Home ServicesLaw Ensure your business is Brexit prepared with the new UKCA mark

Ensure your business is Brexit prepared with the new UKCA mark

by Tom Pattinson
0 comment

Businesses that sell goods into the UK will need a United Kingdom Conformity Assessment (UKCA) Mark from 1 January 2021

The United Kingdom formally left the European Union on January 31, 2020 and the year-long transition period that allowed continuity of rules and regulations ends on December 31, 2020. This includes the rules surrounding the conformity of marking and assessment of products.

Although the UK and EU are attempting to negotiate an agreement in relation to the regulatory regime after the transition period, plans are also being implemented for the introduction of a United Kingdom Conformity Assessment (UKCA) Mark in the event that a deal is not reached.

What is the UKCA Mark?

The UKCA mark is a new conformity mark for goods intended to be placed on the market in England, Wales and Scotland. This compliance mark will replace the existing European CE mark. (Goods being sold on the Northern Ireland market fall under a slightly different jurisdiction. See the table below). UK regulations have been amended to broadly replace references to the CE mark with reference to the UKCA mark and the role of ‘Notified Bodies’ will be replaced with ‘UK Approved Bodies.’


The table below illustrates the accepted markings in each relevant market.

Who is the UKCA Mark for?

Whether you are a manufacturer, importer or distributor, it is important that you ensure that products brought into the UK have the new mark.

Businesses are encouraged to be ready for full implementation of the new UK regime as soon as possible after 1 January 2021. However, there will be a one year period where both the UKCA or CE mark will be accepted for products shipped before 1 January 2021. The UKCA mark will entirely replace the CE mark at the end of 2021.

Read Also
How to protect your IP in time for Brexit

When do you need to use the UKCA mark?

Companies will need to use the new UKCA mark if all of the following apply:

  • The product is for the market in Great Britain
  • The product is covered by legislation which requires the UKCA marking
  • The product requires mandatory third-party conformity assessment
  • The product’s conformity assessment has been carried out by a UK conformity assessment body and you haven’t transferred your conformity assessment files from your UK body to an EU recognised body before 1 January 2021.

This does not apply to existing stock, for example, if the product was fully manufactured and ready to place on the market before 1 January 2021. In these cases your goods can still be sold in Great Britain with a CE marking, even if covered by a certificate of conformity issued by a UK body.

How should you use the UKCA mark?

In most cases, the UKCA mark must be applied to the product itself or to the packaging. In some cases, it may be placed on the manuals or on other supporting literature. This will vary depending on the specific regulations that apply to the product.

The following general rules apply:

  • UKCA markings must only be placed on a product by the manufacturer or an authorised representative (where allowed for in the relevant legislation)
  • When attaching the UKCA mark, the company takes full responsibility for the product’s conformity with the requirements of the relevant legislation
  • The company must only use the UKCA mark to show product conformity with the relevant UK legislation
  • The company must not place any marking or sign that may misconstrue the meaning or form of the UKCA marking to third parties
  • The company must not attach other marks on the product, which affect the visibility, legibility or meaning of the UKCA Mark
  • The UKCA Mark cannot be placed on products unless there is a specific requirement to do so in the legislation.
Read Also
Despite physical and political turbulence, John Edwards paints a positive picture of future trade

Brexit: What you will need to consider or be prepared

  1. The new conformity assessment requirements:
  • The UK Government has confirmed that UKCA marking comes into force from 1 January 2021. However, to allow businesses time to adjust to the new requirements, the existing CE marking is allowed to be used until 1 January 2022 in most cases.
  • After 1 January 2022, the UK will stop recognising the CE mark or conformity assessment activities that have been performed by EU27 Notified Bodies.
  • The new UK legislation requires product conformity assessment activities to be performed by an entity or Assessment Body located in the UK.
  • Likewise, the EU will not recognise conformity assessment activities performed by Notified Bodies in the UK for products placed on the market on and after 1 January 1 2021. And The EU will not recognise the ‘UKCA’ mark.
  • EU Directives require some activities to be performed by entities located within the EU/EEA.
  1. The timeline:

Note: This graphic does not include timescales for marine equipment, medical devices or IVDs.

Manufacturers will need to carefully consider the implications of Brexit on the conformity of their products and take appropriate action to ensure that all declarations are made correctly and on time. Although there is a transition period, it is essential that companies complete the new requirements as soon as possible. Manufacturers will also need to ensure that various partners within the supply chain are located in the correct territory.

  1. Making contact with the ‘Conformity Assessment Bodies’ 

On January 1, 2021, UK-based Notified Bodies will automatically become ‘Appointed Bodies’ under the UKCA legislation. Any UK Notified Body-issued certificates that have not been transferred to an EU27 Notified Body, will automatically become valid as a means for illustrating conformity under the UK Regulations to which they apply: Reaching out to Conformity Assessment Bodies is always recommended if there are questions.


This article was written by BSI. BSI is appointed by the UK Government as the national standards body, holds the Royal Charter, and represents UK interests at the International Organisation for Standardisation (ISO), the International Electrotechnical Commission (IEC) and the European Standards Organisations (CEN, CENELEC and ETSI).

BSI’s role as the UK National Standards Body is to help improve the quality and safety of products, services and systems by enabling the creation of standards and encouraging their use. We represent UK economic and social interests across all European and international standards organisations and in the development of business information solutions for British organisations of all sizes and sectors.

BSI is also a Certification Body and Notified Body. For UKCA Services, BSI is an approved body (0086) for the UKCA Mark and can work with you on the required conformity assessment procedures that will allow you to affix the UKCA marking under the following areas:

Learn more about BSI Services and the new UKCA Mark. At the time of writing, guidelines and timelines regarding UKCA marking for Medical Devices and IVD’s differ to those for the products listed above.

Related Articles

This website uses cookies to improve your experience. We'll assume you're ok with this, but you can opt-out if you wish. Accept Read More