UKCA: the United Kingdom post-Brexit conformity marking

Author Hugues Orgitello Last updated 26 May 2026

Guide · UKCA

The UKCA marking (UK Conformity Assessed) is the British product conformity system designed to succeed the CE marking in Great Britain after the United Kingdom's exit from the European Union. Its trajectory since 2021 has been marked by several deferrals and then by a major policy shift in August 2023, when the British government announced indefinite recognition of the CE marking for most product categories. UKCA has therefore not replaced CE as initially planned, and the two now coexist in an arrangement this guide aims to clarify.

Why a separate British marking?

The United Kingdom's withdrawal from the European Union on 31 January 2020, followed by the end of the transition period on 31 December 2020, removed the country's status as a Member State and, with it, its direct participation in the CE marking system. To preserve the legal continuity of the British internal market, the government transposed most of the EU product acquis into national law through statutory instruments (SIs), foremost among them SI 2019/696 (Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations), which establishes the UKCA framework and adapts about twenty existing regimes to the UK's departure from the EU.

UKCA came into force on 1 January 2021. Its technical logic mirrors that of CE: essential requirements, presumption of conformity through designated standards, declaration of conformity, technical file. The differences are jurisdictional and institutional, not conceptual.

Geographic scope

UKCA applies to Great Britain, which comprises England, Wales and Scotland. Northern Ireland follows a separate regime inherited from the Northern Ireland Protocol and later modified by the Windsor Framework (February 2023): the CE marking remains fully valid there, and UKCA is not required. Where a manufacturer chooses to have a product assessed by a British body for placing on the Northern Ireland market, the CE + UKNI marking (not UKCA alone) must be applied, signalling that the assessment was not carried out by an EU notified body.

Territory	Marking required	Assessment body admitted
England, Wales, Scotland	UKCA, or CE (for recognised regimes)	UK Approved Body for UKCA; EU notified body for CE
Northern Ireland	CE alone, or CE + UKNI	EU notified body (CE alone); UK Approved Body (CE + UKNI)
Rest of the EU/EEA	CE	EU notified body

The August 2023 shift, indefinite recognition of CE

The initial calendar foresaw a full transition to UKCA by 1 January 2022, deferred several times in the face of the practical difficulty for manufacturers and Approved Bodies to process the volume. On 1 August 2023, the Department for Business and Trade (DBT) issued a notice announcing the indefinite recognition of the CE marking for products covered by eighteen regulatory regimes under its remit.

Regimes covered by the recognition

The main regimes affected by this recognition include:

• low-voltage electrical safety (Electrical Equipment (Safety) Regulations 2016),
• electromagnetic compatibility (Electromagnetic Compatibility Regulations 2016),
• radio equipment (Radio Equipment Regulations 2017),
• toys (Toys (Safety) Regulations 2011),
• machinery (Supply of Machinery (Safety) Regulations 2008),
• pressure equipment and gas appliances,
• explosives for civil use and pyrotechnics,
• personal protective equipment (PPE),
• equipment for use in potentially explosive atmospheres (ATEX),
• measuring and weighing instruments.

For these regimes, a manufacturer may continue to apply the CE procedure and affix the CE marking to place a product on the Great Britain market, without a separate UKCA procedure. The recognition no longer has an expiry date: it is indefinite, subject to no major divergence arising between EU and UK regulation in the regime concerned.

Regimes excluded from the recognition

Not every regime is covered. The following remain outside the perimeter of indefinite recognition:

• medical devices (UK MDR 2002), managed by the MHRA on its own calendar,
• construction products (UK Construction Products Regulation), where divergence from the EU CPR is most marked,
• rail equipment, under the authority of the Office of Rail and Road,
• marine equipment (Merchant Shipping Notices), under the Maritime and Coastguard Agency,
• certain sectoral regimes falling under other government departments.

For these categories, UKCA (or the equivalent sectoral marking) remains mandatory for placing on the Great Britain market. A manufacturer wishing to rely on an existing CE file must, in these cases, examine the applicable British SI and supplement with the specific tests or attestations required.

Legal architecture: mapping UK SIs to EU directives

The 2019 transposition created a direct correspondence, regime by regime, between EU directives and British statutory instruments. This mapping remains valid in 2026.

