Brexit: Using the UKCA mark from 1 January 2021

Guide

2 September 2020

Find out if you will need to use the new UKCA marking and how to use it

The UK has left the EU, and the transition period after Brexit comes to an end this year. This page tells you what you'll need to do from 1 January 2021. It will be updated if anything changes.

The UKCA (UK Conformity Assessed) marking is a new UK product marking that will be used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods which previously required the CE marking.

The UKCA marking alone cannot be used for goods placed on the Northern Ireland market, which require the CE marking or UK(NI) marking. See the guidance on placing goods on the Northern Ireland market.

This guidance explains how to use the UKCA marking. For further information on placing these goods on the market, see the guidance on placing manufactured goods on the market in Great Britain.

Check whether you will need to use the new UKCA marking

Selling goods in Great Britain
The UKCA marking will apply to most goods currently subject to the CE marking. It will also apply to aerosol products.

From 1 January 2021, the technical requirements ('essential requirements') you must meet - and the conformity assessment processes and standards that can be used to demonstrate conformity - will be largely the same as they are now.

The UKCA marking can be used from 1 January 2021. However, to allow businesses time to adjust to the new requirements, you will still be able to use the CE marking until 1 January 2022 in most cases.

In some cases, you will need to apply the new UKCA marking to goods being sold in Great Britain immediately from 1 January 2021. You are encouraged to be ready to use the UKCA marking as soon as possible before this date.

The CE marking will only be valid in Great Britain for areas where GB and EU rules remain the same. If the EU changes its rules and you CE mark your product on the basis of those new rules you will not be able to use the CE marking to sell in Great Britain even before 31 December 2021.

Check whether you will need to use the UKCA marking by reading the guidance on placing manufactured goods on the market in Great Britain.

Selling goods in the EU
The UKCA marking will not be recognised on the EU market. Products currently requiring a CE marking will still need a CE marking for sale in the EU from 1 January 2021. Find out how to use the CE marking.

When to use the UKCA marking

You will need to use the new UKCA marking immediately after 1 January 2021 if all of the following apply. Your product:

  • is for the market in Great Britain
  • is covered by legislation which requires the UKCA marking
  • requires mandatory third-party conformity assessment
  • conformity assessment has been carried out by a UK conformity assessment body and you haven't transferred your conformity assessment files from your UK body to an EU recognised body before 1 January 2021

This does not apply to existing stock, for example if your good was fully manufactured and ready to place on the market before 1 January 2021. In these cases, your good can still be sold in Great Britain with a CE marking even if covered by a certificate of conformity issued by a UK body.

How to use the UKCA marking

Placing the UKCA marking
In most cases, you must apply the UKCA marking to the product itself or to the packaging. In some cases, it may be placed on the manuals or on other supporting literature. This will vary depending on the specific regulations that apply to the product.

The following general rules apply:

  • UKCA markings must only be placed on a product by you as the manufacturer or your authorised representative (where allowed for in the relevant legislation)
  • when attaching the UKCA marking, you take full responsibility for your product's conformity with the requirements of the relevant legislation
  • you must only use the UKCA marking to show product conformity with the relevant UK legislation
  • you must not place any marking or sign that may misconstrue the meaning or form of the UKCA marking to third parties
  • you must not attach other markings on the product which affect the visibility, legibility or meaning of the UKCA marking
  • the UKCA marking cannot be placed on products unless there is a specific requirement to do so in the legislation

Rules for using the UKCA image
You must make sure that:

  • if you reduce or enlarge the size of your marking, the letters forming the UKCA marking must be in proportion to the version set out below
  • the UKCA marking is at least 5mm in height - unless a different minimum dimension is specified in the relevant legislation
  • the UKCA marking is easily visible, legible (from 1 January 2023 it must be permanently attached)

Download UKCA mark image files (fill)(ZIP, 818KB)
Download UKCA mark image files (outline)(ZIP, 2.03MB)

Technical documentation

Record keeping
You, or your authorised representative (where allowed for in the relevant legislation), must keep documentation to demonstrate that your product conforms to the regulatory requirements. This must be kept for up to 10 years after the product is placed on the market.

This information can be requested at any time by market surveillance or enforcement authorities to check that your product conforms to the statutory requirements.

The information you must keep will vary depending on the specific legislation relevant to your product. You must keep general records of:

  • how the product is designed and manufactured
  • how the product has been shown to conform to the relevant requirements
  • the addresses of the manufacturer and any storage facilities

You should keep the information in the form of a technical file which can be supplied if requested by a market surveillance authority.

UK Declaration of Conformity
The UK Declaration of Conformity is a document which must be drawn up for most products lawfully bearing a UKCA marking.

In the document, you as the manufacturer or your authorised representative (where allowed for in the relevant legislation), should:

  • declare that the product is in conformity with the relevant statutory requirements applicable to the specific product
  • make sure the document has the name and address of the manufacturer (or your authorised representative) together with information about the product and the conformity assessment body (where relevant)

The UK Declaration of Conformity should be available to market surveillance authorities on request.

The information required on the Declaration of Conformity will be largely the same as what is currently required on an EU Declaration of Conformity. This can vary depending on the application legislation but generally should include:

  • your name and full business address or that of your authorised representative
  • the product's serial number, model or type identification
  • a statement, stating you take full responsibility for the product's compliance
  • the details of the approved body which carried out the conformity assessment procedure (if applicable)
  • the relevant legislation with which the product complies
  • your name and signature
  • the date the declaration was issued
  • supplementary information (if applicable)

You will need to list:

On 1 January 2021, the UK standards will be the same in substance and with the same reference as the standards used in the EU. However, they will use the prefix 'BS' to indicate that they are standards adopted by the British Standards Institution as the UK's national standards body.

Future use of markings in the UK

From 1 January 2022, the CE marking will not be recognised in Great Britain for areas covered by this guidance and the UKCA marking. However, a product bearing the CE marking would still be valid for sale in the UK so long as it was also UKCA marked and complied with the relevant UK rules. Separate rules apply to medical devices.

More information

Product areas covered by the UKCA marking:

  • Toy Safety
  • Recreational craft and personal watercraft
  • Simple Pressure Vessels
  • Electromagnetic Compatibility
  • Non-automatic Weighing Instruments
  • Measuring Instruments
  • Lifts
  • ATEX
  • Radio equipment
  • Pressure equipment
  • Personal protective equipment
  • Gas appliances
  • Machinery
  • Outdoor Noise
  • Ecodesign
  • Aerosols

Products covered by the UKCA marking but have some special rules:

  • medical devices
  • rail interoperability
  • construction products
  • civil explosives

Transitional measures relating to the UKCA marking
For many product types (listed above), the following transitional measures apply.

Until 1 January 2023, for most goods (other than those subject to special rules) you have the option to affix the UKCA marking on a label affixed to the product or on an accompanying document. The economic operators (whether manufacturer, importer or distributor) should take reasonable steps to ensure the UKCA marking remains in place. Products that require the UKCA marking cannot be made available without it (other than where the CE marking is being used before 1 January 2022).

From 1 January 2023, the UKCA marking must, in most cases, be affixed directly to the product. You should start building this into your design process ready for this date.

Construction products, medical devices, interoperability of the rail system and transportable pressure equipment are covered by the UKCA marking, however the above transitional measures are not applicable.

Contact

If you have any queries or require further assistance regarding the UKCA mark, you can contact goodsregulation@beis.gov.uk.

First published 2 September 2020