A lack of capacity among certification bodies and product-testing facilities could jeopardise commercial building engineering projects, according to the engineering services sector body Actuate UK.
It is warning of serious consequences for businesses and commercial projects in six months if no extension to a current transition period between EU and UK regulation is granted.
The issue concerns government plans for the new ‘UKCA’ mark to replace the established EU ‘CE’ product mark on construction products across Great Britain by the end of this year. From 2022, only products approved and tested to UKCA may be placed on the market in Great Britain.
Actuate UK believes that this plan to be overly ambitious, and that there is not enough capacity in UKCA Approved bodies or in current certification bodies and product-testing facilities “to reliably verify that existing or new products meet the UKCA criteria”.
Accordingly, Actuate UK is asking for an extension of the transition time to the new arrangements to allow all products to be tested and accredited.
In some product categories, says Actuate UK, “industry is estimating that 64 years’ worth of retesting will be required, and we currently only have seven months”.
The body warns of installation cancellations, delays and contractual problems for the supply chain and its customers. Actuate UK members warn of the problem bringing the industry to a standstill.
Actuate UK is asking the government to continue recognising the existing CE mark until the end of 2022; during this this time, products used in Great Britain should be allowed to bear either or both marks.
The body represents the interests of membership organisations including the Building Engineering Services Association (BESA), Building Services Research and Information Association (BSRIA) and the Chartered Institution of Building Services Engineers (CIBSE).
Tom Garrigan, technical director at the Building Services Research and Information Association (BSRIA) gives this example of the problem:
“One of the 21 Directives covering products being placed on the market is the Construction Products Regulation (CPR), which is split into five AVCP (Assessment and Verification of Constancy of Performance) systems.
“There are particular issues surrounding AVCP system 3, as the assessment of products is handled differently to other systems due to the EU Notified Body or UK Approved Body being a test laboratory. The current arrangements require all products with an existing CE mark where testing has been carried out in the EU to be retested by a UK Approved Body by 31 December 21, assuming there is one with the relevant accreditations.
“As an example, there are eight Notified Bodies in Europe testing heat emitters for CE marking purposes, and if we assume our European counterparts have a similar annual throughput of samples as ourselves, it’s estimated there is 64 years’ worth of retesting required in less than seven months. A clear and urgent decision relating to the application of the UKCA mark to products is required to give manufacturers and UK Approved Bodies much needed time to prepare and comply.”
Actuate UK is an alliance of the following engineering services bodies:
- The Building Engineering Services Association (BESA)
- The Building Services Research and Information Association (BSRIA)
- The Chartered Institution of Building Services Engineers (CIBSE)
- ECA - Electrical and Engineering Services/The Fire and Security Association
- The Federation of Environmental Trade Associations (FETA)
- The Lift and Escalator Industry Association (LEIA)
- SELECT – the Electrical Contractors’ Association of Scotland
- SNIPEF – The Scottish and Northern Ireland Plumbing Employers’ Federation