Conformity in the UK after Brexit: UKCA as a Successor to CE Mark.
Product Compliance.
Insight.

Conformity in the UK after Brexit: UKCA as a Successor to CE Mark.

On 1 January 2021 the UK becomes a single market economy with its separate Product Regulatory Conformity Assessment System. Access to the UK Market is possible with the new UKCA Mark. The UKCA (United Kingdom Conformity Assessment) will be required for the Products placed on the market in Great Britain (England, Wales and Scotland). As a result of adopting and endorsing EU Regulations and Directives the conformity assessment processes and standards will largely remain the same as they are now. The prefix “BS” would be added to indicate that the standards are adopted by the British Standards Institution.

Marking Requirements and Timeline

Due to the Withdrawal Agreement a transitional period will end on 31 December 2020. After that the CE Mark will be no longer recognized in the UK. All products accessing the UK market instead of CE shall affix UKCA mark. Though the fact that in most cases it is possible to use CE marking until 1 January 2022, it remain some cases that need an immediate UKCA Marking to be sold in Great Britain from 1 January 2021. Access requirements for UK Market

  • After 31 December 2020 products placed in UK Market require UKCA marking.
  • For products that are considered to be subject to mandatory regulatory controls will require interaction with a UK Approved Body.
  • For products that are not considered to be subject to mandatory regulatory controls shall have a Self Declaration of Conformity (SDofC).
  • A self Declaration of Conformity shall be drawn up by the manufacturer.
  • Before placing the product in the UK Market the conformity shall be declared by affixing the UKCA mark to the product.

From 1 January 2022, the CE marking will definitely not be recognized in Great Britain.

Implementation of the Notified Body Certificates

Before 31 December 2020 all Notified Bodies of UK will be automatically changed to UK Approved Bodies. Accreditations of the EU Notfied Bodies will be withdrawn. It means that after 31 December 2020 their CE marking will no longer be valid for products placed on the EU market. As a next step of the transition period UK Notified Bodies are transferring certificates to EU-established Notified Bodies.
The activities needed attention during the transferring process:

  • Transfers must be completed before the UK transition period ends (31 December 2020).
  • New Certificates must reference old Certificates.
  • Transfers after 31 December 2020 will be recognized as a new application.
  • Declarations of Conformity should be updated in accordance with the new certificate.

Transfers to EU Notified Bodies after the 31 December 2020 will be recognized as a new application.

Applicability of CE and UKCA Marks

To select the correct mark is important to know the areas where the CE or UKCA or the combination of both are used:

  • UK enables selling the Products with the CE mark on it so long as it is additionally marked with the UKCA and complied with the relevant UK rules.
  • Northern Irland is the Market where the UKCA marking can’t be used alone. Here are required the CE or UK(NI) marking.
  • The UKCA marking is not recognised in EU. For bringing the Product to EU Market they should confirm the CE requirments.
  • Type Certificates issued by a UK Approved Body are not accepted by EU 27 Notified Bodies.

Applicability of UKCA marking in the countries of UK is different.

The following points should be considered

After 31st of December 2020 products placed in UK Market require UKCA marking.
Until January 2022 in most cases it is still allowed to use the CE marking.
From 1st of January 2022, the CE marking will definitely no longer be recognized in Great Britain.
It is possible to place products with the CE mark in the Great Britain market only when they are additionally marked with the UKCA. In Northern Irland a CE mark is still required.

Go to Product Compliance

More Insights.

Show all

Get in touch.

How can we support you and your company? Please contact us!

Your direct line to MCG

Marco Mauler

Marco Mauler
Head of Product Compliance

Phone: +49 89 383 46 89 0
Email:

Please choose an address.
Please enter your surname.
Please enter your email address.
Please enter a message.
Please select the checkbox.

Fields marked with * are mandatory fields.

Your browser is out-of-date!

Update your browser in order that our website is shown in the best possible way.
Update your browser now!