The question we hear most often about the new UK Conformity Assurance mark – UKCA – from Timber Trade Federation (TTF) members is: “why are we doing this, and is it just a duplication of the CE marking we already have in place?”
The simple answer is: “yes, absolutely it is a duplication” – and many would say an entirely pointless one. However, that is the consequence of exiting the EU single market in a short time frame without a sufficiently comprehensive trade deal to ensure mutual recognition of these technical factors.
As it stands, and will likely remain, industry is being left to carry the cost of these political initiatives, and when it comes to UKCA marking many TTF members may face the cost of certification being doubled – and significantly more than this in some cases.
However, we must remember the CE and UK conformity assurance systems are mechanisms to give end users confidence the construction products they are purchasing are compliant with relevant product standards and safe to use. These principles are critical to UK authorities, and any good business, particularly since the publication of the Hackitt Review, and the work which has followed.
So, while the duplication may seem pointless, the underlying requirements are essential. As ethical product suppliers we must put aside frustrations and get on with rising to meet UKCA – particularly given the final CE marked products must be ‘placed on the market’ by December 31, 2021.
Our team at TTF, along with the Construction Products Association and Confederation of Business Industries, have been calling strongly for a delay to implementation given the intense pressure on the supply chain because of the global health crisis, and the fact that some parts of the new UK system are yet to be written; but for now, this seems to be falling on deaf ears.
However, if we begin logically from the perspective that this is a duplication exercise then it should be quite simple for manufacturers throughout Europe and globally to map out what they need to do to get UKCA marking in place. This includes:
• Creating a new Declaration of Performance (DoP) to frame their product claim in terms of the UKCA requirements.
• Creating a separate version of their Factory Production Control (FPC) manual, which replaces the CE mark with the new UKCA mark.
• Engaging with the necessary third-party bodies to oversee implementation of these new elements.
By way of an example, we know that in volume terms most wood and wood products which need to be UKCA marked are operationally at what is termed Level 2+ with a recognised body required to provide certification of the manufacturers FPC system. For UKCA marking this must be a UK Approved Body working in the construction sector. You can find a list of the 45 bodies who meet these criteria on GOV.UK: https://www.gov.uk/uk-market-conformityassessment- bodies?uk_market_conformity_ assessment_body_type%5B%5D=approved-body& uk_market_conformity_assessment_ body_legislative_area%5B%5D=construction-products
Where it is impractical for the UK Approved Body to provide auditing of the manufacturer’s FPC then such work can be sub-contracted to a suitably qualified organisation – as we saw with CE marking.
For manufacturers who want to apply both the CE and UKCA marks to their products, the first step is for them to tell their current EU Notified Body that the UK is a critical market for them, and that they need to apply a UKCA mark alongside the existing CE mark. If their existing Notified Body is happy to help, then they should approach a UK Approved Body to discuss a sub-contract arrangement.
Of course, some EU Notified Bodies have already had the foresight to put sub-contract arrangements in place with UK Approved Bodies. One example is the main Swedish strength grading body, RISE, which signed a critical sub-contract agreement allowing the nearly 100 mills using RISE as their Notified Body for CE marking to have a simple route to also apply the UKCA mark where they wish to do so.
For wood products that are less safety critical, sitting at Level 4 within the CE marking system, the process is more straight forward. This is because there are no necessary third parties involved in the implementation process. Manufacturers at CE4 can choose to apply the UKCA mark when they wish but should also have a separate DoP which specifically reflects the UK requirements.
The most safety critical products, which sit at Level 1, 1+ and 3 in the CE marking system, have greater third-party involvement making the transition more complex; but I am sure that manufacturers of these products will already have arrangements in hand.
