UKCA Marking for Great Britain
The UKCA marking (UK Conformity Assessed) is a product marking used since the United Kingdom left the European Union. It applies to certain products placed on the market in Great Britain (England, Wales, and Scotland) and shows that a product meets the requirements that apply in that market. For most product areas, Great Britain also continues to recognize the CE marking without an end date, so manufacturers can choose between the two.
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Why the UKCA marking was introduced
The UK introduced the UKCA marking as a result of Brexit to replace the CE marking previously used in Great Britain. Businesses have been able to use it since January 1, 2021. Under the original plan, the UKCA marking would have become mandatory after December 31, 2022, but the government extended the deadline several times to give companies more time to switch.
Which products need UKCA marking
The UKCA marking applies to most products that previously needed CE marking. These include products in the following areas:
- electromagnetic compatibility
- measuring instruments
- equipment for potentially explosive atmospheres (UKEX)
- radio equipment
- pressure equipment
- machinery
- low voltage electrical equipment
Specific rules apply, among others, to:
- medical devices
- marine equipment
- rail products
Special rules also apply to certain product categories and in particular to Northern Ireland.
UKCA and CE marking
The most significant development for the UKCA marking is the continued recognition of the CE marking in Great Britain. The UK government has legislated to continue recognizing current EU requirements, including the CE marking, indefinitely.
As a result, companies can use either the UKCA or the CE marking to sell products in Great Britain. This applies to 21 product regulations. Eighteen of them are managed by the Department for Business and Trade (DBT). The other three cover ecodesign, civil explosives, and, in most cases, the restriction of hazardous substances in electrical and electronic equipment (RoHS).
Rules for using UKCA and CE marking
The UK government has introduced several arrangements to make the move to UKCA marking easier:
- Indefinite recognition of the CE marking: Companies can continue to sell CE-marked products in Great Britain as long as they meet the EU requirements.
- Fast-track provision: A new provision allows manufacturers to place products on the British market if they meet the EU essential requirements. Where required, the products must have been assessed by a conformity assessment body recognized by the EU. To use this provision, manufacturers must affix the UKCA marking and issue a UK declaration of conformity that lists the relevant EU legislation they comply with.
- Mixed conformity assessment: For products covered by several regulations, manufacturers can combine UKCA and CE conformity assessment procedures.
How UKCA marking works
UKCA marking uses conformity assessment procedures similar to those for CE marking. Depending on the product and its risks, these can include:
- self-assessment by the manufacturer
- assessment by a third-party body; in the EU this is a notified body, in Great Britain an “approved body”
- testing of product samples
- quality assurance systems
The fast-track provision also lets manufacturers use EU conformity assessments for the UKCA marking, which simplifies the process for many companies.
Assessment
The introduction and development of the UKCA marking reflect the complex challenges Brexit created for trade and product regulation.
The UK government has taken an increasingly pragmatic approach. It extended the transition periods and finally introduced the indefinite recognition of the CE marking. This shows an awareness of the practical difficulties companies face.
Being able to use either the UKCA or the CE marking gives companies flexibility. In the long term, however, regulatory divergence between Great Britain and the EU could create new challenges.
The UKCA marking has undoubtedly caused additional costs and administrative burden for companies. The recent changes aim to minimize them without giving up the UK's sovereignty over product regulation.
The continued recognition of the CE marking can be read as a positive signal for close trade relations with the EU. At the same time, the UKCA marking allows Great Britain to take its own path in product regulation where it wants to.
What this means for manufacturers
The UKCA marking marks a significant change in product regulation in Great Britain. It reflects the changed trade relationship between Great Britain and the EU and the regulatory challenges that Brexit brings.
The recent developments, especially the indefinite recognition of the CE marking alongside the UKCA marking, point to a balancing act. Great Britain wants to keep its regulatory autonomy but also avoid unnecessary barriers to trade.
For companies, this means more flexibility, but also a need to follow developments closely. Being able to use both markings makes market access easier in both Great Britain and the EU.
It remains to be seen whether and how British requirements will diverge from those of the EU. The UKCA marking gives Great Britain the option to go its own way in regulation. For now, the continued recognition of the CE marking keeps it closely aligned with EU requirements. Companies, consumers, and regulators should therefore watch how the UKCA marking and its relationship to the CE marking develop. This will have a significant effect on trade between Great Britain and the EU.