Do you still need UKCA marking to sell in Great Britain?

For most product categories, no. The UK government announced this on 1 August 2023, and the Product Safety and Metrology etc. (Amendment) Regulations 2024 (in force 1 October 2024) gave it legal effect, with the Product Regulation and Metrology Act 2025 enacted since. CE marking is now recognised indefinitely for eighteen regulatory regimes managed by the Department for Business and Trade, including electromagnetic compatibility, radio equipment, low voltage and machinery. A manufacturer who applies a CE marking in line with EU legislation can therefore place the product on the Great Britain market without an additional UKCA step for those regimes. UKCA remains mandatory for regimes excluded from the recognition, such as medical devices and construction products.

What is the legal difference between CE and UKCA?

CE rests on European Union directives and regulations published in the Official Journal of the European Union, applicable across the twenty-seven member states and the EEA. UKCA rests on British statutory instruments, mostly derived from the Product Safety and Metrology Regulations 2019, which transposed the former directives into domestic law on leaving the Union. The essential requirements are now very close, but the legal references cited in the declaration of conformity differ.

Can an EU notified body issue a UKCA certificate?

No, not since 1 January 2021. For a third-party conformity assessment under the UKCA regime you need a UK Approved Body, designated by a British authority and listed in the UKMCAB database on gov.uk. Conversely, a UK Approved Body cannot issue a certificate for EU CE marking. Where self-assessment by the manufacturer is allowed, no third-party body is required in either system.

Can European harmonised standards be used for UKCA?

Indirectly, yes. The British system relies on designated standards published by the Department for Business and Trade. In practice that list reproduces, regime by regime, the EU harmonised standards, sometimes with a delay of a few months. Designing and testing to EN standards therefore stays valid, provided a matching reference appears on the British designated list at the time the declaration is signed.

How does the Northern Ireland case work?

Northern Ireland follows the Windsor Framework. A product is placed on that market with CE marking if the assessment was carried out by an EU notified body. If the third-party assessment was entrusted to a UK body, the product must carry the CE plus UKNI pair. UKCA alone does not give access to the Northern Ireland market.

Does the UKCA declaration of conformity follow the same format as the CE one?

The content is very close, but the references differ. A UKCA declaration cites British statutory instruments (for example SI 2016/1091 for EMC or SI 2017/1206 for radio) instead of EU directives, and designated standards instead of harmonised standards. The technical headings (product identification, applied standards, signatory) remain equivalent to those of an EU declaration.

Which regimes strictly require UKCA today?

Medical devices under UK MDR 2002, construction products under the British CPR, certain rail and marine equipment, and a few specific regimes. For these categories CE marking is not recognised and UKCA, with assessment by a UK Approved Body where required, stays mandatory for Great Britain. The exact list is maintained by the Office for Product Safety and Standards.

Do you need a UK-based responsible person or importer?

Yes. Any product not originating in the United Kingdom and placed on the Great Britain market must have an importer or an authorised representative established in the UK, whose details appear on the product, its packaging or the documentation. This obligation applies whether the product bears UKCA marking or a recognised CE marking. The EU CE regime imposes the same logic with a representative established in the Union or the EEA.

UKCA vs CE: which marking do you need?

Author Hugues Orgitello Last updated 30 May 2026 ~9 min read

Guide, EU and GB markings

Since the United Kingdom left the European Union, two regulatory markings coexist for the same electronic product: CE marking, which opens the Union and EEA market, and UKCA marking, created for Great Britain. The picture has changed a lot, and the question facing product teams is no longer mainly technical but strategic: which marking do you actually need, and in what order? This guide opens with a side-by-side decision table, then works through each axis (legal basis, scope, assessment bodies, standards, labelling, documentation), before closing with a simple rule to tell which of the two you require for your target markets.

Decision table: which marking for your market

The starting point of a UKCA vs CE comparison is not the list of standards but the geography of your markets. The table below answers the practical question directly.

Target market	Marking required	Third-party assessment	Legal reference
European Union and EEA	CE	EU notified body (if required)	EU directives and regulations
Great Britain (England, Wales, Scotland)	Recognised CE or UKCA	UK Approved Body for UKCA	British statutory instruments
Northern Ireland, EU assessment	CE alone	EU notified body	Windsor Framework
Northern Ireland, GB assessment	CE plus UKNI	UK Approved Body	Windsor Framework
Switzerland	CE (often sufficient)	EU notified body	EU-Switzerland bilateral agreements

Quick reading: for the majority of electronic products (EMC, radio, low voltage, machinery), a compliant CE marking is enough today for Great Britain thanks to the extended recognition announced in August 2023. UKCA only becomes mandatory for the regimes excluded from that recognition, or if you voluntarily choose the British system. To understand the British marking in detail, see the UKCA marking guide.

