Your guide to UKCA certification and CE markings in GB

Table of Contents

UKCA (UK Conformity Assessed) is a new UK product marking that is now used for goods in Great Britain (England, Wales and Scotland). The new mark covers most goods that were previously marked under the European Union’s CE mark.

For businesses looking to trade with the European Union, the UKCA marking will not be accepted for products placed on the European or Northern Ireland markets. For the products that continue to remain on the market in Europe and Northern Ireland, a CE marking will still be required.

There is a wide range of information and legislative literature available on the new markings that can affect products such as aerosols, gas appliances, eco-design, electromagnetic compatibility machinery and ATEX.

What are the requirements for UKCA markings?

The UKCA essential/technical requirements alongside conformity assessment processes and standards are required. However, the above assessments are largely the same as they were for the CE marking.

The circumstances in which a business may use the self-declaration of conformity for the new markings are also the same as for the European Union’s CE markings.

Are the CE and UKCA markings similar?

If your business could self-declare conformity for the CE marking, it’s possible to continue your current CE processes under the new markings. Therefore, assessments, certification requirements, quality data and correct documentation for CE markings may form the basis for your UKCA certification.

Although some amendments may be required to correctly comply with updated markings, it must be remembered that all legislation must be adhered to.

What’s the timeline?

The UKCA marking came into effect on the 1st  of January 2021.  However, as seen with other EU-UK product and safety legislation during this transition period, there is a grace period to allow businesses time to adjust to these new requirements. An example of this is the Annex II of the REACH Safety Data Sheet update. As a result, current CE markings will be valid for a large majority of products in British markets until the 1st of January 2022.

Although CE markings can still be used for products destined for Great Britain until January 1st 2022, it’s advised that businesses require the UKCA marking as soon as possible. No CE-marked product may be placed in the UK market after the above deadline.

Ultimately, after January 1st 2022, all products placed in the UK market must be approved and a UK Declaration of Conformity must be achieved for these products.

Who can provide the UKCA mark?

Only UK approved bodies that are situated in the UK may conduct required assessments and provide the new certification.

For businesses that trade between the UK and the EU, both UKCA and CE markings should be used simultaneously. It must be noted that only the UKCA marking will confirm compliance with relevant UK legislation, while the CE marking will demonstrate EU compliance. The CE certification must therefore be assessed and certified by an EU notified Body.

The UK Declaration of Conformity

The requirements for the UK Declaration of Conformity are similar to the requirements of the EU Declaration of Conformity. After confirming that your products may carry the UKCA marking, it may be placed on the product, its packaging, product literature, or on areas that are allowed under the legislation.

After 1 January 2021, you must use the new marking immediately if all of the following apply:

  • The product is covered by legislation that requires the marking
  • The product requires a mandatory third-party conformity assessment
  • A conformity assessment has been carried out by a UK based Notified Body and you haven’t transferred your conformity assessment files from your UK body to an EU-27 recognized Notified Body before 1 January 2021

Up until 1 January 2022, under the transition arrangements, you will be able to continue to use the CE marking in the United Kingdom if:

  • You currently apply the CE marking to your product based on self-declaration
  • A mandatory third-party conformity assessment was carried out by an EU-27-recognised Notified Body
  • The EU-Type Examination certificate previously held by a UK Notified Body has been transferred to an EU-27 recognized Notified Body

Understanding UKCA EX

As the UK transitions from CE to UKCA markings, UK Conformity Assessed announced that a UKCA ‘EX’ scheme will now replace ATEX in Great Britain.

As a result, only  ‘EX’ certificates will comply with this legislation from the 1st of January 2022.

This new legislation applies to all products that previously required ATEX certifications in the UK.

ATEX products will only be accepted in Great Britain if they comply with UKCA ‘EX’ legislation.

Much like UKCA products in general, only UK approved bodies will be able to issue appropriate certifications.

There is a grace period in place to allow businesses time to adjust to the new ‘EX’ scheme requirements and, as with UKCA products, this legislation will not apply to the Northern Irish market.

As the UK transitions from CE to UKCA markings, UK Conformity Assessed announced that a UKCA ‘EX’ scheme will now replace ATEX in Great Britain.

As a result, only UKCA issued ‘EX’ certificates will comply with this legislation from the 1st of January 2022.

This new legislation applies to all products that previously required ATEX certifications in the UK.

ATEX products will only be accepted in Great Britain if they comply with UKCA ‘EX’ legislation.

Much like UKCA products in general, only UK approved bodies will be able to issue appropriate certifications.

There is a grace period in place to allow businesses time to adjust to the new ‘EX’ scheme requirements and, as with UKCA products, this legislation will not apply to the Northern Irish market.

Further Reading

Sigma-HSE White Paper: EU Commission Regulation 2020.878

Check the list of areas where self-declaration is permitted.

Using the UKCA marking

BEIS provide further detail on the transition from CE markings to UKCA

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