UKCA markings could leave sellers with a mountain of CE marked stock?
OSA The Optical Suppliers Association held a very useful and informative webinar recently on the forthcoming law changes on Medical Device Agency regulations for spectacle frames, spectacle lenses, contact lenses and their supply.
Ann Blackmore led a discussion with a large number of OSA members who import and export both to the EU and Northern Ireland as well as providing home sales to UK optical providers.
Ann has been involved at almost all levels of European Laws effecting the Optical Confederation and is an independent adviser on such complicated matters and has been in past times advising FODO and continues to attend and sit on many of the key committees negotiating MDA adherence whilst trying like the profession did back in 2002 and before to ensure a light touch approach especially to the provision of spectacles either whole or as lens and frame parts.
Brexit has created an unusual divide not least between the UK and its Northern Ireland neighbours and of course the EU. One would have thought that the rules of engagement for safety and quality reasons would have allowed parity. Oh no, that’s far too simple.
What we have now is a set of rules both from the EU and the UK MDA which create the goal posts positioning and the dates to work to but a lack of clear dimensions of said goals. In other words, the devil will be in the detail but from the UK perspective there is a lack of detail as yet.
In short, the CE mark that we all are very aware of on our frames we dispense and on the lens packets we receive will no longer be eligible past a grandfathering date to sell in the UK.
That date is 30th June 2023.
After that date companies cannot sell to UK opticians products with CE sole markings and opticians cannot ask glazers to glaze CE marked frames as they will not be deemed as a correctly adapted product for sale by glazing with UKCA marked lenses.
That is because from next year January 2022 the conforming frames and lenses will need be marked with the term UKCA (UK Conformity Accessed). Precise details (or the devilish small print) are yet to be formulated.
However those importers, manufacturers and wholesalers with conformity processes in place under the CE rules can also use them to apply for UKCA markings but will not need or be able to make a formal application for UKCA certification for at least 2 years. As eyewear is way down the list of importance. They will however be expected to have all their products UKCA marked post Jan 2022.
This gives everyone with CE marked frames and sunglasses, a mountain of products no doubt, 2 years to sell off the stock.
Sunglass and spectacle frame B2C traders as with businesses could always sell off your CE stock to opticians in the EU but you would need to provide a representative to hold your records of conformity and identity based in an EU country.
If you thought that was complicated, consider the companies selling to N Ireland. Their stock must be marked both with the CE and UKCA markings to comply!
One hopes that common-sense will prevail allowing, just as for reglazes, a glazer to verify the competency of a new CE only marked frame and judge it safe to glaze creating a perfectly adapted device.
Or is that wishful thinking!
Congrats to the OSA in attempting to bring its members up to date on what is a complicated issue.