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As the rules change or new procedures are developed, please note that these interpretation and/or guidance may not apply; you should always refer to the latest rules and guidance documents to determine what equipment authorization procedures should be followed. For the latest guidance on specific topics or you don't know where to start, please feel free to contact GTG experts.

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Attention all manufacturers and traders in the United Kingdom! Have you heard of the new UKCA marking? This mandatory certification mark has replaced the CE marking for most goods being placed on the UK market. The UKCA marking confirms that the product complies with UK regulations and standards, ensuring the safety and health of consumers. Failure to comply with this new requirement could result in severe consequences, including fines, penalties, and even product recalls. It can also damage their reputation and lead to loss of customers. Therefore, don’t let your business fall behind the curve. Get informed and take action today to ensure your products meet the UKCA marking standards.

UKCA Marking
▲ UKCA marking

What is the CE marking?

CE Marking
▲ CE marking.

The CE marking is a mandatory conformity marking for products sold in the European Economic Area (EEA). It indicates that the product meets the essential requirements of the applicable EU directives and regulations. The marking is affixed to the product or its packaging to show that it has undergone the necessary conformity assessment procedures and is deemed safe for use within the EEA.

What is the UKCA marking?

The UKCA marking is a new conformity marking that has been introduced by the UK government for products sold in Great Britain (England, Scotland, and Wales). It also applies to Northern Ireland, although there are some specific rules that apply there. The UKCA marking is similar to the CE marking in that it indicates that the product meets the necessary safety, health, and environmental protection standards. However, it applies only to products sold in the UK market.

Update UKCA dated June 20th, 2022 by the UK government. Four easements being introduced across much of the product safety legislation to facilitate UKCA marking:

1. Reduce re-testing costs for UKCA certification

“We will reduce re-testing costs for UKCA certification, by allowing conformity assessment activities for CE marking completed by the December 31st, 2024 to be used by manufacturers as the basis for applying a UKCA marking. This will reduce the immediate costs faced by manufacturers and will be valid until the expiry of their certificate or for 5 years (December 31st, 2027), whichever is sooner. This will reduce duplication and costs for businesses and by extension, consumers.”

2. There is no need to re-test existing imported stock

“We will make clear there is no need to re-test existing imported stock, as these products will be considered already placed on the market in Great Britain (GB). This will prevent the costly, and unnecessary re-labelling of existing stock for businesses.  i.e. completed CE-marked pressure equipment components, imported under contract into the UK by December 31st, 2024, do not need to be re-tested/re-certified or UKCA marked. However, the products should still be checked to ensure they meet the requirements of EU law before they are further supplied and a record should be kept of documentation which demonstrates the product was imported into GB under contract before the December 31st , 2024.”

3. Spare parts that repair, replace or maintain goods already on the GB market

“We will make clear that spare parts that repair, replace or maintain goods already on the GB market can meet the same requirements that were in place at the time the original product or system was placed on the GB market. This will allow products and goods requiring spare parts to continue to be maintained.  i.e. Pressure Equipment manufacturers can continue from January 1st, 2025 to purchase ‘CE’ marked spare parts for ‘CE’ marked equipment placed on the GB market before 11 p.m. on December 31st, 2024. However, if the product or system has been subjected to important changes, overhauling its original performance, purpose, or type, it would be considered ‘new’ and must comply with GB regulatory requirements, including being UKCA marked from 11 p.m. on December 31st , 2024.”

4. Allow businesses to affix the UKCA marking, on an accompanying document or label

“We will continue to allow businesses to affix the UKCA marking, and to include importer information for products from EEA countries (and in some cases Switzerland), on an accompanying document or label until December 31st , 2025. This will allow business to adjust their product design to accommodate marking changes at a convenient and cost-effective time. i.e. pressure equipment or assemblies do not need to have the UKCA mark physically affixed when being placed on the GB market until after 11 p.m. on December 31st, 2025.  Until then the UKCA marking can be in an accompanying document or label.  Similarly, importer information does not need to be affixed on pressure equipment or assemblies imported from the EEA until after 11 p.m. on December 31st, 2025, and can instead be on the packaging or in an accompanying document until that date.  From January 1st, 2026 this information needs to be on the good unless the specific product regulation permits otherwise (e.g., due to the size or nature of the good).”

These changes do not apply to medical devices, construction products, transportable pressure equipment, cableways, unmanned aircraft systems, rail products and marine equipment. Departments responsible for these sectors are making sector specific arrangements.

Please note that UKCA as used refers to all UK product safety legislation not just the sectors that require the UKCA mark.

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When is the UKCA marking required?

The new UKCA marking has been in force in Great Britain since 01 January 2021, following the end of the Brexit transition period. During a four-year transition period to 31 December 2024, the CE marking will continue to be recognised in Great Britain for certain products. After the transition period, starting from 01 January 2025, for particular product groups, only those that bear the UKCA marking will be accepted. Products can carry both the CE and UKCA markings if they fulfil both the EU and UK regulations in full.

What are the implications of Brexit for businesses exporting to the EEA?

For businesses exporting to the EEA, the CE marking is still mandatory. However, they may need to appoint an authorized representative in the EEA to act on their behalf in relation to the conformity assessment procedure. They may also need to comply with additional requirements, such as those relating to product labeling and documentation.

What are the differences between UKCA and CE marking?

The main difference between CE and UKCA marking is that CE marking is required for products sold in the EEA, while UKCA marking is required for products sold in Great Britain. However, there are also some technical differences between the two markings. For example, the UKCA marking requires a different conformity assessment procedure than the CE marking, and there are different requirements for the product labeling and documentation.

What aspects are not changing?

