STOP PRESS – 1 AUGUST 2023
Acceptance of CE marking extended indefinitely
On 1 August the UK government announced that recognition of the CE marking for placing most goods on the market in Great Britain, will be extended indefinitely. This applies to the 18 regulations that fall under the Department for Business and Trade (DBT) such as electrical apparatus, machinery, gas appliances, PPE, pressure equipment and measuring instruments. Other product sectors such as construction products and medical devices are expected to follow soon.
Below are some common questions regarding UKCA marking for products in the UK.
What is the UKCA mark?
The UKCA (UK Conformity Assessed) marking is the UK’s replacement for the CE marking.
The UKCA marking legislation is The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019, which retained and amended 35 pieces of the existing EU product legislation to regulate the UK market rather than the EU single market.
The UKCA mark will also replace the EU epsilon mark on aerosol products.
Other single market legislation is undergoing similar conversions with Transportable Pressure Equipment changing from the EU Pi mark to the Rho mark and Marine Equipment changing from the EU Ships Wheel mark to the UK flag mark.
When does UKCA marking start?
UKCA marking has been available since Single Market Exit Day on 1 January 2021. During the transition period until 31st December 2024 UKCA marking is voluntary and CE marking is still accepted for most products. It becomes mandatory in Great Britain on 1 January 2025.
What is different about UKCA marking?
The UK has retained the principles of EU product legislation and only changed the system as much as is necessary to adapt it to the GB market. The main differences are:
What stays the same for CE and UKCA marking?
Most requirements of CE marking remain the same for UKCA Marking, at least during the transition period, including:
Can UK conformity assessment bodies certify CE marked products?
No. UK Notified Bodies lost their Notified status on exit day and automatically became UK Conformity Assessment Bodies (UKCABs) involved in UKCA marking products for the GB market. Their certificates for mandatory conformity assessment can only be used for UKCA marking, and not for CE marking.
Manufacturers supplying the EU single market had an opportunity to transfer their certificates to an EU27 Notified Body before Exit Day. Since then, recertification has been required.
Can EU Notified Bodies certify UKCA marked products?
EU certificates issued before 31st December 2024 may be used for UKCA marking until their expiry date or until 31st December 2026, whichever is sooner.
Is the UKCA Marking required in Northern Ireland?
Northern Ireland is still a member of the single European market and requires the CE marking, not the UKCA marking.
Manufacturers established in Northern Ireland can place products on both the EU and UK markets without having to meet any importer obligations under product legislation, although customs formalities apply to products moving between Northern Ireland and Great Britain.
Authorised representatives established in Northern Ireland may represent products placed on both the EU and UK markets.
What is the UKNI marking?
The UKNI marking is applied after the CE marking to allow products placed on the NI market and subject to certification by a Conformity Assessment Body to use UKCAB certificates rather than EU Notified Body certificates. These UKNI marked products cannot the be imported into the EU without EU Notified Body assessment.
Does CE-marked stock need UKCA marking?
Products in stock are existing stocks of products that had been “made available” before 1 January 2021. Made available means they were fully manufactured and ready to be supplied to end users. They can continue through Great Britain and EU/EEA supply chains with a CE mark even if certified by a UK body.
What size, shape and colour does the UKCA marking need to be?
In general, the UKCA marking must be at least 5mm high. The shape must be in proportion and not distorted or stretched. The logo and background can be any colours as long as it is easily visible and legible.
What kind of labels do I need for the UKCA marking?
Until 31st December 2027, the UKCA logo can be applied to most products on a temporary label, packaging or on an accompanying document.
After that, the UKCA logo must be permanently applied like the CE marking, on a permanent label, plate or tag or by printing, etching, engraving directly onto the surface. It usually must be on the product itself unless it is too small or has no markable surface. The rules vary as to when the marking can be applied to the, the packaging or user documentation.
In most cases, the UKCA logo should appear alongside or in place of the CE marking and any other conformity markings.
Construction products, medical devices, rail system equipment and transportable pressure equipment do not benefit from these transitional measures.
What is in the Technical Documentation or Technical File required by UKCA marking?
Technical Documentation is required to describe products and demonstrate how they comply with the requirements of the applicable product legislation. It must be made available to the UK market surveillance authorities in English on request.
It must include:
What are the differences between CE and UKCA technical documentation
The only differences are:
Otherwise there is no difference to the content of technical files for CE and UKCA marking
You can read more about Technical Documentation here
How do I complete a UK Declaration of Conformity?
The manufacturer must draw up a UK Declaration of Conformity for most UKCA marked products. Exceptions are:
Declarations should be available to market surveillance authorities on request. Some product legislation requires the declaration to be supplied to the end user.
The UK Declaration of Conformity is similar to the EU Declaration of Conformity for CE marking
The information required on the Declaration of Conformity will be largely the same as required on an EU Declaration of Conformity except:
The British standard (BS) prefix is not required in standards references on EU declarations.
We have UKCA Marking Declaration of Conformity Templates for different directives available to purchase at our sister website Product Compliance Support.
We have Declaration of Conformity Templates for UKCA Marking for different directives available to purchase at our sister website Product Compliance Support.