Talk:UKCA marking

UKNI marking on EU market

Hi @John Maynard Friedman:, the Gov.UK article "Using the UKNI marking" says

The UKNI marking is not recognised on the EU market. If you are placing goods on the EU market, you must use the CE marking on its own, without the UKNI marking.

and

For example, a product with both the CE and UKCA markings can be placed on the EU market. However, for the EU market the CE mark must appear without the UKNI indication as goods bearing the ‘CE and UKNI’ marking are not acceptable in the EU market. This means these goods must be manufactured to EU rules and cannot be assessed by a body based in the UK.

The UKNI-CE marking is only recognised in the UK, not in the EU (where CE, not UKNI-CE, must be used). Unlike the situation where UKCA (Great Britain standards conformity signed off by a UK body) appears alongside CE (European standard conformity signed off by a EU body), UKNI-CE means that the European standards have been signed off by a UK body. As the UK and EU don't have mutual recognition of standards, UKNI-CE goods cannot be traded into the EU. I agree this is complicated, and the HMG site does only a mediocre job of explaining it. --2.219.78.42 (talk) 16:04, 21 December 2021 (UTC)

Here's a europa.eu source saying the same.

Where a product is certified by a Notified Body in Northern Ireland, the indication ‘UK(NI)’ must be affixed next to the CE marking or any other applicable conformity marking. Accordingly, the indication ‘UK(NI’ has been integrated with the identification number assigned to Notified Bodies established in Northern Ireland. This distinct marking allows the identification of products which can be legally placed on the market in Northern Ireland, but not in the EU.

--2.219.78.42 (talk) 16:17, 21 December 2021 (UTC)

[Edit conflict, this was written in reply to message of 16:04, 21 December 2021 (UTC)]

We have difference of opinion on how best to reflect reality because the citation is open to misinterpretation. Your interpretation is

• However, goods intended for export to the EU may not carry the UKNI mark.

I believe that is not a correct interpretation and changed it to

• However, goods intended for export to the EU must carry the CE mark (and need not carry the UKNI mark).

My reason is that there are many goods on sale in the EU that carry the certification marks of other jurisdictions, most commonly the FCC mark. EU regulations don't care about other marks, they only require that the product is asserted to comply with EU standards and carries the CE mark to that effect. It doesn't matter where the product is made - Birmingham, Beijing or Barcelona. Likewise, products on sale in the UK will be required to carry the UKCA mark as evidence of compliance with UK standards and again it doesn't matter if the product also carries CE and/or FCC marks. The citation highlights this statement You never apply the UKNI marking on its own - it always accompanies an EU conformity marking, which I suggest confirms my interpretation.

If the first interpretation is to stand, it needs a europa.eu citation since gov.uk cannot specify what can or cannot be specified on products sold on the EU market. Maybe we could agree to compromise on simply

• However, goods intended for export to the EU must carry the CE mark

Is that acceptable?

The citation fails (IMO) to explain the purpose of the UKNI mark in the first place but neither version of the disputed sentence addresses it. --John Maynard Friedman (talk) 16:21, 21 December 2021 (UTC)

---

In reply to your second message, the europa.eu source is much clearer, though still written in 'code'. What it is saying is that

• products placed on sale in NI (which is de facto in the EU customs union) must conform to EU regulations and carry a CE mark asserting that conformity. This is also true if they are to be exported to the EU.

and

• products placed on sale in NI (which is de jure in the UK customs union) must conform to UK regulations and carry a UKCA mark asserting that conformity.

''and if

• the certification was carried out in Northern Ireland, it carries a UKNI mark.

However we are in extreme danger of drifting into wp:synthesis and WP:original research. It is not the function of Wikipedia to provide this sort of advice. We can do no more that take the most obvious inference from the two citations and direct anybody who wants the detail to those sources. --John Maynard Friedman (talk) 16:34, 21 December 2021 (UTC)

Not quite: your second point isn't the case. Goods in Northern Ireland follow EU rules (not UK ones) -- UKCA is not recognised, only European markings are (most prominently CE). The UKCA and UKNI markings are not related (confusingly).

There's two situations in Northern Ireland here:

(1) a good's EU rules conformity is signed off by a UK body -> UKNI-CE marking given (these cannot be exported to the EU)

(2) a good's EU rules conformity is signed off by a EU body -> CE marking given (these can be exported to the EU)

I believe the table (with the footnote include) from the HMG site is straightforward in support for "However, goods intended for export to the EU may not carry the UKNI mark." It also addresses your point about UKCA/FCC/... appearing alongside CE on goods. This doesn't require synthesis, either.

Footnote reproduced here:

You may use combinations of the product markings listed in each box and your goods may be acceptable with more than one marking. For example, a product with both the CE and UKCA markings can be placed on the EU market. However, for the EU market the CE mark must appear without the UKNI indication as goods bearing the ‘CE and UKNI’ marking are not acceptable in the EU market. This means these goods must be manufactured to EU rules and cannot be assessed by a body based in the UK.

--2.219.78.42 (talk) 17:09, 21 December 2021 (UTC)

Now I understand! I did not appreciate that there is a single UKNI-CE mark. So that would explain the EU prohibition: it risks confusion with a 'real' CE mark that only an EU body is authorised to 'award'.

I think now that both versions are wrong, that it needs to say However, goods intended for export to the EU may not carry the UKNI-CE mark. Is that better? --John Maynard Friedman (talk) 18:08, 21 December 2021 (UTC)

There you go! Yes, it's essentially the case that the CE-UKNI combination is a single marking distinct from CE. Your proposal makes sense (and indeed is clearer than what was there before). --2.220.88.52 (talk) 10:26, 22 December 2021 (UTC)

Unfortunately my Cunning Plan is WP:SYNTH. Although the marks must be paired, there is no single explicit UKNI-CE or CE-UKNI mark. So I have reverted to your version and tried to put some more words around it instead. Feel free to change or even revert as you feel appropriate. --John Maynard Friedman (talk) 11:30, 22 December 2021 (UTC)