Update: The Government has very sensibly postponed the rollout of UKCA by two years to conduct a more thorough of requirements. This is exactly what we recommended, and the Government should be commended for this sensible step.
Originally published: November 2022
The UKCA mark is set to replace the CE mark as the product safety standard for the UK. I have been in direct communication with BEIS on this issue, specifically regarding the impact on the UK technology industry, but have also set out my thoughts below:
Unpreparedness
The large majority of firms we speak to are not prepared for UKCA, and are unlikely to be prepared by January. There are several reasons for this.
Firstly, many firms do not have in-house testing capacity, as they have their electronics designed and built by a third party (often abroad). As such, they have neither the lab space, the equipment, nor the people to self-certify UKCA. They thus need to need to employ a consultant to do this. This is not only expensive, but there is currently poor availability and long lead-times on this sort of service. You can imagine, the complexity is multiplied for firms that have a diverse range of products.
Even if you do design and build electronics in-house (like we do), many of these limitations still apply. Skilled engineers are hard to come by at the moment, so having excess capacity to carry out the necessary testing, paperwork etc. is unlikely. UKCA is complicated (see my next point), and firms will have to make big sacrifices to get everything properly certified on time (as we are trying to do).
Our expectation is that the majority of firms - especially smaller firms - will, come January, just self-certify that they have UKCA, on the basis that they have a CE mark, even though they haven't done the majority of the work necessary to actually achieve UKCA.
Opportunity
So is UKCA worth it?
CE is complex by nature - it makes references for example to 'ensuring you adhere to all relevant harmonised legislation'. Well, that takes a lot of time to be able to make that assurance. The opportunity therefore for UKCA is to be much clearer and simpler. In our experience it doesn't currently achieve that. As such, for any UK firm that exports to the EU, as we do, we now have to go through two very (and unnecessarily) complicated processes for our product range. This adds a lot of red tape.
My recommendation would thus be to make UKCA optional (i.e. you need CE or UKCA to sell in the UK), and take some time to redesign UKCA in consultation with industry (including small firms, as sometimes large firms like complex regulations as they raise barriers to entry) to make it as simple as possible. This will mean that UK firms that don't export to the EU get to benefit from lighter touch regulation, and those that do at least don't have more red tape than they do currently. Over time, maybe the EU/EEA might learn from UKCA, and might be convinced to simplify CE in our sector ... who knows?
It would be sensible therefore not to go ahead with plans to make UKCA mandatory in January, especially in its current guise. It probably won't be a complete disaster, because - as I said - most firms will just claim to have it. But it will add unnecessary red tape at a time when we're all trying to recover from recent (and to some extent lingering) supply chain shortages etc., and penalise the more diligent firms.
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