Transition from CE to UKCA could cause headache for exporters

A Samsung Việt Nam smartphone factory. Machinery and equipment are among the products covered by UKCA marking. VNA/VNS Photo

The new UK Conformity Assessed (UKCA) mark is about to be used in place of the Comformité Européenne (CE) mark for products sold on the market in Great Britain (England, Wales, and Scotland).

The Vintecom International Management Consultancy Company told Việt Nam News that the UKCA mark is a mandatory mark on products in 19 areas, including toys, machinery and outdoor equipment.

The UKCA technical requirements for a product will depend on the specific legislation on that product.

Certain assessment procedures allow manufacturers to self-declare their conformity. However, some other procedures for typically high-risk products require third-party conformity assessment.

Technical documentation and the UK Declaration of Conformity are compulsory in both cases and must be available to market surveillance authorities on request.

Regarding third-party assessment, manufacturers must find a UK-approved body to carry out the work. Once assessment procedures are completed, they will receive a certificate of conformity issued by the body and must affix the UKCA mark and the body's identification number to their products.

After December 31, 2022, assessment for new product types needs to be carried out by the bodies as well. Assessment procedures and modules applicable are the same as those in CE marking.

"Manufacturers should check relevant guidance to know exactly what to do to meet the UKCA requirements", the company said.

UKCA mark is at least 5mm in height unless a different minimum dimension is specified in relevant regulations. It can take different forms as long as it remains visible, legible and indelible and maintains the required proportions.

It may sometimes be placed on the manuals or other supporting literature, but the placement depends on the specific regulations applicable to the products.

A Samsung charger with a CE mark. After 11pm on December 31, 2022, the CE mark may no longer be used for products on the Great Britain market. — VNS Photo Việt Dũng

The Multilateral Trade Policy Department, Ministry of Industry and Trade (MOIT), told Việt Nam News the several steps Vietnamese firms should follow to enter the UK market.

First, they must check whether their products need the UKCA mark standards. If it is the case, they then proceed with a conformity assessment route, which involves either self-declaration of conformity or third-party conformity assessment.

The latter requires a UK approved body to ensure the products are properly checked for conformity. Names of the bodies can be found on the UK governmental services and information websites.

Manufacturers must prepare sufficient documentation to demonstrate that their products conform to regulatory requirements. The documentation includes a UK Declaration of Conformity, largely the same as what was required on an EU Declaration of Conformity.

Lastly, they must affix the UKCA mark to their products and export them to the UK.

"It takes much time and money to find out information on UKCA and prepare relevant documentation for the mark, adding to exporters' costs", the department said.

The department urged firms to improve their understanding of the UK market to stay ahead of the competition. Their knowledge about the market needs to be more practical and cover business culture, consumer preferences and buying habits.

The UK Government has begun to change many trade rules related to product standards and customs procedures post-Brexit. It is advisable to keep a finger on the pulse of the changes to stay compliant with the new rules.

It is equally important to employ legal advisors with extensive expertise in free trade agreements, especially UKVFTA, to deal with legal issues that arise from bilateral trade.

The advisors will ensure firms comply with technical guidelines set by the UK authorities and provide legal advice in case of irregularities and noncompliance.

Nguyễn Khánh Ngọc, deputy director of the MOIT's European-American Market Department, stressed the need for a set of guidelines on UKCA issued by Vietnamese trade authorities to keep firms well-informed about the new marking.

"Equipment and machinery comprise many Vietnamese exports to the UK. A set of guidelines on UKCA is thus indispensable", she said.

The deputy director underscored the UK as a market more demanding than the EU market. As a result, firms are recommended to rely on Vietnamese trade authorities, including trade offices, for in-depth information on UK trade rules and regulations.

They are also recommended to frequently engage in brand building to boost brand awareness and add value to target consumers, thereby gaining ground in the UK.

UKCA mark came into effect on January 1, 2021, but the validity of the CE mark was extended until January 1, 2023, to give firms more time for adjustments. UKCA mark covers most products in Great Britain that previously required a CE mark.

Meanwhile, EU conformity markings will remain in effect in Northern Ireland, which requires a CE mark for most manufactured products and some other marks, such as the Pi mark, for specific products.

Additionally, if firms use a UK body as a third-party conformity assessment, an additional UKNI mark is required.