So Much For CE Labels!

[SillyOldDufferModerator @sillyoldduffer]

Posted by Robert Atkinson 2 on 27/01/2021 07:50:56:

Posted by SillyOldDuffer on 26/01/2021 22:21:43:

Posted by Robert Atkinson 2 on 26/01/2021 22:04:55:

Posted by Neil Wyatt on 26/01/2021 18:33:02:

Posted by SillyOldDuffer on 25/01/2021 12:22:19:

There is no separate marking for NI they will stay with the CE mark.

…

Read all about it on the UK government website…

Dave

As I said " The only exception is those items that have to be assessed by a Notified Body,"

The UKNI is only for Items requiring NB 3rd party approval who use a UK NB. CE marking is still accepted if you use an EU NB.

Robert.

…

So what mark should be used by a Northern Irish manufacturer who wishes to sell in NI and the mainland, but not Europe, and wants to employ a British Notified Body? I assumed UKNI covered that, but the guidance table says UKNI is only valid as a marking if accompanied by a CE mark as well. Given the need for CE I'm not sure what UKNI is for.

I think the marking guidance as a whole means goods sold next year in the UK (apart from NI) will have to be UKCA marked (requiring a UK Notified Body), whilst UK manufactured goods for sale in Europe (including NI), must be CE marked, requiring a European Notified Body. Anyone in the UK making goods for sale in Europe and the UK has to provide both marks. Let's hope the same Technical File will be acceptable on both sides of the border!

Dave

[Mark RandParticipant @markrand96270]

Assuming the proper standards have been met, apply for and use the BSI Kitemark?

[Robert Atkinson 2Participant @robertatkinson2]

Posted by SillyOldDuffer on 27/01/2021 11:02:03:

Posted by Robert Atkinson 2 on 27/01/2021 07:50:56:

Posted by SillyOldDuffer on 26/01/2021 22:21:43:

Posted by Robert Atkinson 2 on 26/01/2021 22:04:55:

Posted by Neil Wyatt on 26/01/2021 18:33:02:

Posted by SillyOldDuffer on 25/01/2021 12:22:19:

There is no separate marking for NI they will stay with the CE mark.

…

Read all about it on the UK government website…

Dave

As I said " The only exception is those items that have to be assessed by a Notified Body,"

The UKNI is only for Items requiring NB 3rd party approval who use a UK NB. CE marking is still accepted if you use an EU NB.

Robert.

…

So what mark should be used by a Northern Irish manufacturer who wishes to sell in NI and the mainland, but not Europe, and wants to employ a British Notified Body? I assumed UKNI covered that, but the guidance table says UKNI is only valid as a marking if accompanied by a CE mark as well. Given the need for CE I'm not sure what UKNI is for.

I think the marking guidance as a whole means goods sold next year in the UK (apart from NI) will have to be UKCA marked (requiring a UK Notified Body), whilst UK manufactured goods for sale in Europe (including NI), must be CE marked, requiring a European Notified Body. Anyone in the UK making goods for sale in Europe and the UK has to provide both marks. Let's hope the same Technical File will be acceptable on both sides of the border!

Dave

UKNI covers the case that NI can accept CE marking, but a UK (inc NI) entity cannot be a Notified Body for CE marking. So for NI sales of items needing assesment by a Notified Body you can certify to EU CE regulations but use a UK (inc NI) Notiifed Body. This would be useful if only selling in NI.
A late breaking and odd arrangement. I would not be surprised if it changes.

[Neil WyattModerator @neilwyatt]

We are now a 'third party' country so these rules apply for exporting into Europe:

europa.eu/youreurope/business/product-requirements/labels-markings/ce-marking/index_en.htm

I suppose the issue will be for products covered by a 'notified body'.

Perhaps Wales will see the emergence of a 'Cymru Export' mark?

Neil

[Andy_GParticipant @andy_g]

Posted by Neil Wyatt on 28/01/2021 11:39:28:

Perhaps Wales will see the emergence of a 'Cymru Export' mark?

Good idea. I think we should have a combined Welsh and Scottish mark – something like

C U JIMMY

[SillyOldDufferModerator @sillyoldduffer]

Posted by Mark Rand on 27/01/2021 16:05:57:

Assuming the proper standards have been met, apply for and use the BSI Kitemark?

Different animal and the UK Guidance doesn't identify it as alternative.

The BSI Kitemark is a Quality Mark. It identifies a system where the supplier's design, methods, and product have been inspected against a specification by an independent authority. Quality Marks assure customers that high standards have been set and met, but not that the product meets all the standards needed to make it legal for sale. Although technically a good thing, cost is a major disadvantage because a third party and more work is involved. It's a high overhead and usually only done when better than CE/UKCA is needed. It's done as well, not instead of.

CE and UKCA are Conformance Marks, not Quality Marks. A different system. Conformance Marks only mean the seller believes the product meets whatever list of standards are applicable within the administration he is selling to. Conformance Marks usually relate to safety requirements. Conformance Marking is self-regulated, except sellers can be required to justify themselves by producing the Technical File. If a CE marked item causes an accident and it's found there is no technical file, or the content is negligent, then the supplier gets fined or someone goes to jail. The CE Mark doesn't cover how well made the product is, or even if it works at all.

CE means the seller asserts the product meets the specifications necessary to sell that type of item in the European Union. UKCA means the seller asserts the product meets British Specifications for sale in the UK. At the moment British and European specifications are practically identical, but leaving the EU means they can drift apart over time. From now on European exporters now have to assert UKCA is met and British exporters have to assert CE is satisfied.

The advantage of Conformance Marking is cheapness. It's not necessary for reputable businesses to do much more than they would do anyway, and they don't have to apply an expensive third-party inspection regime to ordinary goods. Governments don't interfere unless it goes badly wrong.

Unfortunately, self-regulation is abused. There's nothing like a policeman turning up to ensure good behaviour. Another disadvantage, Conformance Marking is often unclear to both sellers and buyers – who knows exactly what should be covered by a Conformance Mark and who knows what actually is? Without seeing the Technical File the customer can't tell, and the Technical File might be a fake. Perhaps the biggest flaw is the much too subtle difference between Conformance and Quality. Confusion galore – everyone I know thinks CE is a Quality Mark, and, if they notice it at all, they'll probably believe UKCA is too. Bottom line: BSI Kitemarks don't apply to international trade rules and UKCA/CE Conformance Marks don't guarantee quality.

Dave

[Mark RandParticipant @markrand96270]

My thought had been that, if the product was for the GB+Ulster market, as stated, and if there was an applicable British Standard, then paying for the inspection and license fee for the BSI Kitemark was a valid method.

[Dave SParticipant @daves59043]

Actually the exporter doesn’t have to worry about ce /ukca – that’s explicitly the problem of the person placing the product on the market. Usually the importer, although there are some exceptions.

If the product doesn’t meet the requirements of course then it shouldn’t be for sale, and the exporter is likely to have a problem selling it to the importers. EU law is changing shortly such that the manufacturer needs a representative in the market to be able to sell to consumers, but b2b sales it’s still the importers responsibility before selling to consumers- they become the manufacturer rep by default.

Clusterfcuk doesn’t even come close…

Dual, virtually identical paperwork for no actual benefit at all.

Dave

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