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Frequently Asked Questions
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Note: Information updated as of 14 November 2022.
- BBA Specific
- CE Marking
- ETA (European Technical Assessment)
- General
- NB (Notified Bodies)
- Other Information
- UKCA
- UKNI
- UKTA
A UK Declaration of Conformity (DoC) must be made for UKCA Marking, this is essentially the same as an EU Declaration of Performance (DoP) for CE Marking, but they must be separate documents. Both documents could duplicate the same information, with the exception of the Notified / Approved Body details and this will remain as such, unless the requirements for either Marking differ.
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Yes.
It should be visible on the product unless the size or nature of the product makes this impossible. The UKCA marking needs to be affixed visibly, legibly and indelibly to the construction product or to a label attached to it. Where this is not possible or not warranted on account of the nature of the product, it shall be affixed to the packaging or to the accompanying documents.
Northern Ireland Information: Construction Products Regulation in Northern Ireland – GOV.UK (www.gov.uk)
UK information: https://www.gov.uk/guidance/using-the-ukca-mark-from-1-january-2021
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It needs to be on the product, unless the size or nature of the product makes this impossible.
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Where harmonised standards in the EU apply for mandatory product CE Marking, the relevant UK Designated Standards will apply in Great Britain for UKCA Marking. Where no Designated Standards exist, voluntary UKCA Marking can be applied via a UKTA provided it complies with the UKAD which are currently based on EADs. See UKTA tab for further details.
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Yes, but both logos should be placed so that neither impedes the visibility of the other.
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Companies who are based in Northern Ireland are in a unique position. Products may be placed on the market with CE marking only, if an EU based Notified Body was used. Alternatively, the use of a UK Approved Body could allow the use of the CE / UKNI combined Mark.
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Yes. Any UK AB can assess Northern Ireland products for the Northern Ireland market.
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CE Marking will not be recognised in Great Britain beyond 31st December 2022. CE Marking will continue to be recognised in NI.
To sell a product into the NI market, you will need either a CE Marking (from an EU Notified Body) or a CE and UKNI Marking (from a UK Approved Body).
The UK Government intends to pass legislation to allow goods manufactured in Northern Ireland to be placed on the GB market based on CE Marking post-transition.
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For a full description and clarification on this topic, please use the link below:
https://www.gov.uk/guidance/placing-manufactured-goods-on-the-eu-market-from-1-january-2021
If you’ve already placed your goods on the market, in an EU country, or in the UK before 1st January 2021, you do not need to do anything if you use an EU Notified Body.
For products already placed on the market, CE marking will continue to be recognised in the UK market until the transition to UKCA Marking is mandatory. For new products covered by a UK Designated Standard, new marking will be required with immediate effect.
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We believe that it is permissible for a label to feature both CE Marking and the UKCA Mark.
The situation in Northern Ireland however is more complex. Products bearing CE Marking and UKNI Marking may be placed on the market in Northern Ireland but not in Eire (or in the rest of the EU).
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Yes.
The BBA has been designated as both a UK Technical Assessment Body (equivalent to an EU TAB) for a wide range of construction products, and also as a UK Approved Body (equivalent to an EU Notified Body) for FPC (Factory Production Control) Certification and AVCP System three testing.
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If you have a CE mark from an EU Notified Body and you’re selling in Northern Ireland, you only need to CE Mark.
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The BBA has been appointed as a UK Technical Assessment Body (UKTAB) by the UK Government, so this is something that the BBA are able to do. The full details of the mechanism for achieving this are currently the subject of negotiations between the UK Government, the EC, EOTA and the UKTABs. It is anticipated that MHCLG will Designate the EADs as UKADs in due course.
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No, all UK based ETAs must be withdrawn.
The technical work carried out prior to the issue of the ETA can be used as the basis of a UKTA, if requested.
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Yes.
The Withdrawal Agreement makes it clear that both the EC and the UK are keen that operators do not have to duplicate their efforts.
The BBA can work with you and our EU TAB partners to transfer technical file information so that the process of moving to a UK TAB and having a UKTA issued is as smooth as possible.
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If you sell into the EU, for products covered by a harmonised European Standard, you must continue to apply CE Marking, including using an EU based Notified Body for conformity activities. .
For the future, if you are placing new goods on the market in the EU and the UK, you may need to have both CE Marking and UKCA Marking.
