishes to sell its products on the UK market, it must have a representative in the UK. Conformity assessments must be carried out by a conformity assessment body recognised in the UK in order to label the products with the UKCA.

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Do you need a UKCA declaration of conformity for electrical products, similar to the CE marking? What must the UKCA declaration of conformity contain?

The conformity assessment procedure for electrical equipment is the same as for the CE marking of products. The information that must be included in the declaration of conformity is basically the same as in a declaration of conformity in the EU. The information may vary depending on the application legislation, but should generally include the following:

Model, batch number, type and serial numbers of the product to which the declaration of conformity applies so that it can be traced.
Address and name of the manufacturer or its authorised representative.
Explanation of the electrical equipment, such as a color image to identify the electrical equipment.
Place and date of issue.
Identification of the persons who will commit on behalf of the authorised representatives or manufacturers.
Relevant GB/UK legislation, not EU legislation.
Mention of the standard designated by the UK and not the EU standards.
Thereafter, the documents shall be compiled and kept, which should include
A general description of the electrical appliance.
The conceptual designs, manufacturing drawings, details of the components along with the information required for the interpretation of all these documents.
A list of standards according to which the electrical equipment has been assembled. If no standards have been used, describe the procedure to ensure compliance with general safety requirements.
Report and results of testing, tests, calculations, etc.

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Does an electrical appliance with UKCA marking have to have a British plug?

This is not necessary because most products are powered by a battery and some are connected by cable. Where electrical appliances have plugs (such as chargers) to be connected directly to the UK public electricity grid via an outlet, the economic operator should ensure that these sockets are compatible with sockets that comply with the BS 1363:13 standard. However, many consumer goods require a UK plug that meets the BS 1363:13 standard, and also in this case the CE marking was used, so nothing has changed. Today, most modern electrical devices are equipped with smart technologies such as Bluetooth and others via apps on mobile phones, laptops and computers. Such devices fall under the Radio Equipment Regulation 2017 (which is the UK’s equivalent to the Radio Equipment Directive 2014/53/EU).

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