Construction Products Regulation in the UK and the introduction of the UKCA mark

The UK has left the EU and the transition period after Brexit comes to an end on 31st December 2020. One area this will impact is the CE marking Directive, used across a variety of products in different sectors.

The UKCA (UK Conformity Assessment) marking is a new UK product marking that will be used for goods being placed on the market in Great Britain (England, Wales and Scotland). Northern Ireland will have its own equivalent system called UKNI.  UKCA/UKNI will cover most goods which previously required the CE marking.

This statement by the BPF Pipes Group is intended as a guide for designers, stockists and users of plastic piping systems that are manufactured to European standards. The statement reflects our current understanding of CE/UKCA/UKNI marking and further updates are likely to follow as more guidance is issued by government

Government guidance can be found here:

https://www.gov.uk/guidance/construction-products-regulation-from-1-january-2021

https://www.gov.uk/guidance/using-the-ukca-mark-from-1-january-2021

https://www.gov.uk/guidance/using-the-ukni-marking-from-1-january-2021

 

  1. Introduction of the Construction Products Regulations

On the 1st July 2013, the Construction Products Directive was superseded by the Construction Products Regulations (CPR). This means that for construction products placed on the market in the European Economic Area (EEA) and either covered by a harmonised European standard (hEN) or conforming to a European Assessment Document (EAD), a Declaration of Performance has to be drawn up and the products need to be CE marked.

The harmonised European Standard (hEN) must be published and cited by the European Commission before CE marking is permitted.

NOTE: "harmonised European Standard" has a specific meaning under the CPR and should not be confused with Euronorms (EN) which are developed by consensus and adopted by countries across Europe (including the UK as BS EN standards) to provide consistent and reliable product performance.

  1. Situation for plastic piping systems

The necessary Harmonised European Standards (hENs) are not yet published and cited in the Official Journal of the European Union.

 This means that it is currently not possible, and not legal, to apply CE marking to, or issue a Declaration of Performance (DoP) for, plastic piping systems in any of the following applications: 

  • Non-pressure soil and waste discharge
  • Underground non-pressure drainage and sewerage
  • Buried and above ground conveyance of liquids under pressure
  • Hot and cold water distribution

CE marking is also not allowed for plastic piping for rainwater downpipes and gutters.

     3. Demonstrating compliance with Construction Products Regulation in UK (from 1st January 2021)

All existing Harmonised European standards (hENs) will become UK Designated Standards on 1st January 2021.

Products legitimately CE marked and placed on the EU market prior to 1st January 2021 can continue to use the CE mark to demonstrate compliance with the regulations in the UK until 31st December 2021. After this date CE marking will no longer be recognised for market access in Great Britain and the UKCA mark will be used. In Northern Ireland, the Northern Ireland Protocol comes into force from January 2021. Whilst this is in force, products placed on the market which can legitimately be CE marked can continue to use CE marking after 1st January 2021 if the mark was awarded by an EU conformity assessment body. Products which can legitimately be CE marked but use a UK body to carry out a conformity assessment must use the UKNI mark together with the CE mark.

To prepare for the changeover at the end of year, manufacturers can seek UKCA marking against UK Designated Standards for their products from 1st January 2021.

      4. What does this mean for purchasers of plastic piping systems?

Where it is currently not possible and not legal to apply CE marking (see Point 2 above), it will not be possible and not legal to apply UKCA marking.

Plastic piping systems are manufactured to recognised product standards (ENs or EuroNorms, adopted as BS ENs in the UK) which contain technical requirements for consistent and reliable performance. The use of these BS EN product standards is unaffected and will not change after 1st January 2021. Plastic piping systems will still be specified, sold and used to these product standards as done until now, in all Member States.

The Pipes Group and its members strongly advise that compliance with these product standards is verified through a third-party certification scheme.

Be assured that products manufactured by our members are meeting all the requirements and are covered by the approvals necessary to stock, sell, install or use throughout Europe.

Construction Products Regulation in UK (from 1st January 2021) and the introduction of the UKCA mark