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Simple Pressure Vessels Regulation

Simple Pressure Vessels Regulation

The CE Marking Authority Compliance Management System defines the regulatory requirements, rules, and standards that apply to your product. Then executes the program which, generates the compliance report, producing detailed clause-by-clause assessments against the standards and reviewing supplier documentation.

We offer you flexible solutions for your business needs by supplying you with a test plan which can be conducted by you in-house, saving time and expense. Then we review the data or we can conduct the testing for you. Then finally, we supply you with a complete technical file that demonstrates compliance with the applicable legislation.

As part of the Compliance Management System, we monitor all the applicable regulations and standards and inform you when they are updated enabling you to manage your technical file effectively and giving you peace of mind.

Guidance on the regulations they apply to vessels being supplied in or into Great Britain.

January 2023

1. Introduction

This Guide is for businesses placing simple pressure vessels on the market in Great Britain (GB).

This Guide is designed to help you understand The Simple Pressure Vessels (Safety) Regulations 2016, as they apply in Great Britain (referred to in this document as the “2016 Regulations”). The 2016 Regulations set out the requirements that must be met before simple pressure vessels can be placed on the GB market. The purpose of the legislation is to ensure only safe vessels are placed on the GB market, by requiring manufacturers to show how their vessels meet the ‘essential safety requirements’.

2. Legislative Background

The Simple Pressure Vessels (Safety) Regulations 2016 implemented Directive 2014/29/EU on simple pressure vessels. The EU Withdrawal Act 2018 preserved the Regulations and enabled them to be amended so as to continue to function effectively now the UK has left the EU. Accordingly, the Product Safety and Metrology, etc. (Amendment, etc.) (EU Exit) Regulations 2019 see footnote 1 fixed any deficiencies that arose from the UK leaving the EU (such as references to EU institutions) and made specific provisions for the GB market.

There is therefore one set of UK 2016 Regulations but some of the provisions apply differently in NI for as long as the Northern Ireland Protocol is in force. References to “the 2016 Regulations” in this guidance are references to those Regulations as they apply in Great Britain.

3. Scope

The 2016 Regulations apply to simple pressure vessels manufactured in series with the following characteristics:

1. the vessels are welded, intended to be subjected to an internal gauge pressure greater than 0.5 bar and to contain air or nitrogen, and are not intended to be fired
2. the parts and assemblies contributing to the strength of the vessel under pressure are made either of non-alloy quality steel or of non-alloy aluminium or non-age hardening aluminium alloys
3. the vessel is made of either of the following elements:
a) a cylindrical part of a circular cross-section closed by outwardly dished and/or flat ends which revolve
around the same axis as the cylindrical part
b) two dished ends revolving around the same axis.
4. the maximum working pressure of the vessel does not exceed 30 bar and the product of that pressure
and the capacity of the vessel (PS × V) does not exceed 10 000 bar.L
5. the minimum working temperature is no lower than – 50 °C and the maximum working temperature is not
higher than 300 °C for vessels constructed of steel and 100 °C for aluminium or aluminium alloy vessels

4. Requirements

There are different requirements according to the category of vessel.

Category A vessels must be designed and manufactured in accordance with the ‘essential safety requirements’ before being placed on the market. Compliance with the terms set out in a designated standard is one way that may demonstrate compliance with the essential safety requirements of the 2016 Regulations. A “designated standard” means a technical specification that has been adopted by a recognised standardisation body see footnote 2 for repeated or continuous application and which has been designated by the Secretary of State by publishing its reference. A “technical specification” is a document listing the technical requirements which a product must meet.

View designated standards for simple pressure vessels on the excel spreadsheet at the bottom of this document

Category B vessels (of a lower capacity and pressure and therefore a lower risk than Category A) must be designed and manufactured in accordance with sound engineering practice.

Category A vessels are simple pressure vessels of which the product of PS x V exceeds 50 bar.L
Category B vessels are simple pressure vessels of which the product of PS x V is 50 bar.L or less

5. Obligations of manufacturers

A manufacturer is a person who manufactures a simple pressure vessel, or has simple pressure vessels designed or manufactured, and markets that simple pressure vessel under their name or trademark.

