Published on: 19 May 2022
The MCA has been holding a series of meetings to both understand industry concerns and put forward solutions to issues surrounding the recertification of Marine Equipment Directive equipment (ship wheel marked equipment) to the new UKCA mark, in time for the January 2023 deadline following Brexit.
Following a meeting in March where industry informed the MCA there was not enough capacity to re certify all the necessary equipment to allow market continuity for the GB marketplace, the MCA held another meeting on the 4 May and made the following announcement:
The MCA is provisionally appointing conformity assessment bodies (CABs), with two going through the final stages currently, and three more who are also going through that process. Once the MCA receives the signed documents back from the provisionally appointed conformity assessment bodies, then they will be able to begin UK conformity assessment for marine equipment.
This is expected in the coming days. This means that all marine equipment product categories will have good CAB coverage.
The provisionally appointment of CABs is also open to existing UK Approved Bodies seeking an extension to scope.
However the provisionally appointed UK Approved Bodies will be unable to access the UK-US Mutual Recognition Agreement for marine equipment, so they will be unable to approve equipment for the US market under the UK-US Mutual Recognition Agreement for marine equipment. However, once provisionally appointed UK Approved Bodies are fully accredited and appointed, then they will be able to access that UK-US Mutual Recognition Agreement.
Provisionally appointed UK Approved Bodies must complete the full accreditation process with UKAS (United Kingdom Accreditation Service) by 30 June 2023. Once the provisional appointment process is complete, and conformity assessment bodies are provisionally appointed, then they will be listed on the UKMCAB database found here and will also be included in the next update to MSN 1874.
Industry still has some concerns about the available capacity, which was highlighted in the Q&A session that the MCA hosted after the above announcement.
Our members could find the following FAQs and answers useful:
Q: Are there any contingencies if CABs cannot cope with workload?
A: The MCA is in regular contact with the CABs and none have expressed concerns over their workloads. However, if there are any particular issues that need to be addressed, please let us know at MEQA@mcga.gov.uk and we can arrange to discuss with the CAB if necessary. The MCA is also working on other measures to ease the approvals process, and hopes to announce details of this towards the end of the month.
Q: What sort of paperwork will CABs require for approvals?
A: If the CAB is an EU certified body and has previously certified equipment for the EU, only a small amount of paperwork should be needed to approve for the UK. However, if equipment was tested by a different organisation, the UK CAB will need to carry out their full process.
Q: Do CABS have to be UK based only?
A: They must be established in the UK in order to be a UK Approved body and certificate UK equipment, as per Schedule 3 of the Merchant Shipping (Marine Equipment) Regulations 2016 as amended, however they do not have to operate exclusively in the UK.
Q: Will the scope of products covered by each provisionally approved body be published?
A: Yes, this will be available as it is for existing CABs on the UKMCAB database, link: UK Market Conformity Assessment Bodies - GOV.UK (www.gov.uk). The website covers all product areas, but can be filtered to marine equipment only for ease of searching. However, to check the types of equipment each body is approved to assess, you will need to click on the UK Approved Body/provisionally appointed UK Approved Body to look at the accompanying information. Please note UK Approved Bodies may cover multiple product sectors in addition to marine equipment.
Q: Will certificates issued by provisional bodies have the same length of validity as fully accredited CABs?
Q: Will there be an extension to the 1 January 2023 deadline?
A: There will be no extension. Marine equipment already had a later deadline than other types of equipment.
Q: What is the reason for provisionally approved bodies not being able to approve equipment for the US under the UK-US MRA?
A: This is purely due to the provisional appointment status. As soon as they are fully accredited and appointed, CABs will be able to approve equipment for the US as normal.
Q: Is it possible that some provisionally EU Notified bodies may already be able to approve equipment for the US under the EU-US MRA?
A: It is possible, however, they will still need to become approved in the UK for UK equipment.
Q: Does the provisional appointment apply for any other product areas?
A:, No, only for marine equipment
Q: What will the process be for the acceptance of Red Ensign certificates by approved bodies which are not an IACS member?
A: It will be down to the CAB to explain any rules it has around certificates it will accept. However, IACS represents class societies, not equipment.