EU directive / regulation	UK statutory instrument	Subject
Directive 2014/30/EU	SI 2016/1091	Electromagnetic compatibility
Directive 2014/35/EU	SI 2016/1101	Low-voltage electrical equipment (LVD)
Directive 2014/53/EU	SI 2017/1206	Radio equipment (RED)
Directive 2009/48/EC	SI 2011/1881	Toy safety
Directive 2006/42/EC	SI 2008/1597	Machinery
Regulation (EU) 2016/425	SI 2018/390	Personal protective equipment
Directive 2014/68/EU	SI 2016/1105	Pressure equipment
Directive 2014/34/EU	SI 2016/1107	Explosive atmospheres (ATEX)
Regulation (EU) 305/2011	SI 2013/1387 (UK CPR)	Construction products
Directives 93/42/EEC and EU 2017/745	UK MDR 2002 (SI 2002/618)	Medical devices

SI 2019/696 modified all of these texts to:

1. Substitute the UKCA marking for the CE marking in national requirements,
2. Replace references to EU notified bodies with references to UK Approved Bodies,
3. Introduce designated standards as the national equivalent of harmonised standards,
4. Adapt importer and authorised representative obligations to the British context,
5. Set out the rules for handling CE markings still present on the market.

Subsequent amendments (SI 2020/676, SI 2020/852, SI 2021/451, SI 2023/1011 among others) successively postponed the deadlines and established CE recognition for the regimes concerned.

Designated standards: the British equivalent of harmonised standards

The presumption-of-conformity mechanism, central to the CE architecture, is reproduced under UKCA through the concept of a designated standard. A standard designated by the Secretary of State and published in the British official list confers, on a product complying with it, a presumption of conformity with the essential requirements of the corresponding regime.

Where to find the list

Lists of designated standards are published by the Department for Business and Trade and accessible from gov.uk pages dedicated to each regime (EMC, radio, machinery, toys, PPE, etc.). Each list indicates:

• the reference and year of the standard,
• the date of designation,
• where applicable, the date from which the previous standard ceases to confer presumption of conformity,
• annotations on restricted clauses (the equivalent of OJEU restrictions on the CE side).

In practice, designated lists largely reproduce the European harmonised lists, with a publication delay ranging from a few weeks to several months. A product designed and tested to up-to-date EN standards is, in the vast majority of cases, compliant with the corresponding designated standards. Checking the status of each applied standard at the time the UKCA declaration is drawn up remains nonetheless a mandatory step.

Standards not yet designated

When an EN standard has just been published and no British designation has yet taken place, the manufacturer can either wait for designation, or apply the standard voluntarily without formally benefiting from the presumption of conformity. In the latter case, the demonstration of conformity with essential requirements must be supplemented by a documented technical rationale in the file.

UK Approved Bodies and the UKMCAB database

For regimes that require third-party intervention (machinery in Annex IV, certain radio equipment, PPE category III, etc.), the assessment must be entrusted to a UK Approved Body. This is the British equivalent of an EU notified body, designated by a UK authority (typically OPSS, ORR, MCA or MHRA depending on the sector).

The UKMCAB database

The official list of UK Approved Bodies is held in the UKMCAB (UK Market Conformity Assessment Bodies) database, accessible on gov.uk. For each body, the database indicates:

• the regimes for which it is designated,
• the conformity-assessment procedures covered,
• the product types accepted,
• contact details and the UKMCAB identifier to be reported on the declaration and the marking.

The UKMCAB number plays the same role as the four-digit notified body number under CE, and must be affixed near the UKCA logo whenever an Approved Body has intervened in the procedure.

Practical consequence for a European manufacturer

Since 1 January 2021, an EU type-examination certificate issued by an EU notified body is no longer valid as a UKCA attestation. For regimes that require a third party and that are not covered by CE recognition (medical, construction, marine), the manufacturer must engage a UK Approved Body in parallel to the CE procedure, generally on the basis of the same technical file. Several major organisations (BSI, SGS, Intertek, TÜV SÜD) operate both as EU notified body and as UK Approved Body, which simplifies the administrative coordination but does not merge the certificates.

