What is UKCA Marking?

Jun 7, 2023 TI Admin

As of January 1st, 2021, the UK has a new compliance scheme for products and marking requirements. This is important for manufacturers placing products on the UK market to ensure their conformity assessments are up to date.

The UKCA (United Kingdom Conformity Assessment) Mark will replace the CE mark for goods placed on the UK market on December 31st, 2022. As of January 1st, 2023, CE marks will no longer be valid in the UK.

Also, at this time, Northern Ireland plans to use the CE mark indefinitely.

Read on to learn more about what is UKCA marking and how is it different from CE marking.

CE Marking vs UKCA Markings

Both product compliance routes for self-certified products are summarised in the table below.

UKCA Marking process	CE Marking process
Decide which Regulations and SIs are applicable for your product	Decide which CE marking Directives and Regulations apply for your product
Search for suitable UK Designated Standards (BS) to show compliance	Search for suitable EN standards to show compliance
Check the product complies with the standards
Rectify any non-compliances
Compile Technical File showing how the requirements are met
Prepare the UK Declaration of Conformity	Prepare the EU Declaration of Conformity
Affix the UKCA logo to the product. From 2023 it must be permanently attached to the product. Before then, it can be on a label or similar.	Affix the CE logo to the product
Ensure ongoing conformity of products
Appoint a UK Authorised Representative (if applicable)	Appoint an EU Authorised Representative (if applicable)

As you can see, there is a lot of similarity between the two routes and this is to keep the administrative burden on manufacturers to a minimum.

The UKCA mark must take the format shown and be a minimum size of 5mm on the product. Starting January 2023, it must be permanently attached to the product. Up to that time, it could be on a label such as fixed to the mains lead or similar.

How CE & UKCA Markings Differ (Examples)

The UKCA marking applies to 22 product groups that previously used EU Directives for CE compliance.

For example, a coffee maker can be self-certified by the manufacturer. Under CE marking, it would typically be subject to these four EU Directives:

Low Voltage Directive (2014/35/EU) for product safety,
ElectroMagnetic Directive (2014/30/EU) for EMC compliance,
Restriction of Hazardous Substances Directive (2011/65/EU) for reducing ten hazardous substances,
Ecodesign Directive (2009/125/EC) for the product’s environmental performance.

Compliance with the Directives is normally managed by a manufacturer assessing the product to the harmonized standards published under each Directive. The standards are usually prefixed EN (Euro Norm). The EU Declaration of Conformity for the product makes those references.

The UKCA mark conformity scheme uses UK legislation, so the equivalents of the above four directives are:

The Electrical Equipment (Safety) Regulations 2016,
The Electromagnetic Compatibility Regulations 2016,
The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012,
The Ecodesign for Energy-Related Products and Energy Information (Amendment) (EU Exit) Regulations 2019.

You can stay compliant with the legislation above by using Designated Standards, which are the same as the EU standards but prefixed by BS to show the UK.

There are no plans to diverge standards yet, so there should not be any product design changes required. The Designated Standards will officially be used in the Declaration of Conformity from January 2021 onward.

From a practical viewpoint, products destined for the UK and European markets could carry dual UKCA and CE marks, allowing them to be freely sold in both markets.

UKCA Marking Requirements

The UKCA process has the same requirements as CE. A manufacturer must keep a Technical File on record for ten years. This file shows how the product meets the legislation requirements and must be available to the authorities if any product issues arise.

There are also obligations for manufacturers to keep records of customer complaints and feedback about non-compliant products and to cooperate with the authorities if required. Manufacturers are obligated to inform the relevant national authorities if there are any non-compliances with their products, in particular, if there is a safety risk identified.

So while it is a new scheme, the requirements are not so different from the CE scheme we were all used to.

What Are The Correct and Appropriate Standards to Use For UKCA Marking?

Originally it was planned that only designated standards adopted by the British Standards Institute (prefixed “BS”) could be used. This was clarified further by defining a designated standard as being one adopted by any one of these bodies:

British Standards Institute (BSI)
European Committee for Standardisation (CEN)
European Committee for Electrotechnical Standardisation (CENELEC)
European Telecommunications Standards Institute (ETSI)
International Organisation for Standardisation (ISO)
International Electrotechnical Commission (IEC)
International Telecommunications Union (ITU)

The content of the standard is the responsibility of the recognized standardization bodies, with BSI as the UK’s National Standards Body representing the interests of UK stakeholders. From January 1, 2021, when deciding if a standard is appropriate for designation, the government checks how far it covers the various essential requirements set out in the relevant legislation.

