What is UKCA marking?
What is the difference between UKCA marking and CE marking?
UKCA stands for “UK Conformity Assessed”. It is the British version of the European Union’s CE marking. CE, as well as the UKCA mark, are not quality indicators or certification marks. UKCA marking is a similar provision as the CE marking, however applicable for UK laws and the UK market. It must be considered as an implicit declaration from the manufacturer or brand-owner that his product complies with all UK laws and the applicable British conformity assessment procedures.
For which type of consumer products UKCA marking is applicable?
CE and UKCA marking are not applicable for all non-food consumer products. Most UK requirements match the directives and regulations for which CE marking is applicable. The relevant legislation for which UKCA-UK requirements match CE-marking EU requirements can be found here.
Legislation for medical devices, rail interoperability, construction products and civil explosives are subject of UKCA marking in the UK and CE marking in the EU and EEA. There are differences between the UK and the EU for these pieces of legislation.
One notable difference between the scope of UKCA marking is for aerosol dispensers. For aerosol dispensers, UKCA marking is mandatory in the UK in contrast to the EU market. Aerosol Dispensers placed on the European market may not bear CE-marking. Products that are not in the scope of one or more of UKCA marking regulations and or directives may not bear the UKCA mark.
Which marking must be used if a product is sold in the EU as well as in the UK?
You may use UKCA marking on the UK market from 1 January 2021. UKCA marking is not recognized in the EU. A consumer product may bear the UKCA marking next to the CE marking on the European market provided that an appropriate European conformity assessment is applied. On 24 January 2024 there was another update to the UK.GOV page on the UKCA/CE mark. Among other things, a voluntary Fast-Track UKCA process is presented, which is intended to offer companies longer-term security and flexibility via a simplified UK declaration of conformity than would be the case with the continued use of the CE marking, which shall be possible for 21 product areas under certain conditions for an unlimited period beyond 31 December 2024.
From which date UKCA marking is mandatory?
The UKCA marking came into effect on 1 January 2021. Currently, UK law still provides that certain products that meet EU requirements, including CE marking, can be placed on the UK market until 31 December 2024.
Legislative changes are planned for spring 2024 that will allow products from 21 product areas to be placed on the UK market beyond 31 December 2024 if they meet EU requirements, including CE marking. This means greater ease and flexibility for companies to use either the UKCA or CE marking to sell products in the UK.
Although you can continue to use the CE marking indefinitely, this only applies as long as the harmonised EU standards and the UK designated standards are aligned. If there are differences between designated standards and harmonised European standards, this may affect the conformity assessment procedures that must be followed before the product can be placed on the UK market with a CE marking!
It should also be noted that if products with the CE mark are also to be made available on the UK market, the EU DoC must be in English.
Longer-term certainty and flexibility by Fast-Track UKCA process?
The UK may make UKCA labelling mandatory for certain products in the future. To provide companies with longer-term certainty and flexibility, a Fast-Track UKCA process is being introduced.
Fast-Track UKCA means that manufacturers can use UKCA marking to demonstrate that they have met either the UK essential requirements or the recognised EU conformity assessment procedures for a product. This also means that for products covered by multiple regulations, a mixture of UK and EU conformity assessment procedures can be used to demonstrate compliance with UK requirements and the UKCA marking can be applied.
Fast-track UKCA therefore means that EU conformity assessment procedures carried out and evidence of conformity to the EU essential requirements will be recognised in the same way as if the UKCA requirements were met based on the UK conformity assessment procedures. If there is a UK requirement that is not covered by an EU requirement, only the UK requirement needs to be checked separately; for the harmonised requirements, the fulfilled EU requirements can still be specified on the UK DoC.
When using the Fast-Track UKCA procedure, manufacturers must therefore affix the UKCA labelling and create a UK DoC.
Picture: Possible routes for placing products onto the UK market
More about placing products on the UK market with UK or EU product labelling (PDF, 345 KB, 9 pages).
What about labelling requirements?
Separate legislation will be presented to ensure continued flexibility in labelling. This applies to UKCA labelling, manufacturer contact details, importer contact details. Companies can then choose whether to apply the required labelling:
- directly on the product
- on an adhesive label, accompanying document or packaging
- voluntarily via digital labelling. Following the adoption of legislation, it will also be possible to submit the declaration of conformity digitally.
There is separate guidance for medical devices, construction products, cableways, transportable pressure equipment, unmanned aircraft systems, rail products and marine equipment.