Importer and authorised representative obligations

The British system retains the manufacturer / importer / distributor chain of responsibility inherited from the European New Legislative Framework, with an additional obligation for manufacturers not established in the United Kingdom.

A UK-established responsible person

Any product placed on the Great Britain market by a manufacturer established outside the United Kingdom must have an importer or authorised representative established in the UK. This obligation derives from SI 2019/696 (and subsequent amendments) and applies to all covered regimes, whether under UKCA or under CE recognition.

The name and postal address of this British responsible person must appear:

• on the product itself, or
• on its packaging, or
• in the accompanying documentation.

The responsible person retains the declaration of conformity (UKCA or CE depending on the case) and the technical file for a typical period of ten years after the last relevant product has been placed on the market, and cooperates with British market surveillance authorities on request.

Difference from the CE authorised representative

The EU authorised representative recognised under Regulation (EU) 2019/1020 is not recognised as a British responsible person. A Chinese or American manufacturer who has designated an authorised representative in Germany must designate, in addition, a UK importer or authorised representative to sell in Great Britain. Conversely, a British representative does not cover EU obligations.

The Northern Ireland case

The Windsor Framework, in force since 2023, clarified the status of Northern Ireland after several years of ambiguity inherited from the Northern Ireland Protocol. For product marking purposes, the principle is as follows: Northern Ireland remains aligned with the European acquis for the free movement of goods, which entails the continued use of the CE marking on most product categories.

When to use CE + UKNI

The UKNI marking is never used alone. It is applied as a complement to the CE marking only in the specific case where:

1. The product is intended for the Northern Ireland market,
2. The conformity assessment procedure was carried out by a UK Approved Body (and not by an EU notified body),
3. The regime concerned requires third-party intervention.

In this case, the CE marking accompanied by UKNI signals to European authorities that the third-party assessment was conducted outside the system of EU notified bodies. A product assessed directly by an EU notified body bears CE only, in accordance with the Union regime.

Cases not requiring UKNI

For products whose assessment procedure does not require third-party intervention (self-declaration, internal conformity check), the CE marking alone is sufficient for Northern Ireland. UKNI only applies to cases where a UK Approved Body has replaced an EU notified body in the procedure.

Case	Marking required for Northern Ireland
Self-declaration, no third party	CE
Assessment by EU notified body	CE
Assessment by UK Approved Body	CE + UKNI

Practical workflow for a British placing on the market in 2026

For a European manufacturer wishing to sell in Great Britain, the rational sequence, starting from an existing CE file, looks like this:

1. Identify the applicable regime for the product (EMC, RED, LVD, machinery, etc.) and check on gov.uk whether the regime is one of the eighteen regimes covered by the indefinite recognition of CE.
2. If the regime is covered by recognition: the existing CE marking is sufficient for placing on the Great Britain market. No separate UKCA procedure is required. See CE procedure for the European sequence.
3. If the regime is not covered (medical, construction, marine, rail, etc.): identify the applicable British statutory instrument, check the designated standards to apply, and engage if necessary a UK Approved Body via the UKMCAB database.
4. Designate an importer or authorised representative established in the UK, and ensure that their name and address appear on the product, packaging or accompanying documentation.
5. Adapt the declaration of conformity: where UKCA is required, draft a UKCA declaration citing the applicable SIs and designated standards. Where CE is recognised, the existing CE declaration remains sufficient but must be made available to British authorities (OPSS and local market surveillance bodies).
6. Retain the technical file under conditions comparable to the CE regime: equivalent structure, comparable retention period, availability on request. See CE technical file.
7. Affix the marking (UKCA, CE, or CE + UKNI depending on the case) in accordance with the visibility, legibility and indelibility rules set out by the applicable statutory instrument.

Substantive differences from the CE regime

Beyond institutional architecture, some regimes have diverged in substance since 2021. Three cases illustrate the amplitude of divergence.

Construction products: the sharpest divergence

The CPR Regulation (EU) 305/2011, transposed into British law as the UK Construction Products Regulation, has not followed recent European evolutions (notably the revision of the CPR adopted in 2024). The UKCA marking remains mandatory for construction products placed on the British market, and the list of designated standards diverges noticeably from the European harmonised list. A French manufacturer of construction products must therefore maintain two distinct technical files in practice, and produce a UK Declaration of Performance (DoP) alongside the CE DoP.

