UKCA vs CE marking in 2026: what actually differs
The difference between UKCA and CE marking is territorial and legal, not technical. CE, based on EU law, opens the European Union and EEA market and, under the Windsor Framework, Northern Ireland. UKCA, based on the Great Britain product regulations, covers England, Scotland and Wales. Since 1 October 2024, Great Britain law accepts CE in 21 product areas with no end date, and lets a UKCA marking rest on EU conformity assessment (Fast-Track UKCA).
TL;DR: For electronics (EMC, low voltage, radio, RoHS, ecodesign), a compliant CE marking is enough for Great Britain today, and UKCA is an option. SI 2024/696 (in force 1 October 2024) removed the expiry of CE recognition and created Fast-Track UKCA. The Product Regulation and Metrology Act 2025 lets ministers keep or end recognition regulation by regulation. A UK declaration can cite EU law and harmonised standards. Two conditions are often missed: English-language documentation, and for radio, the designated-standard gap rule. Northern Ireland uses CE, or CE + UKNI when a UK-based Northern Ireland notified body did the mandatory assessment. Medical devices, construction products, marine, rail, transportable pressure equipment and drones follow their own rules.
UKCA vs CE side by side
Section titled “UKCA vs CE side by side”| Aspect | CE marking | UKCA marking |
|---|---|---|
| Territory | European Union, EEA, and Northern Ireland (Windsor Framework) | Great Britain (England, Scotland, Wales); not Northern Ireland, the Crown dependencies or the British Overseas Territories |
| Legal basis | EU directives and regulations (for example 2014/30/EU, 2014/35/EU, 2014/53/EU) | Great Britain product regulations (for example SI 2016/1091, SI 2016/1101, SI 2017/1206) |
| Accepted in Great Britain | Yes in the 21 recognised product areas (SI 2024/696) | Yes |
| Accepted in the EU | Yes | No |
| Third-party body | EU notified body (NANDO) | UK Approved Body (UKMCAB); or an EU notified body under Fast-Track UKCA |
| Standards giving presumption of conformity | Harmonised standards (OJEU) | UK designated standards, or EU harmonised standards where the EU requirements are recognised |
| Declaration of conformity | EU declaration citing EU law | UK declaration citing UK legislation or recognised EU regulations |
| Economic operator in the territory | Operator established in the Union for the products listed in Article 4 of Regulation (EU) 2019/1020 | UK importer details on the product; UK authorised representative essential or voluntary depending on the regulation |
| Label or document instead of the product | Only where the directive allows it | UKCA may go on a label or accompanying document until 11pm on 31 December 2027 |
For the British marking in detail, sector by sector, see the UKCA marking guide.
Decision table: which marking for which market
Section titled “Decision table: which marking for which market”| Target market | What you can use | Third party, where the regulation requires one |
|---|---|---|
| European Union and EEA | CE | EU notified body |
| Great Britain, recognised sector | CE, UKCA, or both | EU notified body for CE or Fast-Track UKCA; UK Approved Body for UKCA on UK requirements |
| Great Britain, sector with its own rules | See the sector rules (medical devices, construction, marine, rail, transportable pressure equipment, drones, batteries) | As set by the sector regulation |
| Northern Ireland, self-declaration or EU notified body | CE | EU notified body |
| Northern Ireland, UK-based Northern Ireland notified body | CE + UKNI | UK-based Northern Ireland notified body |
| Northern Ireland, UK Approved Body certificate | Not valid | None |
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).
Legal basis: two systems, one of which recognises the other
Section titled “Legal basis: two systems, one of which recognises the other”EU side
Section titled “EU side”CE marking rests on directives and regulations published in the Official Journal of the European Union. For electronics the central texts are the EMC directive 2014/30/EU, the low voltage directive 2014/35/EU and the radio equipment directive 2014/53/EU. They set essential requirements and leave measurable limits to harmonised standards.
Great Britain side
Section titled “Great Britain side”The Great Britain regulations are not a post-Brexit copy. The Electromagnetic Compatibility Regulations 2016, the Electrical Equipment (Safety) Regulations 2016 and the Radio Equipment Regulations 2017 transposed the directives while the UK was a member state. SI 2019/696 then amended them for EU exit, creating the UKCA marking, UK Approved Bodies and designated standards from 1 January 2021, and inserting the provisions under which CE-marked products are treated as compliant in Great Britain (for example regulation 38A of the EMC Regulations and regulation 36A of the Radio Equipment Regulations).
