So Much For CE Labels!

I’ve located the problem, Peter ... but my HTML skills are insufficient to explain it:

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MichaelG.

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Ref. __ https://www.w3schools.com/tags/tag_ul.asp

Edited By Michael Gilligan on 25/01/2021 23:37:14

Weird eh?

I can't make it work either. I looked at Michael's post with Firefox's Inspector facility and, although there are a few oddities, nothing stands outs as different from any other post. When 'Add Post' is pressed, the browser sends a form consisting of what the user typed and any tick box settings (Send me email notifications, and Bookmark this thread), plus hidden info, viz the thread number, an 'insert post' command, and something called 'w' set to 7, purpose unknown. It all looks normal.

So does the network chat triggered by pressing 'Add Post':

• My browser calls the server.
• Server acknowledges. We are connected
• Browser asks for encryption
• Server replies, yes but says change the Cipher
• Browser acknowledges and makes the change successfully
• Browser sends form to server
• Server acknowledges receipt
• Server replies to browser with an error message suggesting it can't find the thread the post is being added too.
• Browser acknowleges

I guess something non-obvious is wrong with the form, but I can't see what it is. Maybe w=7, because the post number sent to the server is correct. Never seen anything like this before on the forum so it's probably just a glitch.

Dave

Er .... yeah

It's the only time I've ever encountered it too.

Michael, thanks for the hard work.

I wonder when people will start moaning that they have to pay twice for documenting both CE and UKCA marking on their products?

<edit> err... three times as they will need a UKNI marking if they want to sell in Northern Ireland as well.

Edited By Neil Wyatt on 26/01/2021 18:37:12

If they moan they do not understand, there is nothing to stop you using one technical file for multple approvals. The only exception is those items that have to be assessed by a Notified Body, they wll have to pay for two of those.

There is no separate marking for NI they will stay with the CE mark.

The real issue is that many smaller suppliers will just stop selling into the UK because of this, customs paperwork and if online, the e-commerce act making them pay UK VAT.

Read all about it on the UK government website...

Dave

As I said " The only exception is those items that have to be assessed by a Notified Body,"

The UKNI is only for Items requiring NB 3rd party approval who use a UK NB. CE marking is still accepted if you use an EU NB.

Robert.

Edited By Robert Atkinson 2 on 27/01/2021 07:53:29

There are "goods covered by national rules (non-harmonised)" i.e. never subject to specific EU regulations just UK ones. I've read the guidance twice and I'm still not understanding how CE will apply to them from 2022, but assume that guidance will come from the EU not from the UK.

It may be that NI goods can be marked UKNI as well as CE non the same evidence, but again that isn't clear to me.

So what mark should be used by a Northern Irish manufacturer who wishes to sell in NI and the mainland, but not Europe, and wants to employ a British Notified Body? I assumed UKNI covered that, but the guidance table says UKNI is only valid as a marking if accompanied by a CE mark as well. Given the need for CE I'm not sure what UKNI is for.

I think the marking guidance as a whole means goods sold next year in the UK (apart from NI) will have to be UKCA marked (requiring a UK Notified Body), whilst UK manufactured goods for sale in Europe (including NI), must be CE marked, requiring a European Notified Body. Anyone in the UK making goods for sale in Europe and the UK has to provide both marks. Let's hope the same Technical File will be acceptable on both sides of the border!

Dave

Assuming the proper standards have been met, apply for and use the BSI Kitemark?

UKNI covers the case that NI can accept CE marking, but a UK (inc NI) entity cannot be a Notified Body for CE marking. So for NI sales of items needing assesment by a Notified Body you can certify to EU CE regulations but use a UK (inc NI) Notiifed Body. This would be useful if only selling in NI.
A late breaking and odd arrangement. I would not be surprised if it changes.

We are now a 'third party' country so these rules apply for exporting into Europe:

europa.eu/youreurope/business/product-requirements/labels-markings/ce-marking/index_en.htm

I suppose the issue will be for products covered by a 'notified body'.

Perhaps Wales will see the emergence of a 'Cymru Export' mark?

Neil

Good idea. I think we should have a combined Welsh and Scottish mark - something like

C U JIMMY

Different animal and the UK Guidance doesn't identify it as alternative.

The BSI Kitemark is a Quality Mark. It identifies a system where the supplier's design, methods, and product have been inspected against a specification by an independent authority. Quality Marks assure customers that high standards have been set and met, but not that the product meets all the standards needed to make it legal for sale. Although technically a good thing, cost is a major disadvantage because a third party and more work is involved. It's a high overhead and usually only done when better than CE/UKCA is needed. It's done as well, not instead of.

CE and UKCA are Conformance Marks, not Quality Marks. A different system. Conformance Marks only mean the seller believes the product meets whatever list of standards are applicable within the administration he is selling to. Conformance Marks usually relate to safety requirements. Conformance Marking is self-regulated, except sellers can be required to justify themselves by producing the Technical File. If a CE marked item causes an accident and it's found there is no technical file, or the content is negligent, then the supplier gets fined or someone goes to jail. The CE Mark doesn't cover how well made the product is, or even if it works at all.

CE means the seller asserts the product meets the specifications necessary to sell that type of item in the European Union. UKCA means the seller asserts the product meets British Specifications for sale in the UK. At the moment British and European specifications are practically identical, but leaving the EU means they can drift apart over time. From now on European exporters now have to assert UKCA is met and British exporters have to assert CE is satisfied.

The advantage of Conformance Marking is cheapness. It's not necessary for reputable businesses to do much more than they would do anyway, and they don't have to apply an expensive third-party inspection regime to ordinary goods. Governments don't interfere unless it goes badly wrong.

Unfortunately, self-regulation is abused. There's nothing like a policeman turning up to ensure good behaviour. Another disadvantage, Conformance Marking is often unclear to both sellers and buyers - who knows exactly what should be covered by a Conformance Mark and who knows what actually is? Without seeing the Technical File the customer can't tell, and the Technical File might be a fake. Perhaps the biggest flaw is the much too subtle difference between Conformance and Quality. Confusion galore - everyone I know thinks CE is a Quality Mark, and, if they notice it at all, they'll probably believe UKCA is too. Bottom line: BSI Kitemarks don't apply to international trade rules and UKCA/CE Conformance Marks don't guarantee quality.

Dave

My thought had been that, if the product was for the GB+Ulster market, as stated, and if there was an applicable British Standard, then paying for the inspection and license fee for the BSI Kitemark was a valid method.

Actually the exporter doesn’t have to worry about ce /ukca - that’s explicitly the problem of the person placing the product on the market. Usually the importer, although there are some exceptions.

If the product doesn’t meet the requirements of course then it shouldn’t be for sale, and the exporter is likely to have a problem selling it to the importers. EU law is changing shortly such that the manufacturer needs a representative in the market to be able to sell to consumers, but b2b sales it’s still the importers responsibility before selling to consumers- they become the manufacturer rep by default.

Clusterfcuk doesn’t even come close...

Dual, virtually identical paperwork for no actual benefit at all.

Dave