The recent BSIF webinar on the UKCA Mark and what it means for the PPE industry was very well attended and yielded a lot of questions. BSIF have now provided answers to those questions, please see below, all questions are answered based upon current understanding and may be subject to change. Some questions have been edited for clarity purposes only:
| Question | Answer | |
| What is the official reference for UKCA / NI PPE documentation? | For GB Market ‘Regulation 2016/425 on Personal Protective Equipment as brought into UK law and amended’ For NI Market ‘Regulation EU 2016/425 on Personal Protective Equipment’ | |
| What will the UKCA Mark look like | https://www.gov.uk/guidance/using-the-ukca-mark-from-1-january-2021 | |
| Where do I find the actually standardized pictograms for markings? (referring to the “UKCA” and “UKNI” ) | https://www.gov.uk/guidance/using-the-ukca-mark-from-1-january-2021 and https://www.gov.uk/guidance/using-the-ukni-marking-from-1-january-2021 | |
| Where can we get the correct UKCA mark symbol and size / format requirements to use it correctly on packaging / products? | https://www.gov.uk/guidance/using-the-ukca-mark-from-1-january-2021 | |
| Markings for PPE Cat III; the “CE-labels”; can we refer to both CE xxxx and the UKCA xxxx on the same label or must they be separated? | They can appear together, but must be clear which is which | |
| Please can you confirm that even though the CE mark is valid until 2023, from January 1st 2021, the UKCA mark will be required on either the product or an accompanying document? | No, from January 1st 2022 the UKCA mark will be required following suitable assessment during 2021 CE is still permitted, but you can mark with UKCA as soon as assessment is completed in 2021 | |
| Please confirm just for 100% clarity, at what point ,if any, must a product be ONLY UKCA marked , IE. Can we continue we dual mark product ongoing over next number of years- | You can continue to multi mark CE & UKCA into the future. All supporting documentation must be valid and complete. | |
| Since January 2023 only UKCA mark should be present on any good, or both marks (CE and UKCA) are allowed? | Multi marking is allowed | |
| Can products be marked UKCA and UKNI? and CE? | In theory yes there is no principal that disallows multiple marking. | |
| To confirm – we have 1 year to get UKCA approval but can add a label to the packaging and update artwork by 2023 | Essentially yes | |
| About UKCA mark – After Jan 1st 2023, is it expected that UKCA mark shall be on the product with the same prescriptions currently in use for CE mark? | Yes. | |
| As I am a GB based regional purchaser for the NW of the UK including NI and the PPE purchased is used throughout the Region what marking will be required on the PPE? | UKCA for GB and UKNI and or CE for NI (indeed if it came from an NI supplier CE on its own would actually suffice) | |
| As a UK based business we have to stamp our products with UKCA requirement when we import from abroad, however, if our distributor has customers in the EU, can they still sell our products to the EU with UKCA marking/documentation which already in our warehouse in the UK? | No for the EU market CE would be required | |
| Ref: use of PPE Regulation (EU) 2016/425 – where we have both CE & UKCA do we need to repeat PPE Regulation (EU) 2016/425 and PPE Regulation (EU) 2016/425 as amended and brought into UK law? Many labels have little spare space | Generally this is not required on the label, but will be required on the relevant documentation – Declaration Of Conformity and Product Certification for example | |
| Is there any exemption for products where the UKCA mark cannot be placed on the physical product due to “space” constraints? Will in these cases be possible to put the UKCA mark on external documents/packaging even after 2023? | Yes, as with the current requirements under the PPE Regulation 2016/425 where it is not possible to place all the required information on the product, it may be placed on the packaging. | |
| UKCA marking to be on the product or the packaging …. is this right. If on the packaging, how does and end user know the product complies if the packaging has gone. I work on a CEN PPE WG and we have to ensure that a product itself carries a CE mark. Or have I missed the point here? | Yes, as with the current requirements under the PPE Regulation 2016/425 where it is not possible to place all the required information on the product, it may be placed on the packaging. | |
| Why no markings of the company on the goods themselves, as a Safety Officer when out on site with staff being mobile workers I would be looking for compliance on the kit, not having to go back to depots to confirm compliance on a package or document supplied by the supplier. | As with the current requirements under the PPE Regulation 2016/425 where it is not possible to place all the required information on the product, it may be placed on the packaging. | |
| Affixing a UKCA label to a product is sufficient until 31/12/2022 but what is required after this date? | The guidance states that it should be applied to the product but as with the current requirements under the PPE Regulation 2016/425 where it is not possible to place all the required information on the product, it may be placed on the packaging. | |
| In the first instance where UKCA can be applied to the packaging, does the term ‘packaging’ include accompanying documentation e.g. the user information sheet? | Guidance states “accompanying documentation”. | |
| Is it correct that on labelling, standards should still be referred to as EN xxx and not BS EN xxx? | Yes. | |
| For Category III Products, is the UKCA mark to be accompanied by the UKAB number, as per the CE XXXX marking requirement? | Yes | |
| Do you have an example pictogram how we stamp the new standard on the back of gloves? Thanks | This is not yet available. |