Guiding European manufacturers from CE to UKCA step by step

Many European businesses, particularly those selling products to Great Britain, are faced with uncertainties around the Brexit transition period. NMi, the international measurement technology institute, outlines how you can comply with United Kingdom Conformity Assessed Mark (UKCA), the most recent change in regulation, affecting all European manufacturer’s access to the UK market.

As part of the EU/UK Trade and Cooperation agreement, the UK government replaced the European CE mark with UKCA early in 2021. Now, it is urging all companies selling their products into the UK to adopt the new changes by 1 January 2022 in order to retain access to the British market. While that deadline may seem a long way off, their advice is to meet the requirements sooner rather than later.

NMi is a leading specialist in legal metrology testing and testing, inspection and certification of measuring technology and delivers UKCA for European equipment manufacturers to become trusted in the UK. With many years of experience in providing metrological tests, they provided a step-by-step guide to helping businesses comply, cut through the red tape, and continue to trade with the UK. 

From EU CE to UKCA

To obtain the new UKCA mark, all products must meet British safety, technical and performance standards. As with the existing EU CE mark, it guarantees the product will meets safety, health, technical and environmental requirements. These markings will apply to a wide range of products, from supermarket scales to car brakes and industrial pressure valves. 

The new British legislation is relevant to manufacturers selling products in the UK that previously required

the CE mark. Adding to the uncertainty is the approach to Northern Ireland. Here, the approach is to allow use of both CE and/or a new UKNI marking. UKCA markings are not permitted for products to be placed on the Northern Irish market.


What does all this mean in practice for European companies and how can you achieve a seamless transition? 


Achieving clarity, step by step


The scope and type of CE and UKCE assessment is wide and dependent on product and regulatory requirements. For example, regulations applying to certain product areas require prescriptive approaches to compliance. These include, the safety of toys, simple pressure vessels, electromagnetic compatibility, and gas appliances. There are separate guidelines for medical equipment, railway interoperability, construction products and explosives for civil use. These products require a third-party conformity assessment carried out by a recognised inspection body. 


To comply with the new product markings, manufacturers who previously sold CE marked products must now comply with the requirements of UKCA. The same standards will apply at least initially, but for UKCA certifications, manufacturers will need to rely on a UKCA-approved body, established in Great Britain and designated by the UK government. To date, there have not been any material changes regarding the required safety, technical and compliance standards themselves, although this may change in the future.


When a product is certified, the inspection data is stored in a file. These files are kept for 10 years and regulators can check the product’s compliance at any point if they need to.

For other products, regulatory requirements are less reliant on third party conformity assessment and covered in manufacturer Declarations of Conformity (DoC). Here, compliance with mandatory technical requirements is demonstrated within technical documentation that accompanies the DoC. This will contain information such as a brief description of the product, testing outputs and evidence of design performance.


If a company requires a mandatory third-party conformity assessment for CE marked goods, it will have to do the same for UKCA-marked goods. These assessments must be carried out by an accredited UKCA approved body, and the procedure is the same as for the CE marking. If self-declaration of conformity was allowed for the CE marking, this applies to the UKCA marking too.


Guiding European businesses to a win-win


An important point to consider is the fact that the UKCA mark will not be recognised in the EU – and after January 1, 2022, for new products, the CE marking will also not be recognised in the UK. This means products currently requiring CE marking for sale in the EU will continue to require CE marking. Some assessment bodies, however, may be able to grant double EU an UKCA certifications, if like NMi, they are a formal presence in both Europe and the UK. 


Fully understanding the new UKCA marking, enabled by specialists like NMi, allows European businesses to start from a position of knowledge and clarity, rather than being baffled by bureaucracy. It is a win-win situation.