PACKAGING
The UKCA mark is now required for products placed on the market in England, Scotland and Wales (GB)
In the EU, including Ireland and (currently) the UK, there are no specific laws to mark Country of Origin (COO). However, fair trading laws require that no false impression of origin & customs must be given and that the import declaration documents must state COO. This is not the case internationally – for example, in the USA and Canada, COO marking is required. EU and UK law requires warning markings
must be clear and legible – I recommend symbols should be at least 2.75mm high, and text is at least 1.5mm high. Markings should also be in a contrasting colour. Alternatively, they can be engraved or embossed, in which case they must be at least 0.5mm deep or proud. These recommendations are based on certain harmonised standards – the law only requires the marking to be legible. The law also requires that if the product is
large enough to accommodate the marking, it must go on the product. Aesthetic factors are not an excuse for not applying the marking directly to the product.
Only if the product is physically too small may the markings be placed instead on the packaging. Markings must be durable and last the
expected lifetime of the product. When checking the durability of the marking, the effects of normal use are considered. For example, markings by means of paint (other than enamel coating) on handles or parts that are likely to be cleaned frequently is not considered to be durable. Therefore, engraving or embossing is recommended in such cases. Similarly, if your equipment uses harsh solvents, be sure to additionally test your markings against those solvents.
FHS-MAY21-SENSORS UK:FHS-MAY21-SENSORS UK 07/05/2021 10:21 Page 1 Thankfully, there is a lot of guidance online
from the EU and national governments. A good starting point for guidance on CE marking is the EU’s “Europa” website:
https://ec.europa.eu/growth/single- market/ce-marking_en While product and packaging labelling
may at first appear to be confusing, a systematic approach works best. Once you identify the directives and regulations that apply to your products, the labelling requirements simply follow.
FHS-OCT19-ROTECH.qxp:Layout 1 11/10/2019 15:53 Page 1
TÜV SÜD
www.tuvsud.com/uk
JUNE 2021 | PROCESS & CONTROL 9
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