News article

Brexit: New UK product safety mark planned

14 February 2019

The new UKCA mark could apply to certain products if there is a no-deal Brexit

The UK government has planned a new product safety symbol, which could replace the existing CE mark in the event of the UK leaving the European Union (EU) without a deal.

The new symbol will carry the letters UKCA, standing for UK Conformity Assessed.

From the date of exit, if a no-deal Brexit occurs, some products intended for selling on the UK market may require the new UKCA mark instead of the existing CE mark.

Who will the changes affect?
If there is a no-deal Brexit, changes to product safety marking will affect companies involved in the manufacture, sale and distribution of CE marked products.

Current product safety in the UK
At the moment, certain goods sold in the UK (and the rest of the EU) require CE marking to demonstrate their compliance with the European regulatory requirements.

In most cases, the manufacturers can obtain the CE mark through self-certification. However, the law requires some high-risk products to be assessed by a third-party assessment body (a 'Notified Body') to confirm they meet relevant requirements.

What is changing?
If the UK leaves the EU without a deal, the EU will no longer recognise the results of conformity assessments carried out by UK Notified Bodies. As a result, you will no longer be able to apply the CE marking after a no-deal exit date if:

  • your product requires a third-party assessment of conformity, and
  • you use a UK body to assess your product against the requirements of EU law

You will have to apply the new UKCA marking after a no-deal exit date to sell your products on the UK market. The rules around using the new UKCA marking will mirror those that currently apply for the application of the CE marking.

Selling your products in the UK
If your goods require a product safety mark and you sell in the UK, you should be aware of the following changes in the event of a no-deal exit:

  • For a time-limited period, you can continue to use the CE mark to sell products on the UK market after a no-deal exit date. How long this period will last is currently unclear. The government will consult with industry and provide notice before ending it.
  • During this time-limited period, you will have the option of using the new UKCA mark instead of the CE mark on your product. However, while the CE mark will still be recognised in the UK (for a limited time), the UKCA mark will not be recognised in Europe.
  • Goods sold on the UK market before a no-deal exit date can continue to circulate in the UK as they do now without any changes to the marking requirements.

Selling your products in the EU
If your goods require a product safety mark and you sell in the EU, you should be aware of the following changes in the event of a no-deal exit:

  • If you obtained the CE mark through self-certification, there will be no change. You can continue to use this to export to the EU.
  • If your products need to be certified by a conformity assessment body, you will have to get them assessed and marked by an EU-recognised Notified Body.
  • If your products have existing CE marking status, which results from conformity assessments undertaken by a UK Notified Body, you should consider transferring assessments to an EU-recognised body before the UK leaves the EU.

Goods sold in both the UK and the EU will need to carry two safety marks - CE for EU markets and UKCA for the United Kingdom market.

Read more about using the UKCA marking if the UK leaves the EU without a deal.

You can email if you have queries or need further assistance regarding the UKCA mark.