When the United Kingdom left the European Union, it also left the EU's CE marking system and introduced its own conformity mark — the UKCA (UK Conformity Assessed) mark — for products placed on the market in Great Britain (England, Scotland, and Wales). For a few years it appeared that manufacturers would need UKCA marking to replace CE for the GB market. For most products, that is no longer the case.

The key point for most manufacturers: your CE marking still works in Great Britain

Under the Product Safety and Metrology etc. (Amendment) Regulations 2024, the UK made recognition of the CE mark in Great Britain indefinite for 21 product regulations — including the categories most of our clients work in: radio equipment, electrical equipment, electromagnetic compatibility (EMC), machinery, toys, and personal protective equipment. In practice, a product already CE-marked to EU requirements can be placed on the Great Britain market without a separate UKCA mark, with no current end date.

So for the majority of electronics and wireless products, your existing CE certification covers both the EU and Great Britain. UKCA marking remains available, but for these categories it is effectively voluntary.

When UKCA (or another UK route) is still required

Indefinite CE recognition does not cover every sector. For these, CE alone is not sufficient for the GB market and a UK-specific route applies: medical devices (administered by the MHRA — CE-marked devices currently retain GB access under transitional arrangements, with a consultation underway on longer-term recognition), construction products, marine equipment, rail products, cableways, transportable pressure equipment, and unmanned aircraft systems. If your product falls into one of these, the path is different — talk to us.

Northern Ireland is different

Northern Ireland follows EU rules under the Windsor Framework. Products placed on the Northern Ireland market must be CE-marked (with the UKNI mark added only in specific cases where a UK-based conformity assessment body is used). UKCA marking alone is not valid in Northern Ireland.

How CSIA helps

The UK picture has changed repeatedly since Brexit, and the details depend on your product category and where in the UK you're selling. CSIA stays current on it so you don't have to — we'll confirm whether your existing CE marking covers your GB needs, identify when UKCA or another UK route is required, and manage the testing and documentation either way.

Selling into the UK? Contact us and we'll map the right path for your product.