Placing transportable pressure equipment on the market in Great Britain
Find out about the rules for placing transportable pressure equipment on the market in Great Britain from 1 January 2023.
Applies to England, Scotland and Wales
Transportable pressure equipment (TPE)
The term ‘transportable pressure equipment’ refers to the following equipment when used for the transport of certain substances in accordance with international agreements on the carriage of dangerous goods by rail (RID) and road (ADR):
- all pressure receptacles, their valves and other accessories when appropriate, as covered in Chapter 6.2 of RID/ADR
- tanks, battery vehicles/wagons, multiple-element gas containers (MEGCs), their valves and other accessories when appropriate, as covered in Chapter 6.8 of RID/ADR
Read more about the international agreement on:
Placing TPE on the market
The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (as amended), (CDG 2009) require that transportable pressure equipment being placed on the market in Great Britain is:
- conformity assessed in accordance with RID/ADR
- conformity marked
The UK ‘Rho’ marking is used on transportable pressure equipment (TPE) in Great Britain (GB). It shows that products comply with requirements in CDG 2009.
See separate guidance for the rules for products covered by UKCA or CE marking.
In the European Union (EU), TPE being placed on the market is conformity assessed by an EU-notified body and Pi marked. After the United Kingdom (UK) left the EU, the Rho conformity marking was introduced as the equivalent to Pi marking in GB.
Definition of placing on the GB market
‘Placing on the GB market’ means the first supply of TPE for distribution or use in Great Britain in the course of a commercial or public service activity, whether in return for payment or free of charge. It refers to each individual item of TPE, not a design type or series. It does not require the physical transfer of the TPE.
You can usually provide proof of placing on the market on the basis of any relevant document ordinarily used in business transactions, including:
- invoices
- documents concerning the shipping of goods for distribution
- contracts of sale
‘Making available on the GB market’ is any supply of TPE (after it is placed on the market) for distribution or use in Great Britain in the course of a commercial or public service activity, whether in return for payment or free of charge. This includes hiring, leasing and renting of TPE.
TPE placed on the GB market by 31 December 2022
Until 31 December 2022, the following types of TPE could be placed on the market in Great Britain:
- Pi marked TPE conformity assessed by a notified body
- Rho marked TPE conformity assessed by an appointed body
Pi marked TPE placed on the GB market by 31 December 2022 can remain in use and be re-filled, used and further made available on the market after 1 January 2023, as long as it complies with RID/ADR. This includes TPE supplied on a for-hire basis or under a rental or lease agreement.
Placing TPE on the GB market from 1 January 2023
As of 1 January 2023, only these types of TPE can be placed on the market in Great Britain:
- Rho marked TPE
- qualifying Northern Ireland TPE
Qualifying Northern Ireland TPE
To ensure that Northern Ireland continues to have unfettered access to the whole of the UK market, TPE in free circulation in Northern Ireland can be placed on the GB market. This means that EU-conformity-assessed TPE that has been lawfully placed on the Northern Ireland market may be made available on the market in GB.
See separate guidance for qualifying Northern Ireland goods.
Mutual recognition agreement between the UK and Switzerland
In November 2022, the UK and Switzerland signed a mutual recognition agreement (MRA) on conformity assessment. This agreement covers 5 sectors including TPE.
MRAs allow countries to agree to recognise the conformity assessment results of another country’s conformity assessment bodies, which can assess products against their requirements. Under the UK-Swiss MRA, GB-appointed bodies may apply for recognition in Switzerland to conformity assess TPE against the technical requirements of Switzerland – and vice versa.
References on this page to ‘GB-appointed bodies’ shall also be read to include conformity assessment bodies recognised under the MRA.
Carriage between GB and another country
TPE that complies with RID/ADR may be used to transport dangerous goods between Great Britain and another country. However, it may only be placed on the GB market and used for transport exclusively within Great Britain if it meets the requirements of CDG 2009.
Pi or Rho marked TPE that complies with RID/ADR may be used for the carriage of dangerous goods between Great Britain and an EU member state.
How to use the Rho marking
A Rho marking is required for TPE being placed on the GB market. TPE that has been Rho marked is known as ‘UK TPE’.
A GB inspection body appointed to conformity assess TPE can authorise the application of the Rho marking. GB-appointed bodies are appointed by the Vehicle Certification Agency on behalf of the Department for Transport to undertake inspection activity in accordance with RID/ADR.
