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Update to UKCA Guidance – PPE

07 December 2022

AS PREVIOUSLY advised the Government has made changes to the implementation of the UKCA regime and has just published the guidelines for the PPE sector.

They can be accessed through this link, Click Here.

The purpose of this note is to communicate the information and not to express views and opinions on the process of implementing the UKCA regime.

However, it is only right to say that I empathise with the feeling that we have again been marched to the top of a hill and marched right back down again!

The publication of the sector specific guidance has allowed further examination of the details and the headline is that until 11pm on the 31st of December 2024 products which conform to EU rules (which includes CE marking) can be placed on the GB market without reference to the UKCA process. This is a 2 year extension of the previously advised time in which CE is acceptable when placing PPE on the GB market. UKCA marking of course remains an option, you now can choose which route to follow.

Further, if an EU recognised conformity assessment body (Notified Body) has completed the relevant conformity assessment activities applying to a product, prior to 11pm on the 31st of December 2024, this would allow manufacturers to apply the UKCA mark without the need for any UK Approved Body involvement.

Manufacturers could then continue to place their products on the GB market on the basis of their existing CE certification for as long as their certificate is valid, or until the 31st of December 2027, whichever comes sooner.

Following on; the easements (published in June 2022) which allowed UKCA marking via labelling or on documents until 2025 have been extended until 2027. This extension to transitional arrangements also includes the UK suppliers of products (who are now in legal terms Importers) from the EEA, to continue to provide their details with accompanying documents as opposed to being on the product until December 2027.

We will continue to drill into the details of the guidance and deal with questions relating to “interpretations” as they arise and do our utmost to keep you informed.