The BBA has arrangements in place with European partners so that ETA technical files can be transferred between bodies to minimise duplication of conformity assessment. If this is necessary, you will enter a contract between you, the BBA and our European partners. The European TAB will then be able to reissue your ETA. Your CE Marking label will need to change to identify the new TAB.
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UKCA and UKNI Marks require that third party conformity activities carried out are done by a UK Approved Body, while CE Marking assessment activities need to be carried out by an EU Notified Body. The BBA has formed a partnership with EU Notified Bodies to prevent any duplication of activity and to facilitate an efficient process for our clients.
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Yes, this existing Certification is acceptable and no further action is necessary.
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Both the UK and the EU wish to minimise duplication of efforts and costs by the manufacturers.
At present it does appear that the EU will refuse to accept such testing and that retesting by an EU Notified Body will be required. There is some reason to believe that this
position may change as a result of the negotiated Agreement, but the details are unclear and require interpretation. We are waiting for further guidance from the UK Government.
As soon as we have additional clarity around this topic, we will confirm the situation.
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There are differences of opinion, but essentially yes, as far as is possible.
The Agreement allows the use of subcontracting by Notified Bodies, including organisations in the ‘other Party’s territory’. Again the practical meaning of this has yet to be defined.
In Government guidance it states that EU Notified Bodies are required to share information with UK Approved Bodies, when requested by a certificate holder. The UK approved body should do the same with EU Notified Bodies.
This will help facilitate the issue of new certificates of conformity were needed, without the need to repeat the entire certification process.
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The UK Approved Bodies need to be based in the UK.
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If you are selling within the UK and wish to update your CE Marking to UKCA Marking, you can use this existing report.
If your product changes in the future and you wish to continue selling on the UK Market, you will need to have the product reassessed by an Approved Body, such as the BBA.
Such reports will not be accepted by the EU in support of CE marking and, unless a further agreement is reached, retesting will be necessary.
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It has now been made clear that separate Declarations of Performance will be required for the EU and the UK markets.
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The situation with goods being imported to the UK from Commonwealth countries to the EU is unchanged. For importing into the UK however, the same rules apply as for countries within the EU (i.e the UKCA rules will also apply).
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You need take no action; the existing surveillance and Certification arrangements can continue to be used in support of UKCA marking.
If you wish to do so, we can re-issue your certification from the BBA as a UK Approved Body
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You will continue to require CE Marking. We will work in contract with you and our European partners so that your CE Marking is supported by a Notified Body in an EU member state. In many cases, we may be able to continue to carry out the factory inspections for continuity.
In some cases, this may not be possible and you will need to source a new Notified Body in the EU. The BBA can advise on individual circumstances.
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You will possibly need both CE Marking and UKCA Marking, depending on whether your CE marking is based on the mandatory route (via harmonised Standards) or the voluntary option (vie ETAs). If the latter, you will be able to choose whether to UKCA mark or not.
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We can accept applications NOW. You can use the formal application form, which can be downloaded here.
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Yes. The BBA will keep the same notified body number but with an additional prefix ie: UK 0836.
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No – unless things change, the EU will not accept UK Approved Bodies for work in support of CE marking, except in Northern Ireland.
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Yes. The BBA is working hard to make sure all of its clients are properly informed and serviced to conform with transitional dates and deadlines by having the adequate capacity, knowledge and understanding into this topic.
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- To sell on the EU market, you will need to continue to CE Mark your product.
- To sell on the GB market, you will need to UKCA Mark your product.
- To sell in Northern Ireland, you will need CE Marking (if applicable). If you don’t CE mark you must use the UKNI Mark, in combination with the CE mark.
- More than one mark can be used if you are selling to multiple markets.
- However, the UKNI mark must not be used on goods intended for the EU market (including the Republic of Ireland).
- The BBA can provide you with the third-party Certification that you need for your UKCA Marking.
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There is no change in the status of your BBA Agrément Certificate. The BBA Agrément Certificate remains the most robust and comprehensive approval in the UK for construction products and systems, both for innovative products and more established ones. As the UK moves away from the CE Marking scheme, independent UK third-party verification of the performance of products is likely to become increasingly important to specifiers and end-users.
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- BSI will keep the same numbering system for European Standards carried over as UK Designated Standards.
