There has been a gradual transition between both entities around legislation, laws and regulations for trade.
One such item in transition is the use of the CE marking within the UK.
The CE marking indicates that a product has met safety, health and environmental protection requirements set forth by the EU and is required for products sold within the European Economic Area (EEA).
Since the UK is no longer a part of the EEA, the CE marking does not apply to products sold within Great Britain (England, Scotland, and Wales). There are special circumstances for the CE mark within Northern Ireland.
The UK still sees value in having products meet safety, health, and environmental regulations and therefore put in place its own required marking called UKCA (United Kingdom Conformity Assessed).
With this new change, most products sold in Europe will require both CE and UKCA marks.
Most products sold in Europe will require both CE and UKCA marks.
Who does UKCA affect?
The new marking affects any business that sells products within the England, Wales, and Scotland markets. There are special circumstances for Northern Ireland businesses.
If your product required a CE mark in the past, then it most likely will require the UKCA mark as well.
There are special rules in place for the following goods: medical devices, construction products, marine equipment, rail products, and transportable pressure equipment.
The UKCA mark affects any business that sells products within the England, Wales, and Scotland markets.
Why do electronic products need the UKCA mark?
The UK Conformity Assessed marking indicates that a product meets Great Britain’s safety, health and environmental regulations. It also means that the product has a UK Declaration of Conformity document that states the standards the product meets.
What is the difference between the CE and UKCA mark?
The difference between the two markings is the geographical markets that it covers. CE is only recognized within the EU and Northern Ireland markets, while the UKCA mark is for the GB market (England, Scotland, and Wales). The rules and regulations behind the marks are the same, but the marks are not interchangeable.
The rules and regulations behind CE and UKCA marks are the same, but the marks are not interchangeable.
How might UKCA affect my business?
UKCA affects your business if you sell goods or plan to sell goods within the UK market, with the exception of Northern Ireland businesses. If you do not comply with UKCA by the enforcement date, then your goods cannot be sold within England, Scotland or Wales.
If you previously sold products with the CE marking within the Great Britain market and you want to continue selling in this geographical region, you will need to update those products to also conform to UKCA.
If you have a new product that you want to sell into England, Scotland, or Wales, it will need to use the UKCA marking.
UKCA affects your business if you sell goods or plan to sell goods within the UK market
Certain products may be self-declared while others require third-party conformity assessment by a UK Approved Body.
Other changes include adjusting the product’s artwork label to include the UKCA mark and having the required UK Declaration of Conformity documentation.
Again, there are special rules in place for certain products such as medical devices.
When will UKCA be enforced?
Though Brexit took effect at the beginning of 2021, the UK has issued grace periods for certain items such as the UKCA mark. It also has extended the enforcement date for the mark due to the disruption by the pandemic.
As of August 24, 2021, the UKCA mark will be enforced starting January 1, 2023.
The UKCA mark will be enforced starting January 1, 2023
Under the grace period by the UK, existing products may continue to be sold until December 31, 2022 with only the CE mark while Great Britain and EU rules are aligned. If either changes their rules before that date, then the CE mark will no longer be recognized within England, Scotland, or Wales.
It is highly recommended to start conforming your products as soon as possible to UKCA if they will be sold in the GB market. For your existing products that have the CE mark and are sold within Great Britain, it is very risky to rely on the CE mark to cover your product within these countries before the enforcement date.
It is your responsibility to ensure your products meet the regulations of the countries that you are selling in. A good contract manufacturer will help shoulder this responsibility by proactively reviewing your planned markets and help in coordinating the certification of your product for these markets. Find out more on how to qualify a good manufacturing partner.
Certifying your products correctly allows you to pass government requirements and gives assurance to your consumers that the product is safe and reliable by their country’s standards. If your market includes Great Britain, start the transition to UKCA today to be in compliance by January 2023.