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What is UKCA marking?

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

What is the difference between UKCA marking and CE marking?

What is UKCA marking?

UKCA stands for “UK Conformity Assessed”. It is the British version of the European Union’s CE marking. CE, as well as the UKCA mark, are not quality indicators or certification marks. UKCA marking is a similar provision as the CE marking, however applicable for UK laws and the UK market. It must be considered as an implicit declaration from the manufacturer or brand-owner that his product complies with all UK laws and the applicable British conformity assessment procedures.

For which type of consumer products UKCA marking is applicable?

CE and UKCA marking are not applicable for all non-food consumer products. Most UK requirements match the directives and regulations for which CE marking is applicable. The relevant legislation for which UKCA-UK requirements match CE-marking EU requirements can be found here

Legislation for medical devices, rail interoperability, construction products and civil explosives are subject of UKCA marking in the UK and CE marking in the EU and EEA. There are differences between the UK and the EU for these pieces of legislation. 

One notable difference between the scope of UKCA marking is for aerosol dispensers. For aerosol dispensers, UKCA marking is mandatory in the UK in contrast to the EU market. Aerosol Dispensers placed on the European market may not bear CE-marking. Products that are not in the scope of one or more of UKCA marking regulations and or directives may not bear the UKCA mark.

Which marking must be used if a product is sold in the EU as well as in the UK?

You may use UKCA marking on the UK market from January 1, 2021. If the EU does not change its CE marking legislation before 31 December 2024, you may continue CE marking on the UK market. UKCA marking is not recognized in the EU. A consumer product may bear the UKCA marking next to the CE marking on the European market provided that an appropriate European conformity assessment is applied.

From which date UKCA marking is mandatory?

The UKCA marking came into effect on 1 January 2021. However, to allow businesses time to adjust to the new requirements, you will still be able to use the CE marking indefinitely, beyond December 2024, in most cases.

However, you can use CE marking beyond December 2024 only if there will be no change in the CE marking legislation for these products to the version applicable on 31 December 2024. Otherwise, these products will have to comply with the UKCA marking legislation and UKCA marking will be mandatory.

Although products can still be placed on the UK market with CE marking under this condition indefinitely, there would be no presumption of conformity. Similarly, if you do not apply harmonised standards in the EEA, i.e. standards published in the Official Journal of the EU for the relevant directive or regulation, to demonstrate conformity. The presumption of conformity only applies if the designated UK standards are met and the product bears the UKCA marking. EU-harmonised standards can also only be used to demonstrate conformity as long as they do not differ from UK-designated standards. If a UK-designated standard contains a restriction that is not included in the corresponding European harmonised standard, additional measures must be taken to bring the product into compliance with the UK requirements before it is placed on the UK market. The British government made detailed guidance for using the UKCA marking.

For products that require the involvement of a Notified Body in the conformity assessment process, additional requirements and deadlines apply, referring to the guidance for mandatory third-party conformity assessment for the UKCA marking.

Incidentally, until 11pm on 31 December 2027, for most product groups, it is permitted to affix the UKCA marking only on a sticker affixed to the product or on an accompanying document, unless otherwise specified in product-specific legislation. The same deadline also applies to manufacturer, brand owner, importer, or UK AR contact details. From that deadline that contact information and the UKCA marking must be permanently affixed onto the product.

 There is separate guidance for medical devicesconstruction productscablewaystransportable pressure equipment, unmanned aircraft systems, rail productsmarine equipment and ecodesign. 

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