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Brexit – What will happen to the restricted substances requirements of your manufactured EE products?

SafeGuardSHardgoodsOctober 10, 2020

The United Kingdom (UK) left the European Union (EU) on January 31, 2020 and the transitional arrangements are coming to an end on December 31, 2020. Recently the UK published guidance on placing manufactured goods on the market in Great Britain (England, Wales and Scotland) from January 1, 2021.

From January 1, 2021, the UKCA (Conformity Assessment) mark (Figure 1) will be the conformity assessment marking for Great Britain for electrical and electronic products that are currently subject to CE marking. A 1-year transition period has been granted – the CE mark will be accepted in the UK until January 1, 2022, except for medical devices, aerospace equipment, products requiring ecodesign and energy labeling and etc. After this date, the UKCA mark must be used for products placed on the British market. The UKCA   mark will not be recognized on the EU market, and thus CE marking is still a must for those products which require CE marking to be sold in the EU. 

Figure 1. UKCA Mark

SG 14320 Body Image

The conformity assessment procedure for UKCA mark is largely the same as the CE mark except that: 

  1. The authorized representative or responsible person (if any) in the EU would no longer be recognized from the January 1, 2021 and an authorized representative or responsible person based in UK shall be assigned for the UKCA mark
  2. The conformity assessment body for the UKCA mark shall be UK approved, while for CE marking it shall be performed by any CE conformity assessment body
  3. The UK Declaration of Conformity is a document which must be drawn up for most products bearing the UKCA mark. The requirements for the UK declaration of conformity are basically same as the EU declaration of conformity, except that relevant UK legislation should be listed, and the UK designated standards shall be listed instead of those cited in the Official Journal of the EU

The UKCA mark shall be applied for all electrical and electronic products that currently bear a CE mark. For other restricted substances requirements, such as REACH, POPs, and food contact materials, etc., currently the UK has no plan diverge the restricted substances requirements from the EU. Table 1 shows the corresponding EU and UK legislation on common restricted substances requirements.

Table 1. EU and UK Legislation on Restricted Substances Requirements 

EU LegislationUK Legislation
Restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS) 2011/65/EU and amendment (EU) 2015/863
(Marking: CE Mark)
The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 (as amended)
(Marking: UKCA Mark)
REACH Regulation (EC) No. 1907/2006 and its amendments
The REACH Enforcement Regulations 2008 (as amended)
POPs Regulation (EC) No. 2019/1021 and its amendments
The Persistent Organic Pollutants Regulations 2007 (as amended)
Battery Directive 2006/66/EC and its amendment 2013/65/EU
The Batteries and Accumulators (Placing on the Market) Regulations 2008 (as amended) and the Waste Batteries and Accumulators Regulations 2009 (as amended)
Packaging Directive 94/62/EC
The Packaging (Essential Requirements) Regulations 2015
WEEE Directive 2012/19/EU and its amendments
The Waste Electrical and Electronic Equipment Regulations 2013 (as amended)
Regulation (EC) No 1935/2004 Materials and articles intended to come into contact with food and regulations under the (EC) No. 1935/2004The Materials and Articles in Contact with Food (England) Regulations 2012 (as amended)

SGS is committed to providing information about development in regulations for consumer products as complimentary services. Through a global network of laboratories, SGS provides a wide range of services including physical/mechanical testing, analytical testing and consultancy work for technical and non-technical parameters applicable to a comprehensive range of consumer products. Please do not hesitate to contact us for further information.

For enquiries, please contact: 

Tiffany Tsui 
Technical Services Executive, SGS HK EET
t: (852) 2774 7160 

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