Understanding UKCA Marking: 5 Common Questions Answered

Since 2021, the UKCA marking has been the product conformity marking in the United Kingdom (England, Wales and Scotland). UKCA marking replaces the European CE-marking as part of Brexit.

To allow companies time to adjust, CE-marked products have still been accepted in United Kingdom (UK) during a transition period, however, on 1 January 2025, this transition period comes to an end, and companies that wish to maintain their market access to England, Wales and Scotland after 31 December 2024, should therefore start to look into the UKCA marking now.

Read more: E-book - The complete overview of UKCA marking.

In this article, we have gathered five common questions on UKCA marking and listed their answers to give you a simple overview of what you need to be aware of, if you want to still have market access to the UK on 1 January 2025.

1. Which areas will be affected and how?

All of the UK – with the exception of Northern Ireland – will be affected. Products sold in Northern Ireland will need either UKNI or CE marking dependent on where the Approved Body is based – see below image for an overall guideline.

CE-marking is not sufficient for use on products for Northern Ireland if a UK-based Approved Body is involved. For products needing certification (mandatory third-party conformity assessment) and the approved body is located in the UK, both the CE marking and the UKNI marking is required for Northern Ireland. You never apply the UKNI marking on its own - it always accompanies an EU conformity marking.

For the products not requiring certificates from an approved body (mandatory third-party conformity assessment), only CE marking will be required to be applied on the product for Northern Ireland.

If you are placing goods on the EU market, you must use the CE marking on its own, without the UKNI marking, as the UKNI marking is not recognized on the EU market.

2. Which products and areas are included in the scope?

Almost all kinds of electrical products are included in the scope. Some products will need a type of examination certificate whereas others may be self-declared. For example, the changes will affect the areas of Safety, Electromagnetic compatibility (EMC), Radio, Energy, and Restriction of Hazardous Substances (RoHS).

3. What will importers need to do from 1 January 2025?

Importers will need local representation in the UK. One key requirement for the UK relates to the requirement for importer information to be provided on the equipment, if the product is being placed on the market in Great Britain from another country.

The requirement that is presently in force requires identification of the importer’s name, registered trade name or mark as well as a postal address to be indicated either on the equipment, packaging or accompanying documentation.

However, from the 1^st of January 2025 the importer identification shall need to be on the equipment, unless this is not possible, for example due to the size of the equipment or other acceptable rationale.

Goods imported from the EEA (and in some cases Switzerland) have a relaxation because the UK government will introduce legislation so that the importer details can be provided via a sticky label or on an accompanying documentation rather than on the good itself until 31 December 2027. After 31 December 2027, the importer details must be affixed to the product or, in circumstances where the legislation allows, on the packaging or an accompanying document.

4. What are the consequences if customers do not do anything to accommodate the change?

CE-marking will no longer be valid in the UK after the transition period has come to an end. British market surveillance will assess products on the market, and products that fail to comply with the new UKCA-marking, may be withdrawn from the market and subject to other penalties.

5. How can Nemko help you maintain market access in the UK?

Nemko can advise on labelling, perform testing, and issue UK Type Examination Certificates when desired. Nemko can also issue letter of opinions and provide gap analysis services to ensure your product maintains market access after 1 January 2025.  

Using a certification body outside of the UK is an advantage as UK based certification bodies most likely will be overloaded with UKCA work as deadline dates approaches quickly and are not accredited in the UK to perform EU Type Examination Certification.

For any further questions or concerns on UKCA marking, you are always welcome to reach out to us.