- A BBA certificate is an independent statement of fitness for purpose. The adequacy of the product for a defined application is not going to change as a result of changing the designation of a Standard.
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The lead time will depend on the nature of the work; for example we undertake to convert an existing ETA to a UKTA within two months, but other processes will of course have their own timescales. We would be pleased to quote for any specific work that you have in mind. If is product covered by a Designated Standard is not UKCA marked by the beginning of 2021, it would currently be illegal to place it on the market unless the transition period for CE marking is extended.
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With the extension of the transition period, UKCA Marking for products covered by a Designated Standard is mandatory in Great Britain from 1st January 2023 and this is unaffected by the presence or otherwise of a BBA Certificate. Work carried out to produce a BBA Certificate may well be used towards UKCA Marking, but this will depend on the individual Standard. UKCA Marking via the voluntary route is, of course, optional.
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We can convert an ETA to a UKTA but UKTAs are voluntory and so it is your choice whether or not to apply for one.
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UKCA Marking is only required for goods being placed on the market in Great Britain, CE Marking is still acceptable in Northern Ireland after 1st January 2023.
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If this relates to an AVCP System 4 Standard then yes. If any EU Notified Body was involved, then the same work will have to be carried out by a UK Approved Body.
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Yes, this is acceptable, provided that the rules for placing the product on both markets have been met.
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UKCA marking for products covered by a Designated Standard will be mandatory, unless the transition period is extended and this is unaffected by the presence or otherwise of a BBA Certificate. Work carried out to produce a BBA Certificate may well be used towards UKCA Marking, but this will depend on the individual Standard. UKCA Marking via the voluntary route is, of course, optional.
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This is currently unclear. There is currently no mutual recognition of test reports between the EU and the UK and potentially it might be necessary to retest. MHCLG are aware and are looking for a resolution to the issue.
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UKCA Marking is done against the existing UK Designated Standard and as such the test requirements remain unchanged to those required for CE Marking. The difference is that for UKCA Marking these tests will need to have been supported by a UK Approved Test facility.
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A Declaration of Conformity is required for the UK market in addition to a separate Declaration of Performance for the EU.
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In the EU, a product will be assessed under an ETA or a hEN but not both. The same principle applies for UKCA marking.
If covered by a UK Designated Standard, UKCA Marking is mandatory; the UKTA route is voluntary.
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Since 2013 it has been mandatory for any product with an ETA to be CE Marked. It is not mandatory that an ETA is converted into a UKTA but as the ETA is not recognised in the UK you cannot UKCA Mark without a UKTA, the UK equivalent)..
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No, many overseas companies sell directly into the UK; there is no reason relating to UKCA Marking that would affect this.
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If you didn’t previously CE Mark then it is unlikely that you would need to UKCA Mark – UKCA Marking mirrors the requirements of CE Marking. Unless you are covered by a Harmonised Standard (or have produced an ETA) then you would not have been required to CE Mark. If your product falls outside of this and you need a robust way to demonstrate performance and durability to satisfy specifiers, insurance and warranty providers then please talk to us about BBA Agrément Certificates and how this could help your product.
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It is down to the individual EU TAB whether or not to use data generated by a UK Approved Body as part of the issue of an ETA. If the applicant wishes to have an ETA based on a UKTA and the supporting technical assessment, then the BBA can speak directly to an appropriate EU TAB, preferably at the time of contract preparation to ensure the suitability/acceptance of data.
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Currently the technical requirements for UKCA, UKNI and CE Marking are identical, and provided that the latter remains identical CE marking will still be accepted in the NI market after the GB transition to UKCA Marking.
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UKCA marking for non-harmonised products are voluntary in the UK, therefore you are not obliged to have a UKTA.
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There is no separate legislation for this, it comes under the UK version of the CPR, along with everything else. You can check this out: https://www.gov.uk/guidance/construction-products-regulation-in-great-britain
Possibly – UKCA is compulsory for products falling under UK Designated Standards (formerly harmonised Standards). Otherwise, it is possible via the voluntary route, but this is optional. BBA Agrément is a voluntary approval but this goes into far greater depth and provides greater validation of a products ‘fit for use’ in terms of performance, longevity, durability etc.
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As of 10th June 21, this is unclear; DLUHC is working on a solution but has yet to make a decision.
