UK • New Rules • New Perspectives

Ready for UKCA

Since January 1st, 2021, the CE mark is no longer officially valid in the United Kingdom. Completely surprisingly, on November 14, an extension of the deadline for the recognition of the CE mark in the UK to December 31, 2024 was announced. The transition period, which originally applied from 2021, was thus further extended.

Accordingly, the deadline for attaching the label to the product for industrial products has been extended to December 2026. First info here in the GOVUK link. This means that the CE mark may continue to be used without restrictions. Things will get serious now from 2025, when the new mark will be applied to the UK market. IMPORTANT: The recognition of the CE mark only applies if there is still a tie between the EU and UK standards. However, should the EU change something in its standards, these would immediately lose their validity in the UK. So the product would then actually be illegal on the market. Therefore, it is advisable to apply for UKCA certification immediately to avoid this risk. A distinction must be made as to whether the certification is carried out by a third party or as part of the self-certification. For more information contact us on request. The following explanations are to be understood from the point of view of a company that is based in the UK.

Here is our latest commentary about the current status for UKCA Marking https://bccg.de/das-quality-ticket-zum-britischen-markt/

The british government is introducing a 12-month extension to the implementation of the future Medical Device Regulations, with an aim to bring the new regulations into force by July 2024

The key to UKCA compliance

despite the extension of the deadline for affixing the mark to the product, UKCA compliance must at least be demonstrated in the documentation from 01 January 2023. Our guidelines provide information on who is allowed to submit and sign this declaration.

New deadline extension and simplifications

On June 20, the British government announced further relief. These relate to simplifications in the conformity procedures, the deadlines for labeling on the product, the certification of stocks and the labeling requirements for spare parts. We will publish the new details soon.

What are the current timings for the UKCA marking?

Until 31 December 2022

CE marked goods in the scope of this guidance that meet EU requirements (where these match UK requirements) can continue to be placed on the GB market until 31 December 2022. However, we strongly encourage all businesses to start using the UKCA marking as soon as possible.

From 1 January 2023

Businesses must use the UKCA marking in most cases from 1 January 2023 if your product:
is being placed on the market in Great Britain; and
is covered by legislation which requires the UKCA marking.

Until 31 December 2025

Businesses can attach the UKCA marking on an accompanying document or label attached to the products. There are different rules for medical devices, construction products, marine equipment, transportable pressure equipment and rail products.

From 1 January 2026

Businesses, in most cases will need to apply the UKCA marking directly on the product, unless specified otherwise by the legislation.

Important Notice: Extension of Grace Period until 2023

Businesses given more time to apply new product safety marking.

Government confirms businesses will have an extra year to start using the new product safety marking - the UKCA marking.

Businesses will have an extra year to start using the UKCA marking, the new product safety marking in the UK
this applies to all goods where businesses were due to begin using the UKCA marking by the end of this year (2021)
businesses will have more time to meet their legal obligations given the continued impact of the pandemic, providing clarity and certainty

Businesses will have an additional year to apply new product safety markings for most products placed on the market in England, Scotland and Wales, the government has announced today (24 August).  

The UK Conformity Assessed (UKCA) marking allows the UK to have control over its goods regulations, maintaining the high product safety standards expected in the UK.

Recognising the impact of the pandemic on businesses, the government will extend this deadline to 1 January 2023 to apply UKCA marks for certain products to demonstrate compliance with product safety regulations, rather than 1 January 2022.

The UKCA marking replaces the product safety labelling the UK previously used while a member of the EU, such as the CE mark.

Today’s announcement follows the government’s extensive and ongoing engagement with business groups and reflects the issues businesses have raised, particularly given the impact of the pandemic.   

Businesses must take action to ensure they are ready to apply UKCA marking by 1 January 2023, the final deadline.

The government will continue to engage with manufacturers to ensure they understand what they need to do to get ready, including through a new series of webinars. The Department for Business, Energy and Industrial Strategy has already run several webinars in the last few months and engaged extensively through trade associations.  

New version from 24.08.2021

Contents

The UKCA (UK Conformity Assessed) marking is a new UK product marking that is 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, known as ‘new approach’ goods.

The UKCA marking came into effect on 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 2023 in most cases.

The UKCA marking alone cannot be used for goods placed on the Northern Ireland market. See the guidance on placing goods on the Northern Ireland market.

This guidance explains how to use the UKCA marking. For further information on placing these goods on the market, see the guidance on placing manufactured goods on the market in Great Britain.

There is separate guidance for medical devices, rail interoperability, construction products and civil explosives.

