UKCA marking in 2026: CE recognition, Fast-Track, UKNI
The UKCA marking (UK Conformity Assessed) is the Great Britain conformity marking created after Brexit. Since 1 October 2024 it has been one option among several: in 21 product areas, Great Britain law lets the manufacturer choose UKCA, CE, or a UKCA marking backed by EU conformity assessment (Fast-Track UKCA). This guide sets out, sector by sector and with dates, what the current texts actually require.
TL;DR: UKCA applies in England, Scotland and Wales, not in Northern Ireland and not in the Crown dependencies. The Product Safety and Metrology etc. (Amendment) Regulations 2024 (SI 2024/696, in force 1 October 2024) keep CE recognised and add Fast-Track UKCA. The Product Regulation and Metrology Act 2025 (passed 21 July 2025) gives ministers the power to keep recognising EU requirements, or to stop. Medical devices, construction products, marine equipment, rail, transportable pressure equipment and drones have their own rules. The UKCA label easement ends at 11pm on 31 December 2027. Connected consumer products must also meet the PSTI security regime, whatever the marking. For a side-by-side decision view, see the UKCA vs CE comparison.
Why a separate British marking?
Section titled “Why a separate British marking?”The United Kingdom left the European Union on 31 January 2020 and the transition period ended on 31 December 2020. To keep its product rules working, the government amended the transposed EU product legislation through statutory instruments (SIs), chiefly SI 2019/696, the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019. These created the UKCA marking, UK Approved Bodies and designated standards for Great Britain from 1 January 2021.
The technical logic mirrors CE: essential requirements, presumption of conformity through standards, a conformity assessment procedure, a declaration of conformity and a technical file. The end date for CE recognition in Great Britain was pushed back several times (to 1 January 2023, then to 31 December 2024) before the government changed course in 2023.
Geographic scope
Section titled “Geographic scope”| Territory | Marking used | Who assesses where a third party is mandatory |
|---|---|---|
| England, Scotland, Wales | UKCA, CE (where recognised), or both | UK Approved Body for UKCA; EU notified body for CE or Fast-Track UKCA |
| Northern Ireland | CE, or CE + UKNI | EU notified body (CE alone); UK-based Northern Ireland notified body (CE + UKNI) |
| Guernsey, Jersey, Isle of Man | UKCA and UKNI do not apply | Local rules |
| EU and EEA | CE | EU notified body |
Qualifying Northern Ireland goods can also be placed on the Great Britain market on the basis of their CE, or CE and UKNI, marking (unfettered access).
From announcement to law: the dated sequence
Section titled “From announcement to law: the dated sequence”| Date | Event | Source |
|---|---|---|
| 1 January 2021 | UKCA marking available in Great Britain; CE and UKNI regime in Northern Ireland | SI 2019/696, gov.uk |
| 24 March 2023 | UK formally adopts the Windsor Framework | gov.uk Northern Ireland guidance |
| 1 August 2023 | DBT announces its intention to extend CE recognition indefinitely for its 18 product regulations | DBT news release |
| 29 April 2024 | PSTI security requirements for connectable products in force, UK-wide | SI 2023/1007, reg. 1 |
| 23 May 2024 | SI 2024/696 made | legislation.gov.uk |
| 2 September 2024 | Written ministerial statement: CE marking stays available for construction products | gov.uk construction guidance |
| 1 October 2024 | SI 2024/696 in force: CE recognition and Fast-Track UKCA for 21 product areas | SI 2024/696, reg. 1(2) |
| 21 July 2025 | Product Regulation and Metrology Act 2025 passed; in force that day except section 11(1) and (3) | Act, section 15 |
| 1 January 2026 | UK class marks (UK0 to UK6) required for open-category drones | gov.uk sector guidance |
| January 2026 | Construction Products (Amendment) Regulations 2025 in force | gov.uk sector guidance |
| 16 February 2026 | Consultation opens on indefinite recognition of CE-marked medical devices | gov.uk sector guidance |
| 31 March 2026 | gov.uk replaces "Using the UKCA marking" with new GB, Northern Ireland and Fast-Track UKCA guides | gov.uk |
| 13 April 2026 | Outdoor noise 2025 Regulations in force: CE recognition continued, DoC copy to OPSS no longer required | gov.uk sector guidance |
| 11pm, 31 December 2027 | End of the label or accompanying-document easement for UKCA and for EEA importer details | gov.uk GB guidance |
| 1 January 2028 | Further conformity assessment rules for drones in force | gov.uk sector guidance |
| 30 June 2028 | End of GB acceptance of CE devices under MDD and AIMDD (or certificate expiry if sooner) | MHRA |
| 30 June 2030 | End of GB acceptance of CE devices under IVDD (or certificate expiry if sooner), EU MDR and EU IVDR | MHRA |
What the 2023 announcement covered
Section titled “What the 2023 announcement covered”The 1 August 2023 release listed the 18 DBT regulations: toys, pyrotechnics, recreational craft and personal watercraft, simple pressure vessels, electromagnetic compatibility, non-automatic weighing instruments, measuring instruments, measuring container bottles, lifts, ATEX equipment, radio equipment, pressure equipment, PPE, gas appliances, machinery, equipment for use outdoors, aerosols and low voltage electrical equipment. It was a statement of intention, not law.
