Fast-Track UKCA: UKCA and CE regimes

Introduction

Fast-Track UKCA provides manufacturers with an optional, alternative route to using the UKCA marking. Compliance can be demonstrated using either UK essential requirements or recognised EU essential requirements, along with the relevant conformity assessment procedures for each regulation that applies to the product.

Fast-Track UKCA can be applied where the relevant EU product requirements are recognised in Great Britain domestic law. If you are eligible and have demonstrated you have satisfied relevant requirements – either through a self-declaration of conformity or third-party conformity assessment – you can automatically apply the UKCA marking.

Many products fall under multiple product regulations. This can make compliance complex and costly, especially if in the future it was not in the interests of UK businesses, or consumers, to continue to recognise EU requirements in a given sector regulation.

Fast-Track UKCA addresses this by allowing manufacturers to use either UK or EU conformity assessment procedures for each regulation applying to a product, and then apply the UKCA marking. Where multiple product regulations apply to a product, manufacturers can therefore use a blend of UK and EU conformity processes to apply the UKCA marking.

Where only one product regulation applies to a product

You can use Fast-Track UKCA if you want to use evidence of your compliance with EU requirements for the relevant regulation as the basis of applying a UKCA mark.

You will need to have undertaken the necessary conformity assessment procedures, including using an EU conformity assessment body where it is required. In this scenario you could also place the product onto the Great Britain (England, Scotland and Wales) market using the CE marking or other applicable EU marking.

Where multiple product regulations apply to a product

If multiple product regulations apply to your product, then you can use Fast-Track UKCA to demonstrate compliance with one of the following:

1. A combination of Great Britain essential requirements and recognised EU essential requirements that apply to the same product. You will also need to have undertaken the necessary conformity assessment procedures, including using either a UK or EU conformity assessment body respectively for each regulation where it is required.

2. Recognised EU essential requirements for all of the regulations that apply to your product. You will need to have undertaken the necessary conformity assessment procedures, including using an EU conformity assessment body where it is required. In this scenario you could also place the product onto the Great Britain market using the CE marking or other applicable EU marking.

Example scenarios

Example A

In this scenario, the UK recognises the EU requirements for all 4 regulations that apply to product A. This means that before placing this product on the Great Britain market, manufacturers can choose whether they wish to:

1. Follow UK requirements to apply the UKCA marking to the product.
2. Follow EU requirements to apply the CE marking to the product.
3. Follow recognised EU requirements to apply the UKCA marking to the product.
4. Follow a mixture of recognised EU and UK requirements to apply the UKCA marking to the product.

Figure 1: using the CE extension and Fast-Track UKCA

Example B

In this scenario, the UK has chosen to mandate UKCA for a specific product regulation, which would be applicable for products being placed on the market in Great Britain. This is a hypothetical example and not a statement of policy.

Here, 4 regulations apply to Product B. Some of the EU regulations are recognised in UK law. However, one of the product’s regulations mandates UKCA, and EU requirements for that product are not recognised.

In this scenario, the manufacturer may choose to:

1. Follow only the UK requirements to apply the UKCA marking to the product to place the product on the Great Britain market.
2. Follow the EU requirements to apply the CE marking. Since this does not meet the new UK requirements, they are not able to place the product on the Great Britain market.
3. Follow the UK requirements for regulation 1 and follow the EU requirements for regulations 2, 3 and 4 to apply the UKCA marking to the product to place it on the Great Britain market.

The manufacturer will however not be able to:

1. Follow the EU requirements to apply the CE marking. Since this does not meet the new UK requirements, they are not able to place the product on the Great Britain market.

Figure 2: using the CE extension and Fast-Track UKCA where there is a divergence