Check whether you need to use the new UKCA marking

Selling goods in Great Britain

The UKCA marking applies to most goods previously subject to the CE marking. It also applies to aerosol products that previously required the ‘reverse epsilon’ marking.

The technical requirements (‘essential requirements’) you must meet – and the conformity assessment processes and standards that can be used to demonstrate conformity – are largely the same as they were for the CE marking.

The circumstances in which you can use self-declaration of conformity for UKCA marking are the same as for CE marking. If you were able to self-declare conformity for the CE marking, you will be able to do the same for the UKCA marking.

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

You must use the UKCA marking from 1 January 2023. You can still use the CE marking until then.

The CE marking is only 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 2022.

Check whether you will need to use the UKCA marking by reading the guidance on placing manufactured goods on the market in Great Britain.

There is separate guidance for medical devices, rail interoperability, construction products and civil explosives.

Selling goods in the EU

The UKCA marking is not recognised on the EU market. Products need a CE marking for sale in the EU. Find out how to use the CE marking.

When to use the UKCA marking

You only need to use the new UKCA marking before 1 January 2023 if all of the following apply. Your product:

is for the market in Great Britain
is covered by legislation which requires the UKCA marking
requires mandatory third-party conformity assessment
conformity assessment has been carried out by a UK conformity assessment body

This does not apply to existing stock, for example if your good was fully manufactured, CE marked and ready to place on the market before 1 January 2021. In these cases, your good can still be sold in Great Britain with a CE marking even if covered by a certificate of conformity issued by a UK body before 1 January 2021. These goods will need to be placed on the market before 31 December 2022.

How to use the UKCA marking

Placing the UKCA marking

In most cases, you must apply the UKCA marking to the product itself or to the packaging. In some cases, it may be placed on the manuals or on other supporting literature. This will vary depending on the specific regulations that apply to the product.

General rules

The UKCA marking must be clearly visible and legible when you affix it to the product. If this is not possible, you must attach it to the packaging (if any) or accompanying documents.

UKCA markings must only be placed on a product by you as the manufacturer or your authorised representative (where permitted in the relevant legislation).

When affixing the UKCA marking, you take full responsibility for your product’s conformity with the requirements of the relevant legislation.

You must only use the UKCA marking to demonstrate conformity with the relevant UK legislation.

You must not place any marking or sign that may misconstrue the meaning or form of the UKCA marking to third parties.

You must not attach other markings on the product which affect the visibility, legibility or meaning of the UKCA marking.

The UKCA marking cannot be placed on products unless there is a specific requirement to do so in the legislation.

A product may have additional markings and marks, as long as they:

fulfil a different function from that of the UKCA marking
are not likely to cause confusion with the UKCA marking
do not reduce the legibility and visibility of the UKCA marking

Rules for using the UKCA image

You must make sure that:

if you reduce or enlarge the size of your marking, the letters forming the UKCA marking must be in proportion to the version set out below
the UKCA marking is at least 5mm in height – unless a different minimum dimension is specified in the relevant legislation
the UKCA marking is easily visible, legible

The UKCA marking can take different forms (for example, the colour does not have to be solid), as long as it remains visible, legible and maintains the required proportions.

Download UKCA mark image files (fill) (ZIP, 818KB)
Download UKCA mark image files (outline) (ZIP, 2.03MB)

Technical documentation

Record keeping

You, or your authorised representative (where allowed for in the relevant legislation), must keep documentation to demonstrate that your product conforms with the regulatory requirements. This must be kept for up to 10 years after the product is placed on the market.

This information can be requested at any time by market surveillance or enforcement authorities to check that your product conforms with the statutory requirements.

The information you must keep will vary depending on the specific legislation relevant to your product. You must keep general records of:

how the product is designed and manufactured
how the product has been shown to conform to the relevant requirements
the addresses of the manufacturer and any storage facilities

You should keep the information in the form of a technical file which can be supplied if requested by a market surveillance authority.

UK Declaration of Conformity

The UK Declaration of Conformity is a document which must be drawn up for most products lawfully bearing a UKCA marking. We recommend that manufacturers have a separate UK Declaration of Conformity to their EU Declaration of Conformity.

In the document you as the manufacturer, or your authorised representative (where allowed for in the relevant legislation), should:

declare that the product is in conformity with the relevant statutory requirements applicable to the specific product
make sure the document has the name and address of the manufacturer (or your authorised representative) together with information about the product and the conformity assessment body (where relevant)

The UK Declaration of Conformity should be available to market surveillance authorities on request.