What SI 2024/696 does
Section titled “What SI 2024/696 does”SI 2024/696 was made on 23 May 2024 under the Retained EU Law (Revocation and Reform) Act 2023, came into force on 1 October 2024 and extends to England and Wales and Scotland only. According to DBT it covers 21 product areas: the 18 DBT regulations plus regimes owned by DESNZ (ecodesign), HSE (civil explosives) and DEFRA (RoHS). It lets businesses use either UKCA or CE, through UK designated or EU harmonised standards, and introduces Fast-Track UKCA.
Each sector SI receives a "Further use of UK marking" regulation. For radio equipment, regulation 36B of the Radio Equipment Regulations 2017 (substituted by regulation 20(4) of SI 2024/696) sets the conditions:
| Regulation 36B | What it says |
|---|---|
| 36B(2)(a) | The equipment meets the essential requirements of Article 3 of Directive 2014/53/EU |
| 36B(2)(b) | The conformity assessment procedure of Article 17 of the Directive has been carried out |
| 36B(2)(c) | The technical documentation follows Article 21 of the Directive |
| 36B(2)(d) | The technical documentation, records and correspondence on the conformity assessment are in English or translated into English |
| 36B(4) and (5) | Where no designated standard corresponds exactly to the harmonised standard relied on, the manufacturer must use one of the Article 17(4) procedures (EU-type examination plus internal production control, or full quality assurance) for Article 3(2) and 3(3) |
The English-language condition and the designated-standard condition are easy to miss when a CE file is reused for Great Britain.
What the Product Regulation and Metrology Act 2025 adds
Section titled “What the Product Regulation and Metrology Act 2025 adds”The Act does not itself recognise CE. It is a framework of powers for the UK market:
| Section | Power |
|---|---|
| 1(1) | Product regulations to reduce or mitigate product risks, make products operate efficiently or effectively, and make weighing or measuring products accurate |
| 1(2) | Provision corresponding or similar to relevant EU law, for the purpose of reducing the environmental impact of products |
| 1(4)(d) | A product presents a risk if it could cause, or be susceptible to, electromagnetic disturbance |
| 2(2)(e) | Requirements on marketing through online marketplaces |
| 2(2)(l) | Requirements on the appointment of authorised representatives |
| 2(6) | Presumption of compliance through technical standards |
| 2(7) | A product requirement can be treated as met where a specified requirement of relevant EU law is met |
| 15 | In force on the day it was passed, except section 11(1) and (3) |
Section 2(7) is the legal basis for continuing, or ending, recognition of EU requirements regulation by regulation.
Fast-Track UKCA
Section titled “Fast-Track UKCA”Fast-Track UKCA is an optional route described in gov.uk guidance published on 31 March 2026. Where the relevant EU requirements are recognised in Great Britain law, a manufacturer who has met them (by self-declaration or third-party assessment, including assessment by an EU notified body where required) can apply the UKCA marking. When several regulations apply to one product, the manufacturer can combine UK requirements for some and recognised EU requirements for others, then apply UKCA.
DBT also illustrates a hypothetical case in which one regulation mandates UKCA and stops recognising EU requirements. The CE marking then no longer gives access to Great Britain, but Fast-Track UKCA still lets the manufacturer reuse EU evidence for the other regulations. That is the practical reason to know the route now.