There’s separate guidance for products covered by the UKCA marking, as different rules apply.
Applying the Rho marking
The Rho marking shall be at least 5mm high, or 2.5mm for TPE with a diameter less than or equal to 140mm.
Multiple conformity marks are permitted. For example, TPE may be conformity assessed by a GB-appointed body and an EU notified body and bear 2 conformity marks (Rho and Pi).
TPE covered by other regulations
If TPE needs to comply with another set of regulations with different rules on UK conformity marking, both CDG 2009 and the other set of requirements continue to apply.
For example, if a TPE valve is part of a medical device covered by other legislation that requires UKCA or CE marking, it will also need that marking before the medical device can be placed on the GB market. It may, therefore, be Rho and UKCA marked or Rho and CE marked.
Arrangements for transferring or reissuing certificates
Certificates of conformity
Conformity assessment certificates for TPE placed on the GB market by 31 December 2022 do not need to be transferred to a GB-appointed body for that TPE to remain in use. For the purposes of Pi marked TPE placed on the GB market by 31 December 2022, the conformity assessments remain valid.
However, no further examples of that type of TPE may be placed on the GB market from 1 January 2023 unless they have been conformity assessed by a GB-appointed body and Rho marked.
GB-appointed bodies can issue certificates of conformity and authorise the Rho marking on the basis of test data from conformity assessments carried out by EU-notified bodies before 1 January 2021.
Type approval certificates
Type approvals issued by an EU conformity assessment body before 1 January 2021 can be transferred to a GB-appointed body. In theory, this may be a paper-based exercise but the GB-appointed body will need to be satisfied with the test data before issuing a certificate of conformity, as it will take on legal responsibility for that assessment.
To enable this transfer to take place, information held by EU-notified bodies about certificates issued before 1 January 2021 shall be made available to a GB-appointed body at the certificate holder’s request.
Where an existing type approval issued by an EU-notified body before 1 January 2021 is reissued by a GB-appointed body, the expiry date will remain the same as the original certificate. A new 10-year period of validity cannot be granted for a type approval reissued by a GB-appointed body on the basis of EU test data as the GB body would not have undertaken a complete review/assessment of conformity against RID/ADR.
Periodic inspection and testing
Periodic inspection and testing of Rho marked TPE shall be conducted by a GB-appointed body in accordance with RID/ADR and CDG 2009. The normal marking requirements under RID/ADR continue to apply. Rho marked TPE that passes a periodic inspection and test conducted by a GB-appointed body may be transported to and from the EU in accordance with RID/ADR but may not be used for carriage exclusively within the EU.
For the purposes of this page, references to periodic inspections being ‘conducted by’ an appointed/notified body may also be read as including those ‘undertaken by an in-house inspection service under the surveillance of’ an appointed/notified body in accordance with RID/ADR.
When the periodic inspection and test is due for Pi marked TPE placed on the GB market before 1 January 2023, there are 4 options.
Option 1
An EU-notified body may conduct the periodic inspection and test in accordance with RID/ADR and TPED. After the periodic inspection and test, the TPE may continue to be used in GB and the EU. For the purposes of CDG 2009, it continues to be ‘Pi marked TPE’ and does not need to be Rho marked.
Option 2
A Northern Ireland-notified body may conduct the periodic inspection and test in accordance with RID/ADR and TPED. After the periodic inspection and test, the TPE may continue to be used in GB and Northern Ireland, but not the EU. It may still be transported to and from the EU, in accordance with RID/ADR. For the purposes of CDG 2009, it continues to be ‘Pi marked TPE’ and does not need to be Rho marked.
Option 3
A GB-appointed body may conduct the periodic inspection and test in accordance with RID/ADR and CDG 2009 without the Rho mark being affixed. After the periodic inspection and test, the TPE may continue to be used in GB but not in the EU or Northern Ireland. It may still be transported to and from the EU, in accordance with RID/ADR. For the purposes of CDG 2009, it continues to be ‘Pi marked TPE’ and does not need to be Rho marked.