The obligations of manufacturers of simple pressure vessels include:

Before placing a Category A vessel on the GB market, a manufacturer must ensure that it has been designed and manufactured in accordance with the essential safety requirements. These are set out in Schedule 1 to the 2016 Regulations. The manufacturer must also have had a relevant conformity assessment procedure carried out and technical documentation is drawn up.

Once this has been done for Category A vessels, before placing a vessel on the GB market, the manufacturer must draw up a declaration of conformity, ensure that declaration accompanies the product, and affix the UKCA marking see footnote 3 visibly, legibly, and indelibly to the vessel or its data plate. and the last two digits of the year in which the UKCA marking is affixed.

Irrespective of the provisions above, until 31 December 2027 see footnote 4, the UKCA marking may be affixed to a label affixed to, or a document accompanying, the vessel.

Qualifying Northern Ireland goods can be placed on the GB market with the CE and CE UKNI conformity markings, see further detail in Section 11 on Qualifying Northern Ireland Goods.

The manufacturer must also affix the inscriptions (that is, the maximum working pressure and temperature, the minimum working temperature, and the capacity of the vessel).

Before placing a Category B vessel on the GB market, a manufacturer must ensure that the vessel has been designed and manufactured in accordance with sound engineering practices.

For Category B vessels, the manufacturer must affix the inscriptions (that is, the maximum working pressure and temperature, the minimum working temperature, and the capacity of the vessel) to the vessel or its data plate.

For category A vessels, the manufacturer must draw up and keep the declaration of conformity up to date and must keep it and the technical documentation for 10 years after the vessel has been placed on the GB market.

The manufacturer must also label the vessel or its data plate with the type and serial or batch identification, the manufacturer’s name, registered trade name or registered trade mark and address and ensure that it is accompanied by instructions and safety information which are clear, legible and in easily understandable English.

The manufacturer must ensure that procedures are in place for series production to remain in conformity with Part 2 of the 2016 Regulations. In doing so, they must take account of any changes in simple pressure vessel design or characteristics, and any change in a harmonised standard or in another technical specification by reference to which the declaration of conformity was drawn up.

The manufacturer must, when appropriate with regard to any risk posed to end-users, carry out sample testing of vessels that they have placed on the GB market and investigate any complaints that the vessels are not in conformity with the relevant legal requirements in the Regulations, and keep records of these complaints.

Manufacturers must take action where they have reason to believe that a vessel they have placed on the GB market is not in conformity with the legal requirements of the 2016 Regulations by bringing the vessel into conformity, withdrawing the vessel, or recalling the vessel. Where the vessel presents a risk, the manufacturer must immediately inform the market surveillance authority (MSA), giving details of how the vessel is not in conformity and any corrective measures taken. Read more information on how to notify the MSA.

The manufacturer must also cooperate with and provide information to enforcing authorities following any requests.

Manufacturers based in Northern Ireland can follow the legislation as it applies to Northern Ireland and place qualifying Northern Ireland goods on the GB market without any additional approvals. See further detail in Section 11 on Qualifying Northern Ireland Goods.

6. Obligations of authorised representatives

Manufacturers are able to appoint authorised representatives to perform certain tasks on their behalf.

Mandated authorised representatives for the GB market can be based in GB or Northern Ireland but cannot be based outside the UK. A manufacturer can only mandate an authorised representative established in the UK, under the 2016 Regulations as they apply in GB.

No GB-based authorised representatives are recognised under EU law. This means that GB-based authorised representatives cannot carry out tasks on the manufacturer’s behalf for products being placed on the Northern Ireland or EEA markets. Therefore, a GB manufacturer selling simple pressure vessels to the EEA market or into Northern Ireland, who wishes to appoint an authorised representative to carry out tasks for them in respect of those vessels, must appoint an authorised representative based in Northern Ireland or the EEA.

An authorised representative must comply with all the duties imposed on the manufacturer under the 2016 Regulations that they are appointed by the manufacturer to perform. There are some duties that a manufacturer cannot mandate an authorised representative to perform (e.g. conformity assessment) and some that must form part of the authorised representative's mandate (e.g. retention of technical documentation). The manufacturer remains responsible for the proper performance of any obligations the authorised representative performs on their behalf.

Any references in the 2016 Regulations to the manufacturer are to be taken to include a reference to the authorised representative including in relation to penalties for failure to comply with those duties.

