UKCA Marking – Testing, Certification, and Guidance

From January 2021, businesses placing products onto the UK market, regardless of where in the world they are based, have the choice to either use the CE marking or begin applying the UKCA marking. As of 31 December 2024, the option to use the CE mark will cease, and the UKCA mark must be used (save for some limited exceptions). Although the rules are broadly similar between the CE and UKCA regimes, some differences must be observed.

To reduce labeling costs, the UK government will allow businesses to affix the UKCA marking and include importer information for products from EEA countries on an accompanying document or label until 31 December 2027.

Most products that are currently covered under CE marking will fall under the new UKCA requirements. There are exceptions and different rules for certain products, including medical devices, construction products, and vehicles. Element is an approved body, and we work in partnership with manufacturers to help to gain UKCA marking for a range of products, including:

• Electrical and electronic equipment
• Radio equipment
• Low voltage equipment
• Equipment used in potentially explosive atmospheres
• Marine equipment

All of this means that businesses should act now to ensure that they have everything in place for the 31 December 2024 deadline. Broadly speaking, each of the CE marking directives has been transposed into UK law under a corresponding UK Regulation.

For example, the Electromagnetic Compatibility Directive 2014/30/EU has been transposed into the Electromagnetic Compatibility Regulations 2016 (as amended), and the Radio Equipment Directive 2014/53/EU has been transposed into the Radio Equipment Regulations 2017 (as amended). Despite some changes in the text, the essential technical requirements remain largely the same, as do the options for conformity assessment procedures.

Because the conformity assessment procedures remain largely unchanged, this means the option for self-declaration still exists, but only for products that also qualify for self-declaration under the CE marking rules. Each directive and regulation has different criteria for this, so it is always best to check before placing any products on the market.

The UKCA declaration of conformity will look very similar to the UK declaration of conformity, but will refer to the UK legislation instead of the EU legislation. There may also be a requirement to list new standards.

For some products, the self-declaration alone will not be sufficient, and an approved body may be required to issue a UK-type examination certificate for the product. If in doubt, Element can advise on the appropriate conformity assessment procedure for any given product.

Where the EU maintained lists of harmonized standards, so too does the UK maintain lists of designated standards, which can be used to support the UKCA declaration of conformity. Each UK Regulation has its own list of standards. Some of these lists will differ from the analogous EU list, and so different standards may be used on the EU and UK declarations of conformity. 

The UK government will allow conformity assessment activities for CE marking undertaken by 31 December 2024 to be used by manufacturers as the basis for the UKCA marking, until 31 December 2027.