The article “UKCA Accreditation Fades Away” (BDN newsletter 1 July 2022) may have elicited a range of emotions from readers, but for those involved in the manufacture, importation, distribution or retailing of motorcycle clothing, it is essential to have a full understanding of how recent measures introduced by the British government actually affect them. Increased Trading Standards activity this year on motorcycle clothing suppliers has already proved the need for better awareness and the consequences for failing to take note.
Contrary to the inference which some may have drawn from the article, the requirement to UKCA mark motorcycle clothing has not been “kicked into the long grass” as a result of the recent government announcement. UKCA marking is already happening. The legislation covering UKCA certification and marking has been in place since the United Kingdom left the European Union, following which a number of motorcycle clothing brands have applied for and received their UKCA certificates, with their products bearing both CE and UKCA marking.
Substantial backlogs have developed for companies waiting for UKCA certificates to be issued, however, and there was a risk that many (including those oblivious to the prevailing, already-extended deadline of 31 December 2022, and who had therefore not yet submitted their applications) would not receive their documents in time. Consequently, the easement which is now in place permits products to be UKCA marked where a manufacturer already holds for those products an EU certificate for CE marking issued by a European Notified Body. This easement can be applied only in respect of EU certificates issued between 21 April 2018 and 31 December 2022.
It is this final date which sets the expiry date for the easement of 31 December 2027, since EU and UKCA certificates have a validity of five years. No connection whatsoever between that date and unkempt lawns! From 1 January 2022, however, an application for UKCA certification will be required to be submitted to a UK Approved Body for any product for which an EU certificate has not been issued by or on 31 December 2022, and for all new products.
In summary, any new stock first placed on the UK market with effect from 1 January 2023 will still be required to feature the UKCA mark, either integrated into the product labelling, or attached as a sticker to the packaging immediately surrounding the product. When one strips away the complexities of the government’s latest announcement, very little has in fact changed.
Paul Varnsverry, technical director, PVA-PPE Group