The information required on the Declaration of Conformity is largely the same as what was required on an EU Declaration of Conformity. This can vary depending on the application legislation but generally should include:

your name and full business address or that of your authorised representative
the product’s serial number, model or type identification
a statement, stating you take full responsibility for the product’s compliance
the details of the approved body which carried out the conformity assessment procedure (if applicable)
the relevant legislation with which the product complies
your name and signature
the date the declaration was issued
supplementary information (if applicable)

You will need to list:

relevant UK legislation (rather than EU legislation)(ODS, 5.08KB)
UK designated standardsrather than standards cited in the Official Journal of the European Union

More information

Product areas covered by the UKCA marking

Toy safety
Recreational craft and personal watercraft
Simple pressure vessels
Electromagnetic compatibility
Non-automatic weighing instruments
Measuring instruments
Lifts
ATEX
Radio equipment
Pressure equipment
Personal protective equipment
Gas appliances
Machinery
Equipment for use outdoors
Ecodesign
Aerosols
Low voltage electrical equipment
Restriction of hazardous substances

Products covered by the UKCA marking but have some special rules:

medical devices
rail interoperability
construction products
civil explosives

Legislative areas where self-declaration of conformity for UKCA marking is permitted

Legislation	Scope of products which can be self-declared
Electromagnetic Compatibility Regulations 2016	All products
Toy (Safety) Regulations 2011	Products where all essential requirements are covered by designated standards and the manufacturer has applied these standards
The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012	All products
Medical Devices Regulations 2002	Some Class I devices
Radio Equipment Regulations 2017	All products except where designated standards for regulation 6 (2) either do not exist or have not been applied by the manufacturer.
The Pressure Equipment (Safety) Regulations 2016	Category I pressure equipment
Construction Products Regulations (Regulation (EU) 305/2011 as brought into UK law and amended)	Products within scope of System 4
Recreational Craft Regulations 2017	Certain categories of recreational craft as specified in the legislation
The Electrical Equipment (Safety) Regulations 2016	All products
The Supply of Machinery (Safety) Regulations 2008	Any machine which is not in Schedule 2, Part 4 of the Regulations. Any machine that is in Schedule 2, Part 4 where the requirements of all relevant designated standards have been applied in full and where those standards cover the applicable essential requirements.

The Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres Regulations 2016	Equipment-group II, equipment category 3
Personal Protective Equipment Regulations (Regulation (EU) 2016/425 as brought into UK law and amended)	Category I personal protective equipment

Old version until 24.08.2021

Applies to: Wales, England, and Scotland

Contents

The UKCA (UK Conformity Assessed) marking is a new UK product marking that is 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, known as ‘new approach’ goods.

The UKCA marking alone cannot be used for goods placed on the Northern Ireland market. See the guidance on placing goods on the Northern Ireland market.

This guidance explains how to use the UKCA marking. For further information on placing these goods on the market, see the guidance on placing manufactured goods on the market in Great Britain.

There is separate guidance for medical devices, rail interoperability, construction products and civil explosives.

Check whether you need to use the new UKCA marking

Selling goods in Great Britain

The UKCA marking applies to most goods previously subject to the CE marking. It also applies to aerosol products that previously required the ‘reverse epsilon’ marking.

The technical requirements (‘essential requirements’) you must meet – and the conformity assessment processes and standards that can be used to demonstrate conformity – are largely the same as they were for the CE marking.

The circumstances in which you can use self-declaration of conformity for UKCA marking are the same as for CE marking. If you were able to self-declare conformity for the CE marking, you will be able to do the same for the UKCA marking.

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

The UKCA marking came into effect on 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.

The CE marking is only 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.

Check whether you will need to use the UKCA marking by reading the guidance on placing manufactured goods on the market in Great Britain.

There is separate guidance for medical devices, rail interoperability, construction products and civil explosives.

Selling goods in the EU

The UKCA marking is not recognised on the EU market. Products need a CE marking for sale in the EU. Find out how to use the CE marking.

When to use the UKCA marking

You only need to use the new UKCA marking before 1 January 2022 if all of the following apply. Your product:

is for the market in Great Britain
is covered by legislation which requires the UKCA marking
requires mandatory third-party conformity assessment
conformity assessment has been carried out by a UK conformity assessment body

This does not apply to existing stock, for example if your good was fully manufactured, CE marked and ready to place on the market before 1 January 2021. In these cases, your good can still be sold in Great Britain with a CE marking even if covered by a certificate of conformity issued by a UK body before 1 January 2021. These goods will need to be placed on the market before 31 December 2021.