The UKCA mark is essentially a replacement for the CE mark in the United Kingdom, in the years after Brexit. While not all products require a UKCA mark, the mark is mandatory for those products that are covered by one or more regulations with UKCA marking as a requirement.
In this guide, we explain which regulations require a UKCA mark, how it compares to the CE mark, and the requirements concerning the placement of the UKCA mark on the products and the packaging.
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What is the UKCA marking?
The UK Conformity Assessed (UKCA) marking indicates that the product to which the marking is affixed conforms with the requirements of any applicable regulation that mandates the presence of the UKCA marking.
Note that a product is not compliant with the UKCA simply because the mark was printed or affixed to it. Importers and manufacturers are required to ensure that their products comply with the labelling, documentation, and other requirements set by the applicable regulations before they can affix the UKCA marking.
These requirements might include:
a. Testing to verify compliance with the applicable standards
b. A UK Declaration of Conformity
c. Technical documentation
d. Traceability labelling
e. A conformity assessment carried out by a UK Approved Body when requested
The UK government prohibits the sale of UKCA-marked products that are neither compliant (e.g. tested against relevant standards) nor correctly documented and labelled. You can find more information about the UKCA marking on the UK government’s website.
Is the UKCA marking mandatory?
Importers and manufacturers must ensure that any product falling under any regulation that requires the UKCA marking, bears the marking. For example, most products sold in the UK that used to require a CE marking pre-Brexit, now require a UKCA marking. In the future, it is possible that the UKCA mark will be expanded to products that did not previously require the CE mark.
As already explained, before affixing the UKCA marking to their products importers and manufacturers must meet the requirements set in the applicable regulations.
Note that, until 11 pm on 31 December 2024, products bearing the CE marking can still be placed in the market.
Which products require the UKCA marking?
The UK government requires importers and manufacturers to use the UKCA marking on products that fall into categories such as the following:
- Personal protective equipment (PPE)
- Measuring container bottles
- Measuring instruments
- Gas appliances
- Pressure equipment
- Non-automatic weighing instruments
- Simple pressure vessels
- Recreational craft and personal watercraft
Which products should not have a UKCA marking?
Products that don’t fall under the scope of any regulation that requires the UKCA marking should not carry the marking. Examples of such products include the following:
- Clothing (unless PPE)
Additionally, products for meant for sale in the EU and Northern Ireland do not need to bear the UKCA marking.
Finally, products should not bear the UKCA marking if they do not comply with the technical requirements of the applicable regulations. For instance, if a toy is not compliant with the requirements set by the Toy Safety Regulations, then it is forbidden to affix the UKCA marking to the product and import or sell it in the UK.
Which regulations cover UKCA labelling?
The “Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019” has amended regulations for which CE marking was required, by specifying that the UKCA marking is now required instead of the CE marking. As such, note that the UKCA requirements amend CE requirements.
The UK government has provided a list of regulations requiring importers and manufacturers to affix the UKCA marking for their products.
Below we provide a non-exhaustive lists of EU legislations for which the CE marking is required, and the corresponding UK legislations for which the UK marking is required:
|EU Legislation||UK Legislation|
|ATEX – Directive||Equipment and Protective Systems Intended for use in Potentially Explosive Atmospheres Regulations 2016|
|Electromagnetic Compatibility Directive||Electromagnetic Compatibility Regulations 2016|
|Gas Appliances Regulation (EU)||Regulation 2016/426 on gas appliances as it applies in GB|
|Lifts Directive||Lifts Regulations 2016|
|Low Voltage Directive||Electrical Equipment (Safety) Regulations 2016|
|Machinery Directive||Supply of Machinery (Safety) Regulations 2008|
|Measuring Instruments Directive||Measuring Instruments Regulations 2016|
|Non-automatic Weighing Instruments Directive||Non-automatic Weighing Instruments Regulations 2016|
|Outdoor Noise Directive||Noise Emission in the Environment by Equipment for use Outdoors Regulations 2001|
|PPE Regulation||Regulation 2016/425 on personal protective equipment as it applies in GB|
|Pressure Equipment Directive||Pressure Equipment (Safety) Regulations 2016|
|Radio Equipment Directive||Radio Equipment Regulations 2017|
|Recreational Craft and Personal Watercraft Directive||Recreational Craft Regulations 2017|
|Simple Pressure Vessels Directive||Simple Pressure Vessels (Safety) Regulations 2016|
|Toy Safety Directive||Toys (Safety) Regulations 2011|
Can the CE marking be used instead of the UKCA marking?