Those recognition provisions originally had an expiry date that was pushed back several times. The explanatory note to SI 2024/696 states that it revokes "provision that sets out the expiry" of the provisions allowing Great Britain obligations to be met by complying with the corresponding EU law, and replaces it with Fast-Track UKCA. That is why the recognition has no end date today, not because of the 2023 announcement.
The dated sequence
Section titled “The dated sequence”| Date | Event | Source |
|---|---|---|
| 1 January 2021 | UKCA, UK Approved Bodies and designated standards in force in Great Britain; CE and UKNI regime in Northern Ireland | SI 2019/696 |
| 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 (a statement of intention, not law) | DBT news release |
| 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 sector guidance |
| 1 October 2024 | SI 2024/696 in force (England and Wales, Scotland): CE recognition without expiry and Fast-Track UKCA in 21 product areas | SI 2024/696, regulation 1 |
| 21 July 2025 | Product Regulation and Metrology Act 2025 passed | Act, section 15 |
| 21 January 2026 | Radio designated standards consolidated list version 10 | gov.uk designated standards |
| 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 separate Great Britain, Northern Ireland and Fast-Track UKCA guides | gov.uk |
| 11pm, 31 December 2027 | End of the easement allowing UKCA on a label or accompanying document | gov.uk Great Britain guidance |
| 30 June 2028 | End of Great Britain acceptance of CE devices under the MDD and AIMDD (or certificate expiry if sooner) | MHRA |
| 30 June 2030 | End of Great Britain acceptance of CE devices under the IVDD, EU MDR and EU IVDR | MHRA |
What the Product Regulation and Metrology Act 2025 changes
Section titled “What the Product Regulation and Metrology Act 2025 changes”The Act does not itself recognise CE; recognition comes from SI 2024/696. The Act is a framework of powers. Section 2(7) allows product regulations to treat a UK requirement as met where a specified requirement of relevant EU law is met, and section 2(6) provides for presumption of compliance through technical standards. It is the legal tool for continuing, or ending, recognition sector by sector, so the comparison on this page is a snapshot that can change by secondary legislation.
The conditions behind "CE is accepted in Great Britain"
Section titled “The conditions behind "CE is accepted in Great Britain"”Recognition is not unconditional. The UK regulations list what the manufacturer must have done. For the two regimes that matter most for electronics, the texts read as follows.
| Condition | EMC Regulations 2016, reg. 38A (CE route) | Radio Equipment Regulations 2017, reg. 36A (CE route) |
|---|---|---|
| Essential requirements | Annex I of Directive 2014/30/EU, reg. 38A(2)(a) | Article 3 of Directive 2014/53/EU, reg. 36A(2)(a) |
| Conformity assessment | Article 14 procedure, reg. 38A(2)(c) | Article 17 procedure, reg. 36A(2)(b) |
| Technical documentation | Annex III, reg. 38A(2)(b) | Article 21, reg. 36A(2)(d) |
| Technical documentation and assessment records in English | Required, reg. 38A(2)(d) | Required, reg. 36A(2)(e) |
| EU declaration of conformity | Article 15, in or translated into English, reg. 38A(2)(f) and (g) | Article 18, in or translated into English, reg. 36A(2)(f) and (g) |
| Marking | CE under Articles 16 and 17, reg. 38A(2)(e) | CE, plus the notified body number where Annex IV is used, reg. 36A(2)(c) |
| Designated-standard gap | No equivalent condition | Where no designated standard corresponds exactly to the harmonised standard used, Article 17(4) procedures apply for Article 3(2) and 3(3), reg. 36A(6) and (7) |
The Fast-Track UKCA versions (regulation 38B of the EMC Regulations and regulation 36B of the Radio Equipment Regulations, both substituted by SI 2024/696) repeat the English-language condition, and regulation 36B(4) and (5) repeat the radio designated-standard condition.
In practice: an EU file written only in German or French does not meet the Great Britain conditions until it is translated, and a radio product that relies on a harmonised standard with no exactly corresponding designated standard needs a notified body procedure for Great Britain even if self-declaration was enough in the EU.
