Background

When the UK voted to leave the European Union, many changes took place with respect to regulatory requirements for goods placed on the market in the UK. This included the incorporation of a formalized regulatory compliance mark, the UKCA Mark, which is separate from the common CE Mark for applicable goods placed on the market in the EU.

The UK will, as of January 1, 2023, no longer accept goods marked with the CE Mark, and the use standards that are not specifically recognized with the UK regulatory agencies. Products currently requiring a CE marking for sale in the EU will continue to need a CE mark (and meet the other EU rules).  Goods marketed in both the UK and the EU must bear both the UKCA and CE marks.

Manufacturers are encouraged to prepare to use the UKCA marking for the UK market as soon as possible, as it is considered voluntary until it becomes mandatory on January 1, 2023. Before that date manufacturers do not need to change the conformity marking on a product if it is CE marked and if either of the following apply:

  • use self-declare the conformity of your goods against the regulations
  • voluntarily use a testing or notified body to test against European or international standards

You may need to take additional action if your goods need third-party conformity assessment. Manufacturers will need to check whether your EU approved body is taking steps that help you continue to export to the UK, as formal registration as an UK Conformity Assessment Bodies will apply.

UK compliance and the UKCA Mark are formally separate from the EU and CE Mark requirements and include commerce in the England, Scotland and Wales as part of the United Kingdom.

Regulatory Requirements and Agencies

As the EU Council of Ministers publishes a series of directives or regulations which are considered law for commerce in the EU and the EEA, the UK has similar regulatory legislation which is compared on the table below:

EU legislation

UK legislation

Toy Safety – Directive 2009/48/EC

Toys (Safety) Regulations 2011

Recreational craft and personal watercraft – Directive 2013/53/EU

Recreational Craft Regulations 2017

Simple Pressure Vessels – Directive 2014/29/EU

Simple Pressure Vessels (Safety) Regulations 2016

Electromagnetic Compatibility – Directive 2014/30/EU

Electromagnetic Compatibility Regulations 2016

Low Voltage Directive 2014/35

Electrical Equipment (Safety) Regulations 2016

Non-automatic Weighing Instruments – Directive 2014/31/EU

Non-automatic Weighing Instruments Regulations 2016

Measuring Instruments – Directive 2014/32/EU

Measuring Instruments Regulations 2016

Lifts – Directive 2014/33/EU

Lifts Regulations 2016

ATEX – Directive 2014/34/EU

Equipment and Protective Systems Intended for use in Potentially Explosive Atmospheres Regulations 2016

Radio equipment – Directive 2014/53/EU

Radio Equipment Regulations 2017

Pressure equipment – Directive 2014/68/EU

Pressure Equipment (Safety) Regulations 2016

Personal protective equipment – Regulation (EU) 2016/425

Regulation 2016/425 on personal protective equipment as brought into UK law and amended

Gas appliances – Regulation (EU) 2016/426

Regulation 2016/426 on gas appliances as brought into UK law and amended

Machinery Directive 2006/42/EC

Supply of Machinery (Safety) Regulations 2008

Outdoor Noise Directive 2000/14/EC

Noise Emission in the Environment by Equipment for use Outdoors Regulations 2001

Ecodesign Directive 2009/125/EC

The Ecodesign for Energy-Related Products Regulations 2010

Energy Labelling Regulation (EU) 2017/1369

Energy Labelling Regulation (EU) 2017/1369 (as retained in UK law and amended)

Restriction of the Use of certain Hazardous Substances in Electrical and Electronic Equipment (RoHS) – Directive 2002/95/EC

The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012

Directive 2013/29/EU – Pyrotechnic Articles

The Pyrotechnic Articles (Safety) Regulations 2015

Manufacturers and companies that place products into the UK marketplace will need to meet similar regulatory practices to those used for EU compliance.

For the most current updates and details on how to place the UKCA mark on products, call 847-537-6400 to speak with a specialist, or request a quote.