Sector by sector: the marking table
Section titled “Sector by sector: the marking table”The gov.uk product marking table, owned by DBT, gives the following position:
| Product type | Great Britain | Northern Ireland | Department |
|---|---|---|---|
| Electrical equipment (LVD), EMC, radio (RED), ATEX, machinery, toys, PPE, pressure equipment, simple pressure vessels, lifts, gas appliances, measuring and non-automatic weighing instruments, pyrotechnics, recreational craft, outdoor noise | UKCA or CE | CE, or UKNI and CE | DBT |
| Ecodesign for energy-related products | UKCA or CE | CE, or UKNI and CE | DESNZ |
| RoHS | UKCA or CE | CE, or UKNI and CE | DEFRA |
| Civil explosives | UKCA or CE | CE, or UKNI and CE | HSE |
| Construction products | UKCA or CE | CE, or UKNI and CE | MHCLG |
| Medical devices | UKCA or CE | CE, or UKNI and CE | MHRA |
| Aerosols, measuring container bottles | UKCA or reversed epsilon | Reversed epsilon, or UKNI and reversed epsilon | DBT |
| Batteries | No product marking in GB | CE, or UKNI and CE | DEFRA |
| Marine equipment | Red Ensign | Red Ensign (single UK ship registry) | DfT (MCA) |
| Rail interoperability constituents | No marking; UK or EU declaration of conformity | CE, or UKNI and CE | DfT |
| Transportable pressure equipment | Rho | Pi | DfT |
| Drones (open category) | UK0 to UK6 class marks | UK0 to UK6 class marks | DfT (CAA) |
The same page pairs each UK instrument with the EU text that can be used today. Two pairs show how recognition follows current EU law: the Supply of Machinery (Safety) Regulations 2008 are paired with Machinery Regulation (EU) 2023/1230, and the Radio Equipment Regulations 2017 with Directive 2022/2380, the common charger amendment to the RED.
Medical devices
Section titled “Medical devices”Under the Medical Devices Regulations 2002 (SI 2002/618), the MHRA accepts CE-marked devices in Great Britain until 30 June 2028 for devices under the MDD or AIMDD, and until 30 June 2030 for IVDD devices and for devices under EU MDR and EU IVDR, or until certificate expiry if sooner for directive certificates. A consultation on indefinite recognition opened on 16 February 2026. UK Approved Bodies cannot assess for CE. A manufacturer based outside the UK must appoint a single UK responsible person, who registers the devices with the MHRA. See the EU MDR guide.
Construction products
Section titled “Construction products”On 2 September 2024 a written ministerial statement confirmed that the CE marking stays available for construction products in Great Britain. DBT describes this as continued recognition subject to system-wide reform, with any later change to CE recognition subject to a minimum two-year transitional period. The Construction Products (Amendment) Regulations 2025 came into force in January 2026, and a reform white paper in February 2026 confirmed the intention to keep CE recognition. To affix UKCA, third-party tasks must be done by a UK approved body. Designated construction product standards are the main case where designated standards are mandatory rather than voluntary. See CPR and EN 50575.
Designated standards
Section titled “Designated standards”A designated standard is recognised by government when its reference is published on gov.uk in a notice of publication. The Office for Product Safety and Standards (OPSS) coordinates designation across departments and maintains the pages; the department owning each regulation decides. Proposals are published for 28 days so that interested parties can object, and references are published on day 29 unless the proposal is withdrawn, amended or objected to. A standard can be designated in full, with restrictions, or not at all, and a replaced standard keeps giving presumption of conformity during a transition period stated in the notice.
Where a designated standard carries an EN prefix, the technical file may cite it as EN, BS EN or another national adoption (for example EN 71-1:2014+A1:2018). Under the 2024 Regulations, EU harmonised standards (published in the OJEU) also give presumption of conformity in Great Britain where the EU requirements are recognised, which is how a CE file built on EN 300 328 or EN 301 489 is reused. For radio, see the condition in regulation 36B(4) and (5) above, and the RED standards page for the EU list.