Self-declaration: where Great Britain allows it
Section titled “Self-declaration: where Great Britain allows it”Gov.uk lists the UK regulations under which a manufacturer can self-declare conformity under the UKCA regime. For the regulations most used in electronics:
| UK regulation | Self-declaration allowed for |
|---|---|
| Electrical Equipment (Safety) Regulations 2016 | All products |
| Electromagnetic Compatibility Regulations 2016 | All products |
| Radio Equipment Regulations 2017 | All products, except where designated standards covering the essential requirements do not exist or have not been applied in full |
| RoHS Regulations 2012 | All products |
| Ecodesign for Energy-Related Products Regulations 2010 | Products in Schedule 1, except boilers under retained Regulation (EU) 813/2013 |
| Supply of Machinery (Safety) Regulations 2008 | Machinery not in Schedule 2, Part 4; or Part 4 machinery where all relevant designated standards are applied in full and cover all essential requirements |
| Toys (Safety) Regulations 2011 | All products, except where designated standards do not exist, are not applied in full, or are published with a restriction |
Assessment bodies: approved, notified and Northern Ireland notified
Section titled “Assessment bodies: approved, notified and Northern Ireland notified”| Criterion | EU notified body | UK Approved Body | UK-based Northern Ireland notified body |
|---|---|---|---|
| Database | NANDO (European Commission) | UKMCAB | UKMCAB |
| Accreditation | National accreditation body of the member state | UKAS | Listed in UKMCAB for the Northern Ireland market |
| Marking it supports | CE in the EU and Northern Ireland; CE or Fast-Track UKCA in Great Britain | UKCA only | CE + UKNI in Northern Ireland |
The common reading that "since 2021 an EU notified body can never support UKCA" stopped being true on 1 October 2024. What remains true is that a UK Approved Body certifies only for UKCA. Where the regulation requires it, the body number appears on the product. For the underlying choice between self-declaration and a third party, see Self-declaration vs notified body.
Standards: harmonised and designated
Section titled “Standards: harmonised and designated”In the EU, applying a harmonised standard cited in the Official Journal gives a presumption of conformity. In Great Britain, a designated standard is recognised when its reference is published on gov.uk in a notice of publication; the Office for Product Safety and Standards coordinates designation and each proposal has a 28-day objection period. Under the 2024 Regulations, EU harmonised standards also give presumption of conformity in Great Britain where the EU requirements are recognised.
The lists are similar but not identical, and the radio case shows why it matters. The radio equipment consolidated list version 10 (21 January 2026) designates, for example, EN 300 328 V2.2.2 for 2.4 GHz wideband systems (see EN 300 328) and parts of the EN 301 489 series, some with restrictions. It contains no EN 18031 reference: the EU cybersecurity requirements of RED Article 3(3)(d), (e) and (f), applicable in the EU since 1 August 2025, have no designated counterpart in that list. Connected consumer products in the UK are instead covered by the PSTI security regime (see below). For the EU lists, see CE harmonised standards and RED standards.
Documentation and marking
Section titled “Documentation and marking”| Formal element | CE (EU) | UKCA (Great Britain) |
|---|---|---|
| Declaration of conformity | EU declaration citing EU legislation and harmonised standards | UK declaration citing UK legislation or recognised EU regulations, and designated or harmonised standards, with dates; gov.uk publishes a template |
| Language in Great Britain | EU declaration and technical documentation in or translated into English (CE route) | Instructions in easily understandable English |
| Technical file retention | Set by each act, typically 10 years after placing on the market | Set by each regulation, typically 10 years after each individual product is placed on the Great Britain market |
| Marking form | At least 5 mm unless the act sets another minimum, visible, legible, indelible | Same rules; UKCA and CE may appear together |
| Where the marking goes | On the product or data plate; packaging and documents only where that is not possible | On the product, or on a label or accompanying document until 11pm on 31 December 2027 |
A single technical file can support both markings, provided the references, the language and (for radio) the standards check above are handled. See Technical documentation file contents and EU declaration of conformity.
Sectors outside the general rule
Section titled “Sectors outside the general rule”| Sector | Great Britain position |
|---|---|
| Medical devices | CE accepted until 30 June 2028 (MDD, AIMDD) or 30 June 2030 (IVDD, EU MDR, EU IVDR), or certificate expiry if sooner; consultation on indefinite recognition opened 16 February 2026; a UK responsible person is required for manufacturers outside the UK. See the EU MDR guide |
| Construction products | CE recognition continues subject to system-wide reform, with a minimum two-year transitional period before any change; designated construction standards are mandatory. See CPR and EN 50575 |
| Marine equipment | Red Ensign marking (the EU uses the Wheelmark) |
| Rail interoperability constituents | No marking; UK or EU declaration of conformity |
| Transportable pressure equipment | Rho marking |
| Open-category drones | UK0 to UK6 class marks since 1 January 2026 |
| Batteries | No product marking in Great Britain; CE, or UKNI and CE, in Northern Ireland |
| Aerosols, measuring container bottles | UKCA or reversed epsilon |
Connected products: PSTI applies whatever the marking
Section titled “Connected products: PSTI applies whatever the marking”Neither CE nor UKCA answers the UK security rules for consumer connectable products. The Product Security and Telecommunications Infrastructure Act 2022 and SI 2023/1007, in force since 29 April 2024 across the UK including Northern Ireland, set requirements on passwords, vulnerability reporting and the minimum security update period. In the EU, the RED delegated act applies from 1 August 2025 and the Cyber Resilience Act applies its reporting obligations from 11 September 2026 and in full from 11 December 2027. A product sold in both markets has to meet both sets. See the EN 303 645 guide.