Importers and manufacturers can continue using the CE marking until 31 December 2024 (the deadline has been extended from 1 January 2023), after which they are required to use the UKCA marking on their products.
What is the difference between UKCA and CE marking?
The CE marking indicates that a product meets the requirements of any EU directive or regulation that requires importers and manufacturers to affix the CE marking to their products (e.g. Low Voltage Directive).
The UKCA marking on a product indicates its conformity with applicable requirements of any regulation that requires importers and manufacturers to affix the UKCA marking to their products in the UK (e.g. Electrical Equipment (Safety) Regulations 2016).
Is the UKCA marking recognised in the EU?
No. The EU does not recognise the conformity of a product to applicable regulations and directives if it only carries the UKCA marking.
For being legally imported or sold in the EU, a product covered by CE marking directives or regulations should carry the CE marking to signify its compliance with EU requirements.
What are the supporting documents needed?
Importers and manufacturers, or their authorised representatives, are required to maintain for a minimum of 10 years documentation that provides evidence of their product’s compliance with requirements concerning regulations that require the UKCA marking.
Market enforcement or surveillance authorities may request, at any time, compliance information to ensure that products conform to requirements.
More specifically, importers and manufacturers normally need to draft and provide documents such as the following:
a. UK Declaration of Conformity
b. Technical documentation
c. Information concerning UK Market Conformity Assessment Bodies (if applicable)
d. User instructions
Is lab testing needed for using the UKCA marking?
Testing is usually required in order to show compliance with relevant technical requirements or designated standards, before affixing the UKCA marking to your products. These requirements and standards cover areas such as the following:
- Chemical safety
- Mechanical safety
- Electrical safety
- Electromagnetic compatibility
- Energy efficiency
For some products, e.g. Category III personal protective equipment, a mandatory third-party conformity assessment carried out by a UK Approved Body is also required.
This requirement applies to products for which mandatory a third-party conformity assessment is needed under EU directives and regulations that require CE marking.
Companies that offer lab testing services against UKCA requirements include the following:
- TÜV SÜD
- F2 Labs
How much does it cost to use the UKCA marking?
Importers and manufacturers do not need to contribute a fee to use the UKCA marking in itself, but they may have to pay to have their products tested or undergo a conformity assessment by a UK Approved Body.
The testing costs depend on many factors, including:
a. The product specifications (e.g. materials) and functionality
b. The regulations that apply to the product
c. The country where you are testing your product
What is the required size of the UKCA marking?
Importers and manufacturers are required to abide by several rules regarding the size of the UKCA marking:
a. The UKCA marking must be at least 5mm in height – unless relevant legislation requires the marking to adhere to a different minimum dimension
b. The letters of the UKCA marking, if enlarged or reduced in size, must remain proportionate to the official version provided on the UK government website
c. The UKCA marking should be presented in such a way that it is easily visible, decipherable, and permanent
The marking can be slightly customised (e.g., the colour does not need to be solid), so long as it adheres to the above requirements.
Must the UKCA marking be placed on the product?
Generally, importers and manufacturers are required to affix the UKCA marking onto the product and the packaging in a permanent way, if relevant legislation specifically requires the product to carry the UKCA marking.
They may, depending on product-specific regulations, include the UKCA marking with the user instructions or place it on other supporting documents.
Can I place both the UKCA and CE markings on my products?
Importers and manufacturers can place both UKCA and CE markings on a product provided that:
a. Neither marking impinges on the other’s visibility; and
b. The product meets the requirements of the UK and EU legislation to warrant the use of both markings
Must the UKCA marking be placed on the packaging?
As already explained, importers and manufacturers are generally required to place the UKCA marking on their products. They may place the marking on the packaging, user instructions, or other supporting documents if the product’s nature renders the direct placement of the UKCA marking on the product impossible (e.g. because the product is too small, or for other reasons).
You can also affix the UKCA marking in both your product and packaging.