7. Obligations of importers

An importer is a person or business based in the UK who places vessels on the GB market from a country outside the UK. This means that UK businesses that used to act as ‘distributors’ before 1 January 2021 legally become ‘importers’ if they place products from an EEA country on the GB market.

This includes vessels that are supplied to NI businesses from the EEA and then placed on the GB market. In this instance, the NI business will take on importer obligations for EEA-supplied goods that are placed on the GB market (see also Section 11 on Qualifying Northern Ireland Goods).

Importers have additional legal obligations which go beyond those of distributors, such as checking that manufacturers have carried out the required conformity assessment procedures and including their (the importer’s) name, registered trade name or mark, and a postal address on the equipment or, where this is not possible, on the accompanying documentation.

To assist with the transition, the UK is applying a transitional period ending on 31 December 2027 see footnote 5 to allow UK businesses who import from EEA states or Switzerland (and therefore are importers) into the GB market to provide their details on the accompanying documentation as an alternative to placing them on the vessel itself. This applies to goods that are not qualifying Northern Ireland goods. For further detail, please see Section 11 on Qualifying Northern Ireland Goods.

Can you be contacted easily if there is a problem?

A key principle underpinning product safety, for the benefit of consumers and regulators, is the traceability of a product back to its source.

In recognition that under the new regulatory arrangements, you may have the new status of an importer when placing simple pressure vessels from an EEA state or Switzerland on the GB market, you are temporarily permitted when placing such vessels on the market (until 31 December 2027) to indicate your name, registered trade name or registered trade mark and a postal address in a document accompanying the vessel, instead of on the vessel itself. As set out above, this is usually only permitted where it is not possible to provide the specified information on the vessel itself. This additional temporary easement is permitted until 31 December 2027.

We understand that there may be a period of adjustment to the new arrangements for importer documentation for the GB market, and it may be difficult to provide your details on documentation accompanying each and every individual product.

You may therefore use an alternative method where, for example, your contact information is on a document accompanying a batch of products. This document would then follow each batch of products through the distribution chain. Your contact details must follow each product through the distribution chain, but not necessarily by one document per product. Ultimately, the end user, each distributor (and a regulator) must be able to access the information.

Methods that enable traceability of the product after the initial batch has been broken up could include:

1. The importer's address is present in shipping documents.
2. The importer address is present on the invoice to the GB customer.
3. The importer address is present on the label that is on the outer packaging (“shipper”) in which a number of finished goods is packed (normally customers will receive shippers unless the order is very small so that the shipper has to be opened and split).
4. The importer address is included in the EU Declaration of Conformity and/or UK Declaration of Conformity (whichever is relevant for the product in question).

You should work with your distributors to ensure physical documentation does accompany batches of the product as far as possible, and in all cases that there are measures in place to ensure end users are able to identify the UK importer.

Alongside that, but not as an alternative, you can use your company website to provide more information, access to product details, and contact points for retailers, consumers, and enforcement bodies.

These options are for a time-limited period only and may not be used after 31 December 2027. You are encouraged to put in place measures to ensure that individual items do carry the importer’s address where required ahead of this date.

The EU does not have any such transitional provision. In the absence of this, vessels being sold from GB to NI or the EU must be labelled with the NI or EU-based importer’s address.

The obligations of importers include:

Before placing a Category A vessel on the GB market, an importer must ensure that it is in conformity with Part 2 of the 2016 Regulations. This means that the vessel must comply with the essential safety requirements set out in Schedule 1 and that each economic operator has complied or is complying with their obligations under Part 2 of the 2016 Regulations.

For Category A vessels, the importer must ensure that the relevant conformity assessment has been carried out by or on behalf of the manufacturer; the manufacturer has drawn up technical documentation; the vessel bears the UKCA marking see footnote 3 and is accompanied by the Declaration of Conformity. For Category B vessels, the importer must ensure the vessel has been designed and manufactured in accordance with sound engineering practice and that the manufacturer has complied with their labelling obligations. Until 31 December 2025, the UKCA marking may be affixed to a label affixed to, or a document accompanying, the vessel.

The importer must keep a copy of the Declaration of Conformity and technical documentation for a period of 10 years after the vessel has been placed on the GB market.