Procedure: one product, both markets
Section titled “Procedure: one product, both markets”- Identify every regulation that applies, in the EU and in Great Britain, and check the gov.uk sector table for each.
- Design and test to the EU harmonised standards; for radio, check the UK designated list for an exactly corresponding reference.
- Run the EU conformity assessment (self-declaration or notified body).
- Write the technical documentation and EU declaration in English, or have them translated.
- Choose the Great Britain route: CE alone, or UKCA through Fast-Track on the same evidence, or UKCA on UK requirements with a UK Approved Body where required.
- For Northern Ireland, use CE (or CE + UKNI if a UK-based Northern Ireland notified body was used).
- Put the EU economic operator and the UK importer details on the product, and check PSTI for connected consumer products.
To frame the overall effort, see Certification getting started.
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 cannot support a UKCA marking since 2021 | Since 1 October 2024, Fast-Track UKCA lets UKCA rest on recognised EU requirements, including EU notified body assessment (gov.uk Fast-Track UKCA guidance) |
| A UKCA declaration must cite UK statutory instruments and designated standards | A UK declaration can cite UK legislation or recognised EU regulations, and designated or harmonised standards (gov.uk Great Britain guidance, section 5) |
| The UKCA regulations come from SI 2019/696, which transposed the directives | The directives were transposed by the 2016 and 2017 regulations while the UK was a member state; SI 2019/696 amended them for EU exit |
| The 1 August 2023 announcement made CE recognition indefinite | The announcement was a statement of intention; SI 2024/696, in force 1 October 2024, revoked the expiry provisions |
| 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 guidance) |
| Construction products have indefinite CE recognition | Recognition continues subject to reform, with a minimum two-year transitional period before any change (gov.uk sector guidance) |
| Medical devices move to UKCA after 2028 to 2030 | Those are the current acceptance end dates; a consultation on indefinite recognition opened 16 February 2026 |
| Designated standards copy the harmonised list with a few months of delay | Designation is notice by notice, with a 28-day objection period; the radio list has no EN 18031 reference, and regulation 36A(6) and (7) impose a notified body procedure where no designated standard corresponds exactly |
| CE recognition means a CE file is reused with no change | The UK regulations require the technical documentation and EU declaration in or translated into English (EMC reg. 38A(2)(d) and (g), radio reg. 36A(2)(e) and (g)) |
| Every non-UK product needs a UK authorised representative | The UK importer details are required; an authorised representative is essential or voluntary depending on the regulation (gov.uk Great Britain guidance) |
| CE or UKCA covers every regulated product in Great Britain | Marine equipment uses the Red Ensign, transportable pressure equipment Rho, drones UK class marks, and batteries carry no Great Britain marking |
Which one do you need?
Section titled “Which one do you need?”- EU and EEA only: CE.
- EU and Great Britain, product in a recognised sector (EMC, low voltage, radio, machinery, RoHS, ecodesign and the other areas listed by gov.uk): CE is enough for both, provided the English-language and, for radio, designated-standard conditions are met. UKCA is optional, and Fast-Track UKCA lets you apply it on the same evidence.
- Great Britain, sector with its own rules: follow the sector table above.
- Northern Ireland: CE, or CE + UKNI when a UK-based Northern Ireland notified body did the mandatory assessment.
In every case the technical work is shared; what differs is the legal reference, the body and the paperwork.
