Regulatory Open Forum

 View Only
  • 1.  UKCA mark

    This message was posted by a user wishing to remain anonymous
    Posted 12-Jan-2021 08:57
    This message was posted by a user wishing to remain anonymous

    Our products (non-medical) are currently CE marked. They are manufactured in China and shipped in bulk to a warehouse in the UK for onward fulfillment of customer orders in the UK .

    We understand that there is now a UKCA marking requirement for selling these products in the UK . The UKCA marking came into effect on 01 Jan 2021, however, to allow business' time to adjust there is an exemption to continue to sell CE marked product until 01 Jan 2022. UKCA marking will be required after 01 Jan 2022.

     My question is whether product that was placed in our warehouse before 01 Jan 2022 will require UKCA mark. I think this depends on definition of "placing on the market".

    I would be very grateful for any help with this.



  • 2.  RE: UKCA mark

    Posted 12-Jan-2021 11:31
    Edited by Jay Pathak 12-Jan-2021 11:32
    Hello Anon,

    According to the guidance for Medical Devices, CE marking will be recognized until 30 June 2023 after that the certificate is not valid which means the product CE mark is not valid. After that, all the placed products will require UKCA. In my opinion, it will be the same for your product, after 01 January 2022, the CE will not be valid. Hope this helps.


    ------------------------------
    Jay Pathak
    Regulatory Affairs Specialist
    Salt Lake City UT
    United States
    ------------------------------



  • 3.  RE: UKCA mark

    Posted 15-Jan-2021 03:21
    Thank you Jay, 
    That is indeed the case i.e. CE mark is not valid after 01 Jan 2022 but the question arises for devices that will have been brought into the UK (into a 3rd party warehouse) under CE mark in say Nov 2021 or Dec 2021 and whether they need to be UKCA marked.

    regards


    ------------------------------
    Mike Kilkelly
    Quality & Regulatory Affairs Manager
    Galway
    Ireland
    ------------------------------



  • 4.  RE: UKCA mark

    Posted 15-Jan-2021 11:00
    Hello Mike,

    So, once the CE mark is not recognized, the device is non-compliant, so for a non-medical device, it would require a UKCA mark if it will still be in the market after 01/01/2022. For Medical Devices, it is 01st July 2023, to comply with the UKCA mark.

    ------------------------------
    Jay Pathak
    Regulatory Affairs Specialist
    Salt Lake City UT
    United States
    ------------------------------



  • 5.  RE: UKCA mark

    Posted 18-Jan-2021 03:36
    Thank you Jay.

    ------------------------------
    Mike Kilkelly
    Quality & Regulatory Affairs Manager
    Galway
    Ireland
    ------------------------------