In August 2021 the UK government postponed the requirement for manufacturers to adopt the UK Conformity Assessment (UKCA) mark for goods placed in the UK market until January 1st, 2023, allowing an additional 12 months for manufacturers to prepare.
Manufacturers of goods headed to the UK market began adding the new UKCA mark to their products on January 1, 2021. Beginning January 1, 2023, the UKCA mark will be mandatory. During this transition period, the ATEX "Ex" or CE mark will also be accepted for the UK market.
The UKCA mark will take the place of the EU requirements for ATEX and CE Marking and will indicate that a product placed on the GB market meets the UKCA marking requirements. FM Approvals Ltd., based in Maidenhead UK, has become a UK Approved Body (1725), designated by the UK Secretary of State, and is currently providing the relevant UKCA mark certification services.
FM Approvals can offer one-stop services consisting of certification for:
- Access to international markets—FM Approvals certification
- Access to European market for CPR and ATEX products—CE certification (CPR and ATEX)
- Access to UK market for UK CPR and UKEX products—UKCA certification (UK CPR and UKEX)
- Access to IECEx markets for equipment in explosive atmospheres—IECEx certification
Additional services as needed:
- FM Approvals is assisting interested customers with the transition from CE to UKCA marking for ATEX and CPR products
- For products that are already CE certified by FM Approvals based on up-to-date standards, efficient UKCA certification process
- For FM Approved products that are CE certified by another Notified Body, UKCA certification process does not require retesting in general provided there is sufficient evidence of performance conformity in the submitted reports
- UK FPC and QAN audits will be combined with EU FPC and QAN audits as well as with FM Approvals audits to ensure an efficient auditing program
Emerson Automation Solutions
One FM Approvals customer that has worked hard to transition its many ATEX and CE certified products to the new UKCA marking is Emerson Automation Solutions (Fisher-Rosemount Systems, Inc.) in Round Rock, Texas, USA.
Emerson moved nearly 400 of its FM Approved and ATEX certified products to the new UKEX mark from March to August 2021. According to Emerson certification manager Kim Le, "After the Brexit transition period—at the end of 2020—no one had all of the information we needed about how to proceed. We had to work our way through the new requirements, which were not totally clear at first, to meet the deadline to transition our marks to the new UKCA marking at the end of 2021."
Emerson relies on FM Approvals for the FM Diamond and its ATEX certifications as well. "Since we maintain our ATEX certification through FM Approvals, it was pretty straightforward for us to have them transition those certifications for us. I'm sure it was more complicated for them, but from our perspective it was pretty easy."
Kim Le, who has been with Emerson since 2007, notes that internally, her team had to issue an engineering change order (ECO) to the firm's manufacturing organization for each product that needed to be relabeled with the new UKEX mark. "We manufacture at multiple sites in Asia so having to coordinate all of the label changes with them was a little challenging. We were pretty happy when the UK decided to extend the deadline to the end of 2022. Now we can use our inventory with existing CE and ATEX (Ex) marking in a more controlled manner. They reissued all of our FM Approvals certificates out of the Dublin office for acceptance by the EU. It feels good to be done with all of this early."
Siemens AG
For Siemens AG's Process Industries and Drives division, based in Karlsruhe, Germany, the challenge was to transition the ATEX certification of more than 160 devices—primarily flow meters—to the new UKEX scheme.
According to Jasmin Landenberger, certification coordinator for the Siemens division, the process took about six months in total. "We worked with six different agencies and FM Approvals was the quickest. Overall, the process was quite easy."
Landenberger, who has been with Siemens since 2009, worked closely with FM Approvals' Mike Kornitsky, senior engineering specialist for hazardous locations, in making sure the firm's paperwork was up-to-date to ensure a smooth transition to the UKCA mark. Kornitsky also assisted Emerson with its conversion to the new UKCA scheme.
"Both Emerson and Siemens were what we refer to as revision requests, which is essentially an update to an existing certification," Kornitsky explains. "A revision request is much quicker than a full project, which involves testing, auditing, and so forth. Most of our customers required the transfer both for ATEX in the EU to the UKEX for Great Britain and for IECEx as well."
Steps to success
For an existing FM Approvals customer, the transition from ATEX or IECEx to the new UKCA Ex scheme is fairly straightforward, notes FM Approvals Ltd.'s UK certification manager Victor Aluko-Oginni. "The customer submits a revision request to us to issue the UKEX certificate based on their current ATEX or IECEx certification because there is an agreement between the UK and the EU that they will still recognize those certifications in UK. So the existing EU standards still apply."
Once the revision request has been submitted, an FM Approvals representative will review the request and the product in question to make sure it is still valid within the context of both FM Approvals standards and the ATEX directives. A report on this analysis is prepared and reviewed.
"There are other scenarios as well," Aluko-Oginni says. "For instance, new customers can come to us as well and we can review the certification work that has been done by their own Notified Body and, provided it is satisfactory, we can also issue the UKCA for them as well."
He adds, "One of the essential requirements for any customer is to make sure they have the UK version of the Quality Assessment Notification (QAN). A new UKEX QAN certificate is required. We have been an Approved Body in the UK since December 2020 and can meet the needs of new and existing customers. We're happy to provide a proposal upon request."
More detailed information on the new UKCA marking requirements can be found in the FM Approvals UKCA FAQ document. If you have any question regarding your specific certificates please contact your project manager or send an email to europe@fmapprovals.com.