Further reading
Section titled “Further reading”- UKCA marking
- EU declaration of conformity
- Technical documentation file contents
- Certification getting started
- Self-declaration vs notified body
- CE pillar
Sources and references
Section titled “Sources and references”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
- 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 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
- 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
- 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
- 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
- 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
- The Electromagnetic Compatibility Regulations 2016, regulation 38A (CE route) and 38B (Fast-Track UKCA), legislation.gov.uk www.legislation.gov.uk/uksi/2016/1091/regulation/38A
- The Radio Equipment Regulations 2017, regulation 36A (CE route), legislation.gov.uk www.legislation.gov.uk/uksi/2017/1206/regulation/36A
- Designated standards: radio equipment (notices and consolidated list v10, 21 January 2026), gov.uk (Department for Business and Trade) www.gov.uk/government/publications/designated-standards-radio-equipment
- Designated standards, gov.uk (Office for Product Safety and Standards) www.gov.uk/guidance/designated-standards
- Find a conformity assessment body (UKMCAB database), gov.uk find-a-conformity-assessment-body.service.gov.uk/
- The Windsor Framework, gov.uk www.gov.uk/government/publications/the-windsor-framework
- 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
- Regulation (EU) 2019/1020 on market surveillance and compliance of products, Article 4, EUR-Lex eur-lex.europa.eu/eli/reg/2019/1020/oj
- The Blue Guide on the implementation of EU product rules 2022 (2022/C 247/01), EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:C:2022:247:TOC
Frequently asked questions
- Do you still need UKCA marking to sell in Great Britain?
- Not in the sectors where Great Britain law recognises the EU requirements. The Product Safety and Metrology etc. (Amendment) Regulations 2024 (SI 2024/696), in force since 1 October 2024, removed the expiry date of CE recognition for 21 product areas, including electrical equipment, EMC, radio, machinery, toys, ecodesign and RoHS. In those sectors the manufacturer chooses UKCA, CE, or both. The Product Regulation and Metrology Act 2025 gives ministers the power to keep or end that recognition regulation by regulation.
- What is the legal difference between CE and UKCA?
- CE rests on EU directives and regulations published in the Official Journal of the European Union. UKCA rests on the Great Britain versions of the product regulations, such as the Electromagnetic Compatibility Regulations 2016 (SI 2016/1091) and the Radio Equipment Regulations 2017 (SI 2017/1206), which were adopted to transpose the directives while the UK was a member state and amended for EU exit by SI 2019/696. CE recognition in Great Britain is itself a provision of those UK regulations.
- Can an EU notified body certificate support a UKCA marking?
- Yes, since 1 October 2024, through Fast-Track UKCA. Where the EU requirements are recognised in Great Britain law, a manufacturer who has completed the EU conformity assessment, including an EU notified body where required, can apply the UKCA marking. The reverse is not true: a UK Approved Body certifies only for UKCA and cannot support a CE marking.
- Can EU harmonised standards be used for UKCA?
- Yes. Gov.uk states that a UK declaration of conformity can reference UK designated standards or EU harmonised standards, with their dates. For radio equipment there is one condition to check: where no designated standard corresponds exactly to the harmonised standard relied on, the Radio Equipment Regulations 2017 require an Article 17(4) procedure (EU-type examination or full quality assurance) for the Article 3(2) and 3(3) requirements.
- How does Northern Ireland work?
- Under the Windsor Framework the relevant EU product rules apply in Northern Ireland, so products carry the CE marking. UKNI is added next to CE only when the mandatory third-party assessment was done by a UK-based Northern Ireland notified body. A UK Approved Body certificate (UKCA) is not valid for Northern Ireland, and UKNI is never used alone.
- Must a UKCA declaration of conformity cite UK statutory instruments?
- Not necessarily. Current gov.uk guidance says a UK declaration of conformity can reference either UK legislation or the recognised EU product regulations, and either designated or harmonised standards. When the CE route itself is used in Great Britain, the EU declaration of conformity must be prepared in or translated into English, a condition written into the UK regulations.
- Which sectors have their own rules?
- Medical devices: CE-marked devices are accepted in Great Britain until 30 June 2028 or 30 June 2030 depending on the EU legislation, and a consultation on indefinite recognition opened on 16 February 2026. Construction products: CE recognition continues subject to reform, with at least two years of transition before any change. Marine equipment uses the Red Ensign, transportable pressure equipment the Rho marking, open-category drones UK0 to UK6 class marks, and batteries carry no Great Britain marking.
- Do you need a UK-based importer or authorised representative?
- The UK importer of a product made outside the UK must give its name and postal address on the product, whatever the marking. An authorised representative established in the UK is essential or voluntary depending on the regulation; medical devices require a UK responsible person. On the EU side, Article 4 of Regulation (EU) 2019/1020 requires an economic operator established in the Union for products under the EMC, LVD and RED directives, among others.