As things stand, while the Government is encouraging mutual recognition in principle and the BBA would like to be able to accept existing EU NB test reports towards supporting UKCA marking, this is not allowed.
At present, duplicate testing will be necessary; we await DLUHC’s final decision.
PLEASE NOTE: This is correct at the time of publishing and may have changed. Contact the BBA for further updates before proceeding with any decisions.
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Yes, but please see: Using the UKCA marking – GOV.UK (https://www.gov.uk/guidance/using-the-ukca-marking) for the advice from the Government on how to use the mark.
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Yes, if a test was issued by a UK Approved Body (or Notified Body at the time) such as the BBA then this is suitable for UKCA Marking.
However, if CE marking is also required, test reports from a UK Notified Body are no longer acceptable and, as things stand, the product must be retested.
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The company that is responsible for putting the product on the UK market takes responsibility for marking that product, not necessarily the EU manufacturer.
There is no requirement to UKCA Mark, unless the product is covered by a UK Designated Standard (equivalent to a harmonised European Standard) in which case it is mandatory, as for CE marking.
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If a product is covered by CE Marking, backed up where appropriate by an EU based Conformity Body, this is sufficient to place the product on the market in NI.
UKNI Marking would be applied if a UK rather than EU Conformity Body was supporting the marking. In this case, it would be appropriate to apply both CE and UKNI Marking – the UKNI Mark is never applied in isolation.
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Yes. For products subject to harmonised standards each company placing the product on the UK market must have it’s own Declaration of Conformity and UKCA mark. If this has been obtained by the 3rd party manufacture then it can be used to support the UKCA marking by others with their permission.
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The BBA is seeking to rebrand notified body test reports where possible, but advice and clarification by MHCLG is awaited.
As things stand, while the Government is encouraging mutual recognition in principle and the BBA would like to be able to accept existing EU NB test reports towards supporting UKCA marking, this is not allowed.
At present, duplicate testing will be necessary; we await MHCLG’s final decision.
PLEASE NOTE: This is correct at the time of publishing and may have changed. Contact the BBA for further updates before proceeding with any decisions.
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Currently, CE marking for products subject to harmonised standards.
If a product is covered by CE Marking, backed up where appropriate by an EU based Conformity Body, this is sufficient to place the product on the market in NI.
UKNI Marking would be applied if a UK rather than EU Conformity Body was supporting the marking. In this case, it would be appropriate to apply both CE and UKNI Marking – the UKNI Mark is never applied in isolation.
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The requirements will be defined in the relevant product Standard, on a case by case basis.
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Yes, that’s the case, provided that it is an EU body supporting the certification, CE Marking will be acceptable. UK based organisations can no longer be used in support of CE Marking.
If a UK based Notified Body was used to support the CE Marking, this is no longer acceptable, and the tasks must be transferred to an EU based Notified Body.
Conversely, only UK based Approved Bodies can be used in support of UKCA Marking.
The BBA is committed to working with partners in the EU to coordinate wherever possible and so to minimise duplication of conformity activities
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A UKTA is a United Kingdom Technical Assessment which is the means for non-harmonised products to achieve UKCA Marking. The UKTA is the UK equivalent of ETA’s (European Technical Assessments) for non-harmonised products to achieve CE Marking in Europe. UKCA Marking for products covered by harmonised / designated standards is mandatory, whilst the UKTA route is voluntary.
UKCA (UK Conformity Assessed) marking is a new UK product marking that is used for goods being placed on the market in Great Britain (England, Scotland, Wales). It covers most goods which previously required the CE marking, known as ‘new approach’ goods.
The UKCA marking came into effect on 1 January 2021. However, to allow businesses time to adjust to the new requirements, you will still be able to use the CE marking until 1 January 2023 in most cases.
UKTA’s can be issued by UK-based Technical Assessment Bodies. Assessed products may then be affixed with UKCA Marking.
The British Board of Agrément has been given the greenlight to commence the issuing of UK Technical Assessments (UKTAs) – the first Technical Assessment Body in the UK to be able to do so.
UKTAs (United Kingdom Technical Assessments), will replace ETAs (United Kingdom) for any applicable products that are or will be placed on the Great British market.
UKTAs are voluntary assessments, however, UKTAs will be an important way to achieve the industry expected UKCA Marking. This can be especially important where ETAs (as a route to CE Marking) are accepted as industry norms for certain product types.