UK Approved Bodies and the UKMCAB database
Section titled “UK Approved Bodies and the UKMCAB database”Where a regulation requires third-party assessment for UKCA, the body must be a UK Approved Body, accredited by UKAS and listed in the UKMCAB database (now the "Find a conformity assessment body" service). UK Approved Bodies can only certify for UKCA. EU notified bodies, listed in NANDO, certify against EU requirements, which can be used in Great Britain under CE recognition or Fast-Track UKCA. For Northern Ireland, UKMCAB also lists the UK-based Northern Ireland notified bodies. Where the regulation requires it, the body number appears on the product. A UK Approved Body certificate is the attestation behind a UKCA marking only, never behind a CE marking.
Economic operators and documentation
Section titled “Economic operators and documentation”Importer details and authorised representatives
Section titled “Importer details and authorised representatives”A manufacturer and an importer must each give their name, registered trade name or trademark, and postal address on the product. Where this is not possible (for example a product too small), the legislation may allow the packaging or an accompanying document. An importer is a business established in the UK that supplies a product from outside the UK.
An authorised representative is established in the UK and appointed in writing by the manufacturer. Gov.uk states that the role may be essential or voluntary depending on the regulation; medical devices are the clearest case where a UK-based person is mandatory. An EU authorised representative does not fill a UK role.
Declaration of conformity and technical file
Section titled “Declaration of conformity and technical file”The UK declaration of conformity may reference UK legislation or recognised EU product regulations, and UK designated or EU harmonised standards, with their dates. Gov.uk provides a model declaration. Technical documentation is kept for the period set in each regulation, typically 10 years after each individual product is placed on the Great Britain market. See CE technical file.
Marking rules and the 2027 easement
Section titled “Marking rules and the 2027 easement”UKCA and CE markings must keep their standard form, stay proportionate if resized, be at least 5 mm high unless the legislation sets another minimum, and be visible, legible and indelible. Both may appear on the same product.
Until 11pm on 31 December 2027, the UKCA marking may be placed on a label affixed to the product or on an accompanying document instead of the product itself. For products imported from an EEA state (or in some cases Switzerland) before that time, importer details can be given in an accompanying document or on the packaging. Specific rules apply to cableway installations, construction products, marine equipment, medical devices, rail products, transportable pressure equipment and drones. A manufacturer that plans to use UKCA after 2027 needs a marking area designed into the product.
Northern Ireland and UKNI
Section titled “Northern Ireland and UKNI”Under the Windsor Framework, formally adopted by the UK on 24 March 2023, the relevant EU rules on manufactured products apply in Northern Ireland. Products carry the CE marking. Where a UK-based Northern Ireland notified body carried out mandatory third-party assessment, the UKNI marking is added next to the CE marking. UKNI is never used alone.
| Case | Marking for Northern Ireland |
|---|---|
| Self-declaration, no mandatory third party | CE |
| Third-party assessment by an EU notified body | CE |
| Third-party assessment by a UK-based Northern Ireland notified body | CE + UKNI |
| Assessment by a UK Approved Body (UKCA) | Not valid for Northern Ireland |
Connected products: PSTI applies in addition
Section titled “Connected products: PSTI applies in addition”CE recognition only answers the conformity marking question. Consumer connectable products placed on the UK market must also meet the security requirements of the Product Security and Telecommunications Infrastructure Act 2022, set by SI 2023/1007. These Regulations came into force on 29 April 2024 and extend to England and Wales, Scotland and Northern Ireland. Schedule 1 covers passwords (unique per product or defined by the user, and not based on incremental counters or public information), information on how to report security issues, and information on the minimum security update period. See the EN 303 645 guide.