The importer must provide their name, registered trade name or registered trade mark and a postal address at which they can be contacted on the vessel or, where it is not possible to provide this on the vessel, or where the importer has imported the vessel from an EEA state or Switzerland and places it on the GB market before 31 December 2027, in documentation accompanying the vessel.

The importer must ensure that when placing vessels on the GB market, it is accompanied by instructions and safety information which are clear, legible, and in easily understandable English.

The importer must ensure that Category A vessels under their responsibility are safely stored and transported.

The importer must, when appropriate with regard to any risk posed to consumers, carry out sample testing of vessels and investigate complaints about vessels that are not in conformity with the 2016 Regulations, and keep a register of those complaints.

The importer must take action where they have reason to believe that the vessel they have placed on the GB market is not in conformity with the legal requirements of the 2016 Regulations by bringing the vessel into conformity, withdrawing the vessel or recalling the vessel. Where the vessel presents a risk, the importer must immediately inform the market surveillance authority, giving details of how the vessel is not in conformity and any corrective measures taken. Read more information on how to notify the MSA.

The importer must also cooperate with and provide information to enforcing authorities following any requests.

Qualifying Northern Ireland goods complying with the legislation as it applies in Northern Ireland, including affixing the CE marking, may also be placed on the GB market. See further detail in Section 11 on Qualifying Northern Ireland Goods.

8. Obligations of distributors

UK businesses that were distributors of simple pressure vessels within the EU single market should now consider whether they are importers from the EU single market and therefore what additional requirements they need to comply with – see section 7 above. The same applies to distributors of vessels from the EEA and Switzerland.

A distributor is any person, other than the manufacturer or importer, who makes a simple pressure vessel available on the GB market.

The obligations of distributors include:

Before making a simple pressure vessel available on the GB market, the distributor must act with due care to ensure that it is in conformity with Part 2 of the 2016 Regulations.

Before making a Category A vessel available on the GB market, the distributor must ensure that it bears the UKCA marking see footnote 3 and for all vessels subject to the Regulations the distributor must ensure that the vessel bears the inscriptions, that it is accompanied by instructions and safety information, that the manufacturer has complied with the requirements as to labelling and the importer has complied with the requirements as to identification. Until 31 December 2027, the UKCA marking may be affixed to a label affixed to, or a document accompanying, the vessel.

The distributor must ensure that the Category A vessels under their responsibility are safely stored and transported.

The distributor must take action where they have reason to believe that the vessel they have placed on the GB market is not in conformity with the legal requirements of the 2016 Regulations by bringing the vessel into conformity, withdrawing the vessel or recalling the vessel. Where the vessel presents a risk, the distributor must immediately inform the market surveillance authority, giving details of how the vessel is not in conformity and any corrective measures taken. Read more information on how to notify the MSA.

The distributor must also cooperate with and provide information to enforcing authorities following any requests.

9. Conformity assessment and marking – products placed on the GB market before 11 pm 31 December 2024

If you place an individual fully manufactured product on the EEA or the UK market (either in Northern Ireland or Great Britain) before 11 pm 31 December 2024, you do not need to do anything new. These individual goods can continue to circulate on either market until they reach their end user and do not need to comply with the changes that take effect from 11 pm 31 December 2024.

A fully manufactured good is ‘placed on the market’ when there is a written or verbal agreement (or offer of an agreement) to transfer ownership or possession or other rights in the product. This does not require the physical transfer of the good.

You can usually provide proof of placing on the market on the basis of any relevant document ordinarily used in business transactions, including:

1. contracts of sale concerning goods that have already been manufactured and meet the legal requirements
2. invoices
3. documents concerning the shipping of goods for distribution

The relevant economic operator (whether manufacturer, importer or distributor) bears the burden of proof for demonstrating that the good was placed on the EEA or UK market before 11 pm 31 December 2024.

Spares

Products that are repaired, refurbished, or exchanged without changing their original performance, purpose, or type, are not considered ‘new’ and therefore do not need to be recertified and remarked.

This includes if the product is temporarily exported for repair (as the product is not being placed on the GB market for the first time when re-imported).

If the product has been subject to important changes, substantially changing its original performance, purpose, or type, it will be considered as a ‘new’ product. Therefore, the modified product must comply with GB regulatory requirements, including the requirement for UKCA marking from 11 pm 31 December 2024.

