UKCA and CE Marking of Boilers

[Nick (Name)Participant @nickname]

Hi

With today's announcement on the demise of the UKCA mark, what markings should appear on a commercial boiler, UK made and supplied now or in the future? Are there any UK commercial boilermakers? I take it that CE marks have always been acceptable and will continue to be.

Nick

[Nick (Name)Participant @nickname]

[JasonBModerator @jasonb]

I would expect the boiler makers revert to the CE mark as any other manufacturer will if it falls into one of the groups were CE will remain acceptable. Those that have also been selling to Europe have continued to CE mark those boilers and UKCA mark ones for the home market. Some even dual plate them so they can be used throughout europe and the UK.

Quite a few UK boilermakers

Edited By JasonB on 04/08/2023 09:26:16

[Paul LParticipant @paull58212]

Do you have a link to the announcment please?

[JuddyParticipant @juddy]

Here you go:

Using the UKCA marking – GOV.UK (www.gov.uk)

[JasonBModerator @jasonb]

Link to not having to use UKCA

[Nick (Name)Participant @nickname]

Thanks Jason

Are there many boilers around with the UKCA mark, I wonder. Going to be an oddity in years to come. CE marking from 1993 then a couple of years with UKCA a possibility, then back to CE. Probably saved an Orange Book rewrite!

[SillyOldDufferModerator @sillyoldduffer]

Posted by Nick (Name) on 04/08/2023 09:00:25:

Hi

With today's announcement on the demise of the UKCA mark, what markings should appear on a commercial boiler, UK made and supplied now or in the future? Are there any UK commercial boilermakers? I take it that CE marks have always been acceptable and will continue to be.

Nick

A CE mark means the supplier asserts the item meets all the necessary legal requirements that apply before the item can be sold in the European Union. They mostly relate to safety, and most developed countries have similar or identical requirements. In practice, most UK manufacturers have continued to meet EU requirements and CE mark all their products. Two reasons:

• British products have to be CE marked before they can be sold in Europe or any other country that recognises the CE mark. Brexit does not alter the need for exports to be CE marked.
• Almost all the legal requirements needed to get a CE mark are enshrined in British Law, and nothing has been done to unpick them. Thus, UKCA and CE both require conformance to the same British legislation, which is still EU compatible. In most respects CE and UKCA are identical, except UKCA adds more bureaucracy, especially when products are sold in Europe and the mainland UK, and in Northern Ireland where special rules apply. Basically, it's necessary to satisfy UK law to get a UKCA mark, and because British law is the same as EU law, it might just as well be a CE.

To be sold outside the UK, boilers have to be CE marked.

Even though UKCA and CE are equivalent at the moment, UKCA isn't accepted abroad. The problem is UKCA could different to CE in future, and foreign purchasers aren't interested in working out what the differences might be. It's easier for them to demand CE, because then they only have to track one system.

I suspect after all the rah-rah-rah of leaving, the government is finding 'getting Brexit done' to be far more hard work than the optimists expected. Fairly easy to leave the EU and sort out a divorce settlement, but not to fix what happens next. It includes revising the entire body of British legislation. Not easy to unpick European requirements from British ones, especially as European and many British requirements are satisfactorily interrelated in complex ways, and shouldn't be changed unless there's a positive advantage.

Typical of how all governments work: they'd rather fix details when they're obviously broken than plunge into tricky new policy that requires making complex legislative changes on a grand scale. Extra painful for Conservative politicians who are against intervention on principle.

Could be done, but it requires MPs to work much harder on changing the law than they are. Instead, they passed the Great Repeal Bill in 2016, and empowered themselves to make changes later. Since then it's been found difficult and/or counter-productive to change anything. The devil is in the detail.

UKCA burdened British firms with a lot of extra bureaucracy for no practical benefit. Recognising that, government are backing away from it. Quite right.

Dave

[Martin Johnson 1Participant @martinjohnson1]

I BRIEFLY read the announcement which seems to introduce the option to CE mark. That is not the same as "demise of UKCA marking.

Please enlighten me.

Martin

[Nick (Name)Participant @nickname]

Hi Martin

There has been CE marking in the UK since the 1990's. Including our size boilers.

“Demise” in that the CE mark will not be dropped as seemed to be part of Brexit. This would have forced all appropriate products to be UKCA mark compliant. So, if you export boilers, why would you bother with additional UKCA requirements, CE does it.

This change will also answer the questions around importing a boiler into UK from abroad. CE marking will still be valid.

From a pedants point of view perhaps UKCA has not gone, but there seems little reason to use it. The politicians are hardly likely to say we wasted everybody's time trying to introduce a new UKCA mark are they. Time will tell!

Nick

[john halfpennyParticipant @johnhalfpenny52803]

And because of Brexit, we no longer have a say in the CE regulations – another great leap forward for an independant UK.

[Robert Atkinson 2Participant @robertatkinson2]

There are a number of problems with this change. Some of the UK legislation has been changed. The presumption is that it will still be changed and if you want too you can UKCA mark. And for a product that won't be sold outside the UK, for whatever reason, that may actually be easier. But what happens when the EU and UK regulations drift apart? If we continue to accept CE marked goods then a CE marked item would have be accepted when it would not meet UK law.
As long as the UK accepts CE marked goods any maker or seller who sells in both markets will only CE mark them. Why even spend time on the paperwork to add UKCA.

So will they ukdate UK law to match EU? Or let / drive them to diverge and let someone else sort out the mess later?

Anyone who voted to leave the EU didn't know what they were doing because they were not told what would happen and clearly some changes that were supposed to happen have not.

We are seeing issues in my day job – aviation. There was a recent change to the regulations around UK CAA design approvals (Part 21J). This was without UK consultation and mirrors a EU (EASA) change. Apparently they think having the Europeans consult on the changes on behalf of the UK industry is OK

This is purely my personal opinion and has nothing to do with my employer and does not represent any view that they may or may not have.

Robert.

[Nigel Graham 2Participant @nigelgraham2]

This thread risks the dreaded "P"! word, and I don't mean ticket-machines or 3am expeditions along the landing.

However, since anything imported by any EU nation needs comply with its rules including SE assessment where applicable, irrespective of country of manufacture, I do wonder why it was thought necessary, and by whom, to drop the CE laws in favour of the same with a different name. All this legalistic , politicised manouvering does is make life awkward for manufacturers and test-laboratories.

.

Anyway the only people who really benefit are the so-called "Notified Bodies" (notified of what? ) and lawyers. Read the original PER 2000 and as I recall the word safe appears hardly at all. One clause says something like, "… and in fact has to be safe" , as an afterthought.

Oh, and it all refers to only two pressure-vessel materials – stainless-steel and aluminium! So come one, who says we can't have stainless-steel boilers, even if practicably a trade-only product.

[Nick (Name)Participant @nickname]

Hi Nigel

We could start another thread. For me we are done, seems we are back to CE marking. UKCA was an unnecessary diversion. For us we just need to know we are looking for CE mark or Orange Book amateur makers mark when buying or testing a boiler.

Nick

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