Frequently Asked Questions About UKCA Marking

Here you’ll find answers and insights to some of the most commonly asked questions relating to the subject of UKCA marking.

Find more information on our UKCA mark webpage

What is the UKCA mark?

The UKCA (United Kingdom Conformity Assessed) mark is UK legislation which will replace the CE mark for placing products on the market in Great Britain (CE marking is still required in Northern Ireland). The UKCA mark will apply to most products, exceptions are for example Marine equipment where there is a proposed Marine UK mark replacement for the current Marine Wheel mark. Products being placed on the EU market will still require CE marking so that dual CE/UKCA marking may be required. UKCA marking applies to products that require mandatory third-party conformity assessment via a UK Approved Body (using for example conformity route Module B UK Type Examination) and products which can be self-declared (using for example conformity route Module A Internal Production Control).

How long will the CE mark continue to be accepted in Great Britain?

Current UK guidance allows a period of acceptance of CE (and Wheel) marking in Great Britain until 1st Jan 2022 for most products, for Marine products until January 1, 2023 (for the Wheel mark) and for Medical products until June 30, 2023. These extensions for acceptance of CE marking will require updated UK legislation before they are legally accepted and are subject to the UK and EU legislation requirements still aligning during these periods. UKCA marking can be applied from January 1, 2021 and manufacturers are being encouraged to consider these requirements as soon as possible and engage with a UK Approved Body if applicable.

What are the differences between the CE mark and UKCA mark?

Whilst initially UKCA marking requirements will follow EU requirements with respect to EU harmonized standards for example there is a possibility that this will diversify in the future. The main principles behind Brexit, the Withdrawal agreement and current trade deal discussions is allowing the UK to create their own legislation and laws with respect to product safety for example. Manufacturers will need to apply the UKCA mark to most products being placed on the market in England, Scotland and Wales which will demonstrate conformity to UK legislation (UK Statutory Instruments) and the associated essential requirements in this UK legislation. Manufacturers will additionally require a UK Declaration of Conformity which will need to list UK legislation (UK Statutory Instruments) and UK designated standards for compliance. For products and UK legislation that require a certification body, a UK Approved Body such as TÜV SÜD BABT will be required.

What about EU notified bodies and UK approved bodies?

A new UK framework will mean that on January 1, 2021 UK based EU notified bodies will automatically become UK Approved Bodies for their current scope of accreditation allowing UKCA certification work to commence. UK based notified bodies have been contacted about these appointments and will retain their current 4 digit notified body number. Without an EU/UK Mutual Recognition Agreement (MRA), UK based approved bodies will no longer be recognized in Europe for CE marking and EU based notified bodies will not be recognized as UKCA approved bodies after January 1, 2021.

What should I do with UK notified body type examination certificates?

In all probability a UK based Notified Body EU type examination certificate will no longer be acceptable in the EU after January 1, 2021. Whilst a full MRA between the UK and EU is still possible for certification bodies, this is looking very unlikely, so you would be advised to transfer your existing UK notified body type examination certification to an EU based notified body. TÜV SÜD can help with this process with multiple EU based Notified Bodies.

How will the UKCA mark affect my existing products in the UK market already carrying the CE mark?

With respect to existing products, the rules for the EU and UK are the same, that is that legislation applies at the point when the individual product is placed on the market. UKCA marking would not be required for products already placed on the market (already imported and with a distributor for example) prior to January 1, 2021 or longer depending on the acceptance period of the CE marking.

How do I get my products UKCA marked with TÜV SÜD as the UK approved body?

TÜV SÜD BABT will be appointed as a UK approved body shortly and can support your requirements. The TÜV SÜD BABT scope of accreditation is also currently being extended for additional product types news of this will be published shortly.

Where can I find additional guidance?

TÜV SÜD

UKCA Mark

UKCA Update Blog

UK Government Guidance

Using the UKCA mark beginning January 1, 2021

Min 590 amendment 3 UK conformity assessment procedures for marine equipment following the transition period

Regulating medical devices beginning January 1, 2021

Conformity assessment bodies change of status beginning January 1, 2021