Three Markings, Three Territories
| Territory | Applicable marking | Notes |
|---|
| Great Britain (England, Scotland, Wales) | UKCA — but CE still widely accepted | UK government has extended recognition of CE marking indefinitely for most product categories; a defined list of categories follows separate UKCA-only timelines |
| Northern Ireland | CE marking (CE + UKNI where a UK body was used) | Governed by the Windsor Framework; NI continues to follow EU product rules for goods |
| European Union / EEA | CE marking | UKCA marking has no validity in the EU |
⚠ Rules for GB recognition of CE marking have changed multiple times
The UK government has repeatedly extended the deadline for mandatory UKCA marking in Great Britain, and for most goods has now made recognition of CE marking indefinite. However, this does not apply uniformly — medical devices, construction products, transportable pressure equipment, cableway installations, and ecodesign/energy-labelling goods each have their own separate rules and timelines. Always verify current guidance for your specific product category before finalising a compliance strategy.
What Is UKCA Marking?
The UK Conformity Assessed (UKCA) mark is the UK's post-Brexit equivalent of the CE mark. It applies to goods placed on the market in Great Britain (it does not cover Northern Ireland) and largely mirrors the EU system: essential requirements, conformity assessment modules, technical documentation, and a Declaration of Conformity — but assessed against UK-designated (rather than EU) legislation and standards, which have started to diverge from their EU equivalents over time.
UK Approved Bodies vs EU Notified Bodies
Where third-party conformity assessment is required, the UK system uses UK Approved Bodies instead of EU Notified Bodies. The two designations are entirely separate:
- A certificate from an EU Notified Body is valid for CE marking but not for UKCA
- A certificate from a UK Approved Body is valid for UKCA but not for CE marking
- Many organisations that previously acted as EU Notified Bodies now operate separately re-designated UK entities to issue both types of certificate, but manufacturers must engage each certification path independently
The UK Responsible Person (UKRP)
Just as CE marking requires an EU Authorized Representative for non-EU manufacturers of certain products, UKCA marking requires a UK Responsible Person (UKRP) for manufacturers based outside the UK. The UKRP:
- Must be established in the UK
- Holds a copy of the technical documentation and Declaration of Conformity, available to UK market surveillance authorities on request
- Has their name and UK address on the product, packaging, or an accompanying document
- Cooperates with authorities on corrective action if a product presents a risk
Northern Ireland: A Third System
Under the Windsor Framework, Northern Ireland continues to follow EU product rules for goods. This means:
- Goods placed on the NI market must carry the CE mark, not UKCA
- Where a UK (rather than EU) body carried out mandatory third-party assessment, the product carries CE + UKNI markings together — UKNI alone has no standalone validity and cannot be used without CE
- Certain retail goods moving from GB into Northern Ireland through the green lane may require "Not for EU" labelling as part of the wider NI retail movement scheme
Do You Need Dual Marking?
Whether to pursue UKCA marking alongside CE depends on your specific situation:
CE marking alone may be enough if…
Your product category is one where GB continues to recognise CE marking indefinitely, and you are not required to use a UK Approved Body for any reason.
Dual marking (UKCA + CE) makes sense if…
Your product category has a firm UKCA-only requirement in GB, you want to hedge against future policy changes, or you specifically need certification from a UK Approved Body for commercial or contractual reasons.
In practice, most manufacturers selling identical product lines into both the EU and GB markets today rely on CE marking for both, appointing a UK Responsible Person only where their category strictly requires UKCA, and revisiting the decision as UK rules continue to evolve.
Selling Into the UK Market?
Submit a request on ECP describing your product and target market. We route it to UK Responsible Person providers, UK Approved Bodies, and consultants who can confirm exactly what your product needs for GB and Northern Ireland.
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Frequently Asked Questions
Can I still use CE marking to sell in Great Britain?
For most product categories, yes — the UK has extended recognition of CE marking indefinitely. A defined list of categories (medical devices, construction products, transportable pressure equipment, cableways, ecodesign/energy labelling) follows separate rules, so always check the current guidance for your product.
Does UKCA marking apply in Northern Ireland?
No. Northern Ireland follows EU product rules under the Windsor Framework — goods there need CE marking (or CE + UKNI), not UKCA.
What is a UK Approved Body and how is it different from an EU Notified Body?
A UK Approved Body carries out third-party conformity assessment for UKCA marking, mirroring the Notified Body role for CE. The two designations are separate — certificates from one are not valid for the other.
Who needs a UK Responsible Person?
Manufacturers based outside the UK placing UKCA-marked goods on the GB market must appoint a UK-established Responsible Person, similar to the EU Authorized Representative role for CE marking.
Do I need both UKCA and CE marking?
Only if your product category requires UKCA specifically, you want to hedge against future GB policy changes, or you need certification from a UK Approved Body. Many manufacturers rely on CE marking for both EU and GB today.
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