There are 4 Easy Steps for issuing a UKTA based upon an ETA.
Application – It’s simple, contact the BBA. Include your ETA numbers and the European issuing body & submit this to: [email protected]
Programme of Work – We will prepare all the appropriate documents and issue a programme of work based on:
a) Evaluation Report from issuing TAB
b) Associated Test reports (if required)
c) Manufacturer’s technical file / Factory Production Control
Data Assessment – We will work with your existing EU Technical Assessment Body and evaluate the data.
UKTA Issued – We issue your UKTA to support your UKCA Marking (this takes approximately 2 months from receipt of data).
There is currently no mutual recognition of test reports between the EU and the UK and potentially it might be necessary to retest. DLUHC are looking for a resolution to the issue.
UKCA AVCP Systems 1+, 1 and 2+and UK ETA
The BBA has decided to accept existing reports (data from EU Notified Bodies, as well as other accredited laboratories) for UKCA AVCP Systems 1+, 1 and 2+ and UK ETAs, in addition to continuing to do so for BBA Certification. If either of these is essential to your business, get in touch with the BBA to discuss your requirements and develop a product roadmap.
UKCA AVCP Systems 1+, 1 and 2+and UK ETA
The BBA has decided to accept existing reports (data from EU Notified Bodies, as well as other accredited laboratories) for UKCA AVCP Systems 1+, 1 and 2+ and UK ETAs, in addition to continuing to do so for BBA Certification. If either of these is essential to your business, get in touch with the BBA to discuss your requirements and develop a product roadmap.
The BBA is a UKAS-accredited Product Certification Body (No. 0113), Testing Laboratory (No. 0357), Inspection Body (No. 4345) and Management Systems Certification Body (No. 0113).
The scopes of the accreditation are linked towards the bottom of this page: Accreditations – BBA (bbacerts.co.uk)
Alternatively, the schedules can be found on the UKAS website:
The BBA is often referred to as a not-for-profit company or charity, which is not the case. The BBA is a ‘company limited by guarantee’ – an ownership structure that is somewhat unusual but not uncommon in the UK, Ireland or Australia. It can be used for not-for-profit organisations, such as sports clubs and membership organisations or indeed for profit-focused organisations, such as the BBA.
A company limited by guarantee differs from a company limited by shares, since shares are owned by people and/or institutions (like pension funds) and the profits are distributed to shareholders.
The BBA, or indeed other companies limited by guarantee, does not have any shareholders and does not distribute profits. Instead, the profits made by the BBA are to be used for the benefit of the construction industry or the public good. It is for the Governing Board to decide how, when and where these profits are distributed.
Review Reissue contact: This is a contract between the BBA and an existing Certificate holder covering both the Review of their Certificate, but also a non-technical Reissue at the end of the Review process. It is important to note that, should the Review identify additional changes of a technical nature, this will require an additional contract and cost to assess and amend the Certificate accordingly.
Certificate Withdrawal: A certificate withdrawal usually relates to a product no longer conforming to the original criteria it was certified against. It may be that the product itself has been withdrawn, or that processes of production or materials have changed significantly, which means that the certificate is no longer valid against the original certification scheme. When this happens, the certificate is removed from our website and is no longer searchable. When withdrawals happen, that means that the certificate is closed, and cannot be re-opened. If the product needs to be re-certified, the process is started as a new project, under a new certificate.
Certificate Technical Re-issue: A Technical Re-issue is usually recommended when a substantial change of the certificate is required following additional technical assessment.
For example, if a new product is added to the scope of the Certificate. If a technical re-issue is deemed necessary, this is a compulsory change that has to be made, in order to continue the validity of a certificate.
Certificate Suspension: Suspension is usually applied where a serious issue is identified where it is identified that the Certificate no longer accurately describes the product. It may also be appropriate in their circumstances, for example when the site of production is being changed. Suspension means that the existing certificate is paused (rendering it invalid during this time) and removed from the website while the issues raised are dealt with, after which it could resume and the product could then be sold once again as a BBA-certified product. However, we encourage our clients, should they know that major changes are due to occur, let us know in advance, so that our assessors can review the changes and work with you to deal with any issues raised, avoiding the least amount of certificate down-time or disruption.
