Timber & UKCA Delays

The UK government has delayed the date when businesses must have switched from CE marking to UKCA marking on their products. What does this mean for the timber supply chain?

According to the Construction Products Association: “There are only two types of harmonised technical specification to allow CE marking, which have been mirrored to permit UKCA marking. These are a harmonised standard or ETA for CE marking, and therefore a designated standard or a UKTA for UKCA marking. If neither of these exist a manufacturer cannot apply the CE or UKCA mark, however if these do exist for a product, then a manufacturer has to apply the relevant mark.”

In December 2022, the UK Government announced the delaying of the full implementation of the UK Conformity Assessed (UKCA) marking scheme for products sold in England, Scotland and Wales until 30 June 2025.

Originally, businesses had been told they would need to have the UKCA mark on all their relevant products from 1 January 2023, but this latest delay now applies to all products, including structural timber, plywood and other wood-based panels including OSB and MDF. This means businesses will have an additional two years to apply the UKCA mark to their products. Until then, they may use either the existing CE mark, or the UKCA mark, if they have already made the transition.

To help timber businesses navigate the confusion, TDUK has issued a Technical Note to outline the changes and explain how businesses can make sure they remain compliant during this transitionary period.

Nick Boulton, head of Technical and Trade at TDUK, explains: “Manufacturers in the wood sector have already invested considerable resources to meet the original deadline for requirement of this new UK mark. It is important to note that, like the original deadline, this new date of 30 June 2025 is currently a UK government stated intention but is not yet supported by UK legislation.”

Which products must have a UKCA/CE mark?

Across the European Union, a CE mark is used by manufacturers to declare that their products comply with, and conform to, relevant EU health, safety and environmental protection legislation and requirements. CE marking is mandatory for products that fall under the scope of a European Commission product directive, such as the Construction Products Regulation (CPR), which lays down harmonised rules for the marketing of construction products in the EU.

Post-Brexit, the UK government introduced the UKCA mark to replace the existing CE mark, and all products that previously required a CE mark will eventually need a UKCA mark to be placed on the market in England, Scotland and Wales.

For many wood products the UKCA situation is very clear, as market requirements are based on Harmonised European Standards which are published as the list of UK Designated standards. These can be found online at: www.gov.uk/government/publications/designated-standardsconstruction-products

Most wood products are at AVCP Level 2+ or AVCP Level 4, which means that either no input is required from a UK Approved Body (Level 4), or just oversight of the Factory Production Control (Level 2+). In either case, manufacturers can already move ahead to UKCA marking. In contrast, Level CE 2+ Manufacturers can move to UKCA marking once they:

• Have registered with a UK Approved Body

• Have adjusted their quality manual

• Have received their UKCA certificate reference.

This UKCA mark may be on its own or could be alongside a CE mark if the manufacturer chooses to retain their registration with an EU Notified Body. A good example of this is structural timber, which uses the harmonised standard BS EN 14081, or structural plywood that uses BS EN 13986.

At Level 4 there is no Notified Body or Approved Body input, so manufacturers can move to UKCA marking whenever they choose by simply adjusting the relevant section of their quality manual. This UKCA mark may be on its own or alongside a CE mark.

Where manufacturers want to make a specific claim for fire performance on products which are normally Level 4, such as for cladding, flooring, or post-treated wood-based panels, then a Fire Test Certificate is required from a Notified Test Laboratory which raises the product to CE Level 3 status. If the Notified Testing Laboratory is in the UK, manufacturers can proceed to UKCA marking. If not, manufacturers should seek further legal advice. For structural wood products that hold European Technical Assessments (ETAs) the UKCA situation is less clear, and more information is available on TDUK’s Technical Note.