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Questions and answers about the UKCA mark from easyCE

UKCA: The CE mark for Great Britain

The new UKCA mark has been in force in the UK since 1 January 2021:

  • The UKCA marking (UK Conformity Assisted marking) is the UK marking for products placed on the market in the UK (England, Scotland and Wales) and replaces the EU requirements for CE marking.
  • Since the UK's membership of the EU came to an end on 31 January 2020 ("Brexit"), the UK has been in a transition phase in which it remains part of the EU single market.
  • This transition phase has been adjusted several times (the last time was 31 December 2024) and has now been suspended indefinitely.
  • For manufacturers, this means that products can still only be sold with the CE mark in the UK. Nevertheless, there are many manufacturers who value the UKCA mark.

The experts at easyCE will be happy to help you place your products on the market and assess special cases. We are happy to support you with CE, UKCA and other labelling.

What does the UKCA mark mean?

The UK Conformity Assessment Mark will, after a currently indefinitely suspended period, be a mandatory mark on products indicating conformity with UK legislation. The manufacturer or their authorised representative will be responsible for affixing the UKCA mark to the product. The process is analogous to that of CE conformity assessment, except that it applies to the UK market.

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Will the CE marking remain valid for products placed on the UK market?

For most products placed on the UK market, the CE marking was only supposed to be valid until 31 December 2024 after multiple extensions. However, this deadline has now been suspended indefinitely. It is not yet possible to estimate when the UKCA mark will finally become mandatory.

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What are the differences between the UKCA mark and the CE mark?

Many of the differences between the two systems are administrative in nature and reflect the fact that the UKCA only applies in the UK and only requires information in English. This simplifies some aspects, such as where the technical information must be kept, or which language applies. Other differences relate to the separation of UK Conformity Assessment Bodies from the EU Notified Body system as described below.

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What aspects of UKCA do not change compared to CE?

Many aspects are the same; the scope of products covered, the technical requirements (essential requirements, standards) and the conformity assessment procedures will all initially be the same. If your product is sold in both the EU and the UK, the technical documentation showing that it fulfils these requirements will also be the same.

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How will the UKCA mark affect Northern Ireland?

Products placed on the market in Northern Ireland (and the EU) must be CE marked regardless of their origin. Products placed on the market in Great Britain must be UKCA marked as described above, regardless of their origin, with one exception: companies in Northern Ireland will be in a special position to supply products certified under EU (CE mark) or UK (UKCA mark) regulations to Great Britain.

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Can I apply both the CE and UKCA marks on my product?

Yes, provided they fulfil the associated requirements. It is already common practice to affix several conformity marks to products sold internationally.

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What specific UK laws must be observed when marking UKCA?

To implement the new regulation, the UK government has issued several regulations (Statutory Instruments) to amend the current legislation. The most important regulations are the Product Safety and Metrology and (EU Exit) Regulations 2019, which run to 659 pages. These regulations amend most of the UK CE marking requirements for products placed on the UK market and require the UKCA mark. Where a directive requires CE marking and the UK regulations have already been established, the changes are limited to

  • replacing the CE mark with the UKCA mark,
  • restriction of applicability to products for the UK market,
  • change of references to Notified Bodies in Approved Bodies,
  • change of language references to English.
  • In cases where an EU regulation on CE marking is amended and not a directive, more substantial changes were required, similar to the regulations implementing the directives.
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According to which standards must the UKCA marking be carried out?

The British Standards Institution (BSI) remains firmly committed to the EN and international standards systems and 'harmonised standards' remain best practice for both CE and UKCA marking. UK regulations refer to them as 'named standards' and the lists of harmonised and named standards will initially be the same. It is unlikely that the BSI will withdraw the EN standards, but the list of UK notified standards is likely to vary slightly over time as UK authorities such as the HSE exert their influence over standards they do not like.

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What other measures are required for the UKCA marking?

Other aspects that have a direct impact on manufacturers and importers are

  • From the end of the transition period, importers of products marketed in the UK must be established in the UK. Their product labelling obligation can be fulfilled by information on the documents accompanying the product for a period of 18 months.
  • Authorised representatives already established in the EEA will continue to be recognised in the UK, but those established after 31 December 2020 must be established in the UK.
  • Organisations based in the EU that import UK products for marketing in the EU will become an "importer" with increased responsibility for compliance. Currently, these organisations are classed as 'distributors' with responsibility for checking declarations, instructions and labelling. As importers, they must also check that the products have adequate technical documentation, which is a significant additional obligation, and they must put their name and address on the product.
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What is the impact of Regulations (EU)2019/1020 on UKCA labelling?

Regardless of the UK's exit from the EU, in July 2021, Regulation (EU)2019/1020 will introduce important changes to manufacturers' obligations that are likely to impact UK and other non-EU manufacturers wishing to export to the EU single market. This regulation was enacted with the aim of better protecting the EU single market against non-compliant products and avoiding loopholes in the system of application of the law, particularly in view of the increasing number of products being offered for sale online to end consumers within the EU. It states that for manufacturers based outside the EU, the responsible economic operator established in the EU must be one of the following:

  • an importer
  • a representative appointed by the manufacturer
  • a fulfillment service provider handling the product if neither of the above-mentioned exist
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