UKCA Compliance – Importers Need Copies of Technical Files

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Following on from the success of his video explaining the implementation of UKCA MarkingHoward Wheeler is back with a series of four videos discussing more areas relating to UKCA compliance.

With the Transition period ending in 2021, projects purchase specifications should have new requirements for the supply of product Technical Files.

The advice here is for organisations in GB and not the UK as a whole. Many GB organisations obtain machinery and equipment direct from the EU. But if you don’t buy directly from the EU but purchase from a UK distributor or a GB office of a European manufacturer, you are not the importer, and these are not issues.

If YOU bring products requiring UKCA or CE marking from the EU, YOU will become the ‘Importer’.

For those bringing in such products from the rest of the world, little changes, you are already an ‘importer’ with these responsibilities.

You have to check the Declaration of Conformity or Incorporation is correct and for many products ‘Importers’ may have to provide the Technical Files if ever requested by the UK ‘Authorities’. This can be up to 10 years later.

There are differences for machinery regulations but for non-machinery equipment, ‘importers’ need to be able to supply an actual copy of the Technical File.

However many machines also fall under other regulations, so just because it is a machine, does not mean that a Technical File is not needed, only that the information specifically required by the UK’s Machinery (Safety) Regulations is not needed. To some, this may be confusing.

There is no legal requirement for manufacturers to supply the Technical File to anyone but the relevant Authorities, manufacturers not having a UK base may not comply. To ensure Technical Files are obtained if ever asked, ‘importers’ need commercial agreements with the manufacturer.

Assuming that a request will never occur or that if it does you can obtain files 10 years later is risky. So, after the end of 2020, when importing into GB specifications should include commercial requirements for the provision of copies of the Technical File. Without a commercial requirement, this would be unlikely.

To repeat, if you do buy from a GB distributor or via a GB office of a European manufacturer, you are not the importer and these requirements apply to them, not to you.

For any more information relating to UKCA compliance, please don’t hesitate to contact howard.wheeler@finch-consulting.com.