Many facets are the same; the scope of products covered, technical requirements (essential requirements, standards) and conformity assessment procedures will all initially be alike. If your product is sold in both the EU and the UK, the technical file to show that it meets these requirements will also be the same.

It’s important to note that product regulations and certifications can change over time. For the most up-to-date and accurate information regarding UKCA and CE marking, GTG recommend visiting the official government websites or consulting with relevant regulatory bodies. Or you can choose to stay up with GTG by subscribing to our email list, our UKCA experts will inform you the very first updates on UKCA marking.

Legal requirements in the product areas with UKCA conformity assessment and UKCA marking

EU legislation still applies in Great Britain until 31 December 2024, after which certain product groups are only subject to GB law. Below is a selection of the products for which GTG can offer manufacturers either direct or indirect solutions. These changes do NOT apply to all products. Please refer to the sector-specific guidance for more information in the UK.

EU-legislationLegislation in Great Britain
Toy Safety – Directive 2009/48/ECToys (Safety) Regulations 2011
Simple Pressure Vessels – Directive 2014/29/EUSimple Pressure Vessels (Safety) Regulations 2016
Electromagnetic Compatibility – Directive 2014/30/EUElectromagnetic Compatibility Regulations 2016
Low Voltage Directive 2014/35Electrical Equipment (Safety) Regulations 2016
Radio equipment – Directive 2014/53/EURadio Equipment Regulations 2017
Pressure equipment – Directive 2014/68/EUPressure Equipment (Safety) Regulations 2016
Machinery Directive 2006/42/ECSupply of Machinery (Safety) Regulations 2008
Outdoor Noise Directive 2000/14/ECNoise Emission in the Environment by Equipment for use Outdoors Regulations 2001

What products are covered by the UKCA marking?

  • Toy safety
  • Recreational craft and personal watercraft
  • Simple pressure vessels
  • Electromagnetic compatibility
  • Non-automatic weighing instruments
  • Measuring instruments
  • Lifts
  • ATEX
  • Radio equipment
  • Pressure equipment
  • Personal protective equipment
  • Gas appliances
  • Machinery
  • Outdoor noise
  • Ecodesign
  • Aerosols
  • Low voltage electrical equipment
  • Restriction of hazardous substances

Products covered by the UKCA marking but have some special rules

  • Medical devices
  • Rail interoperability
  • Construction products
  • Civil explosives

How can GTG assist you with UKCA marking recognition

GTG supports manufacturers or their authorised representatives throughout the recognition and conformity assessment process for the UKCA marking. Either directly or through partnership agreements, GTG helps with the implementation of the UKCA label from the very beginning. With our partners at our side, we offer tailor-made market access solutions for a wide range of product groups. Manufacturers and distributors are responsible for their products conformity with the relevant rules in Great Britain and for the creation the conformity assessment documents. With more than 12 years of market experience, we offer practical support and advice to help you develop a frictionless conformity assessment strategy.

FAQs on UKCA marking

In which countries do I need the UKCA marking?

The UKCA marking only applies in Great Britain (England, Scotland and Wales).

When does the UKCA marking need to be used?

The new UKCA marking only needs to be used before January 1st, 2025 if all of the following apply. The product:

  • is destined for the British market
  • is covered by legislation requiring the UKCA marking
  • requires mandatory third-party conformity assessment
  • conformity assessment has been carried out by a UK conformity assessment body
Can a UKCA and CE declaration of conformity be created in a single document?

No, the two declarations of conformity cannot use the same document. Two separate documents have to be drawn up. These must be retained for 10 years from the date the product is brought to market.

What are the rules in Northern Ireland?

As a member of the United Kingdom, Northern Ireland has special status. The new UKCA rules are not applied in Northern Ireland and the UKCA marking alone will not be accepted. Products there must correspond to harmonised EU standards and be labelled with either the CE or the UK(NI) marking

How can I prepare for the UKCA label?

If a product needs to be converted or adapted to UKCA requirements, GTG and its partners can help, in some cases offering the services of a UKCA label body. Just get in touch by email at [email protected].

Can both the CE marking and the UKCA marking be applied to a product?

Yes, both labels can be applied to a product if the product complies with both sets of requirements. 

What needs to be considered when affixing the marking?
  • the marking may only be affixed to the product by the manufacturer or its authorised representative if this is permitted by law.
  • the manufacturer or its authorised representative is responsible for the conformity of the product with the applicable legal requirements. 
  • declaration of conformity of the product with the applicable UK legislation.
  • the meaning and form of the UKCA marking must not lead to misunderstandings by third parties 
  • the visibility, legibility and meaning of the label must be ensured.
What are the rules for products from the UK?

Conformity Assessment Bodies lost their status as notified bodies on the GB’s exit from the EU on 01 January 2021 and are no longer allowed to carry out EU conformity assessments. Consequently, their conformity certificates were rendered invalid from 01 January 2021. Manufacturers and distributors may no longer declare conformity on the basis of such certificates. There remains the option of being certified by a notified body. GTG is such a body and is happy to assist. Just get in touch by email at [email protected].

What needs to be considered when creating a UK declaration of conformity?

Basically, the contents of a UK declaration of conformity are largely the same as those of an EU declaration of conformity. Depending on the applicable legislation these may vary, but should contain the following: 

  • Name and business address of the manufacturer or authorised representative.
  • serial number, model or type identification of the product.
  • if applicable: Details of the UK Approved Body that carried out the conformity assessment procedure.
  • Statement of responsibility for the product.
  • The relevant legislation with which the product complies.
  • List of standards in the United Kingdom.
  • Name, signature, date (that declaration is made).
Sources: Our guidance and/or articles are written in part based on publicly available information, and our own practical experience relating to product testing, compliance and certification. These are some of the primary sources we use:
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