A Detailed Guide to UKCA Marking Compliance

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.

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.

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:

• The UKCA mark replaces the CE mark
• Minor differences to the Declaration of Conformity
• Technical files and other documentation must be in English when supplied
• Notified Body roles are performed by UK Conformity Assessment Bodies issuing certificates valid only in the UK. However valid EU certificates issued before 31/12/2024 may be used for UKCA marking until 31/12/2027).
• Designated Standards, designated by the UK government, replace EU Harmonised standards.

Most requirements of CE marking remain the same for UKCA Marking, at least during the transition period, including:

• Essential requirements describing technical characteristics and levels of protection products must meet.
• Standards used to demonstrate conformity with essential
• The Conformity Assessment Procedures describing technical documentation and Conformity Assessment Body involvement

There are some minor differences for medical devices, rail interoperability, construction products and civil explosives.

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.

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.

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.

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.

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.

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.

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.

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:

• a technical description of the product(s)
• a list of legislation complied with and standards applied
• checklists, test reports, etc. demonstrating compliance with the legislation and standards
• certification details
• quality control procedures to ensure conformity of production
• traceability and product recall procedures
• copies of markings and instructions
• the UK declaration of conformity

The only differences are:

• The UK declaration of conformity
• references to legislation should be to UKCA regulations rather than EU legislation.
• UK authorities are likely to require technical documentation in English. EU legislation allows any EU language

Otherwise there is no difference to the content of technical files for CE and UKCA marking

You can read more about Technical Documentation here

The manufacturer must draw up a UK Declaration of Conformity for most UKCA marked products. Exceptions are:

• construction products that have a Declaration of Performance
• Partly Completed Machinery (unfinished sub-assemblies) supplied with a Machinery Declaration of Incorporation.

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 title is Declaration of Conformity rather than EU Declaration of Conformity.
• The relevant UK legislation must be listed rather than EU legislation.
• standards lists should refer to designated standards rather than EU harmonised standards, although the lists are likely to remain very similar for the foreseeable future. 

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.

UKGovguidance on using UKCA marking

Placing manufactured goods on the market in Great Britain from 1 January 2021

Placing manufactured goods on the EU market

Product safety for businesses: A to Z of industry guidance

Electrical Equipment Safety Regulations 2016

Consumer goods sector: end of transition period guidance

Brexit transition: new rules for 2021