On 1 January, 2021, the United Kingdom left the EU Single Market, meaning that goods that were previously freely traded between the EU and the UK will now be subject to regulatory checks and controls. On the same date, the UKCA marking came into effect on the Great Britain (England, Wales, and Scotland). But what does it refer to and how should it be used?
Similarly to the CE marking, the UKCA (UK Conformity Assessed) marking proves that goods placed on the UK market meet the applicable UK requirements, which are largely comparable to the EU ones. Likewise, the UKCA marking must also be placed on the product or on its packaging, except in particular cases where it is sufficient to place it in the instruction manual.
For what concerns the general rules for its use, the UKCA marking must be easily visible and must respect the right proportion of the letters (as shown in the picture), while being at least 5mm in height.
Government of the UK, 2021
Overall, the UKCA marking covers most goods that were previously bearing the CE marking – with aerosols being an exception – and the manufacturer must place it on a product to show conformity with the relevant legislation. Technical documentation and a UK Declaration of Conformity must be always kept available by the manufacturer or the Authorised Representative in case of inspection or vigilance cases, for up to 10 years after the product was placed on the market.
UPDATE: 1 June 2021
According to the updated guidance, the self declaration of conformity for UKCA marking is now allowed for:
- All products under the Electromagnetic Compatibility Regulations 2016
- Products under the Toy Safety Regulation 2011 where all essential requirements are covered by designated standards and have been applied
- All products where the restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulation 2021
- Certain Class I devices covered by the Medical Devices Regulations 2002
- All products under the Radio Equipment Regulation 2017, except where designated standards for regulation 6 do not exist or not have been applied by the manufacturer
- Category I pressure equipment under the Pressure Equipment Safety Regulation 2016
- Products within scope of System 4 under the Construction Products Regulations
- Certain categories of devices under the Recreational Craft Regulation 2017
- All products under the Electrical Equipment Safety Regulation 2016
- Any machine which is not in Schedule 2, Part 4 of the Supply of the Machinery Safety Regulation
- Category I personal protective equipment under the Personal Protective Equipment Regulations
- Equipment-group II, equipment category 3 as per The Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres Regulations 2016
As per other new requirements that came into effect at the beginning of this year, a grace period has been established in order for manufacturers to fulfill their new obligations. Therefore, apart from certain exceptions, it will still be possible to use CE marking on most goods that are being sold in UK until 1 January, 2022, in those areas where GB and EU apply the same rules. However, should there be any change in the EU rules, the CE marking must be replaced by the UKCA marking before 31 December, 2021.
Another important aspect to keep in mind is that the counterpart does not apply in the EU. In fact, the UKCA marking is not an equivalent for the CE marking in the EU single market and, therefore, products need to have the CE marking affixed to be placed on the Union market.
Regulatory Affairs Department
If you wish keep selling your products in Great Britain, or if you are thinking of introducing them on this market, do not hesitate to contact us – we can help you!
- Government of the UK. (2021). Guidance Using the UKCA marking. Retrieved on 06.05.2021 from https://www.gov.uk/guidance/using-the-ukca-marking Government of the UK. (2021).
- Government of the UK. (2020). Guidance Placing manufactured goods on the market in Great Britain. Retrieved on 06.05.2021 from https://www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-great-britain
- Mar(2020). Brexit, what about UK-EU Trade? Retrieved on 06.05.2021 from https://www.obelis.net/blog/brexit-what-about-uk-eu-trade/