Check Your Mark of Approval
The decision on a product’s mark of approval depends on whether you are placing goods in EU countries, Great Britain (England, Scotland and Wales) or Northern Ireland.
Changes to certification system
From January 2023, panel product manufacturers outside the UK must change the official conformity assessment body they use if they want to supply the UK market. Previously EU Notified Body certification was required, but they will now have to use a separate UK Approved Body. If manufacturers want to supply both EU and UK markets, product will need to assessed separately by different panel certification bodies.
Product from outside the UK that goes directly into Northern Ireland and not into England, Scotland or Wales (Great Britain) still only needs to use an EU Notified Body.
CE Mark: For products such as US engineered wood panels directly entering EU countries, the CE Mark continues to be the mark of approval alongside the EU Notified Body system.
UKCA: The official UK Conformity Assessed (UKCA) marking is for product coming into Great Britain (England, Wales and Scotland) and replaces CE marking from January 2023. Product with the UKCA mark will have undergone third-party conformity assessment by a UK body. (Other changes include the importer’s details being permanently marked on the product, not just on the documentation or with a sticky label).
UKNI: This new conformity marking is only for products placed on the market in Northern Ireland which have been assessed by a UK body. It cannot be used on its own, but must be added alongside the UKCA. For GB manufacturers supplying NI, a special provision in the Protocol allows UK Approved Bodies to test to EU standards so that both CE and UKNI marking can be affixed.
Special treatment for products entering NI was set down by the Northern Ireland Protocol as part of the Brexit arrangements. The marking is unique to Northern Ireland and will not be recognised within the EU.
It is already common to see multiple conformity marks on internationally sold products so the CE and UKCA marks are likely to appear on many legally compliant products sold in both the UK and the EU.