Claims the texts contradict
Section titled “Claims the texts contradict”| Common claim (including earlier versions of this page) | What the texts say |
|---|---|
| An EU notified body certificate can never support a UKCA marking | Since 1 October 2024, Fast-Track UKCA lets a manufacturer apply UKCA on the basis of recognised EU requirements, including EU notified body assessment (gov.uk Fast-Track UKCA guidance) |
| A UKCA declaration must cite UK statutory instruments only | A UK declaration can reference UK legislation or recognised EU product regulations, and designated or harmonised standards (gov.uk GB guidance, section 5) |
| UKNI follows assessment by a UK Approved Body | UKNI follows assessment by a UK-based Northern Ireland notified body; UK Approved Bodies only certify for UKCA (gov.uk Northern Ireland and GB guidance) |
| Construction products have indefinite CE recognition | CE recognition continues subject to system-wide reform, with a minimum two-year transitional period before any change (gov.uk sector guidance) |
| The government has announced a future consultation on CE-marked medical devices | The consultation on indefinite recognition opened on 16 February 2026 (gov.uk sector guidance) |
| Every non-UK manufacturer needs a UK authorised representative | Importer details are required; an authorised representative is essential or voluntary depending on the regulation; medical devices require a UK responsible person (gov.uk, MHRA) |
| The Product Regulation and Metrology Act 2025 created CE recognition | Recognition comes from SI 2024/696; the Act gives the power, in section 2(7), to keep or end it |
| Designated standard lists are published by DBT with a lag of weeks or months | OPSS maintains the lists; each proposal has a 28-day objection period and is published on day 29 (gov.uk designated standards guidance) |
| CE recognition lets a CE radio file be reused with no condition | Regulation 36B requires English documentation, and Article 17(4) procedures where the harmonised standard used has no exactly corresponding designated standard |
| CE or UKCA covers every regulated product in Great Britain | Marine equipment uses the Red Ensign, transportable pressure equipment Rho, drones UK0 to UK6 class marks, and batteries carry no GB marking |
| UKCA applies across the British Isles | UKCA does not apply in Northern Ireland, the Crown dependencies or the British Overseas Territories |
| A CE marking settles all UK requirements for a connected product | PSTI security requirements apply UK-wide since 29 April 2024, whatever the marking |
See also CE procedure and Self-declaration vs notified body for the underlying mechanism.
Key takeaways
Section titled “Key takeaways”- UKCA applies in England, Scotland and Wales only. Northern Ireland uses CE, or CE + UKNI, under the Windsor Framework.
- SI 2024/696, in force since 1 October 2024, keeps CE recognised in Great Britain for 21 product areas and adds Fast-Track UKCA.
- The Product Regulation and Metrology Act 2025 (21 July 2025) holds the power to keep or end recognition of EU requirements.
- Medical devices: CE accepted until 30 June 2028 or 2030, consultation on indefinite recognition opened 16 February 2026. Construction products: CE continues subject to reform, with at least two years of notice before any change.
- Marine, rail, transportable pressure equipment, batteries and drones follow their own marking rules.
- The UKCA label easement ends at 11pm on 31 December 2027.
- PSTI applies to consumer connectable products UK-wide, whatever the marking.
For situating UKCA within the broader regulatory map, see CE marking and free movement, CE marking scope and the Glossary for definitions.
Sources & references
- Placing UKCA or CE marked products on the market in Great Britain, gov.uk (Department for Business and Trade) www.gov.uk/guidance/placing-ukca-or-ce-marked-products-on-the-market-in-great-britain
- Product regulations by sector and current approaches to product marking: UKCA and CE regimes, gov.uk (Department for Business and Trade) www.gov.uk/government/publications/product-regulations-by-sector-and-current-approaches-to-product-marking-ukca-and-ce-regimes/product-regulations-by-sector-and-current-approaches-to-product-marking-ukca-and-ce-regimes
- Fast-Track UKCA: UKCA and CE regimes, gov.uk (Department for Business and Trade) www.gov.uk/guidance/fast-track-ukca-ukca-and-ce-regimes
- Product safety and metrology regulatory changes: UKCA and CE regimes, gov.uk (Department for Business and Trade) www.gov.uk/government/publications/product-safety-and-metrology-regulatory-changes-ukca-and-ce-regimes/product-safety-and-metrology-regulatory-changes-ukca-and-ce-regimes
- The Product Safety and Metrology etc. (Amendment) Regulations 2024 (SI 2024/696), legislation.gov.uk www.legislation.gov.uk/uksi/2024/696/contents/made
- Product Regulation and Metrology Act 2025 (c. 20), legislation.gov.uk www.legislation.gov.uk/ukpga/2025/20/contents
- UK Government announces extension of CE mark recognition for businesses (1 August 2023), Department for Business and Trade www.gov.uk/government/news/uk-government-announces-extension-of-ce-mark-recognition-for-businesses
- Placing CE, or CE and UKNI marked products on the market in Northern Ireland, gov.uk (Department for Business and Trade) www.gov.uk/guidance/placing-ce-or-ce-and-ukni-marked-products-on-the-market-in-northern-ireland
- The Windsor Framework, gov.uk www.gov.uk/government/publications/the-windsor-framework
- Find a conformity assessment body (UKMCAB database), gov.uk find-a-conformity-assessment-body.service.gov.uk/
- Designated standards, gov.uk (Office for Product Safety and Standards) www.gov.uk/guidance/designated-standards
- Regulating medical devices in the UK, gov.uk (MHRA) www.gov.uk/guidance/regulating-medical-devices-in-the-uk
- Construction Products Regulation in Great Britain, gov.uk (MHCLG and OPSS) www.gov.uk/guidance/construction-products-regulation-in-great-britain
- 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
- Product Security and Telecommunications Infrastructure Act 2022 (c. 46), legislation.gov.uk www.legislation.gov.uk/ukpga/2022/46/contents
- The PSTI (Security Requirements for Relevant Connectable Products) Regulations 2023 (SI 2023/1007), legislation.gov.uk www.legislation.gov.uk/uksi/2023/1007/contents/made
Frequently asked questions
- Is the CE marking still accepted in Great Britain?
