The Time to Act is Now

An expert from TÜV SÜD provides insight regarding the CE and UKCA markings and the implications for the VT industry.

With Brexit, the requirements for placing lifts and components on the British market have changed. The new British U.K. Conformity Assessed (UKCA) marking will be mandatory by 1 January 2023 for all products and it is comparable to the Conformité Européenne (CE) marking for the European market. German-born Jonas Conrady (JC), head of New Technologies for lifts at TÜV SÜD and strategic account manager for Schindler, took the time to speak with your author (KW) about the implications of this change for the lift and components industry. Conrady holds a bachelor’s degree in industrial engineering from Baden-Württemberg Cooperative State University and a double master’s degree in business administration from the University of Augsburg and the KATZ Graduate School of Business in Pittsburgh.

KW: From what I have read, at this point, it seems that having a UKCA marking is simply a matter of obtaining and affixing a different label/plate/sticker (from CE) on products. Is this correct?

JC: The UKCA marking is not only a different label to be affixed, but is required for goods being placed on the market in Great Britain — including England, Wales and Scotland but not Northern Ireland. The new regulation covers most goods that required the CE marking until the withdrawal of the U.K. from the European Union in early 2020. Fortunately, the conformity assessment processes and standards remain largely the same as they were for the CE marking.

Speaking of elevators, a conformity assessment procedure carried out by an Approved Body has been mandatory for lifts, safety components and all quality assurance systems since 1 January 2021. But companies have a grace period until 1 January 2023. This was recently extended. That means manufacturers are obliged to undergo a complete certification and declaration process for the U.K., as well. It is, of course, helpful to know the CE procedures. If a product already has a CE marking, a U.K. Approved Body might be able to acknowledge some of the performed tests and assessments.

KW: What is the significance of the transitional grace period for replacing the CE with the UKCA marking?

JC: The U.K’s Department for Business, Energy & Industrial Strategy just extended this grace period for one more year, until the end of 2022. This extension shows how important and urgent this topic is for all market players. If you ask me, all affected companies should not wait any longer to start their UKCA activities. Even though there could be some loopholes about how placing a product on the market is defined, one should not wait any longer to be on time.

KW: Regardless, products will need new labels. Are there any requirements for these labels — size, material, approved manufacturer, where it goes on a product, etc.?

JC: Firstly, when reducing or enlarging the UKCA marking, the proportions of the letters must be retained. But, they cannot be smaller than 5 mm in height, unless a different minimum dimension is specified in the relevant legislation. Secondly, it must be highly visible and legible, and be permanently attached to the safety component by 1 January 2023. Before that date, the details can also be placed in an accompanying document or affixed to a label. Colourwise, it may take different forms.

KW: Initially the UKCA marketing requirements will align with the CE marking requirements they replace, but, over time, divergence is possible. Could you please elaborate? Are there instances in the past from which you can draw parallels?

JC: I am not aware of a similar situation in the past. At present, neither the EU nor the U.K. plan to change their directives/regulations until 2023. Based on EN 81-20/-50, the ISO Technical Committee is now revising the prescriptive elevator code ISO 8100 (parts 1 and 2) with updated safety rules for construction and installation, as well as design rules, calculations, examinations and tests of components.

I consider the separate development of a British standard that deviates from the ISO 8100-1/-2 versions very unlikely within the next few years. I’d rather expect the amended/revised ISO 8100-1/-2 standards will fulfil the presumption of the conformity principle for both the EU Lifts Directive and the UK Lifts Regulation — each under the umbrella of their respective standardization organizations.

However, as the British Standards Institution (BSI) will continue its membership in Europe with the Comité European de Normalization (CEN) and ISO, I don’t expect there will be any significant changes in the applicable standards. That’s because both have agreed to cooperate in the further development of the current EN 81-20/-50 under the new reference number ISO 8100-1/-2. Nevertheless, we’ll look closely at that and follow up on any changes, for example, by joining the U.K. lift working groups.

KW: Explain what TÜV SÜD BABT is.

JC: The BABT is a legal entity of TÜV SÜD in the U.K., which went through the accreditation process with the U.K. Accreditation Service (UKAS) to become an Approved Body.

KW: What sort of UKCA certification work must be done for the Supply of Machinery (Safety) regulations 2008? This is the one that applies to components for vertical-transportation (VT) equipment such as ropes, right?

JC: Are the components CE-marked? If so, they would need to go through the same sort of process for UKCA. If not, and they fall out of the scope of CE because they are spare parts not placed separately on the market, then the same would apply for UKCA.

KW: How will importers to the U.K. need to handle the transition and does this mean, for them, a dual CE/UKCA marking? When should they begin and what should they do?

JC: It’s important that the different parties make sure of what their roles are. Manufacturers may become importers or distributors may become importers. For a manufacturer, it might even be useful to appoint an authorized representative. The new roles and the correspondent responsibilities and requirements need to be absolutely clear because the legal obligations of the respective economic actors vary. For example, other than distributors, importers must check whether manufacturers have carried out the right conformity assessment procedures. They must also include their name and registered trade name or mark, as well as a postal address on the safety component or, where this isn’t possible, on its packaging or in accompanying documentation.

Even if the deadline has been extended, as described above, the various economic actors should act immediately to avoid time and capacity problems. A dual marking will be mandatory once the goods are placed on both the EU and the U.K. markets.

KW: What sort of costs are involved in consulting with a U.K. Approved Body, what does this consist of and how much time is involved?

JC: This needs to be evaluated on an individual basis. For the evaluation, the full set of documents is required in English. We are happy to support you if you send requests to liftcertification@tuvsud.com.