Lauren

Just to confirm - the extension to 2027 is only for how the product must be 
labelled to show compliance with UKCA, and not whether it must comply with UKCA 
- i.e. they're allowing manufacturers and extra 3 years to update product 
labels, artwork and rating plates.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Lauren Crane <00001afd08519f18-dmarc-requ...@listserv.ieee.org>
Sent: Friday, January 12, 2024 11:53 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UKCA Extension .... again

Thanks for this Dean,

In part it, pointed me towards the current UK incarnation of the LVD - that is 
to say, I had not noticed until now that the LVEESR (Low Voltage Electrical 
Equipment Safety Regulations) SI 1989 No. 728 had been replaced by the EESR 
(Electrical Equipment Safety Regulations) SI 2016 No. 1101.

The delays built into the EESR and the SoMSR (Supply of Machinery Safety 
Regulations) SI 2008 No. 1597 seem to be similar - which is to be expected ---- 
neither of them last indefinitely, so I guess we will have to wait and see if 
that promise is fulfilled.

Instrument
Allowing CE processes (incl. DoC) to stand (conditionally) for UKCA
Allowing UKCA mark to be in product documentation rather than on the product.
SoMSR SI 2008 No.1597 consolidated doc generated 15nov2023 incorporating F50 
(SI 2022 No.1393)
Allowed in regulation 12A
The expiry of regulation 12A is defined in regulation 12B as "regulation 12A 
ceases to have effect at the end of the period of [F50 four years] beginning 
with IP completion day." - which equates to Dec 31, 2024
In regulation 7 point (2A) - "[F36(2A) For a period of [F37seven years] 
beginning with IP completion day, the UK marking may be affixed to-
(a) a label affixed to the machinery; or
(b) a document accompanying the machinery.]"- which equates to Dec 31, 2027.
EESR SI 2016 No. 1101 consolidated doc generated 15nov2023 incorporating F54 
(SI 2022 No.1393)
Allowed in regulation 34A.
The expiry of regulation 34A is defined in regulation 34B as "regulation 34A 
ceases to have effect at the end of the period of [F54 four years] beginning 
with IP completion day." - which equates to Dec 31, 2024.
In regulation 39 point (1A) - "[F66(1A) For a period of [F67seven years] 
beginning with IP completion day, the UK marking maybe affixed to-
(a) a label affixed to the electrical equipment; or
(b) to a document accompanying the electrical equipment;]" - which equates to 
Dec 31, 2027

But note there is a further provision that kicks in following the expiry of the 
above and allows the UKCA mark in a document+package if the equipment is too 
small (or other issues) - and this provision does not expire.
"(2) Where [F68paragraph (1A) does not apply and] it is not possible or 
warranted, on account of the nature of the electrical equipment, to affix the 
[F69UK] marking in accordance with paragraph (1),the [F69UK] marking must be 
affixed to-
(a) the packaging; and
(b) the accompanying documents."

Best Regards,
-Lauren

From: Jurgensen, Dean <djurgen...@delta-q.com<mailto:djurgen...@delta-q.com>>
Sent: Thursday, January 11, 2024 9:18 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] UKCA Extension .... again

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Hello Colleagues,

RE: Electrical Equipment (Safety) Regulations 2016

Here is what I was able to find:

General guidance site: On this site page:   
https://www.gov.uk/guidance/using-the-ukca-marking
"The government intends to introduce legislation to extend recognition of goods 
that meet EU requirements, including the CE marking, indefinitely, beyond 31 
December 2024 for many products. This will mean that certain goods that meet EU 
requirements can be placed on the GB market. These updates apply to the 18 
regulations that fall under the Department for Business and Trade (DBT).  
Manufacturers will have the choice to use either the CE marking or other 
recognised EU markings (where permitted), or the UKCA marking to supply 
products to Great Britain in the following areas: ..."
===
The UK regulation Section 34A - seems to allow for CE Marking: 
https://www.legislation.gov.uk/uksi/2016/1101/regulation/34A

And

The UK regulation Section 34B - seems to allow for CE Marking for an extended 
period of time after the expiry of Section 34A: 
https://www.legislation.gov.uk/uksi/2016/1101/regulation/34B/2022-12-31

Thoughts,
Dean

Dean Jurgensen
Delta-Q Technologies Corp.
www.delta-q.com<http://www.delta-q.com/>


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From: Lauren Crane 
<00001afd08519f18-dmarc-requ...@listserv.ieee.org<mailto:00001afd08519f18-dmarc-requ...@listserv.ieee.org>>
Sent: Thursday, January 11, 2024 10:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] UKCA Extension .... again

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Hello Experts,

In Nov 22 we (this listserve) were discussing the UKCA extension aiming to 
allow CE marking to stand in for UKCA for a longer period. We were tracking a 
related statutory instrument, which I believe has been released as SI 2022 No. 
1393 (https://www.legislation.gov.uk/uksi/2022/1393/contents/made).

This SI 1393, however, does not appear to extend the deadline indefinitely.  
According to a accompanying explanatory memorandum 
(https://www.legislation.gov.uk/uksi/2022/1393/memorandum/contents) ... "the 
instrument makes only the necessary changes to extend the time period for 
recognition of products meeting EU requirements and markings until 31 December 
2024, to extend existing labelling easements until 31 December 2027, and 
extending the time period to allow any steps taken under EU conformity 
procedures before 31 December 2024 to be considered valid to demonstrate 
compliance with UKCA, for the duration of the certificates issued or until 31 
December 2027, whichever is the sooner."

Nonetheless, a couple official uk.gov webpages  (e.g., 
https://www.gov.uk/guidance/using-the-ukca-marking) say "The government intends 
to introduce legislation to extend recognition of goods that meet EU 
requirements, including the CE marking, indefinitely, beyond 31 December 2024 
for many products."

I cannot identify any SI in the works that will provide the alleged indefinite 
extension.

Does anyone on the list have more certain information about the indefinite 
extension they could share?

Best Regards,
-Lauren


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