Note: This article was last updated in March 2025 and takes into account the current regulations on CE and UKCA marking in the UK.
When the United Kingdom left the European Union, the UKCA (UK Conformity Assessed) mark was introduced. It was intended to become an independent British conformity mark and replace the CE marking in the long term.
However, this original plan has been adjusted several times in recent years. The aim was to avoid economic disadvantages, supply bottlenecks and unnecessary double certifications.
Contrary to earlier announcements, the CE marking continues to be recognized for many product groups in the UK – without a fixed end date.
The UK government has decided to continue to accept EU product requirements, including CE marking, provided that:
the technical requirements in the EU and UK are the same and
no expressly deviating British regulations apply.
Important:
The introduction of UKCA has not been abolished, but it has been made much more flexible. In many cases, manufacturers can decide for themselves whether to use CE, UKCA or both markings.
The following currently applies to the UK market:
However, UKCA may still be required in certain regulated areas. Product-specific testing is therefore essential.
Northern Ireland remains subject to EU product regulations:
This regulation applies permanently as part of the so-called Windsor Framework.
The recognition of the CE marking does not apply across the board to all products. Deviating or supplementary regulations exist, for example, for
Medical devices
Building products
pressure equipment
ATEX products
Measuring and weighing rights
In these areas you can:
own transitional regulations apply,
national British requirements exist,
or separate reforms may be planned.
Recommendation: Always make labeling decisions on a product- and market-specific basis.
EU Notified Bodies are still responsible for CE marking
British bodies became UK Approved Bodies
UKCA markings may require a UK inspection body
In many cases, existing CE certificates remain valid for the UK market
The following points must be observed during practical implementation:
A UK Declaration of Conformity is required for UKCA
CE and UKCA declarations of conformity must be kept separately
Technical documentation must be available in English
Depending on the product, the labeling may also appear on the packaging or accompanying documents
Dual labeling (CE + UKCA) is permissible and often useful
This additional complexity is painful to read and will also cause headaches for some of those responsible for label management. If you are also worried about this change, you should get to know our Label Management System. With our decision matrices such requirements can be easily implemented.
Urs Bartholdi, Product Manager OPAL LABELMANAGEMENT
Clearly distinguish target markets (GB vs. Northern Ireland)
Evaluate product categories individually
Check whether CE is sufficient or UKCA is required
Clearly separate technical documentation and explanations
Strategically manage labeling variants
Complexity increases quickly, especially with broad product portfolios.
OPAL Label Management supports companies in this,
CE, UKCA and UKNI markings in a structured manner,
to map country-specific requirements centrally,
implement regulatory changes efficiently and in an audit-proof manner.
This allows manufacturers to maintain an overview even in complex regulatory frameworks.
Yes, the CE marking will continue to be recognized in the UK for many product groups, provided that the technical requirements in the EU and UK are the same and no specific UK regulations apply.
No. The UKCA marking is not mandatory across the board. In many cases, products can continue to be placed on the UK market with CE marking. However, UKCA may be required for certain product groups or in the case of deviating UK requirements.
Yes, dual marking with CE and UKCA is permitted and is used by many manufacturers to cover both the EU and UK markets.
Northern Ireland continues to follow EU product regulations.
CE marking is mandatory there. If a British inspection body is also involved, the UKNI marking is required. UKCA marking alone is not sufficient in Northern Ireland.
In many cases, yes. Existing CE certificates remain valid as long as they meet the relevant technical requirements. However, UKCA markings may require assessment by a UK testing body.
Special regulations apply, among other things, to:
Medical devices
Building products
Pressure equipment
ATEX products
Measuring and weighing rights
The requirements for these product groups should always be checked on a product-specific basis.
Depending on the labeling, the following are required:
EU Declaration of Conformity (for CE)
UK Declaration of Conformity (for UKCA)
Technical documentation in English
CE and UKCA documents must be kept separately.
Our experts will be happy to show you in a live demo how easy it is to implement the requirements for UKCA labeling.