This meant that manufacturers would not have to change the standards currently used for certification in most cases. There are minimal standards divergence between the UK and EU.

Designated standards are prefixed “BS”, “EN”, “EN ISO,” or “EN IEC”. The “EN” prefix indicates that the standard has been adopted by a European standardization body. Where the designated standard specified in the notice of publication is prefixed “EN,” it is acceptable to reference this version in technical documentation or a version of the same standard with a national prefix. This is because European standards are adopted identically by the 34 national members of CEN and CENELEC.

Designated standards give a ‘Presumption of Conformity’ with the respective UK legislation.

For goods being placed on the Northern Ireland market, the CE mark and the harmonised standards can still be used indefinitely.

The UK Government publishes a list of the designated standards which are applicable and to be used with each specific legislation. Four of the main product legislations are listed below:

How Will UKCA Marking Be Accepted in Northern Ireland?

The CE marking will continue to be acceptable for products placed on the Northern Ireland market, making no border with Ireland. Northern Ireland businesses are in the unique position of being able to ship products certified to CE or UK rules into Great Britain.

There is also the UKNI conformity assessment marking for products placed on the market in Northern Ireland, which has undergone mandatory third-party conformity assessment by a body based in the UK. This will be by a UK Approved Body.

The UKNI mark can only be used if all of these three conditions apply:

1. Goods are mostly placed on the NI market,

2. The goods require mandatory third-party conformity assessment and cannot be self-certified,

3. A UK body is planned to carry out the assessment.

The UKNI mark has the same physical marking requirements as the UKCA mark in terms of size, proportion, legibility, and durability.

What About The Role of Notified Bodies, and What Are Approved Bodies?

As of January 1st, 2021, Notified Bodies are no longer used in the new system of UK Regulations. This is due to the UK’s departure from the EU. For UKCA marking purposes, UK Notified Bodies have now become UK Approved Bodies, and their certificates only apply to products placed on the UK market. To find a UK Approved body use the UKAS website.

For UKCA marking, you should typically use an Approved Body for these example cases:

The Pressure Equipment (Safety) Regulations 2016—all except Cat I pressure equipment
The Supply of Machinery (Safety) Regulations 2008—for cases where essential requirements are not covered by designated standards or standards have not been applied.
Personal Protective Equipment Regulations (Regulation (EU) 2016/425 as brought into UK law and amended) Category II and III PPE.
Radio Equipment Regulations 2017—where the product is not covered by designated standards, or they have only been partially or not applied.

What Technical Documentation Does a Manufacturer Have to Keep on File?

For CE marking, there is a requirement to have a technical file on the product. It shows how compliance with the essential requirements of the directives is addressed and achieved. It also is a living document showing compliance through the production life of the product to the relevant requirements. The document needs to be kept on file for ten years.

The information typically contained within a file is:

How the product is designed and manufactured.
How the product is shown to comply with the requirements of the applicable legislation.
Details of the manufacturer and the supply chain players such as the Importer.
Copies of the Declarations of Conformity for the product.
Copies of any testing carried out on the production line.
Copies of documentation such as installation and user guides.

The file is only to be shown to enforcement authorities upon demand. It is not for use by your customers. The customers have a right to see the Declarations of Conformity.

Whose Name Should Be Clearly Shown on the Product and Packaging?

For UKCA marking, the Manufacturer/Importer/Authorized Representative based in the UK must be identified along with contact details, which is normally a postal address. This is used in the case of any enforcement authorities who may wish to investigate the compliance of the product to the legislation declared.

If the product carries a CE mark, then a UK economic operator should be identified. This is a requirement of Regulation EU 2019/1020, which came into effect in the Summer of 2021. It is a contact point within the EU for the enforcement authorities to approach.

Let Technology International Help You Obtain a UKCA Marking

Now that you know what UKCA marking is, you can start working toward obtaining it. The experts at Technology International will help save you time and money through our UKCA Marking services.

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