- Yes, for most sectors. The Department for Business and Trade announced on 1 August 2023 its intention to extend CE recognition indefinitely for the 18 product regulations it owns. The Product Safety and Metrology etc. (Amendment) Regulations 2024 (SI 2024/696), in force since 1 October 2024, put this into law for 21 product areas, adding regimes owned by DESNZ, HSE and DEFRA (ecodesign, civil explosives, RoHS). Construction products and medical devices have their own CE arrangements, and some sectors use other marks (Red Ensign for marine equipment, UK0 to UK6 class marks for drones).
- What is Fast-Track UKCA?
- An optional route created by the 2024 Regulations. Where the relevant EU requirements are recognised in Great Britain law, a manufacturer who has met them (including, where required, assessment by an EU notified body) can apply the UKCA marking instead of, or as well as, the CE marking. For a product under several regulations, UK and EU routes can be mixed regulation by regulation.
- What is the difference between UKCA and UKNI?
- UKCA is the Great Britain marking (England, Scotland, Wales). In Northern Ireland the EU rules apply under the Windsor Framework, so products carry the CE marking. UKNI is never used alone: it is added next to CE when the mandatory third-party assessment was done by a UK-based Northern Ireland notified body rather than an EU notified body. UK Approved Bodies can only certify for UKCA.
- Is UKCA mandatory today?
- Not in the sectors where CE is recognised: there the manufacturer chooses UKCA, CE, or both. UKCA becomes the only route where Great Britain law stops recognising the EU requirements. For medical devices, CE-marked devices are accepted until 30 June 2028 or 30 June 2030 depending on the EU legislation, and a consultation on indefinite recognition opened on 16 February 2026.
- How long can the UKCA marking go on a label or accompanying document?
- Until 11pm on 31 December 2027. Until then the UKCA marking may be placed on a label affixed to the product or on an accompanying document, and importer details for goods imported from the EEA (or in some cases Switzerland) can be given on the packaging or an accompanying document. Construction products, medical devices, marine equipment, rail products, cableway installations, transportable pressure equipment and drones have specific rules.
- Does a non-UK manufacturer need a UK authorised representative?
- Not as a general rule. The UK importer must put its name and postal address on the product, and gov.uk states that an authorised representative may be essential or voluntary depending on the regulation. Medical devices are the main exception: a manufacturer based outside the UK must appoint a single UK responsible person to register its devices with the MHRA.
- Must a UKCA declaration of conformity cite only UK legislation?
- No. Current gov.uk guidance says a UK declaration of conformity can reference either UK legislation or the recognised EU product regulations, and either UK designated standards or EU harmonised standards, with their dates.
- Does CE recognition cover the UK cyber security rules for connected products?
- No. The Product Security and Telecommunications Infrastructure (PSTI) Act 2022 and SI 2023/1007, in force since 29 April 2024 across the whole UK including Northern Ireland, set their own security requirements for consumer connectable products (passwords, vulnerability reporting, security update period). They apply whatever conformity marking the product carries.