Gaps On Shelves: UKCA Marking, A Looming Threat To Markets & Supply Chains Or A Brexit Bonus?

Consequent upon the Brexit withdrawal agreement, from 1 January 2023 the CE mark on products will no longer be allowed. New products coming onto the market will instead have to be labelled with the UK Conformity Assessment mark (UKCA mark). This apparently simple change could place a heavy burden on UK product testing capabilities and result in delays in bringing new products to market. The CE mark applies to products which fall within the scope of 23 different EU Directives and associated regulations. These cover a wide variety of products from ‘white goods’ and electronic goods to lawnmowers, toys and fireworks. Application of the CE mark requires products to be tested for compliance to the relevant EU standards by EU approved, accredited testing laboratories.

The process to be introduced in the UK is very similar except that products must be tested to British Standards by approved and accredited UK labs. An important change is that UK test labs will no longer be recognised by the EU. Anyone wishing to place a product on the EU market after 1 January 2023 must have it tested by an EU Lab. Conversely all new products coming into the UK must be tested by a UK approved laboratory irrespective of their country of origin. There are 148 testing laboratories approved in the UK but they are not evenly distributed across all 23 sets of UK regulations. Some areas such as construction products are well served, but for others, for example cableways and fireworks, there are no UK approved test labs. For a number of other areas there are only a handful. Even in well served areas like construction products there is such a wide range of products regulated that for some products there isn’t a lab with the appropriate testing capability. The UK’s ability to test products coming onto the market after 1 January 2023 is both capacity and capability limited. Given the very large number of types of product that will need testing there is very likely to be a bottleneck in the product labelling process. Any hold up will inevitably lead to delays in getting products to markets and gaps on shelves.

This webinar sets out the problem, discusses the implications for UK markets and supply chains and proposes some solutions.


Dr Jeff Llewellyn is a chemist by profession. Since 2008 he has been President of the British Measurement and Testing Association (BMTA) and was Chief Executive from 2009 until 2019 when the post was abolished. He has been a Non-Executive Director of the United Kingdom Accreditation Service (UKAS) since 2016 and was a Board member of EUROLAB aisbl (a European Trade Association for testing and calibration laboratories) from 2010 until 2017 serving as Vice President for 6 years. Prior to that from 2002 to 2007 he was Chief Executive of the National Weights and Measures Laboratory, an Executive Agency of the former Department of Trade and Industry. Previous experience was as a research director, manager and research scientist at BRE Ltd (formerly the Building Research Establishment), the Department of the Environment and the Laboratory of the Government Chemist (LGC). His main research interest was in air pollution in buildings and sustainable construction whilst his early career was in food analysis. In 1972 he obtained his Ph D in carbohydrate chemistry from the University of Wales, Swansea (now Swansea University) which was followed by 2 years Post Doctoral research until joining LGC at the end of 1973. He is married with 2 children and 4 grandchildren. His main interests are sailing and railways.

Thursday, 25 November 2021

11:00 - 11:45 GMT



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  • Jeff Llewellyn.JPG
    Dr Jeff Llewellyn
    British Measurement & Testing Association
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    Professor Michael Mainelli
    Executive Chairman
    Z/Yen Group