UKCA marking
Following the United Kingdom's exit from the European Union, a new conformity marking for goods has been introduced in Great Britain: the "UKCA" or "UK Conformity Assessed". This guide describes the new requirements in this area.
What changes does a European exporter face?
All economic operators placing goods on the market in Great Britain (i.e. England, Wales and Scotland) can now choose between using either the CE mark or the UKCA mark, or both simultaneously, to certify the conformity of their goods to British technical requirements. However, the UKCA marking cannot be used for Northern Ireland, which still uses the CE marking valid for all EU countries, and its own marking, the UKNI, showing that a UK-based notified body has approved the goods.
While it was originally decided that only the UKCA marking would be accepted from January 2025, the UK government recently announced that the CE marking would be accepted indefinitely for a wide range of products. The list is as follows:
- Toys
- Pyrotechnics
- Pleasure craft and personal watercraft
- Simple pressure vessels
- Electromagnetic compatibility
- Non-automatic weighing instruments
- Measuring instruments
- Measuring vessel bottles
- Lifts
- Equipment for potentially explosive atmospheres
- Radio equipment
- Pressurised equipment
- Personal protective equipment
- Gas appliances
- Machinery
- Equipment for outdoor use
- Aerosols
- Low-voltage electrical equipment
For these 18 product categories, you can choose between the CE or UKCA marking. For other categories of goods, only the UKCA marking will be accepted in 2025.
Please note that in order to benefit from this marking, it will be necessary to have your product's conformity to the UK market approved by a UK Market Conformity Assessment Body, rather than by a European Union body. You can find all of the UK's accredited organisations at https://find-a-conformity-assessment-body.service.gov.uk/.
Useful information
A product is said to be placed on the UK market when it is first made available to that market for distribution, consumption or use as part of a commercial activity. This does not necessarily imply the physical presence of the product on British territory, but may result from an agreement between the two parties to transfer ownership, possession or any other right concerning the product from one party to the other.
The following documents can serve as proof that the product has been placed on the new market:
- sales contracts for the goods in question
- invoices
- shipping documents for the goods concerned
Where should the UKCA marking be placed?
Until 31 December 2027, the marking can be printed on a sticker directly on the product or on a document accompanying it. The document should reach the end user of the item in question. This means that one document per individual package will be required, unless the product is delivered as a batch. There is no regulation to specify what form this document should take. From 1 January 2028, it will be compulsory in most cases to place the UKCA marking on the product itself or on the packaging.
The marking must be clearly visible, legible and indelible when affixed to the product. Rules have also been laid down regarding its size and dimensions.
As mentioned above, the CE and UKCA markings can be placed jointly on the same article, provided that the rules applicable in both territories are complied with and that both markings are clearly legible.
Please note that specific rules apply to the following categories of goods:
- Medical devices
- Railway products
- Construction products
- Marine equipment
- Cableway installations
- Transportable pressure equipment
- Automatic Aircraft Systems
To check which rules apply to your property, and for further details about placing the UKCA mark, please visit the UK government website.
Who is responsible for the marking?
In the United Kingdom, this is the manufacturer, your authorised representative or yourself if you market the products under your company name or brand.
When you use the UKCA mark, you undertake full responsibility for the conformity of your products to the requirements of UK legislation.
Please note that documents attesting to the conformity of products marked "UKCA" or "CE" must be written in or translated into English.
Further information can be found on the UK government's UKCA marking page.
What about importing into the EU?
Since 1 January 2021, declarations of conformity issued by UK authorities for products imported into the EU are no longer considered to be valid. This means that any goods requiring authorisation must be authorised by an EU notified body before they can circulate within the single market.
The UKCA mark is therefore not recognised within the European Union.
All EU notified bodies can be found on the NANDO database.
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