UKCA marking: the complete guide
Updated May 2025 · 9 min read
The UKCA (UK Conformity Assessed) mark replaced CE marking for the Great Britain market after Brexit. If you sell regulated products in England, Wales, or Scotland, you need to understand how UKCA works — and how it differs from CE.
What is UKCA marking?
UKCA is the UK equivalent of CE marking. It demonstrates that a product meets the applicable UK product safety regulations and is required before placing regulated products on the Great Britain (England, Wales, Scotland) market.
UKCA was introduced when the UK left the EU single market. Because UK product safety legislation largely mirrors EU directives (retained EU law), the underlying technical requirements for most product categories are essentially identical — only the marking, documentation, and sometimes the conformity assessment route differ.
CE vs UKCA: what's different?
| Aspect | CE marking | UKCA marking |
|---|---|---|
| Market | EU / EEA | Great Britain (England, Wales, Scotland) |
| Legislation | EU Directives / Regulations | UK Statutory Instruments (retained EU law) |
| Technical requirements | EU harmonised standards | UK Designated Standards (same content, different reference) |
| Third-party assessment | EU Notified Bodies | UK Approved Bodies |
| Declaration | EU Declaration of Conformity | UK Declaration of Conformity |
| Mark acceptance cross-border | Not accepted in GB (from Jan 2025) | Not accepted in EU |
| Northern Ireland | Required (Windsor Framework) | Not required in NI |
UK Statutory Instruments (the UK regulations)
The key UK product safety regulations corresponding to EU directives are:
- Electromagnetic Compatibility Regulations 2016 (SI 2016/1091) — mirrors EMC Directive 2014/30/EU
- Electrical Equipment (Safety) Regulations 2016 (SI 2016/1101) — mirrors LVD 2014/35/EU
- Radio Equipment Regulations 2017 (SI 2017/1206) — mirrors RED 2014/53/EU
- Supply of Machinery (Safety) Regulations 2008 (SI 2008/1597) — mirrors Machinery Directive 2006/42/EC
- Construction Products Regulations 2013 (SI 2013/1387) — mirrors CPR
- Medical Devices Regulations 2002 (SI 2002/618, as amended) — mirrors MDR/IVDR
The MHRA maintains a list of designated standards that give presumption of conformity with UK regulations — these mirror the EU harmonised standards and are usually identical in technical content.
UK Approved Bodies
For products requiring third-party conformity assessment (equivalent of EU Notified Body involvement), you must use a UK Approved Body for UKCA marking. EU Notified Body certificates issued after 31 December 2020 are not accepted for UKCA.
UK Approved Bodies are accredited by UKAS (United Kingdom Accreditation Service). Search the register at ukas.com. Many organisations that were EU Notified Bodies (e.g. Intertek, SGS, TÜV SÜD UK, Eurofins) are also UK Approved Bodies for the same product categories.
For most electronic products (EMC, LVD, RED self-declaration routes), no Approved Body is needed — the requirement only applies where the EU route would also require a Notified Body.
Northern Ireland — the Windsor Framework
Northern Ireland has special rules
Under the Windsor Framework, Northern Ireland remains aligned with EU product regulations. Products placed on the NI market must carry the CE mark (not UKCA). A special UKNI mark exists for products requiring third-party assessment that used a UK Approved Body — but this mark only allows sale in NI, not in the EU.
In practice: if you sell across the whole UK including Northern Ireland, you may need both CE (for NI) and UKCA (for GB) certification.
Selling in both GB and the EU
If you sell the same product in both markets, you need both CE and UKCA marks. The good news is that the technical requirements are essentially identical, so:
- One set of testing and one Technical File can usually serve both marks
- You must produce two separate Declarations of Conformity (EU DoC and UK DoC)
- For third-party assessment products, you need both an EU Notified Body certificate (for CE) and a UK Approved Body certificate (for UKCA)
- The product can carry both marks on the same label
How to affix the UKCA mark
The UKCA mark must be applied to the product, its packaging, or accompanying documentation. Requirements:
- Minimum height: 5mm (same as CE)
- Must be clearly visible, legible, and indelible
- Must be accompanied by the name and address of the UK Responsible Person where relevant
- Cannot be affixed to products not covered by UK product safety legislation
UK Responsible Person
Non-UK manufacturers placing products on the GB market must appoint a UK Responsible Person(equivalent of the EU Authorised Representative). This entity must be established in the UK, hold the technical documentation, and can be contacted by market surveillance authorities.
What happens next — PSTI and future UK regulations
The UK is now developing its own product safety legislation independently from the EU. The Product Security and Telecommunications Infrastructure (PSTI) Act 2022 introduced cybersecurity requirements for consumer connectable products from April 2024 — independently of EU cybersecurity rules. UK manufacturers of IoT devices must comply with minimum security requirements around default passwords, vulnerability disclosure, and software update periods.
Does your product need UKCA marking?
Our assessment engine covers UK market requirements alongside EU directives — giving you a complete picture including UKCA requirements, applicable UK SIs, and whether you need a UK Approved Body.
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