Repair, replacement, and maintenance operations are often carried out using other products which are spare parts. Spare parts are considered to have been placed on the market at the time at which the original product or system they are ultimately intended to repair, replace or maintain was placed on the market.

This means that spare parts can comply with the same conformity assessment requirements that were in place at the time the original product or system they are ultimately intended to repair, replace or maintain was placed on the market.

The definition of a spare part will vary depending on the commercial context, but it is broadly determined by a product’s ultimate intended usage. Whether a product is ultimately intended to be used as a spare part should be evidenced by any document demonstrating this intended use, which should be produced when requested by market surveillance authorities.

10. Conformity assessment and marking – products placed on the GB market from 11 pm 31 December 2024

Assessment through third-party organisations

From 11 pm 31 December 2024, vessels intended for the GB market should be conformity assessed by a UK-approved body and UKCA marked, not CE marked. See footnote 4

Qualifying Northern Ireland goods complying with the legislation as it applies in Northern Ireland, including affixing the CE marking, may be placed on the GB market after 11 pm 31 December 2024. See further detail in Section 11 on Qualifying Northern Ireland Goods.

Rules around physically affixing the new UKCA marking mirror those which applied for the application of the CE marking although, until 31 December 2027, the UKCA marking may be affixed to a label affixed to the vessel or a document accompanying the vessel, rather than being affixed to the vessel itself (even where it is otherwise possible to affix it to the vessel itself).

Reducing re-certification/re-testing costs for UKCA marking

The Government has introduced legislation to allow conformity assessment activities undertaken by EU-recognised Conformity Assessment Bodies (CABs), for CE certification before 11 pm 31 December 2024, to be used by manufacturers, and other relevant persons, to declare existing product types as compliant with UKCA requirements. Products must still bear the UKCA marking and will need to undergo conformity assessment with a UK Approved Body at the expiry of the certificate or after 31 December 2027, whichever is sooner. For ongoing production, they will need to undergo conformity assessment with a UK Approved Body once any of the relevant CE certifications have expired, or after 31 December 2027, whichever is sooner.

Before 11 pm 31 December 2024, if an EU-recognised CAB has completed the relevant conformity assessment activities applying to a product, this would allow manufacturers to apply the UKCA mark without the need for any UK Approved Body involvement. They could continue to place their goods on the market on the basis of their existing CE certification following the end of this year, for the lifetime of the certificate issued, or until 31 December 2027 (whichever is sooner).

Where manufacturers are using conformity assessment under existing CE certification before 11pm 31 December 2024 as the basis to demonstrate compliance with UKCA requirements for their products, it is recommended they include in the UK Declaration of Conformity the list of relevant UK designated standards and equivalent EU harmonised standards that apply to their product, as well as details of the EU-recognised CAB (or CAB recognised under an EU Mutual Recognition Agreement with a third country) which carried out the conformity assessment procedures.

This measure applies across all relevant module types.

11. Qualifying Northern Ireland Goods

The government committed to providing unfettered access for qualifying Northern Ireland goods to the rest of the UK market after 1 January 2021. Products that can be placed on the market in Northern Ireland in accordance with the legislation, as it applies to Northern Ireland, can be sold in the rest of the UK without any additional approvals.

This means that products that are qualifying Northern Ireland goods can be sold in the rest of the UK if any of the following apply:

1. the CE marking is lawfully applied to the good on the basis of self-declaration
2. any mandatory third-party conformity assessment was carried out by an EU-recognised notified body (including a body in a country with which the EU has a relevant mutual recognition agreement) and a CE marking is affixed
3. the certificate of conformity previously held by a UK-approved body has been transferred to an EU-recognised notified body and a CE marking has been affixed
4. any mandatory third-party conformity assessment was carried out by a UK-based body, and the good is therefore marked with the CE marking and with the new UKNI marking

This will be the case even if there are changes between the EU rules that the Northern Ireland Protocol applies to NI and the GB rules.

NI businesses that are importing products from the EEA and placing them on the GB market must ensure that the relevant conformity assessment procedure has been carried out, that the technical documentation has been drawn up, and that the vessel bears the CE marking. They will also have to comply with the importer labelling duties (see Section 7 on obligations of importers).

