Before I start this article, I will clarify some geographic terms. The United Kingdom (UK) consists of four countries, England, Scotland, Wales and North Ireland. Great Britain (GB) consists of England, Scotland and Wales. This is why you may have heard the phrase “Great Britain and Northern Ireland” or the “United Kingdom of Great Britain and Northern Ireland”. Under the Brexit (withdrawal of the UK from the European Union) agreement though, Northern Ireland is currently following EU (European Union) regulations to ease border checks with the Republic of Ireland.
According to the UK government website, “the UKCA (UK Conformity Assessed) marking is a new UK product marking that is used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods which previously required the CE marking.” Figure 1 shows the marking.
Figure 1: UKCA mark
Before Brexit, the UK used the CE Mark to show conformity with the relevant EU legislation. After Brexit, UK and EU legislation may start to differ, and the UK needed an independent mark to indicate conformity with UK law. In the future, products will need to carry both marks if imported into both areas.
Some important points:
Note that this is a label change process not a safety certification process
The UK currently references the same EN standards as the EU - for a power supply these include EN 62368-1, EN 60335-1 and EN 60601-1. This means there is no additional safety certification work required.
The UKCA marking came into effect on January 1st 2021 but to give businesses time to adjust (in most cases) the CE marking can continue to be used until January 1st 2022. From that date onwards, CE marking will no longer be recognized in Great Britain.
Until January 1st 2023 there is an option to apply the UKCA mark to the product, product packaging or an accompanying document. This can also be a packing slip and/or an invoice.
From January 1st 2023 onwards, it is compulsory to have the mark on the product and if this is not possible, the mark should be on the product packaging or accompanying product documentation as appropriate.
The product, product packaging or an accompanying document must also have the contact address of the authorized UK representative. In TDK-Lambda’s case this will be TDK-Lambda UK.
The UKCA marking is not a replacement for the CE marking. Both marks will be required if a product is to be sold in both regions. Both will require a Declaration of Conformity.
For further advice and application support on this, or any other power supply related topic, please contact your local TDK-Lambda office.