The UKCA mark will replace the CE mark after Brexit
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Update - Brexit and the CE marking

We’ve known about the Brexit decision for while now - the UK left the EU on January 31st 2020 with a withdrawal agreement. With this in mind, there has been longstanding confusion over what to do with the CE and/or UKCA (‘UK conformity assessed’) marks.

Dr.-Ing. Klaus Kreß

In the meantime, it has emerged that the UKCA mark will be mandatory from 01.01.2021 in the UK. The UKCA label is linked with the UK declaration of conformity, with UK laws applying instead of EU guidelines. This consists of an exact transfer of EU regulations. The technical requirements and modules of the conformity assessment process will therefore initially be taken on without change.

Up to 31.12.2021, manufacturers are still permitted to bring products exclusively carrying the CE mark onto the British market. As well as the EU declaration of conformity, there will also be a UKCA declaration of conformity for the British market, which will reference British law instead of EU guidelines/regulations and use British standards (BS) as normative verification. The norm reference BS indicates that this is a norm approved by the British Standards Institution, the UK’s national standards organization.

The CE mark, the EU declaration of conformity and the EU type approval test are considered equal alternatives to the corresponding UK elements until the end of 2021 at the latest. There is therefore a one-year transition period from 01.01.2021 to 31.12.2021. Afterwards, the UKCA mark must be used and related requirements implemented.
If there are related changes to EU or UK law from 01.01.2021, the UKCA label will immediately be mandatory for affected products from 31.12.2021. The same also applies to interim changes to UK law. The transition period also correspondingly applies to products that require a confirmation from a notary.  

The following general rules apply to the application of the UKCA mark:

Up to the end of 2022, manufacturers are allowed to “provisionally” use the UKCA label on their products. This can be implemented by adding the relevant mark to the operating manual, an additional label or similar. From 01.01.2023, the UKCA label must be firmly applied to the product itself under a similar regulation to which the CE mark is subject.

  • It may only be applied to the product by the manufacturer or an authorized representative, insofar as this is permissible within the relevant legal guidelines.
  • The manufacturer (or its authorized representative) takes full responsibility for the conformity of its product with the applicable legal requirements.
  • This declares the conformity of the product with the applicable legal requirements.
  • The foundation for the application of the UKCA mark is a UKCA declaration of conformity.
  • No further marks or symbols can be applied to the product alongside the UKCA mark that would impact the readability or meaning of the UKCA label.


Further information on technical documentation:

  • The manufacturer (or its authorized representative) must create technical documentation. It must clearly state that the product complies with statutory requirements.
  • This information can be requested by the market’s supervisory authorities or law enforcement bodies.
  • As with the CE mark, documentation must be stored for 10 years.

In general:
It must be clear... the product has been constructed and manufactured. the manufacturer has fulfilled the statutory regulations for its product.
...the address of the manufacturer and any warehousing.

Further information complies with the requirements of the EU declaration of conformity.  


This information has been taken from publications of the British government on Brexit. We accept no liability for its correctness or implementation.

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