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)

"Reversed epsilon": Bold, revert, discuss

Per WP:BRD and to prevent an edit war, I am formally opening a discussion on this topic: the disputed section should not be changed while the discussion in in progress.

I have twice reverted the addition of a specific marker said to used for aerosol cans sold in the UK, as being WP:UNDUE. It is not appropriate to get into the details of a particular product class without exceptional reasons. It is not a UKCA, UKNI or CE mark, which are the topics of this article.

(But if such a mark does exist, we have no information about it anywhere. "Reversed epsilon" redirects to Open-mid central unrounded vowel (U+025C ɜ LATIN SMALL LETTER REVERSED OPEN E) (or indeed figure 3 for that matter: out of context, the glyphs are virtually indistinguishable). But this by the way since the key question is whether it WP:DUE to include it in any form. 𝕁𝕄𝔽 (talk) 00:21, 28 May 2024 (UTC)

@JMF The reason why I put that is because if you have a look at a spray can or other aerosol container (for example, spray deodorant), then it will likely show the UKCA mark, often alongside the reversed epsilon. Obviously, the main thing the UKCA was intended to replace was the CE marking, but that also applied to the reversed epsilon for one specific product. Therefore, I don't see that marking being mentioned on the CE article. Here is an example of what I meant. And here is another example. Indeed, if you look at the official guidance, then I can see it being mentioned twice, one inside the grey box as part of the indefinite extension and the other under the subsection 'Selling products in Great Britain'.

Plus, the cited article actually stated the reverse epsilon on the header, but doesn't say its purpose and I meant to put this instead. JuniperChill (talk) 09:21, 28 May 2024 (UTC)

@JuniperChill: Thank you for responding. Yes, on further investigation, I agree that the mark does exist (see the Council Directive 75/324/EEC (1975) and this Aerosol Dispensers Regulations 2009 (UK), revised 17 November 2022). I can now see a case to include something about it, but I suggest that it needs a separate paragraph and it certainly should not link to Open-mid central unrounded vowel, we should just give the Unicode code point. The particular relevance is that it to be abolished in GB but is to remain in NI. So how about an additional paragraph in the section "Applicability of UKCA and CE marks" that reads something like

European regulations for Aerosol spray dispensers are defined in Council Directive 75/324/EEC of 20 May 1975.<ref>https://echa.europa.eu/legislation-profile/-/legislationprofile/EU-AEROSOL_DISPENSERS </ref> This predates the CE scheme and specifies a "reversed epsilon" (U+025C ɜ LATIN SMALL LETTER REVERSED OPEN E) as an indicator of compliance; as of May 2024 the mark remains in force in the European Single Market. In Great Britain, the UK government has decided to end this exception and absorb it into the general UKCA scheme but it will continue to be required in Northern Ireland.<ref>https://www.gov.uk/guidance/aerosol-dispensers-regulations-2009 </ref> The reversed epsilon ('3') mark is to remain valid in GB until the end of 2024; thereafter UKCA must be used.<ibid>

Refs to be done properly of course but let's see if we can agree that it needs its own para and how best to word it (if we do).

(WP:NOTFORUM applies of course but it wouldn't surprise me to see the plan abandoned under the principle of "no unnecessary differences to be introduced into the UK Internal Market" promise that Sunak gave the DUP.) --𝕁𝕄𝔽 (talk) 10:28, 28 May 2024 (UTC)

Since I am off to work, I will make a proper response in ~8 hours time. JuniperChill (talk) 10:48, 28 May 2024 (UTC)

@JMF I think the paragraph will work. It will be the second paragraph on the applicability section. I will however put the '(U+025C ɜ LATIN SMALL LETTER REVERSED OPEN E)' in a footnote since it feels like it needs to be away from the main sentence.

I also note that the if you look at the official guidance of the UKCA marking, the reversed epsilon is actually part of the permanent extension of the CE marking (inside of the top grey box - use Ctrl+F then type 'epsilon'). It's just medical devices, construction and a few other products that won't benefit from the indefinite extension and will have their own deadlines regarding the CE marking. And what is the ibid tag?

I will also do a little of copyediting and moving the UKNI image to the Northern Ireland section in addition to the reversed episilon situation. JuniperChill (talk) 18:36, 28 May 2024 (UTC)

ibid = the same source. Yes, footnote a good idea, will do. The reason I did it is that Unicode does not recognise that name and atm it redirects to an IPA article. (The redirect could become a disambig if the EU usage were documented in any article?)

It is not just aerosols that use the reversed epsilon, it seems (though I've never noticed it, perhaps I have but ignored it as a random figure 3).. See Council Directive 75/107/EEC of 19 December 1974 on the approximation of the laws of the Member States relating to bottles used as measuring containers. So do we need to generalise, that it just happens to be aerosols in the first instance? How? --𝕁𝕄𝔽 (talk) 18:52, 28 May 2024 (UTC)

I didn't realise it also applied to measuring containers too. Even the gov.uk page stated that. But anyway I will put the paragraph to show that the UKCA marking applies to aerosol cans and measuring containers, which formerly (and still does) use the reversed epsilon marking. It's just odd that the EU chose to have its own marking covering only a couple of products but at least the UK didn't adopt its own marking to use just that and instead merged it with the UKCA scheme.

I also edited the aerosol spray dispenser article about adding the symbol requirements. JuniperChill (talk) 19:35, 28 May 2024 (UTC)

If I've read it correctly (ok, superficially), the EEC [sic] established the RE mark long before the more general CE mark was introduced. I suspect there was a plan to migrate it into CE but it was never a priority. So products for sale in UK and EU will need RE and UKCA marks. Products for sale in UK only will still need the RE if they are to be sold in NI and GB. UKCA only means GB only. --𝕁𝕄𝔽 (talk) 17:30, 29 May 2024 (UTC)

The reference to use of the reversed epsilon on measurement containers was a "stumble upon" and is probably irrelevant. The relevant Directive that I should have cited is Council Directive 75/324/EEC of 20 May 1975 on the approximation of the laws of the Member States relating to aerosol dispensers

Article 3
The person responsible for the marketing of aerosol dispensers shall affix the symbol "3" (inverted epsilon) to aerosol dispensers, as proof that they satisfy the requirements of this Directive and the Annex thereto.

if you want to cite it. --𝕁𝕄𝔽 (talk) 20:16, 29 May 2024 (UTC)