The UK consists of Great Britain (England, Scotland and Wales) and Northern Ireland. The UKCA (UK Conformity Assessed) marking applies to most of the products that previously required the CE marking, meaning that the UKCA marking will replace the CE marking in GB.
It is crucial to note that the Northern Ireland Protocol differs from the Great Britain Protocol and that the UKCA marking is not valid in Northern Ireland. For most of the products the CE marking remains in Northern Ireland. However, there are specific products that also require a different conformity marking: the UKNI marking.
||Type of goods
||Accepted markings or combination of markings
|Placing goods on the market in Great Britain
||Manufactured goods being placed on the GB market until the end of 2022
||UKCA or CE
||Manufactured goods placed on the GB market from 1 Jan 2023
|Placing qualifying Northern Ireland goods on the market in Great Britain (unfettered access)
||Qualifying Northern Ireland goods being placed on the GB market under unfettered access
||CE of CE and UKNI
The steps for obtaining a UKCA marking
Check relevant UK (GB) legislation and GB Designated Standards
Determine whether your product falls within the scope of the relevant UK (GB) legislation and GB Designated Standards.
Replace your CE marking with the UKCA marking
Determine whether you need to replace your CE marking with the UKCA marking; most CE-marked products will remain valid on the GB market until 1 January 2022.
Appoint a UK-based authorised representative
If you are not established in the UK, you may choose to appoint a UK-based authorised representative who will act on your behalf (EU-based authorised representatives are no longer recognised by Great Britain).
Carry out the applicable UK conformity assessment procedure
For most products the UK conformity assessment procedure is largely similar to the EU conformity assessment procedure. If mandatory third-party conformity assessments for the UKCA marking are required, these must be performed by a UK market conformity assessment body (UKMCAB).
Create new UKCA Technical Documentation
This documentation can be based on the CE Marking Technical Documentation. Specifically keep in mind that you must comply with the UK (GB) legislation instead of the EU legislation, as well as with the GB Designated Standards instead of the EU Harmonised Standards.
Draw up a UKCA Declaration of Conformity
The UKCA Declaration of Conformity must be kept for 10 years.
Affix the UKCA marking
The UKCA marking may only be affixed to the product by you as the EU manufacturer (or, on your behalf, by your UK authorised representative, if allowed by the UK legislation).
How can we help you? UKCA marking services
Determine your role and responsibilities under UKCA marking
Carry out the applicable UKCA conformity assessment procedure
Compile UKCA Technical Documentation
Draft UKCA Declaration of Conformity
Provide instructions on how to affix UKCA marking