Medical devices: a calendar of their own

Under UK MDR 2002, supplemented by the Medical Devices (Amendment etc.) (EU Exit) Regulations, the MHRA published in 2024 a transitional calendar extending the recognition of CE certificates issued under the former Directive 93/42/EEC up to staggered dates between 2028 and 2030, depending on device class. Beyond those dates, a UKCA issued by a UK medical Approved Body will be required. Manufacturers should follow the MHRA Medical Devices Regulations roadmap setting out the planned trajectory.

Radio: near-complete equivalence

Conversely, the radio regime is one of the most aligned. SI 2017/1206 reproduces the architecture of RED Directive 2014/53/EU, articles 3.1, 3.2 and 3.3 have their British equivalents, and designated standards reproduce the harmonised EN standards (series EN 300 328, EN 301 893, EN 301 489, etc.). The August 2023 recognition covers this regime, and a product compliant with RED can be placed on the British market under CE marking. See RED standards for the detailed list of applicable standards.

Common pitfalls and points of attention

A few mistakes recur in the files of manufacturers discovering the British system:

1. Confusing UKCA and UKNI. UKNI only exists as a complement to CE for Northern Ireland, and only when a UK Approved Body has intervened. Applying it in Great Britain or in place of UKCA is a marking error.
2. Forgetting the UK responsible person. The absence of an identified UK importer or authorised representative on the product is one of the most frequent reasons for British customs to block a shipment.
3. Relying on CE recognition for a non-covered regime. Check regime by regime: the August 2023 indefinite recognition only applies to the eighteen DBT regimes, not to medical devices, construction products, or rail equipment.
4. Citing EU directives in a UKCA declaration. A UKCA declaration must cite the British statutory instruments and the designated standards. A declaration copying CE references is non-compliant.
5. Believing that an EU type-examination certificate is valid for UKCA. Since 1 January 2021, only a certificate issued by a UK Approved Body counts as a UKCA attestation. Where the regime is covered by CE recognition, the European certificate is accepted under the CE marking, not under UKCA.

See also CE procedure and Self-declaration vs notified body for the underlying mechanism, applicable mutatis mutandis to the British regime.

Key takeaways

• UKCA is the post-Brexit British conformity marking, applicable in Great Britain. Northern Ireland remains aligned with CE via the Windsor Framework.
• Since 1 August 2023, the CE marking is recognised indefinitely by the United Kingdom for eighteen regimes (EMC, radio, LVD, toys, machinery, PPE, ATEX, etc.).
• UKCA remains mandatory for regimes excluded from this recognition: medical devices (UK MDR), construction products (UK CPR), rail equipment, marine equipment.
• The designated standards published on gov.uk play the role of harmonised standards. They largely reproduce the EN standards, with a designation lag.
• UK Approved Bodies (UKMCAB database) replace EU notified bodies for regimes requiring a third party.
• A UK-established responsible person (UK importer or authorised representative) is mandatory for any product placed on the British market.
• UKNI is a complementary marking, never standalone, reserved for cases where a UK Approved Body has assessed a product intended for Northern Ireland.

For situating UKCA within the broader regulatory map, see CE marking and free movement, CE marking scope and the Glossary for definitions.

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Sources & references

1. Using the UKCA marking , gov.uk (Office for Product Safety and Standards) www.gov.uk/guidance/using-the-ukca-marking
2. UK Market Conformity Assessment Bodies (UKMCAB) database , gov.uk www.gov.uk/uk-market-conformity-assessment-bodies
3. Government extends recognition of EU product rules to help businesses (1 August 2023) , Department for Business and Trade www.gov.uk/government/news/government-extends-recognition-of-eu-product-rules-to-help-businesses
4. The Windsor Framework , gov.uk www.gov.uk/government/publications/the-windsor-framework
5. The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 (SI 2019/696) , legislation.gov.uk www.legislation.gov.uk/uksi/2019/696/contents/made
6. Placing manufactured goods on the market in Northern Ireland , gov.uk www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-northern-ireland