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 | |
| ‘Regulation 2016/425 on Personal Protective Equipment as brought into UK law and amended’ | 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 regulations apply when selling to southern Ireland? | As Southern Ireland remains part of the EU, CE Standards and the PPE Regulation 2016/425 will still apply | |
| Please explain the situation in Northern Ireland re UKNI mark and CE mark and what you can and can’t do re product marking – thanks | For this type of detail you should refer to the UK Gov guidance https://www.gov.uk/government/publications/moving-goods-under-the-northern-ireland-protocol | |
| What is the UKNI mark ? same as UKCA or yet another different/seperate marking. | It is a different mark see https://www.gov.uk/government/publications/moving-goods-under-the-northern-ireland-protocol | |
| What is the timing for Northern Ireland marking? Can CE be used indefinitely? Can products be marked CE, UKCA and UKNI? | Timings are the same as far as commencement is concerned. The NI rules as explained will remain subject to the NI Protocol remaining in place. | |
| Can you please advise if we sell to Ireland, will the products need the UKCA and the UKNI Mark? We distribute in the UK, EU and IE. | CE or UKNI (single or together) will be required. | |
| So, to place products on the NI market we need to go through the UKNI process? Or will CE still be recognized in NI? | CE or UKNI (single or together) will be required. | |
| If we as manufacturer “import” goods for sale in UK – do we also separately need UKNI certification if goods are sold in Northern Ireland. | CE or UKNI (single or together) will be required. | |
| If a product is marked CE and UKCA – can it be sold in Northern Ireland? | We believe so as they will be CE with the “addition” of UKCA therefore multi marked. | |
| Could you place a product on the market in NI with the CE mark and the UKCA? | We believe so as they will be CE with the “addition” of UKCA therefore multi marked. | |
| Can CE & UKCA dual marks be placed on market in NI? | We believe so as they will be CE with the “addition” of UKCA therefore multi marked. | |
| If my product is CE & UKCA dual marked / certified can this be legally sold in Northern Ireland, on the basis that N.I still accepts the CE marked products..? | We believe so as they will be CE with the “addition” of UKCA therefore multi marked. | |
| If items are made available in Northern Ireland, can you mark with both CE and UKCA as a duel marking? Or does it need to be just CE or CE and UKNI? | We believe so as they will be CE with the “addition” of UKCA therefore multi marked. | |
| Can a product be sold in NI with both the UKCA and CE mark on it? | We believe so as they will be CE with the “addition” of UKCA therefore multi marked. | |
| If a product is CE marked by an EU NB and UKCA marked by a UK Approved Body, and the product sold in GB, NI & EU, is the UKNI mark needed as well? | We believe so as they will be CE with the “addition” of UKCA therefore multi marked. | |
| Can UKNI marked product be sold in GB? | Yes under the “unfettered access” status for NI businesses. | |
| If a CE marked PPE is placed on the market in Northern Ireland (without UK NI, nor UK CA marking), it can then be further sold in GB ? | Yes under the “unfettered access” status for NI businesses. | |
| If a product carries the UKNI mark can it be sold across NI, EU and UK (GB) territories? If the business uses UKNI must they also be based in NI or just use a person based in NI (Notified Person.)? | For EU it would need CE. If it is being sold by an NI business into the GB market “unfettered access” says that it would require no further approvals | |
| As an end user in Northern Ireland, must all of our PPE have either CE or UKNI mark? If the PPE only had UKCA mark is it “non-compliant”? Thanks in advance. Do the same principles apply to other CE marked items such as machinery? | In NI the PPE can have UKNI or CE or both. UKCA on its own is not recognised. Supply of Machinery (Safety) Regulations 2008 covers Marking for Machinery – but is out of our remit, please check gov.uk for guidance | |
| Will NI have product standards or adopt GB/European EN standards? Or perhaps this is not yet known? | The standards will be UK designated standards for UKNI and EN for CE | |
| Is the general view amongst BSIF members who are manufacturers that products will be labelled such that a company in NI will be able to buy them from GB, and then sell the either within NI, back to GB or into Rep of Ireland or other parts of the EU? | We believe that as a view the most flexible position would be for NI businesses to “prefer” CE as this would allow them to sell into Eire and the EU GB and the NI domestic market. | |
| Are you saying that if you are a distributor in NI with a CE marked product, they can import from NI to UK without a UK CA marking? | Yes | |
| If a product is imported through NI the UKNI mark is applied and these can be sold in the rest of the UK? so in essence we have 2 different standards to check for when looking for compliant products post 2022? UKCA, with CE and UKNI with CE? | Yes they can. | |
| As a company that imports European product to the UK – could we now have product delivered to a site in NI which could then be legitimately be sold into the UK mainland without the UKCA mark ? | Yes | |
| Can UKNI accreditation be given by a UKCA UKAB – or is UKNI accreditation via another set of approved bodies? | UKNI approval would be given by a UK Approved Body | |
| Is there anyway BSIF would help the whole sector ref NI labelling such that: if it was assumed that any NI company buying from a GB PPE company would want to a) sell within NI b) sell back to GB after having brought the goods to NI to store, c) sell anywhere within EU after bringing to NI to store. The idea being a BSIF document formatted could be used by any GB PPE company such that there would be one document that can be used by everyone for the same purpose – this would save money, time, enhance clear communication and provide value for all BSIF members. This would allow quick and easy assessment of what the status of any product was at any point in time and when if at all it would be available to meet a, b, or c | Yes, I believe that we could do this. |