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Putting product labelling to the test

26 May 2023

There are a range of requirements which manufacturers need to be aware of when the UKCA mark comes into effect, says Carl Hunt

THE UKCA (United Kingdom Conformity Assessment) mark will be required for most products placed on the market in England, Scotland and Wales (GB) from 1st January 2025. At present UKCA requirements align well with CE marking, but over time divergence is possible. There is currently a transition period until 31 Dec 2024, where UKCA is optional (suggested) and CE marking is accepted. 

Label requirements

The manufacturer’s label must include their name and address; the type, batch, serial or model number; or another element that allows identification. Whatever is used, it must link to the product’s declaration of conformity and technical files. If applicable, the importer’s label must include their local (EU or GB based) name and address. 

EU law also indicates that if the product is large enough to accommodate the marking, it must go on the product. Aesthetic factors are not an excuse for failing to apply the marking directly to the product. Only if the product is physically too small may the markings be placed on the packaging instead. This is not presently the case for UKCA where no such consideration on the size of products exists, but further guidance is evolving all the time. 

It is also worth noting that UKCA currently has a transition period of leniency about labelling for goods manufactured in the European Economic Area (EEA) or EU. Until the end of 2027, the UKCA mark may be applied to either product, via sticky label, or on accompanying documentation, such as a user guide. After that date only the product itself is permitted to carry the UKCA logo, but again that is expected to evolve over time and may end up aligning with the EU regarding smaller devices.

The market

Placing goods on the EU or GB market means making a fully manufactured good available for sale. The term ‘economic operator’ covers: 

  • The manufacturer
  • The importer
  • The authorised representative
  • The distributor

Easily the most prominent position here is the manufacturer. They can be based anywhere in the world and are typically responsible for a multitude of tasks. This includes designing and producing a safe product, performing a conformity assessment, testing with a third-party laboratory, creating the technical file, writing and signing the Declaration of Conformity, and labelling the product correctly.

When goods first enter the GB market, that most often makes the receiving party the Importer. Importers have some legal responsibilities, of which some people are not aware. This includes checking the conformity approach taken by the manufacturer and adding their own company details to the label.  

If the Importer finds that the conformity assessment approach taken by the manufacturer was incorrect, they have a legal obligation to raise it with the manufacturer and seek resolution. Ultimately, this could include declining to accept the shipment of possibly non-compliant goods.  

Authorised persons and representatives

Another alternative is for the manufacturer to appoint an authorised person or representative. This may be a subsidiary company or a private contracted firm, of which there are many available for either a yearly or per-product fee basis, to act on their behalf in the local GB market. With a known authorised representative labelling could be applied at the time of production, thereby relieving importers of any possible headaches and making business transition much smoother.

It is worth noting that only manufacturers and importers ‘place on the market’. Any subsequent operations termed ‘making available’ are likely to come under the final economic operator role of distributor. By this point, most checks and validations should have already been performed and goods are free to move without further encumbrance.

While product labelling may at first appear to be confusing, a systematic approach works best. Once you identify the directives and regulations that apply to your products, the labelling requirements simply follow.

Carl Hunt is product compliance assessor at TÜV SÜD

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