Certificate Reproduction: In the case where a product is white-labelled for distribution, the BBA offers a solution that means the distributor can also apply for their own BBA certificate for use in their own distribution marketing activity; but only if the original manufacturer of the product has an active certificate for the same product.
The BBA Agrément Certificate relates to a specific product, and a specific organisation, certifying that particular product against a specific set of criteria for a particular use. Each Certificate is unique to the organisation that has requested the certification and testing to be conducted – the output of which is an individual document that complies only to that specific organisation, thus allowing that business to make use of the BBA Certification logo on their products and marketing material.
When a manufacturer white-labels a product, and makes it available for re-branding and resale by another business, although the product itself might be identical, the new business that is re-branding the product, does not have authority to apply the same certificate within their promotional material, as the certificate does not correlate to their business. That’s when we are able to issue a Reproduction Certificate for the distributor to use which means that the distributor has an added benefit to verifying the credibility of the product they’re selling, and the manufacturer that their product complies to the same stringent set of criteria – increasing the value of their market share through their distribution network.
In the case of Reproduction Certificates, for the distributor, maintenance usually means 1 visit per year to the business’ office in order to assess and check the supply chain, and to confirm that the product they’re distributing is still the same product as the originally-certified product, but is simply being relabeled. The process for the manufacturer of that product will be consistent with our standard maintenance schedule of surveillance and 3-year Reviews.
Certificate Non-Technical Re-issue: A Non-Technical Re-issue relates to changes of a non-technical changes, that are still required for the validity of the Certificate to continue. For example, updates to the titles of Standards or Regulations, but not changes to the technical content of the documents.
Certificate Amendment: Amendments are permissible for very basic changes for non-technical, such as a change of address of the certificate holder, where no other more significance amendments are required for the Certificate.
Joint ISO-ILAC-IAF Communiqué (ISO/IEC 17025)
A laboratory’s fulfilment of the requirements of ISO/IEC 17025 means the laboratory meets both the technical competence requirements and management system requirements that are necessary for it to consistently deliver technically valid test results and calibrations. The management system requirements in ISO/IEC 17025 are written in language relevant to laboratory operations and operate generally in accordance with the principles of ISO 9001.
The BBA is a UKAS-accredited management systems certification body (No. 0113) to BS EN ISO/IEC 17021-1:2015 Conformity assessment – Requirements for bodies providing audit and certification of management systems Part 1: Requirements. This accreditation includes ISO 9001 (quality management systems).
According to BS EN ISO/IEC 17021-1:2015, as a certification body the BBA cannot hold ISO 9001 certification. See clause 5.2.4: “A certification body shall not certify another certification body for its quality management system.”
The BBA’s fulfilment of the requirements of BS EN ISO/IEC 17021-1:2015 means that the BBA meets the management system requirements necessary for it to consistently deliver its accredited activities. The management system requirements are generally in accordance with the principles of ISO 9001.
No. However, the BBA is UKAS-accredited as a Management Systems Certification Body (No. 0113) including for ISO 45001, and the fulfilment of the requirements of BS EN ISO/IEC 17021-1:2015 means that the BBA’s management system is generally in accordance with the management system requirements of ISO 45001.
No. However, the BBA is UKAS-accredited as a Management Systems Certification Body (No. 0113) including for ISO 14001, and the fulfilment of the requirements of BS EN ISO/IEC 17021-1:2015 means that the BBA’s management system is generally in accordance with the management system requirements of ISO 14001.
An inspection body’s fulfilment of the requirements of ISO/IEC 17020:2012 means the Inspection body meets both the technical competence requirements and management system requirements that are necessary for it to consistently deliver technically valid inspection results. The management system requirements in ISO/IEC 17020:2012 (Section 8) are written in language relevant to inspection body operations and are aligned with the pertinent requirements of ISO 9001.
No, but we work with our own videographer & photographer who is able to provide a quote to do this on your behalf. While customer products are in the care of the BBA during testing and certification processes, the BBA works as a custodian in protecting customer and product IP. Because of this, we don’t allow any unauthorised filming or photography on site and, when requested and provided with a full brief, are able to provide a quote for obtaining footage of product testing where available.
UK Government Sources
The UK Government sources below can help if you require any further detailed information that is not provided on the BBA website
The EU Construction Products Regulation
UK adoption of CPR as a ‘designated standard’
UK Government guidance on the CPR from 1-1-2021
