UKCA Marking:  

Unless there is a last minute rethink , from 1st January 2021 all goods sold in the UK that currently require CE Marking, willneed UKCA marking... both if you do anything but trade in Great Britain.  The UKCA marking can be used from 1 January 2021. However, to allow businesses time to adjust to the new requirements, you will still be able to use the CE marking until 1 January 2022 in most cases.

Click here to see the official guidance , carry on below to see a summary ... and our current advice!

The situation concerning UKCA is becoming clearer but  the guidelines for the possible introduction of UKCA have appeared before and then disappeared when the initial divorce deal was done , it is possible that this may happen again , although some form of mutual recognition is more likely….  Currently it would be a one-way recognition i.e. the UK will accept CE marking , but the EU won’t accept UKCA in the transition.  


  • UKCA marking can be used from 01/01/2021     

  • However, CE marking can still be used until 01/01/2022  (this is new and was added to the current version … by sensible people!)

  • CE marking will only be valid in Great Britain (not the UK ironically!) or areas where GB & EU rules remain the same. If EU rules change you CE mark product on basis of new rules, you will not be able to use CE mark to sell into GB, even before 31/12/2021. (Note that this is highly unlikely to happens as the EU typically take 2-3 years to bring in legislation and nothing is on the immediate horizon) 

  • Northern Ireland will be different and CE Marking will continue for an unspecified time ….and these will be able to be legally shipped to the rest of the UK!  Possibly there will be a NI mark? 

  • UKCA mark will not be recognised in EU market, CE mark will still be needed for products sold on EU markets.

  • A UK Declaration of Conformity must be drawn up for most products lawfully bearing UKCA mark. Information required will largely be same as for the EU DoC , but will reference the UK Statutory Instruments rather than the EU Directives and Regulations .

  • On 01/01/2021 a list of EN standards will be put together which can provide a Presumption of Conformity for UKCA (just like the Official Journal of the EU), 

  • From 01/01/2023 the UKCA mark must, in most cases, be affixed directly to the product. 

The “advice” that we are currently giving people (that already CE Mark their products) is the reverse to that the government is pushing , i.e. hold on and don’t do anything yet….. the reason that this makes sense (to us anyway) is


  1. Sensible people got involved when the last set of UKCA guidelines were withdrawn such that the new ones include a 12 month extension 

  2. The process will be completely unchanged and just mirror that of the current system , with the directives replaced by the relevant UK SI (statutory instruments) and the EU DoC changed to a UK DoC .

  3. Some required SI may be changed

  4. The list of standards has not be assembled or ratified

  5. The list of useable UK Statutory Instruments is likely to change

  6. The situation with Notified Bodies is still being discussed , currently there are no UK approved bodies  since they cannot exist until 1st January 2021 

Statement: Petts Consulting Ltd will provide an Organization with the knowledge of the Directives and an appropriate process which, when applied correctly will demonstrate due-diligence. However, the CE-marking is the manufacturers claim that the product meets the essential requirements of all relevant European Directives. In many cases the process to be carried out is a self-declaration process and the responsibility for any decisions lie with the management of the Company. During the course of the project Petts Consulting Limited will provide guidance and advice but ultimately it cannot be held responsible for such decisions.

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