Legal basis: two parallel systems

The core difference between CE and UKCA is not a difference in technical requirement but in legal framework. Both systems descend from the same body of law, yet their sources have diverged since 2021.

EU side

CE marking rests on a set of directives and regulations adopted at Union level and 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, for radio products, the RED directive 2014/53/EU. These texts set essential requirements without numeric values, and delegate measurable thresholds to harmonised standards. CE marking is valid across the twenty-seven member states and in the EEA countries (Norway, Iceland, Liechtenstein).

Great Britain side

On leaving the Union, the United Kingdom transposed the directives into domestic law through statutory instruments. The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 (SI 2019/696) recast the package of directives into the UKCA regime. In concrete terms, SI 2016/1091 covers EMC, SI 2016/1101 low voltage, and SI 2017/1206 radio equipment. The essential requirements reproduce almost word for word those of the original directives.

Practical consequence

Aspect	CE (Union)	UKCA (Great Britain)
Legal source	EU directives and regulations	British statutory instruments
Reference publication	Official Journal of the Union	Designated standards list (gov.uk)
Territory	EU plus EEA	Great Britain
Surveillance authority	National authorities of the member states	Office for Product Safety and Standards
How requirements evolve	Revision of directives at EU level	Amendment of SIs by the UK Parliament

This divergence is legal before it is technical. An identical product can comply with both regimes from the same design, but its declaration of conformity will cite different texts depending on the market.

Scope and the extended CE recognition

This is the axis that has moved the most, and the one that changes everything in the decision.

The indefinite CE recognition in Great Britain

The UK government announced on 1 August 2023 its intention to recognise CE marking indefinitely for eighteen regulatory regimes managed by the Department for Business and Trade. That date is the announcement only. The operative legal basis came later: the Product Safety and Metrology etc. (Amendment) Regulations 2024, in force 1 October 2024, gave the indefinite recognition legal effect, and the Product Regulation and Metrology Act 2025 has since been enacted as the wider statutory framework. Before that announcement, UKCA was due to become mandatory at a deadline repeatedly postponed. Now, for these regimes, a product carrying a valid CE marking can be placed on the Great Britain market with no additional UKCA procedure and no known end date.

The regimes covered include in particular:

electromagnetic compatibility,
radio equipment,
low-voltage electrical equipment,
machinery,
toys,
pressure equipment.

The regimes excluded from recognition

A few product families stay outside the CE recognition and therefore require UKCA for Great Britain:

medical devices, under the UK MDR 2002 regime,
construction products, under the British CPR,
certain rail equipment,
certain marine equipment.

For these categories, CE does not open the British market and UKCA is mandatory, with assessment by a UK Approved Body where the regime demands it. The current list is maintained by the Office for Product Safety and Standards.

The Northern Ireland case

Northern Ireland is a separate case, governed by the Windsor Framework. CE marking stays fully valid there. The UKNI marking comes into play only when a product destined for Northern Ireland has undergone a third-party assessment entrusted to a British body: in that case the product must carry the CE plus UKNI pair, never UKCA alone. When the assessment is done by an EU notified body, CE alone is sufficient.

Assessment bodies: approved vs notified

Where the regime requires a third-party assessment, the competent body differs by marking. This point often surprises manufacturers used only to the Union system.

EU notified body

A notified body is designated by a member state, listed in the European Commission NANDO database, and authorised to issue certificates for CE marking. For most electronic products under EMC and low voltage, self-assessment by the manufacturer is enough and no notified body is involved. Under the RED directive, a notified body becomes necessary in certain cases, notably when no complete harmonised standard is applied.

UK Approved Body

The British equivalent is the UK Approved Body, designated by a United Kingdom authority and listed in the UKMCAB database on gov.uk. Since 1 January 2021, an EU notified body can no longer issue a UKCA certificate, and conversely a UK Approved Body cannot issue a certificate for EU CE marking. This separation explains why a product needing third-party assessment may require two distinct certificates to cover both markets.

Criterion	Notified body (CE)	UK Approved Body (UKCA)
Designating authority	EU member state	United Kingdom authority
Reference database	NANDO (European Commission)	UKMCAB (gov.uk)
Number on the marking	Four-digit number after the CE	Number after the UKCA
Cross-recognition	None since 2021	None since 2021

Standards: harmonised vs designated

Technical standards are the pivot of both systems, and this is where the two are closest.

Harmonised standards for CE

On the Union side, applying a harmonised standard published in the Official Journal gives a presumption of conformity with the essential requirements covered. For radio, you might cite EN 300 328 for the 2.4 GHz band and the EN 301 489 series for radio EMC. For the full mechanism, see CE harmonised standards.

