The UK Conformity Assessed (UKCA) marking is the UK's post-Brexit product certification framework. Mandatory for most goods in Great Britain (England, Scotland, Wales), it signifies compliance with UK safety, health, and environmental regulations. Recent legislation has transformed the compliance landscape: CE marking is now recognized indefinitely alongside UKCA for 21 product categories under The Product Safety and Metrology, etc. (Amendment) Regulations 2024. Businesses can choose either marking for GB market access, though critical exceptions exist for medical devices, construction products, and other regulated sectors. This guide demystifies evolving requirements and strategic pathways.
UKCA applies to 18 core categories (e.g., machinery, PPE, electronics), with CE marking now permanently accepted for 21 regulations through 2024 legislative changes:
Department for Business and Trade (DBT) Regulations (18):
Equipment for Use in Potentially Explosive Atmospheres Regulations 2016/1107
Electromagnetic Compatibility Regulations 2016/1091
Lifts Regulations 2016/1093
Electrical Equipment (Safety) Regulations 2016/1101
Pressure Equipment (Safety) Regulations 2016/1105
Pyrotechnic Articles (Safety) Regulations 2015/1553
Recreational Craft Regulations 2017/737
Radio Equipment Regulations 2017/1206
Simple Pressure Vessels (Safety) Regulations 2016/1092
Toys (Safety) Regulations 2011/1881
Aerosol Dispensers Regulations 2009/2824
Gas Appliances (EU Regulation) 2016/426
Supply of Machinery (Safety) Regulations 2008/1597
Noise Emission in the Environment by Equipment for Use Outdoors Regulations 2001/1701
Personal Protective Equipment (EU Regulation) 2016/425
Measuring Instruments Regulations 2016/1153
Non-automatic Weighing Instruments Regulations 2016/1152
Measuring Container Bottles Regulations 1977
Additional Regulations (3):
Restriction of Hazardous Substances (RoHS) in Electrical Equipment (Defra)
Ecodesign for Energy-Related Products (DESNZ)
Explosives Regulations 2014 (DWP/HSE)
Excluded Sectors (Require UKCA):
Medical devices
Construction products
Marine equipment
Rail products
Cableways
Transportable pressure equipment
Unmanned aircraft systems
Table: UK Legislation vs. EU Directives
| EU Directive | UK Legislation | CE/UKCA Status |
|---|---|---|
| ATEX 2014/34/EU | Equipment for Explosive Atmospheres Regs 2016 | CE accepted indefinitely |
| Machinery Directive | Supply of Machinery (Safety) Regs 2008 | Dual marking allowed |
| Construction Products Regulation | Construction Products Regs 2020 | UKCA mandatory from 2025 |
Great Britain: UKCA or CE accepted indefinitely for 21 regulations
Northern Ireland: Requires CE or UK(NI) marking
EU: CE marking only
Technical Standards: UKCA uses UK Designated Standards (initially mirroring EU standards).
Conformity Assessment Bodies:
UKCA requires UK Approved Bodies
CE uses EU Notified Bodies
A 2024 provision allows accelerated UKCA certification using existing EU compliance:
Products meeting EU essential requirements
Conformity assessed by EU-recognized bodies
Manufacturers affix UKCA marking
UK Declaration of Conformity lists EU legislation
Key Benefit: Avoids duplicate testing for GB market access
For products under multiple regulations:
Mix UKCA and CE procedures
Example: PPE (UKCA) + electronics (CE) in one product
Table: Market Access Requirements
| Market | Accepted Markings | Key Conditions |
|---|---|---|
| Great Britain | UKCA or CE | Indefinite for 21 regulations |
| Northern Ireland | CE or CE + UK(NI) | Windsor Framework rules |
| European Union | CE only | EU notified body required |
Self-Declaration: Low-risk products (e.g., Category I PPE)
Third-Party Assessment: High-risk products via UK Approved Bodies
Fast-Track Option: Leverage EU compliance for UKCA
Identify applicable UK/EU regulations
Verify technical requirements against UK standards
Conduct product testing (UKCA or EU-recognized)
Compile technical documentation
Draft UK Declaration of Conformity
Affix UKCA marking
Must include:
Manufacturer’s details
Product identification
List of UK/EU regulations
Approved Body details
New legislation enables:
UKCA on adhesive labels or accompanying documents
Importer details on product, packaging, or label
Digital labeling for UKCA/manufacturer/importer info
Must be stored for 10 years
Include EU test reports for fast-track UKCA
July 1, 2025: UKCA mandatory for construction products
December 31, 2027: Expiry of transitional labeling measures
Indefinite: CE acceptance for 21 regulations
Market Surveillance: Random checks by UK authorities
Penalties: Fines up to £20,000 per violation, product recalls
Fast-Track Advantage: Use EU compliance for UKCA certification
Digital Labeling: Reduce physical labeling costs
Hybrid Documentation: Single technical file for UKCA/CE
UK(NI) Mark: Required for GB-NI trade under Windsor Framework
Additional statutory instrument for:
Permanent digital labeling rules
Expanded importer detail flexibility
Sector-specific guidance
UKCA certification now offers unprecedented flexibility with CE coexistence. To capitalize:
Audit Products: Determine if covered under 21 CE-recognized regulations
Prioritize Exceptions: Medical/construction sectors require urgent UKCA action
Implement Fast-Track: Leverage EU compliance for UKCA certification
Adopt Digital Labeling: Prepare for 2024 regulatory updates
Pro Tip: Use the UK’s Designated Standards Repository to track real-time regulatory shifts.
Businesses that strategically integrate these changes will minimize compliance costs while maximizing market access across GB, NI, and EU markets.
Key Resources