UKCA marking

UKCA applies to Great Britain: England, Scotland and Wales. Northern Ireland continues to follow EU rules under the Windsor Framework, uses CE marking, and has the UKNI mark for cases where a UK body carried out the assessment.

A manufacturer treating "the UK" as one destination will eventually ship the wrong mark to one half of it. Where a product goes to both, the working answer is CE for everything, with UKCA added only for a category where Great Britain has not extended CE recognition.

Fewer than the 2021 announcements suggested. In August 2023 the Department for Business and Trade announced that CE marking would be recognised indefinitely for the product regulations it owns, and the Product Safety and Metrology (Amendment) Regulations 2024 wrote that into law. The list covers toys, electrical equipment under the Electrical Equipment (Safety) Regulations 2016, electromagnetic compatibility, radio equipment, machinery, pressure equipment, simple pressure vessels, equipment for explosive atmospheres, personal protective equipment, gas appliances, lifts, measuring and weighing instruments, RoHS, aerosols, outdoor noise, recreational craft and pyrotechnics. For those categories a valid CE marking can still be placed on the Great Britain market.

Outside that list each regulator sets its own timetable. Medical devices sit with the MHRA under the Medical Devices Regulations 2002 and have their own transition dates. Construction products under the retained Construction Products Regulation belong to a different department and are being reformed separately. Marine equipment and several transport-regulated categories are outside the DBT list as well. For any of those, check the regulator's current position before deciding to skip UKCA.

Less than the paperwork suggests, and there is no UKCA certification as such: like CE, it is a declaration you sign, with a UK approved body involved only where the regulation names third-party assessment. The 2019 Regulations amended the domestic regulations that had transposed the EU directives, among them the Electrical Equipment (Safety) Regulations 2016, the Electromagnetic Compatibility Regulations 2016, the Radio Equipment Regulations 2017 and the Supply of Machinery (Safety) Regulations 2008, and left the essential requirements untouched. The same test evidence supports both. What differs is the legal furniture: a UK Declaration of Conformity instead of an EU one, UK approved bodies instead of notified bodies, and designated standards instead of harmonised standards.

The two sets of standards have not diverged much so far, but they are separate lists maintained separately, and the Product Regulation and Metrology Act 2025 gives ministers the power to follow or depart from EU rules by regulation. One divergence already exists. Connected consumer devices in Great Britain fall under the Product Security and Telecommunications Infrastructure regime, in force since 29 April 2024, while the EU applies the RED cybersecurity delegated regulation from 1 August 2025; the two ask for different documents. Record which designated standard edition you applied, with its date.

A manufacturer outside the United Kingdom needs an importer or authorised representative established in the UK, named in the documentation and able to produce the declaration and technical file on request. This mirrors the EU arrangement and, like it, is a legal appointment that carries duties toward the Office for Product Safety and Standards and local Trading Standards.

An EU-based authorised representative does not cover Great Britain. The two appointments are separate.

Recognition of CE marking in Great Britain is set per product regulation. Confirm the position for your category before deciding to skip UKCA, and go to the regulator itself when the product is a medical device or a construction product.