The UKCA mark will replace the CE mark after Brexit
Rawf8 /
2019-11-28 expert contribution

Brexit and the CE mark

We have been dealing with the Brexit issue since March 2017. Whether Great Britain will exit the EU with an agreement or via a "hard Brexit" (also known as a no-deal Brexit) in the future remains to be seen. As of now, Great Britain is expected to leave the EU on January 31, 2020. The transition period is furthermore expected to last until the end of December 2020.


Dr.-Ing. Klaus Kreß

Brexit also has consequences for testing and certification. After a particular transition period, Great Britain will probably cease to recognize the CE mark. After this time, manufacturers must apply what is known as the UKCA mark (UK Conformity Assessed). It replaces the CE mark in the British market. It entails the following in detail:

During the transition period

In particular cases, products with the CE mark will continue to be recognized in Great Britain. However, the UKCA mark will immediately become mandatory for certain products. Therefore, manufacturers should inform themselves early on about the regulation under which their product is classified. You can find more information on the British government’s website.

In addition, "Notified Bodies" in the UK will lose their status as "EU Notified Bodies". This means that they will no longer be allowed to perform EU conformity assessments once Great Britain leaves. However, if British manufacturers wish to export their products to the EU, there are three options to get around this problem:

  1. The manufacturer creates an EU conformity declaration according to module A (internal production inspection of the manufacturer) to the extent possible and applies the CE mark to their product.
  2. "Notified Bodies" that are recognized in the EU must be used for the EU conformity assessment.
  3. The existing conformity assessment, which was issued by a British "Notified Body, is forwarded and handled by a "Notified Body" that is recognized in the EU.

After the transition period

The British government will timely notify the manufacturers when the transition period - and thus the recognition of the CE mark in the UK - will end. As of now, only the UKCA mark will be recognized in Great Britain. The UKCA mark can only be issued by British "Notified Bodies".

Since the UKCA mark is not recognized in the EU, the CE mark must continued to be applied for the European market. This can furthermore be accomplished - to the extent possible - via a self-declaration or via validation by a "European Notified Body".

Accordingly, products that will be introduced to both the UK and EU markets must bear both marks – the CE mark and the UKCA mark.

Naturally, we will inform you about what you need to be aware of in the future once the final Brexit decision has been made.


Despite careful research, this text may be incomplete or contain errors. The publisher shall assume no liability for any resulting damage to persons or objects.

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