UKCA marking

# UKCA marking The UKCA (UK Conformity Assessed) marking is the conformity mark for goods placed on the market in Great Britain, showing that the product meets the relevant UK product legislation. Introduced after Brexit, it parallels the EU's CE marking, and the UK government now recognises CE marking indefinitely for most product areas, giving businesses a choice of routes. ## Key facts - UKCA marking has applied since 1 January 2021 for goods placed on the GB market under UK product legislation. - It covers Great Britain (England, Scotland and Wales); Northern Ireland follows special arrangements with CE marking and the UKNI indication. - The UK government announced it will recognise CE marking indefinitely for a wide range of product regulations. - UKCA rules are set in UK statutory instruments that mirror EU directives, such as the Electrical Equipment (Safety) Regulations 2016. - Where third-party assessment is required, a UK approved body must be used; EU notified bodies cannot certify for UKCA. - The UKCA mark must be at least 5 mm high, visible, legible and indelible. - Importers placing goods on the GB market must verify conformity, add their details and keep documentation. ## Brexit and the creation of UKCA When the UK left the EU, EU product law ceased to apply in Great Britain, and the UK converted the EU directives into domestic law as UK statutory instruments. The UKCA marking was created as the domestic successor to CE marking: the same essential requirements, the same conformity assessment modules, but assessed against UK law and marked with the UKCA symbol instead of CE. The original timetable envisaged CE marking being phased out for the GB market, with UKCA becoming mandatory from the end of 2024 for most goods. That plan changed. In August 2023 the Department for Business and Trade announced that CE marking would be recognised indefinitely for 18 sets of product regulations, removing the cliff edge. Businesses can therefore continue using CE marking for the GB market in those areas, or use UKCA, or in some cases both. This pragmatism reflects commercial reality: most manufacturers selling into Great Britain also sell into the EU, and maintaining two parallel conformity systems for identical technical requirements adds cost without improving safety. The indefinite recognition lets companies choose the most efficient route while keeping UKCA available for those who want a purely domestic compliance path. ## Where UKCA is required and where CE suffices For the 18 regulations covered by indefinite CE recognition, which include electrical equipment, machinery, toys, radio equipment, EMC, pressure equipment, personal protective equipment and others, CE marking remains accepted for the GB market with no end date currently set. Manufacturers in these sectors can place CE-marked goods on the GB market without additional UKCA assessment. Some product areas sit outside the recognition and require UKCA. These include certain sectors with distinct UK regimes, and businesses should check the current UK guidance for their product category rather than assuming coverage. Medical devices have followed their own transitional timelines, and construction products have had a separate, evolving story with the UKCA and CE recognition arrangements changing over time. Northern Ireland is different again. Under the Windsor Framework arrangements, goods placed on the Northern Ireland market follow EU product rules with CE marking, and where a UK approved body was used, the UKNI indication accompanies the CE marking. Goods moving from Great Britain to Northern Ireland must meet the Northern Ireland requirements. This creates three practical regimes for the UK: Great Britain, Northern Ireland and the EU, each with its own marking logic. ## Approved bodies and conformity assessment The UK system mirrors the EU's conformity assessment modules. Where the legislation allows self-declaration, the manufacturer assesses conformity against the UK statutory instrument, draws up the UK Declaration of Conformity and affixes the UKCA marking. Where third-party assessment is required, a UK approved body must perform it: EU notified bodies cannot issue UKCA certifications. Approved bodies are designated by the UK government and listed publicly. Many are the UK entities of the same groups that operate as notified bodies in the EU, but the legal entities and designations are separate. A manufacturer needing both CE and UKCA marks for a product requiring third-party assessment will typically engage both a notified body and an approved body, or a group offering both services, and hold two sets of certificates. The UK Declaration of Conformity mirrors the EU version: it identifies the product, the manufacturer, the applicable UK legislation, the standards applied and, where relevant, the approved body. It must be kept with the technical documentation for 10 years and made available to market surveillance authorities on request. ## Marking rules and importer duties The UKCA marking must be affixed visibly, legibly and indelibly to the product, or where that is not possible, to the packaging or accompanying documents. The mark must be at least 5 mm in height, preserving its proportions, and must not be confused with other marks. It should generally be affixed by the manufacturer before the product is placed on the market. Importers into Great Britain carry duties parallel to EU importer duties: verifying that the manufacturer carried out the conformity assessment, that the product bears the UKCA or recognised CE marking, that the declaration of conformity exists and that traceability information and instructions are present. The importer must add its name and address to the product, packaging or documents, and must not place non-compliant products on the market. Market surveillance in Great Britain is carried out by authorities such as Trading Standards and the Office for Product Safety and Standards, with powers to inspect, test, withdraw and recall products. Enforcement practice closely resembles the EU system from which it derives. | Topic | Great Britain | Northern Ireland | EU | |---|---|---|---| | Marking | UKCA or recognised CE | CE, with UKNI if UK body used | CE | | Third-party bodies | UK approved bodies | EU notified bodies | EU notified bodies | | Declaration | UK Declaration of Conformity | EU Declaration of Conformity | EU Declaration of Conformity | | Importer duties | UK importer verifies and labels | EU importer rules apply | EU importer rules apply | | Market surveillance | UK authorities | UK authorities applying EU rules | EU member state authorities | ## Practical strategy for businesses For most companies, the efficient strategy is to maintain CE marking as the primary route for the GB market in the recognised sectors, since the same assessment serves the EU. This avoids duplicating testing and documentation. UKCA becomes relevant where the business wants a domestic-only compliance path, where customers or contracts specifically require it, or for product areas outside CE recognition. Where third-party assessment is needed for both markets, coordinate the two assessments: use the same test data, align the technical documentation and manage certificate timelines together. Keep the UK Declaration of Conformity alongside the EU version in the technical file, and ensure importer entities are correctly identified for each market, since the GB importer and the EU importer may be different companies. Track the guidance. The UK product safety framework continues to evolve, with consultations on reform and sector-specific changes. The indefinite CE recognition is a policy decision that businesses rely on, so monitoring official announcements remains prudent, particularly for construction products and medical devices where the arrangements have been most fluid. ## Frequently asked questions Can I still use CE marking for Great Britain? Yes, for the product regulations covered by indefinite CE recognition, which include most consumer and industrial product areas. Check the current UK guidance for your specific regulation to confirm coverage. Do I need UKCA marking as well as CE marking? Not generally for the recognised sectors; one marking suffices where the recognition applies. Some businesses apply both for commercial reasons, and some product areas outside recognition require UKCA. Can my EU notified body certify for UKCA? No. UKCA third-party assessment must be performed by a UK approved body. The notified body and the approved body may belong to the same corporate group, but the designations are legally distinct. What are the rules for Northern Ireland? Goods placed on the Northern Ireland market need CE marking under EU rules. If conformity assessment was done by a UK approved body, the UKNI indication must accompany the CE marking. Goods qualifying for unfettered access from Northern Ireland to Great Britain follow separate provisions. How big must the UKCA marking be? At least 5 mm high, with proportions preserved, affixed visibly, legibly and indelibly. The same dimensional logic as the CE marking applies. What documentation must I keep? The technical documentation and the UK Declaration of Conformity for 10 years after the product is placed on the market, available to UK market surveillance authorities on request. Importers must be able to produce the declaration and ensure the file is accessible. ## Sources - Using the UKCA marking (UK government guidance) - Placing manufactured goods on the market in Great Britain - EU market surveillance framework