What is the UKNI marking?

The UKNI marking indicates that a product has undergone a mandatory third-party conformity assessment performed by a UK approved body. UKNI marking is often affixed together with CE marking to indicate that the assessment has been made by a UK approved body, instead of an EU notified body.

This guide explains what you need to know about the UKNI marking, including when it is necessary, which products you should use it for, and where you should place the marking.

What is the UKNI marking?

The UKNI marking, also called UK(NI) indication, is a conformity marking that indicates that products have passed the required assessments by a UK approved body (sometimes also called UK notified body).

As a result of the Windsor Framework, Northern Ireland is aligned with EU regulations and directives. Many of these regulations and directives require an EU notified body to perform a third-party safety assessment, at least in some cases.

For example, the Toy Safety Directive requires an EU notified body when harmonised standards do not exist or are not fully applied.

As another example, the Personal Protective Equipment Regulation requires an EU notified body for personal protective equipment (PPE) that is classified as Category II or Category III (PPE). Note that the higher the category, the higher the risk that the PPE protects from.

Assuming your product passes the assessment performed by the EU notified body, you must affix the CE marking, or other required compliance marks, to your product.

However, if the assessment is performed by a UK approved body – instead of a EU notified body, – you must also affix the UKNI marking to your product.

Here is an explanation taken from The Toys (Safety) Regulations 2011:

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15A.—(1) Where the CE marking is affixed on the basis of an assessment or a certificate issued by a UK notified body, a UK(NI) indication must be affixed in relation to the toy, in accordance with this regulation.

(2) The UK(NI) indication must be affixed—

(a) visibly, legibly and indelibly; and

(b) before a toy is placed on the market in Northern Ireland.

(3) The UK(NI) indication must be affixed wherever the CE marking is affixed, in accordance with regulation 18.

(4) The UK(NI) indication must be affixed by—

(a) the manufacturer; or

(b) the manufacturer’s authorised representative who has been appointed by the manufacturer in accordance with regulation 25(1) to affix the UK(NI) indication on the manufacturer’s behalf.

(5) When placing a toy on the market in Northern Ireland, an importer must ensure that the manufacturer has complied with their obligations under this regulation.

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Which products may require the UKNI marking?

The UK guidance page on using the UKNI marking lists categories of products for which you may need to affix a UKNI marking, which include:

• Toys
• Electronic products
• Personal protective equipment
• Measuring container bottles
• Measuring instruments
• Non-automatic weighing instruments
• Outdoor-use equipment
• Gas appliances
• Simple pressure vessels
• Pressure equipment
• Aerosol dispensers
• Machines
• Equipment for use in potentially explosive areas
• Recreational craft and personal watercraft
• Pyrotechnics products
• Lifts

According to the guidance page, you may also need to affix a UKNI marking to civil-use explosives, medical devices, and rail interoperability constituents, even though these products are subject to specific rules.

Also, note that there may be additional product categories for which you may need to affix the UKNI marking.

Is the UKNI marking mandatory for covered products?

The usage of the UKNI marking is only mandatory in some instances. The UK’s guidance page on using the UKNI marking lists the following four conditions you need to meet for using the UKNI marking:

Condition 1: You sell certain products in Northern Ireland (e.g. toys or other products listed in the above section)

Condition 2: The EU regulations that cover the product require you to affix a conformity marking (e.g. the CE marking, or another marking that may require the UKNI marking, as listed below)

Condition 3: Your products should undergo a third-party conformity assessment, and

Condition 4: You decide to use a UK approved body instead of an EU notified body to perform the assessment.

Besides the CE marking, we found that a UKNI marking may also be necessary for products that require the following markings:

a. The inverted epsilon “3” – For example, you should use this marking for aerosols covered by the Aerosol Dispensers Regulations 2009.

b. The Pi (π) marking – For example, you should use this mark for some types of transportable pressure equipment covered by the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009.

c. The Wheelmark – For example, you should use this mark for ship parts covered by the Merchant Shipping (Marine Equipment) Regulations 2016.

Can I use the UKNI marking in combination with CE marking?

Yes. In fact, you need to use the UKNI marking in combination with the CE mark when selling products in Northern Ireland. As such, the UKNI mark is not affixed alone.

As explained, this requirement only applies to products covered by CE marking directives and regulations, and for which you used a UK approved body instead of an EU notified body.

Can I use the UKNI marking in combination with the UKCA marking?

The UKNI marking must be used in combination with the CE marking for goods sold in Northern Ireland that have been assessed by a UK approved body.

As far as we know, you cannot use the UKNI marking in combination with the UKCA marking alone.

Can I use the UKNI marking by itself?

No, you cannot use the UKNI marking by itself. You need to use an EU conformity marking (e.g. the CE marking) combined with the UKNI marking.

For example, according to The Toys (Safety) Regulations 2011, a UK approved body needs to affix the UKNI marking “wherever” it has also affixed the CE marking.

Can products with the UKNI marking be sold in the EU?

No, you cannot sell products in the EU if you affix the UKNI marking onto them. This same prohibition applies even if your product carries both the CE and UKNI markings.

This is because the UKNI marking indicates that you used a UK approved body. If you sell products in the EU, you need to get your products assessed by an EU notified body, when a third-party assessment is required.

Can products with the UKNI marking be sold in England, Scotland, and Wales?

According to GOV.UK, you can sell products with the CE and UKNI markings in England, Wales, and Scotland under “unfettered access”, provided they are “qualifying Northern Ireland goods”.

According to the UK’s guidance page on moving qualifying goods from Northern Ireland to the rest of the United Kingdom, your products are “qualifying Northern Ireland goods” if they were freely circulating in Northern Ireland before you sell them in England, Scotland, and Wales.

Note that free circulation means the goods “are not under a customs procedure or in an authorised temporary storage facility”.

Where must the UKNI marking be located?

According to the UK guidance page for using the UKNI marking, you need to permanently attach the UKNI marking to:

• The product, or
• The packaging, or
• The manuals, or
• Other supporting documents

The UKNI marking should be placed near the CE marking – or other relevant conformity marking such as the inverted epsilon “3” – and have a minimum height of 5 mm.

Note that some regulations may have different requirements regarding affixing the UKNI marking.

Note: Contains public sector information licensed under the Open Government Licence v3.0.