Monday 22nd June 2020
The Rt Hon Alok Sharma, MP
Secretary of State for Business, Energy and Industrial Strategy
I Victoria Street
Westminster London, , SW1H 0ET
Implementing the UKCA mark
Dear Mr Sharma,
I write as secretary of the Engineering and Machinery Alliance, an alliance of trade associations representing firms working across industry – in machine tools, automation, robotics, component manufacturing, materials handling, distribution, and maintenance, including compressed air and fluid power.
The UKCA mark is currently set to be adopted immediately at the end of the Brexit transition period, in December 2020. We have concerns arising from the process and timeline for the adoption of the new mark.
Many firms will need to make changes well in advance if they, their distributors and retailers, are to sell their products legally in the UK. These changes include product certification and manufacture and cannot be made at short notice.
We are unaware of any government guidance for business on this issue. Guidance posted on gov.uk in February 2019, relating to leaving the EU without a trade agreement, has subsequently been withdrawn. Businesses therefore have no call to action from government to which to respond, or signposting. Firms may even be unaware of the significance of the change to UKCA for their businesses.
Covid-19 has hugely distracted business owners and managers from what was their routine, and has created new challenges and uncertainties, many of which are widely recognised and discussed. The time left to make the changes required for UKCA would be insufficient without the Covid crisis; with it, the timescale is even less realistic.
Were the change to UKCA to go ahead at the end of this year without any period for implementation, the consequences would be to reduce the availability of products from reputable manufacturers and suppliers that follow regulations, and to release a flood of products which simply ignored the new requirements. That would be a most unsatisfactory start for a flagship initiative such as UKCA.
For UKCA to have a secure foundation, an implementation period will be needed well beyond the end of this year. Exactly how long will depend on when government is able to give clarity on what businesses need to do, and should be the subject of discussion. This is a technical issue, but an important one, that we need to get right.
On behalf of EAMA’s members listed below, I urge you to make clear the importance of strong adherence to UKCA from the start, and that you will review the current timeline. EAMA would welcome the opportunity to be part of that review, as well as to help to promote guidance to firms when it becomes available.
Please advise as to your thinking on this issue.
Representing the machinery and component supply chain
t: 07400 394855
62 Bayswater Road, London W2 3PS
EAMA Members: Agricultural Engineers Association | British Compressed Air Society | British Fluid Power Association | British Plastics Federation | British Turned Part Manufacturers Association | Gambica | Gauge and Toolmakers Association | Manufacturing Technologies Association | Printing Industry Confederation | Solids Handling and Processing Association
Company number: 5974924
UKCA mark – guidance ‘in due course’ says BEIS
The business department (BEIS) has re-iterated that UKCA marking ‘will come into force at the end of the [Brexit] transition period, so will be valid for products being sold in GB after 1 January 2021’.
Guidance on the UKCA mark, and on the status of CE marking in the UK from 1 January 2020, will be published ‘in due course’, BEIS says. (There is no published guidance on the matter at present: such as there was, 18 months ago, has been withdrawn.)
Exact requirements in respect of the UKCA will in part depend on the outcome of trade negotiations with the EU, BEIS says. It adds that it recognises the challenges faced by businesses in preparing for the end of the Brexit transition period.
BEIS’ was responding to a letter from the Engineering and Machinery Alliance, which wrote to business secretary Alok Sharma a month ago to express concerns about the process and short timeline for adoption of the UKCA mark. EAMA urged Mr Sharma to review the current timeline for introduction, and to make clear the importance of strong adherence to UKCA from the start.
Meanwhile, there is no clarity as to whether there will be a UKNI mark for Northern Ireland. There is provision for such a mark in the EU/UK Withdrawal Agreement. Whether one is required – along with much else to do with Northern Ireland – will depend on the outcome of the current talks.