Two questions that arrive as one
A UK buyer asking whether a toilet can be sold into the market is usually holding two questions in a single sentence. The first is about marking: what symbol has to be on the product or its paperwork, and which symbol that is this year. The second is about water: whether a fitting that connects to the mains supply meets the rules that govern that connection.
They are unrelated questions with unrelated answers. One is administered as product marking. The other is administered as plumbing regulation. Nothing in the first answers the second, and a file that holds one of them is not a compliance file, it is half of one.
Where CE and UKCA actually stand
The marking question has moved, and a lot of supplier documentation has not moved with it. In Great Britain — England, Scotland and Wales — CE marking is now recognised indefinitely for most goods. For the products covered by that position, UKCA is optional rather than mandatory. A supplier who tells you UKCA is required for a WC is working from guidance that has been superseded.
Construction products have followed the same direction. CE marking for construction products has been extended indefinitely, and the government has committed to giving at least two years’ transition if that position ever changes. Two years is a long time in a container programme, but it is not long in a product development cycle, which is why the commitment is worth knowing about even when it does not bind you today.
Read the two paragraphs above as what they are: a statement of the marking position as currently published, with a promise about how a future change would be handled. Neither is a statement about your product’s conformity. Marking is the visible part of a conformity process that sits behind it, and the process is what a technical file has to evidence.
The water fittings regulations are a separate regime
The Water Supply (Water Fittings) Regulations 1999 apply to fittings that connect to the public water supply. The obligation is about the fitting and its connection, not about the product’s marking. A fixture can carry every mark its manufacturer wants and still fail this test, because the test is about whether water can be protected from contamination at the point of connection.
WRAS certification is the route most suppliers use to demonstrate that a fitting complies, and it is the certificate most UK buyers ask to see. It is a common route, not the only permissible one, and it is worth being precise about that: the regulations set the requirement, and approval schemes exist to show the requirement is met. If your project insists on WRAS specifically, say so at enquiry stage, because that is a different request from “meets the water fittings regulations” and it is answered by a different document.
The detail that catches cisterns
Among the specific requirements in the regulations is one that concerns the inlet to a flushing cistern. For each storage cistern, WC flushing cistern or urinal flushing cistern, a servicing valve has to be fitted on the inlet pipe immediately adjacent to the cistern. It is a small, unglamorous provision, and it is the kind of thing that decides whether an installation passes an inspection.
Note what kind of requirement that is. It describes work on the inlet pipe next to the cistern, which means it is partly a product decision — whether the fitting arrangement leaves room for the valve — and partly an installation decision. A supplier who has never discussed it with a UK buyer has never had to think about whether the inlet arrangement on a given model makes that valve easy to fit. It is worth asking, and asking in writing, before the order rather than after the first inspection.
Why a CE certificate does not close the water question
The confusion is understandable. Both processes produce a document with a logo on it, both are described as compliance, and both are often held by the same supplier. But the CE marking route is about the product’s conformity with the requirements that apply to it as a product; the water fittings regulations are about the fitting’s effect on the supply it is connected to.
So a technical file that answers the marking question can be complete, correct and entirely silent on whether the inlet arrangement is acceptable. If your project’s plumbing consultant asks a water fittings question, the answer has to come from the water fittings side of the file. Handing over the CE documentation at that point ends the conversation without answering it.
What we hold for the UK, and what we do not
We hold CE marking on our wall-hung models, and the technical file that sits behind it. That is the marking side of the file. It is a real document set, tied to those models, and it is what a UK buyer usually asks for first.
On the water side, we are careful about what we claim. We do not present WRAS approval as held across the range. Where a project requires WRAS approval or a specific water fittings declaration, tell us the model and the requirement, and we will confirm what exists for that model. If nothing exists, we will say so plainly rather than send a document that looks like an answer and is not one. The same applies to any approval we hold that is not published on the site: the answer is certificate documents on request, not a link to a PDF.
That distinction is worth more to a buyer than a folder of logos. A supplier who tells you which documents exist for which model is giving you something you can build a submission on. A supplier who sends a folder is giving you work.
A UK enquiry, written properly
- The model codes, printed, so the document set matches the order rather than the catalogue.
- Whether the project asks for CE documentation specifically, and whether it names construction products as the route.
- Whether the plumbing specification names WRAS approval, or asks for compliance with the water fittings regulations without naming a scheme.
- The proposed inlet arrangement, so the servicing valve requirement can be checked against it before anything is manufactured.
- Who is responsible for the water fittings side of the submission — the importer, the contractor or the consultant.
Five lines, and the reply you get back will separate the two regimes for you whether or not the supplier wants to. A supplier who answers all five has a file. A supplier who answers the first one and changes the subject has a marking certificate and a gap.
The habit that prevents the problem
Keep the two files separate on purpose. Label one marking and one water, and keep them apart even when they arrive in the same email. The reason is not pedantry: when an inspector or a client asks a question, the label tells you which document answers it, and the absence of a document under one label is visible immediately instead of being buried inside a folder that appears complete.
That is the whole argument. Two regimes, two files, one product. The supplier’s job is to tell you which documents exist for the model you are buying, and the buyer’s job is to ask before the container is booked rather than after the first inspection.
Frequently asked questions
Is UKCA mandatory for toilets sold in Great Britain?
For most goods, no. Great Britain recognises CE marking indefinitely, and for the products covered by that position UKCA is an option rather than a requirement. Construction products have also had CE marking extended indefinitely, with at least two years’ transition promised if the position changes. Confirm the current wording against the official guidance.
Does CE marking satisfy the water fittings regulations?
No. The Water Supply (Water Fittings) Regulations 1999 apply to fittings connected to the public supply, and they are a separate obligation from product marking. A product can be correctly marked and still fail the water fittings requirements. The two are evidenced by different documents.
Is WRAS approval compulsory?
WRAS approval is the route most commonly used to demonstrate compliance with the water fittings regulations, and it is the certificate most UK buyers ask for. It is a common route rather than the only one. If your specification names WRAS specifically, say so at enquiry stage, because that is a narrower request than compliance alone.
What does the servicing valve requirement cover?
The regulations require a servicing valve on the inlet pipe immediately adjacent to each storage cistern, WC flushing cistern or urinal flushing cistern. It is a requirement about the inlet arrangement rather than about the pan, which is why the inlet layout on a model is worth checking against it before an order is placed.
Do your wall-hung models carry CE marking?
Yes. CE marking is held on our wall-hung models, with the technical documentation behind it. If your project needs the declaration for a specific model, give us the code and we will send the matching document rather than a general statement about the range.
Can you supply WRAS documentation?
We do not present WRAS approval as held across the range. Tell us the model and the exact requirement your project applies, and we will confirm what documentation exists for that model. Where an approval is not published on the site, the answer is certificate documents on request, and we will say plainly if it is not available.
Related on this site
Documents and certificates
- Certificates and the markets each one covers
- Catalogues, drawings and published test reports
- Working with European buyers
Related reading
- CE marking for toilets: what the file contains
- Specifying toilets for an EU project
- WaterMark Is Not Installation Compliance