UNITED KINGDOM: UKCA marking and UK approval process

As follow-up on our NEWS from 19^th SEP 2020 (https://www.7layers.com/en/united-kingdom-ukca-marking-after-brexit/), we want to inform as follow:

For getting market access in Scotland, England and Wales till 31.12.2021, the CE marking of products for showing compliance to RED regulation is fully accepted as a kind of transition period. This also applies in the case that an EU-type examination (TEC) has been issued in case of non-harmonized standard to demonstrate compliance with RED article 3.2.

Since 01.01.2021, a manufacturer has to issue a UK Declaration of Conformity (UK DoC*, similar to this for EU), as long the product fulfil the harmonized standards which are currently almost identically to them for EU**. If a product is not compliance to harmonized standard (“non-designated”), an UK Conformity Assessment Body must be involved for getting a UKCA certificate to demonstrate compliance with the UK Radio Equipment Regulations. This can be also done voluntary although fully compliancy to harmonized standards is given.

In other words: If a product needs a EU-type examination certificate for fulfilling the RED requirements, it will also need a UKCA certificate for market access in Scotland, England and Wales.

Btw, Northern Ireland is covered by EU regulations as before. There are just some minor cases where further rules should be considered (https://www.gov.uk/guidance/using-the-ukni-marking). While marking of products with CE-logo will be sufficient till end of 2021, from 01.01.2022 marking with UKCA mark* by fulfilling UK regulations is obligatory. The CE mark can be kept simultaneously. Till 31.12.2022, UKCA marking and labelling with importer company’s name and contact address can be done with a temporarily sticker or on accompanying documentation, after this date it must be a permanent marked on the product***.

* Guidance regarding the UK DoC and UKCA mark: https://www.gov.uk/guidance/using-the-ukca-marking#self-declaration

** Information regarding the designated standards: https://www.gov.uk/government/publications/designated-standards-radio-equipment

*** Information for import requirements: https://www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-great-britain

TURKEY: Import regulation change since November 2020

The Turkish authority for information technologies and communications BTK (Bilgi Teknolojileri ve İletişim Kurumu) updated their regulation for compliance to RED on 5th November 2020 (gazette no. 31295):
https://www.btk.gov.tr/telsiz-arayuz-ozellikleri

As conclusion, for products placing on their market, the CE Declaration of Conformity (CE DoC) must be translated into Turkish language as well as the user manual beside safety information. A simplified (or multi-language) CE DoC should be extended with Turkish written passus (as usual for other EU languages). A fully translated CE DoC should be available on a manufacturer’s webpage, pointed out in the simplified CE DoC.

MEXICO: Request for SAR evidence from 25th February 2021

The Technical Disposition IFT-012-2019, published by IFT (Instituto Federal de Telecomunicaciones) will come into force on 25th February 2021. It contains request for showing compliance with the maximum limits of non-ionizing electromagnetic radiation caused by telecommunications devices (public communication networks).
It will effect on those devices, which are intended to use close to human heads, especially ears, operating in a range of 300 MHz to 6 GHz, or with distance of =<20cm from human bodies in a operating frequency range of 30 MHz to 6 GHz.

This assessment must be carried out by local accredited laboratories and certification bodies by issuing a related Certificate of Conformity. For RF transmitter/transceiver with such a use case and a max power in all supported bands of 20 mW (13 dBm), local testing is not compulsory required. However, compliance with other standards like EN 62209-1 or EN 62209-2 must be shown. The assessment, respective the fulfilling of EN 62209 will be used for issuing new Type Approval Certificate by IFT by applications from 25th February. Extending of existing certificates (Renewals) are not affected.

MOLDOVA: Label regulation change from 22nd Feb 2021

From 22nd February 2021, an updated Moldova Government decision will come into force which includes an update regarding product marking. This change does forbid having CE mark and Moldova mark simultaneously on a device.

The Moldova mark is required only in case of national approval for devices which are not in compliance to CE regulatory and manufacturers don’t have a CE declaration of conformity. Devices which are conform with CE and where the national approval in Moldova was issued based on the CE conformity documentation, mustn’t be marked with the Moldova mark, the CE mark should be used for presenting the compliance. This regulation should be considered for devices getting their national approval from 22nd February 2021. Products approved before this date shall be labeled with SM mark. For this, the bearing of both SM and CE mark is possible.

Please note:
The CE declaration of conformity and the CE mark on the product is not sufficient for placing the products on the market of the Republic of Moldova. The usual approval process must still be followed.

Update: MOLDOVA: REVOCATION OF LABEL REGULATION FROM 22ND FEBRUARZ 2021 – 7layers 

MEXICO: Certificate owner update mandatory for import process from Feb 2021

A new IFT Conformity Assessment Procedure (PEC-IFT) for telecommunications and broadcasting products has been published in the Mexico Official Gazette and will take effect on 25th February 2021.

One of the topics is related to certificates, which were issued on the name of a 3rd party as local representative service. These 3rd party service providers have been able to optionally serve as certificated holders .

With the new regulation, approvals which require testing and are issued on the name of these 3rd party service providers are no longer allowed to be used for import.
Certificates held by 3rd party service providers and based on testing can no longer be used to demonstrate compliance during customs clearance and each importer must obtain their own IFT certificate and their respective CoC.

All IFT certificates where no testing was or will be done are not affected by this change.
For upcoming homologation process, it is no longer useful to involve any 3rd party local representative service as certificate holder for devices, which require laboratory tests, and a contact from local importer should be provided for approval, to serve as certificate holder.