12. Approved Bodies

The UK has established a new framework for UK-based bodies to assess simple pressure vessels against GB rules. Existing UK-notified bodies have been granted new UK ‘approved body’ status and are listed on a new UK database.

UK-approved bodies are conformity assessment bodies that have been approved by the Secretary of State to carry out the procedures for conformity assessment and certification for the GB market as set out in the 2016 Regulations.

These approved bodies retain their 4-digit identification number. New approved bodies will be assigned a number by the Office for Product Safety and Standards on behalf of the Secretary of State.

Approved bodies can assess vessels for the GB market against GB essential safety requirements (which are, as yet, the same as EU essential requirements).

Approved bodies must be established in the UK and be independent of the manufacturer. Approved bodies must examine the technical documentation and supporting evidence in respect of a vessel to assess the adequacy of the technical design.

Where an approved body finds that essential safety requirements have not been met, it must not issue a certificate of conformity and it must require the manufacturer to take corrective measures.

The register also contains details of bodies in other countries such as Australia, New Zealand, Canada, Japan, and the United States of America, which the UK is designating as Approved Bodies through Mutual Recognition Agreements.

13. Enforcement

For products intended for workplace use, the Health and Safety Executive (HSE) has a duty to enforce the Regulations in Great Britain.

In Great Britain, local trading standards authorities have a duty to enforce the Regulations in relation to private use or consumption.

Where the vessels are intended to be used on nuclear sites (either primarily or exclusively), the Office for Nuclear Regulation has a duty to enforce the 2016 Regulations.

The 2016 Regulations also provide powers to the Secretary of State or a person appointed to act on their behalf to enforce the 2016 Regulations and RAMS in its application to vessels (Regulation (EC 765/2008, as amended by the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019, which sets out requirements for market surveillance of products).

The 2016 Regulations provide the power to enforcing authorities to take action against economic operators for vessels that present a risk or are not in conformity with the Regulations. There are requirements for economic operators to cooperate with the enforcement authority as appropriate on request.

The UK market surveillance authorities will take all appropriate measures and ultimately can withdraw from the market or prohibit and restrict the supply of vessels that may endanger the health and safety of persons, property, or the environment.

Regulators’ Code

Market surveillance authorities must have regard to the Regulators’ Code when developing the policies and operational procedures that guide their regulatory activities in this area. They should carry out their activities in a way that supports those they regulate to comply and grow, including choosing proportionate approaches that reflect risk.

In responding to non-compliance that they identify, regulators should clearly explain what the non-compliant item or activity is, the advice being given, actions required, or decisions taken, and the reasons for these. Unless immediate action is needed to prevent a serious breach, regulators should provide an opportunity for dialogue in relation to the advice, requirements or decisions, with a view to ensuring that they are acting in a way that is proportionate and consistent. The Secretary of State takes account of the provisions of both the Regulators’ Code and the Growth Duty in exercising their regulatory functions.

Penalties

A person committing an offence under the 2016 Regulations may be liable for a penalty. Penalties can include a fine or a prison sentence of up to three months for the most serious offences. It is a matter for the enforcement authority to decide what action is appropriate in each case taking into account the circumstances of the case and the enforcement authorities’ own policies, operational procedures, and practices in line with the Regulators Code. Should a prosecution take place, it is at the discretion of the court to decide the penalties imposed on the offender.

14. Glossary

Approved Body – A conformity assessment body that has been approved by the Secretary of State.
Authorised Representative – A person appointed in writing by a manufacturer to perform specific tasks for the manufacturer. Authorised representatives for the GB market must be based in the UK. Manufacturers remain ultimately responsible for ensuring these tasks are carried out properly.
Declaration of conformity – A document prepared by the manufacturer that must detail, amongst other things, the following:
1. the specific vessel to which the declaration is referring
2. the name and address of the manufacturer and, where applicable, their authorised representative
This must be kept by the manufacturer for a period of ten years from the date on which the vessel was placed on the GB market. This declaration must be made available to the enforcing authority upon request.

