The UK has left the EU, and the transition period after Brexit comes to an end this year.
The UKCA (UK Conformity Assessed) marking is a new UK product marking that will be used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods which previously required the CE marking.
How UKCA marking will be applied?
Beginning on January 1st, 2021, manufacturers can start applying the UKCA Mark to their products, if their products are already CE marked or if it meets the requirements of applicable EU standards.
If the product is not already CE Marked, testing would need to be conducted to the EN standards so that the CE and/or UKCA mark can be applied to the product.
Manufacturers can supply a UKCA Declaration of Conformity beginning on January 1st, 2021. However, for most cases, it will not be mandatory until the end of the implementation period (January 1st, 2021 and January 1st, 2022).
How to sell goods in Great Britain?
The UKCA marking will apply to most goods currently subject to the CE marking.
From 1 January 2021 the technical requirements you must meet, and the conformity assessment processes and standards that can be used to demonstrate conformity, will be mostly the same as they are now.
The UKCA marking can be used from 1 January 2021. However, to allow businesses time to adjust to the new requirements, you will still be able to use the CE marking until 1 January 2022 in most cases.
In some cases you will need to apply the new UKCA marking to goods being sold in Great Britain immediately from 1 January 2021. You are encouraged to be ready to use the UKCA marking as soon as possible before this date.
The CE marking will only be valid in Great Britain for areas where GB and EU rules remain the same. If the EU changes its rules and you CE mark your product on the basis of those new rules you will not be able to use the CE marking to sell in Great Britain even before 31 December 2021.
What are the Declaration of Conformity Requirements for the United Kingdom?
CE Mark and EU Declaration of Conformity are still valid until the CE mark is no longer accepted in the UK (date unknown at this point).
Largely like an EU Declaration of Conformity.
Has the same content as an EU Declaration of Conformity, but no reference to the EU Directives (only lists the standards).
UKCA mark is only accepted in the UK Market. It is not valid in the EU.
UK is still using standards that are also acceptable for CE compliance, for now.
Please note that all information is subject to change as the UK and EU continue to make Brexit transition adjustments.
For further details, check this guidance published by UK government: Using the UKCA mark from 1 January 2021 (Guidance)
What are the differences between CE marking and UKCA marking?
Both marking are similar but there are some differences. We are listing these differences here:
UKCA marking uses the word ‘regulations’ while CE marking uses ‘directives’ instead of regulations. UKCA marking uses ‘designated standards‘ while CE marking ‘ harmonised standards’. Technically they are same but you have to be familiar if you would like to use both UKCA mark and CE mark on your products.
UKCA mark is only valid for UK, except Northern Ireland. Due to agreement between UK and European Union, in Northern Ireland CE marking or UKNI marking is used.
CE marking is valid in EU countries (Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden) and non-EU countries like Iceland, Liechtenstein, Norway, Switzerland and Turkey, following EU regulations.
UK started to use its own regulations instead of EU directives. Three of these regulations are shown on this table with its EU equivalences:
|UKCA marking regulation||CE marking directive|
|S.I. 2016/1091 EMC Regulations 2016||2014/30/EU EMC Directive|
|S.I. 2017/1206 Radio Equipments Regulations 2017||2014/53/EU Radio Equipment Directive (RED)|
|S.I. 2016/1101 Electrical Equipment (Safety) Regulations 2016||2014/35/EU Low Voltage Directive (LVD)|
Even though names of UKCA marking regulations differs from CE marking directives, they are using similar or same standards. UKCA marking uses its own ‘designated standards’ and CE marking uses its ‘harmonised standards’ to fulfil requirements of the listed regulation/directive.
For UKCA marking, UK government is the whole authority. There are two UK governmental office dealing with UKCA marking: Office for Product Safety and Standards, and Department for Business, Energy & Industrial Strategy. For CE marking, European Commission of EU is the authority publishing directives and harmonised standards. Each member country of EU is adapting these directives and standards into their national legislation.
Is self-declaration of conformity for UKCA marking applicable?
Yes self-declaration is applicable for the regulations listed: Electromagnetic Compatibility Regulations 2016, Toy (Safety) Regulations 2011, The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012, Medical Devices Regulations 2002 , Radio Equipment Regulations 2017, The Pressure Equipment (Safety) Regulations 2016, Construction Products Regulations (Regulation (EU) 305/2011 as brought into UK law and amended), Recreational Craft Regulations 2017, The Electrical Equipment (Safety) Regulations 2016, The Supply of Machinery (Safety) Regulations 2008, The Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres Regulations 2016 and Personal Protective Equipment Regulations (Regulation (EU) 2016/425 as brought into UK law and amended). Scope of products which can be self-declared are also shown on the same list.
What are designated standards for UKCA marking?
Designated standards are lists of standards that businesses can use to show their products, services or processes comply with essential requirements of UKCA marking legislation. Designated standards are prefixed “BS”, “EN”, “EN ISO” or “EN IEC”. Designated standards are grouped as nine main fields:
2. Conformity assessment and management systems
4. Consumers and workers protection
5. Energy efficiency
6. Electric and electronic engineering
7. Healthcare engineering
8. Measuring technology
9. Mechanical engineering and means of transport
Each field has specific designated standards. Under Electric and electronic engineering, there are four types of regulations and their designated standards:
- Electromagnetic compatibility (EMC)
- Low voltage equipment (LV)
- Radio equipment (RE)
- Restriction of the use of certain hazardous substances (RoHS)
Designated standards published by UK are mostly based on IEC, CEN, CENELEC and ETSI standards. Thus, designated standard of a UKCA marking regulation are mostly same standard as published by European Commission of EU. For instance, when you check recent notice of publication related to S.I. 2016/1091 EMC Regulations 2016 , you will see that most of the EMC standards, like EN 55032, EN 55035, EN 55014-1, EN 55014-2 and ETSI EN 301 489-1, published by EC, also exist on this list. To follow up recent designated standards for UKCA marking, you have to regularly visit https://www.gov.uk/guidance/designated-standards
Recent designated standards for EMC, LV, RE and RoHS can be reached from the links below:
Do you need any testing or certification service for UKCA marking of your product?
We are offering EMC, Electrical Safety, Radio Equipment, Medical and Automotive testing and certification services with accredited partner laboratories. Let us certify your products. Then affix UKCA mark and sell them within UK.