Most UK manufacturers are driving at speed to meet the deadline of the transition period; 1st January 2022, so INCA deemed it worth updating those members outside of the External Wall Insulation product supply chain on the current issues and challenges. The main purpose is to reiterate that the process of applying the new marks is not as simple as people may think and that the supply chain is working hard on making this as simple a transition as possible, many draining their resources in the process.
We are all aware of the ‘CE mark’ and have accepted it as a mark of product declaration. It shows that an individual product has been manufactured against a harmonised European Norm and in most cases, manufacturers have used third party assessment bodies to validate the declared data. ‘CE marking’ works well for simple products or components where EN standards exist such as cementitious renders but does not lend itself to kit systems such as External Wall Insulation / ETICS systems. Initially, the UKCA and UKNI mark will use the same EN standards, the only difference being they will become a British Standard with no reference to EN in the subject title as we are no longer part of the EU.
The transition for product marking started on the 1st January 2021 and ends on the 31st December 2021 with all new products produced during this period having to comply with the new UKCA / UKNI mark. To demonstrate compliance to the new marks, EU test data can still be used as new BS standards are currently a mirror image of the EN standards, but it should be noted that over time the BS standards may steer away from these and new testing will be required. At this stage, it is not expected that products placed under the new marks will need to be tested or validated by a UKAS Approved Body due to lack of capacity in the UK, but this could change. For those products tested in the UK by a UKAS Approved Body, this data can no longer be used for placing a product into the EU under the CE mark, it must be tested or validated by an EU Notified Body.
The UKCA mark applies to all parts of the UK with the exception of Northern Ireland, which has its own mark called the ‘UKNI’. Depending on where the testing has been completed, products placed into Northern Ireland will be required to carry the CE mark and if tested by a UKAS Approved Body, must also carry the UKNI mark. Whilst the CE mark will still be recognised and accepted in Northern Ireland, it will cease to exist in the rest of the UK from the 31st December 2021.
For kit systems such as EWI / ETICS, it is slightly more complicated in that these systems can be placed into the UK under the current European mark of ETA (European Technical Assessment) or a third-party Certification scheme such as BBA or Kiwa BDA. Whilst these routes all use the same testing programme, European Approval Document (EAD, formerly known as ETAG), depending on the route to market this could become complicated. Those companies choosing to place their systems into the UK cannot use a European Technical Assessment (ETA) to CE mark the system as of the 31st of December 2021; but instead, will need a UK Technical Assessment (UKTA) against a United Kingdom Approval Document (UKAD) to UKCA mark the system. However, this is not yet possible due to ongoing negotiations with the European Organisation for Technical Approvals (EOTA). When using third party Certification bodies such as BBA or Kiwa BDA, these are voluntary Certifications and currently do not require any changes other than ensuring the data used within the Certificates is up to date.
As stated in my last update, this is not just related to products associated with INCA and External Wall Insulation but all construction-based products including PPE, hardware used for installing and even includes everyday items such as tape used for protecting window frames and mastic sealants.
INCA Technical Committee Chairman, Kevin Mangan
Insulated Render and Cladding Association (INCA)
66 Bondgate, Castle Donington, DE74 2NR
Tel: 0330 124 6585 Email: info@inca-ltd.org.uk
Website: www.inca-ltd.org.uk