Distributor – Any person in the GB supply chain, other than the manufacturer or the importer, who makes a vessel available on the GB market.
Enforcing Authority – In Great Britain, for vessels in use in the workplace, this is the Health and Safety Executive (apart from when used on nuclear sites). For products for private use this is local trading standards authorities. For vessels in use on nuclear sites, this is the Office for Nuclear Regulation.
Importer – A person established in the UK who places a vessel from a country outside of the UK on the GB market. This includes a person based in NI who has been supplied with the product from an EEA country, who would, under NI law, be a distributor. A person who before 1 January 2021 (under EU Rules) distributed vessels within EU (including the UK) will now be an importer if they are bringing vessels into GB from another country (including EU Member States, the EEA or Switzerland).
Manufacturer – A person who manufactures a vessel or has a vessel designed or manufactured and markets that vessel under their name or trademark.
UKCA Marking – The UKCA (UK Conformity Assessed) marking is the new UK conformity marking used for certain goods (including simple pressure vessels) being placed on the GB market, in place of the CE marking, which is the conformity marking used in Northern Ireland and the European Union.
UKNI Marking (also known as the UK(NI) indication) – The UKNI marking is a new marking applied in addition to the CE marking, where a good requiring mandatory third-party conformity assessment has been tested against EU requirements by a UK body. The UKNI marking applies when placing such products on the Northern Ireland market. Under the Government’s unfettered access commitments, products lawfully marked with the UKNI marking can also be placed on the GB market if they are also qualifying Northern Ireland goods.

15. Footnotes

1: The following legislative amendments and Government announcements apply:

The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 were amended by the Product Safety and Metrology etc. (Amendment to Extent and Meaning of Market) (EU Exit) Regulations 2020 to apply to Great Britain only, and not to Northern Ireland, in support of implementing The Protocol of Ireland and Northern Ireland (“The Northern Ireland Protocol”).
The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 were further amended by the Product Safety and Metrology etc. (Amendment etc.) (UK(NI) Indication) (EU Exit) Regulations 2020 to provide for a 24-month transition period for importer labelling (for goods from the EEA) and the UKCA marking, to amend the definition of “authorised representative” as well as introducing an end (in 12 months from the end of the Transition Period) to the recognition of goods meeting EU requirements, as well as introducing provisions for qualifying Northern Ireland goods.
On 24 August 2021, the Government announced the transition period for UKCA marking would be extended until 31 December 2022. The Product Safety and Metrology etc. (Amendment) Regulations 2021 gave effect to this. On 14 November 2022, the Government announced it would be extending this until 31 December 2024. The Product Safety and Metrology (Amendment and Transitional Provisions) Regulations 2022 (SI 2022/1393) give effect to this.
On 20 June 2022, the Government announced the provisions for UKCA labelling and importer labelling would be extended until 31 December 2025. On 14 November 2022, the Government announced it would be extending the provisions for UKCA labelling and importer labelling until 31 December 2027. The Product Safety and Metrology (Amendment and Transitional Provisions) Regulations 2022 (SI 2022/1393) give effect to this.

2: Standardisation bodies recognised by this legislation are: the European Committee for Standardisation (CEN); the European Committee for Electrotechnical Standardisation (Cenelec); the European Telecommunications Standardisation (Cenelec); the British Standards Institute (BSI).

3: Until 11 pm 31 December 2024, vessels conforming to EU rules, including the CE marking, may be placed on the market of Great Britain.

4: On 24 August 2021 the Government announced the transition periods for UKCA marking and UKCA labelling would each be extended until 31 December 2022 and 31 December 2023 respectively. The Product Safety and Metrology etc. (Amendment) Regulations 2021 gave effect to this. On 20 June 2022, the Government announced the provisions for UKCA marking and labelling would be extended until 31 December 2025. On 14 November 2022, the Government announced it would be extending the transition period for UKCA marking until 31 December 2024 and the provisions for UKCA labelling and importer labelling until 31 December 2027. The Product Safety and Metrology (Amendment and Transitional Provisions) Regulations 2022 (SI 2022/1393) give effect to this.

5: On 20 June 2022, the Government announced the provisions for importer labelling would be extended until 31 December 2025. On 14 November 2022, the Government announced it would be extending the provisions for importer labelling until 31 December 2027. The Product Safety and Metrology (Amendment and Transitional Provisions) Regulations 2022 (SI 2022/1393) give effect to this.

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