When did UKCA marking become mandatory?

UKCA marking became the mandatory mark for most products placed on the GB market from January 1, 2025. Prior to this, there was a transition period where CE marking was still accepted. Products placed on the market before this date with CE marking can continue to circulate.

Is CE marking still valid in the UK?

CE marking is no longer valid for the Great Britain market (England, Scotland, Wales) for most product categories. However, CE marking remains valid in Northern Ireland under the Windsor Framework. Products sold in both GB and NI may need both UKCA and CE marks.

What products require UKCA marking?

UKCA marking is required for products covered by UK legislation that previously required CE marking, including: electrical equipment, toys, machinery, medical devices, PPE, radio equipment, construction products, and many others. Some product categories have specific transition arrangements.

What is a UK Responsible Person and when is one needed?

A UK Responsible Person is required for most products placed on the GB market by non-UK manufacturers. They must be established in the UK and are responsible for ensuring products comply with UK requirements, keeping documentation, and cooperating with enforcement authorities.

Can I use the same test reports for UKCA and CE marking?

In many cases, yes. If the technical requirements are identical and the testing was performed by a body acceptable to both UK and EU systems, the same test reports can support both UKCA and CE marking. However, you need separate Declarations of Conformity for each mark.

What is the UKNI marking?

The UKNI marking is used alongside CE marking for products placed on the Northern Ireland market that have undergone mandatory third-party conformity assessment by a UK-based body. It indicates the UK body's involvement while the CE mark shows EU conformity.

How do I affix the UKCA mark correctly?

The UKCA mark must be at least 5mm in height (unless otherwise specified), maintain correct proportions, be visible and legible, and be permanently affixed to the product or its packaging. If a UK Approved Body was involved, their number must appear next to the mark.

What documentation is required for UKCA marking?

You need: technical documentation demonstrating conformity, UK Declaration of Conformity listing applicable UK regulations and standards, test reports from accredited laboratories, risk assessments, and user instructions in English.

Can I self-declare UKCA conformity?

For many product categories, yes. Products following Module A conformity assessment can be self-declared by the manufacturer. However, higher-risk products like certain machinery, medical devices, and PPE require third-party assessment by a UK Approved Body.

UK Regulation

Post-Brexit

15 min read

UKCA Marking Guide

Q: What is UKCA marking?

UKCA (UK Conformity Assessed) marking is the UK product marking required for goods being placed on the market in Great Britain (England, Wales, and Scotland). It replaced CE marking for the GB market following Brexit and covers most products that previously required CE marking.

The UK Conformity Assessed (UKCA) mark is your gateway to the Great Britain market. This guide explains when UKCA is required, how it differs from CE marking, and the steps to achieve compliance.

What is UKCA Marking?

The UKCA (UK Conformity Assessed) mark is the UK's product conformity mark for goods placed on the market in Great Britain (England, Scotland, and Wales). It was introduced following Brexit as the domestic equivalent of the EU's CE mark.

UKCA marking demonstrates that a product meets the safety, health, and environmental requirements set out in UK legislation. It covers most products that previously required CE marking, including electronics, toys, machinery, and personal protective equipment.

As of January 2025, UKCA marking is mandatory for placing products on the GB market. Products with only CE marking are no longer accepted in Great Britain for most regulated product categories.

UKCA

CE Marking vs UKCA Marking

Aspect

CE Marking

UKCA Marking

Geographic Scope

European Economic Area (EU + EFTA)

Great Britain (England, Scotland, Wales)

Responsible Person

EU Authorized Representative

UK Responsible Person

Conformity Bodies

EU Notified Bodies

UK Approved Bodies

Declaration

EU Declaration of Conformity

UK Declaration of Conformity

Standards

Harmonised Standards (hEN)

Designated Standards (UK)

Legislation

EU Directives/Regulations

UK Statutory Instruments

Key insight: While UKCA mirrors CE in structure, each requires separate documentation. Many technical standards are identical or equivalent, allowing test data to be reused, but you need distinct declarations for each market.