Option 4
A GB-appointed body may conduct the periodic inspection and test in accordance with RID/ADR and convert the Pi marked TPE to ‘UK TPE’. If the TPE owner chooses this option when the periodic inspection and test is due, the Rho mark shall be affixed to the TPE. The existing Pi mark shall not be removed and the documentation associated with the Pi mark will not need to be amended.
The periodic inspection and test certificate may optionally state that the TPE has been converted to UK TPE. After the periodic inspection and test, the TPE may continue to be used in GB but not in the EU. It may still be transported to and from the EU in accordance with RID/ADR.
Converting Pi marked TPE to UK TPE by affixing the Rho mark is optional. It is not a requirement. If a TPE owner prefers to use the services of a GB-appointed body but not to convert their Pi marked TPE to UK TPE, they may choose option 3.
Converting Pi marked TPE to UK TPE
When the periodic inspection and test of Pi marked TPE is due, it may be converted to UK TPE by affixing the Rho mark. Converting Pi marked TPE to UK TPE is optional and shall only be carried out if a GB-appointed body is conducting the periodic inspection and the owner wants the Rho mark to be affixed.
If the owner elects to convert Pi marked TPE to UK TPE, the following marks must be affixed:
- Rho mark
- date of the periodic inspection and test
- identification number of the GB-appointed body responsible for the periodic inspection and test
If the TPE is not converted to UK TPE, the normal marking requirements under RID/ADR continue to apply.
The Rho mark shall be adjacent to the date of the periodic inspection and the identification number of the GB-appointed body responsible for the periodic inspection and test.
For dual Rho and Pi marked TPE placed on the GB market from 1 January 2023, a GB-appointed body will also need to conduct a periodic inspection and test for the TPE to remain in use in GB. If an EU-notified body conducts the periodic inspection and test and there is no periodic inspection and test conducted by a GB-appointed body, the TPE cannot remain in use in GB.
Valves
Valves may be considered TPE. Rho marking is required for valves that meet the definition of TPE before they can be placed on the GB market.
In practice, Rho marking of valves will only be necessary where the Pi mark would have been required under the Transportable Pressure Equipment Directive (2010/35/EU) (TPED).
Read separate guidance for more information about UKCA marking.
Businesses in GB that hold stock of Pi marked valves that were placed on the GB market before 1 January 2023 can continue to use up existing stocks of those valves after that date.
Bundles of cylinders
A bundle consists of a frame in which there are several cylinders manifolded together. The following requirements apply to bundles of cylinders being placed on the GB market from 1 January 2023:
- the complete assembly of the bundle of cylinders shall be conformity assessed by a GB-appointed body (or a body designated under a mutual recognition agreement)
- the frame of the bundle shall be Rho marked
All cylinders within the bundle will need to be individually conformity assessed and marked with a Rho and/or Pi mark. Individual cylinders have to comply with the regulations in force at the point in time they were placed on the market.
Spare parts
Repair, replacement and maintenance operations are often carried out using other products that are spare parts. Spare parts are considered to have been placed on the market at the time at which the original product or system they are ultimately intended to repair, replace or maintain was placed on the market. This means that spare parts can comply with the same conformity assessment requirements that were in place at the time the original product or system they are ultimately intended to repair, replace or maintain was placed on the market.
Cylinder shells or other parts for onward manufacture
Where such shells and/or other parts are intended for onward manufacture or processing, these will not be considered to be placed or made available on the market.
Components may be placed on the market separately and could constitute a fully manufactured product in their own right. A finished product must be compliant with all applicable legislation when placed on the market
Authorised representatives and subcontracting
Existing rules for the appointment of authorised representatives will still apply. Manufacturers based anywhere must fulfil certain obligations under CDG 2009 and they may choose to appoint an authorised representative from a relevant territory (Great Britain, Northern Ireland or an EU member state) to carry out some of those obligations. See regulation 20 of CDG 2009.
This does not affect the obligations of UK-based importers when placing TPE on the GB market that was manufactured in another country.
GB-appointed bodies may continue to appoint subcontractors in accordance with 1.8.6 and 1.8.7 of RID/ADR.
Breathing apparatus
TPE for breathing apparatus is covered by the Pressure Equipment (Safety) Regulations 2016 rather than part 4 of CDG 2009. The Rho mark is only required on TPE which was required to be Pi marked under TPED. TPE used for breathing apparatus may additionally be Pi marked to comply with TPED if it is also used to transport dangerous goods.