UKCA vs CE Marking: What Manufacturers Need to Know

Before the UK left the European Union, the CE mark was the single conformity mark for products sold across the entire European Economic Area. Post-Brexit, the UK introduced the UKCA (UK Conformity Assessed) mark for products placed on the Great Britain market (England, Scotland, and Wales). Northern Ireland follows separate rules under the Windsor Framework and continues to accept CE-marked goods. Products sold in both GB and the EU need both marks.

UKCA marking is required for most products that previously needed CE marking when they are placed on the GB market. This includes electrical and electronic equipment falling under the Low Voltage Directive (LVD), EMC Directive, and RoHS regulations. The UK government has extended the recognition of CE marking for certain product categories, but manufacturers should not rely on indefinite acceptance. Building UKCA compliance into your product development process now avoids last-minute scrambles when recognition periods end.

While the technical requirements are largely identical (both reference the same harmonised standards in most cases), there are important procedural differences: • Conformity assessment — for products requiring third-party assessment, a UK Approved Body must be used for UKCA (not an EU Notified Body). • Declaration of Conformity — separate declarations are required for UKCA and CE. They cannot be combined into a single document. • Marking placement — the UKCA mark must be placed on the product or its packaging. It cannot be placed on a label where it could easily be removed. • Importer requirements — if you are placing UKCA-marked goods on the GB market as an importer, your name and address must appear on the product or documentation.

1. Identify which regulations apply to your product in both the UK and EU markets. 2. Check whether self-declaration is sufficient or whether third-party assessment is required. 3. Appoint a UK Approved Body if needed (or maintain your existing EU Notified Body for CE). 4. Prepare separate Declarations of Conformity for each mark. 5. Ensure your product labelling accommodates both marks if you sell into both markets. 6. Keep technical files up to date and accessible — UK market surveillance authorities can request these at any time.