Products Requiring UKCA Marking

Electrical Equipment

Electrical Equipment (Safety) Regulations 2016

Covers low voltage equipment 50-1000V AC

Electromagnetic Compatibility

EMC Regulations 2016

All electrical/electronic equipment

Toys

Toys (Safety) Regulations 2011

Products designed for children under 14

Machinery

Supply of Machinery (Safety) Regulations 2008

Assembly of linked parts with movement

Personal Protective Equipment

PPE Regulations 2018

Category I, II, and III PPE

Radio Equipment

Radio Equipment Regulations 2017

Wireless devices, Bluetooth, WiFi products

Medical Devices

Medical Devices Regulations 2002 (as amended)

Special transition rules apply

Construction Products

Construction Products Regulations

Products for permanent incorporation in construction works

Conformity Assessment Routes

The conformity assessment route depends on your product type and risk level. UK legislation specifies which modules are available for each product category.

Module A

Internal Production Control

Self-Declaration

Self-assessment by manufacturer. Suitable for lower-risk products.

Module B

Type Examination

UK Approved Body Required

UK Approved Body examines design and issues certificate.

Module C

Conformity to Type

Self-Declaration

Manufacturer ensures production matches approved type.

Module D

Production Quality Assurance

UK Approved Body Required

UK Approved Body assesses manufacturing quality system.

Module F

Product Verification

UK Approved Body Required

UK Approved Body verifies each product or batch.

Module H

Full Quality Assurance

UK Approved Body Required

UK Approved Body assesses complete quality management system.

UK Responsible Person

If you are a non-UK manufacturer placing products on the Great Britain market, you must appoint a UK Responsible Person. This requirement applies to manufacturers based in the EU, US, China, or any other non-UK country—including those who previously relied on CE marking alone.

UK Responsible Person Duties

Verify products meet UK regulatory requirements

Ensure technical documentation is available in English

Keep Declaration of Conformity for 10 years

Provide documentation to enforcement authorities on request

Inform manufacturer of any non-compliance issues

Cooperate with authorities on corrective measures

Have procedures to maintain conformity in series production

Display their name and address on product or packaging

Important: The UK Responsible Person cannot be based in Northern Ireland for GB market access purposes. They must have an establishment in England, Scotland, or Wales.

Northern Ireland: The Windsor Framework

Northern Ireland has unique rules under the Windsor Framework. Products sold in NI generally follow EU requirements (CE marking), but special rules apply for goods moving between GB and NI.

Product manufactured in EU

Can move freely into NI under Windsor Framework

CE marking only

Product manufactured in GB, self-declared

Manufacturer must ensure EU compliance

CE marking required

Product manufactured in GB, UK Approved Body used

UKNI indicates UK body involvement

CE + UKNI marking

Product from NI to GB

Unfettered market access for qualifying goods

CE or UKCA accepted

UKNI Marking: The UKNI mark is used alongside CE marking when a product destined for Northern Ireland has been assessed by a UK Approved Body. This is necessary because EU Notified Bodies cannot be used for NI market access where third-party conformity assessment is required.

Documentation Requirements

Technical Documentation

Product description and intended use
Design and manufacturing drawings
List of UK designated standards applied
Risk assessment documentation
Test reports from accredited bodies
Quality control procedures
Calculation notes where applicable

UK Declaration of Conformity

Manufacturer name and address
UK Responsible Person details (if applicable)
Product identification (model, type, batch)
Statement of conformity
List of applicable UK regulations
Reference to UK designated standards
UK Approved Body number (if involved)
Signature of authorized person

UKCA Mark Placement Rules

Requirements

Minimum height of 5mm (unless legislation specifies otherwise)
Letters 'UKCA' must maintain correct proportions
Must be visible and legible on product
Permanent and not easily removed
If UK Approved Body involved, their number appears nearby

Placement Options

Directly on the product (preferred)
On product packaging if product is too small
On product dataplate or label
In accompanying documents as last resort
Never on a removable tag alone

Frequently Asked Questions

Related Guides

CE Marking Complete Guide

The EU equivalent to UKCA—required for European market access.

Amazon EU Compliance Guide

Platform-specific requirements for Amazon UK and EU.

Need UKCA marking for your products?

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