Designated standards for UKCA

On the British side, the equivalent mechanism uses designated standards published by the Department for Business and Trade. In practice that list reproduces, regime by regime, the same EN references as the Union harmonised list, sometimes with a delay of a few months. A standard such as EN 300 328 thus appears both on the Union harmonised list and on the British designated list.

Consequence for design

Designing and testing to EN standards remains the single valid strategy for both markets. The only point to watch is timing: confirm that a matching reference appears on the British designated list at the moment you sign the UKCA declaration. The lab work itself does not double, since the measured thresholds are identical.

Labelling, documentation and declaration

Once conformity is established, the formal obligations differ on three points: the marking applied, the technical file, and the declaration of conformity.

The marking applied

The CE logo and the UKCA logo are distinct but follow similar rules: minimum height of five millimetres, kept proportions, applied visibly and indelibly. Where a third-party assessment has taken place, the body number follows the marking (notified body after the CE, UK Approved Body after the UKCA).

The technical file

The technical file is almost identical in both systems: product description, risk analysis, list of applied standards, test reports, drawings. A single file serves as the basis for both declarations, provided you adapt the normative and legal references. See Technical documentation file contents for the detail of the expected headings.

The declaration of conformity

The declaration is the document that diverges most. An EU declaration cites the directives and the harmonised standards; a UKCA declaration cites the British statutory instruments and the designated standards. The technical content (identification, standards, signatory, place) stays equivalent. For the full structure on the Union side, see EU declaration of conformity.

Formal element	CE	UKCA
Logo	CE	UKCA
Cited references	EU directives plus harmonised standards	British SIs plus designated standards
Body number	Notified body (if required)	UK Approved Body (if required)
Responsible person	Representative or importer in the Union or EEA	Importer or representative in the UK
File retention	Ten years generally	Ten years generally

Procedure: marking for both markets

For an electronic product destined for both the Union and Great Britain, the pragmatic sequence is as follows.

Design and test to EN standards, which serve both regimes.
Build a single technical file, complete enough to cover the common essential requirements.
Check whether a third-party assessment is required. If so, identify the right body (notified body for CE, UK Approved Body for UKCA).
Check the CE recognition status for the relevant regime in Great Britain. If the regime is recognised, CE is enough and no UKCA step is required.
Draft the EU declaration citing the directives and harmonised standards.
If UKCA is needed (excluded regime or voluntary choice), draft a UKCA declaration citing the British SIs and designated standards, and apply the UKCA marking.
Appoint a responsible person in each territory (representative or importer).

To frame the overall effort, see Certification getting started.

Common pitfalls

Pitfall	Consequence	How to avoid it
Believing UKCA is still mandatory everywhere	Doubled, needless certification costs	Check the CE recognition since August 2023 for the relevant regime
Confusing UKCA and UKNI	Refused access to the Northern Ireland market	Remember: UKCA for Great Britain, CE or CE plus UKNI for Northern Ireland
Asking an EU notified body for a UKCA certificate	Certificate not valid for Great Britain	Use a UK Approved Body listed in UKMCAB
Forgetting the UK responsible person	Product non-compliant at market placement	Appoint a UK importer or representative from the start
Citing EU directives in a UKCA declaration	Invalid declaration	Cite the British statutory instruments and designated standards
Assuming a designated standard matches the harmonised one	Missing reference at signature	Check the British designated list on the declaration date

Which one do you need?

The decision rule fits in a few lines.

You target only the European Union and the EEA: only CE marking is required.
You target the Union and Great Britain, and your product falls under a recognised regime (EMC, radio, low voltage, machinery): CE marking is enough for both markets since August 2023, UKCA is optional.
You target Great Britain for an excluded regime (medical devices, construction products): UKCA marking is mandatory, with a UK Approved Body if a third-party assessment is required.
You sell in Northern Ireland: use CE if the assessment is done by an EU body, or the CE plus UKNI pair if it is entrusted to a British body.

In every case, design and testing to EN standards remain the common foundation. The UKCA vs CE decision therefore turns mostly on regulatory scope and geography, not on the technology.

Sources and references

Sources & references

Using the UKCA marking , gov.uk (Office for Product Safety and Standards) www.gov.uk/guidance/using-the-ukca-marking
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
UK Market Conformity Assessment Bodies (UKMCAB) database , gov.uk www.gov.uk/uk-market-conformity-assessment-bodies
The Windsor Framework , gov.uk www.gov.uk/government/publications/the-windsor-framework
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 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 , legislation.gov.uk www.legislation.gov.uk/ukpga/2025/13/contents
CE marking: Blue Guide on the implementation of EU product rules , EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:C:2022:247:TOC
Placing manufactured goods on the market in Northern Ireland , gov.uk www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-northern-ireland