UKCA marking: complete guide for manufacturers

If you manufacture or place products on the Great Britain market (England, Scotland, and Wales), you need to understand the UK Conformity Assessed (UKCA) marking requirements. This guide explains when UKCA marking is needed, how the December 2024 policy change affects your options, and what you must do to comply.

Key update (October 2024): The UK Government now recognises CE marking indefinitely for 21 product categories. This means for most products, you can choose to use either UKCA marking, CE marking, or both.

When you need UKCA marking (or don't)

Before December 2024, CE marking acceptance had an end date. Manufacturers were preparing to switch entirely to UKCA. That deadline has now been removed for most product categories.

You have a choice if your product falls under the 21 product regulations with indefinite CE recognition. You can:

• Continue using CE marking alone (if you have valid EU conformity assessment)
• Use UKCA marking alone
• Use both CE and UKCA markings together

You must use UKCA marking if:

• Your product falls outside the 21 recognised regulations (medical devices, construction products, marine equipment - see section on excluded products)
• You want to demonstrate compliance with UK-specific requirements that differ from EU rules
• You're exporting to GB from outside the EU/UK and don't have CE certification

Northern Ireland is different: UKCA marking does not apply in Northern Ireland. Products for the NI market use CE marking under the Windsor Framework. If a UK Approved Body assessed your product for the NI market, you use the UKNI marking alongside CE marking.

Understanding the current marking policy

The Product Safety and Metrology etc. (Amendment) Regulations 2024 fundamentally changed the product marking landscape. Previously, businesses faced a hard deadline to switch from CE to UKCA marking. That uncertainty has been replaced with long-term flexibility.

What this means in practice:

If you're already CE marked and sell to both the EU and GB markets, you don't need to make any changes for the GB market. Your existing CE marking remains valid indefinitely.

If you only sell to Great Britain and have never obtained CE marking, you should use UKCA marking. This demonstrates compliance with UK legislation and avoids any dependency on EU conformity assessment.

If you're a new manufacturer deciding between CE and UKCA, consider your target markets:

• GB only: UKCA marking is cleaner and self-contained
• GB plus EU: CE marking covers both markets under current rules
• Future-proofing: Having both markings provides maximum flexibility if rules change

Conformity assessment: proving your product is safe

Before applying any product marking, you must demonstrate that your product meets the essential requirements set out in the relevant legislation. How you do this depends on your product's risk level.

Self-declaration (lower-risk products)

For many products, you can self-declare conformity without involving a third party. This is appropriate when:

• The relevant product legislation permits self-declaration
• Your product doesn't require third-party testing under the regulations
• You can demonstrate conformity using designated standards

Self-declaration still requires rigorous testing and documentation. You're taking legal responsibility for your product's safety. If OPSS (the Office for Product Safety and Standards) investigates and finds non-compliance, you face enforcement action.

UK Approved Body assessment (higher-risk products)

Higher-risk products require independent assessment by a UK Approved Body. These are organisations accredited by UKAS (UK Accreditation Service) and designated by the relevant government department.

You need a UK Approved Body when:

• The product legislation specifically requires third-party assessment
• Your product poses higher safety risks (pressure equipment above certain thresholds, Category III PPE, machinery with specific hazards)
• You cannot demonstrate conformity through self-declaration routes

Find an Approved Body using the UKMCAB database. Search by product type, regulation, and conformity assessment procedure to find bodies authorised for your specific needs.

Fast-track route from CE marking

If your product already has valid CE marking based on EU conformity assessment, you can convert to UKCA marking without repeating the entire assessment. This fast-track route recognises the work already done.

To use the fast-track route:

1. Verify your product has valid CE marking and EU conformity assessment
2. Draw up a UK Declaration of Conformity (see documentation section)
3. Reference the EU legislation you've met in your UK Declaration
4. Affix the UKCA marking to your product

This route works because UK and EU product requirements remain largely aligned for the 21 covered regulations. If UK requirements diverge significantly in future, this fast-track route may become unavailable for affected products.

Documentation you must keep

Proper documentation protects you legally and demonstrates good faith compliance. You must create and retain:

UK Declaration of Conformity

This is your formal statement that the product meets requirements. It must include:

• Your business name and address (the manufacturer or authorised representative)
• Product identification (model, type, batch or serial number)
• Statement that you take sole responsibility for compliance
• References to relevant UK legislation (by SI number and title)
• List of UK designated standards applied (or other specifications used)
• UK Approved Body name and number (if one was involved)
• Signature, date, and signatory's name and function

The declaration must be in English. Keep it for 10 years after the last product of that type is placed on the market.

Technical documentation

You must compile technical documentation that demonstrates how your product meets each essential requirement. This typically includes:

• Design drawings and manufacturing specifications
• Test reports and calculation results
• Risk assessment documents
• Quality control procedures
• Instructions and safety information provided with the product

Keep technical documentation for 10 years. OPSS can request to see it at any time.

Labelling and marking rules

The physical UKCA marking must be applied correctly. Getting this wrong can invalidate your compliance.

Where to place the marking

Primary rule: Place the UKCA marking on the product itself. This is the default requirement.

Exceptions: You may place the marking on the packaging or accompanying documents if:

• The product's nature makes it impossible to mark (too small, would damage product)
• The relevant legislation specifically permits alternative placement

Temporary flexibility (until 31 December 2027): You can currently place UKCA marking on a label affixed to the product rather than directly on the product. This flexibility ends in 2027 - plan ahead if your current approach relies on labels.

Using UKCA and CE together

You can display both markings on a product if it meets both UK and EU requirements. Each marking must be visible and clearly separate. The markings cannot overlap or be placed in a way that suggests they are one combined mark.

Approved Body identification number

If a UK Approved Body was involved in your conformity assessment, their four-digit identification number must appear directly after the UKCA marking on the product. This number links your product to the specific body that certified it.

Products with separate rules

The 21 product regulations with indefinite CE recognition cover most manufactured goods, but some categories have their own arrangements.

Medical devices

Medical devices are regulated by the MHRA under separate rules. CE marking is currently accepted with extended deadlines (30 June 2028 for devices certified under the old EU Medical Devices Directive, 30 June 2030 for devices certified under the new EU MDR). The MHRA is consulting on proposals to extend CE recognition indefinitely for medical devices too.

Construction products

Construction products have their own regulatory framework. CE marking continues to be available, and OPSS has stated it will not take enforcement action against UKCA marking based on EU notified body testing completed before 31 December 2022.

Other excluded categories

Marine equipment, rail products, cableways (ski lifts), transportable pressure equipment, and unmanned aircraft systems (drones) all have separate sector-specific rules. Check the relevant regulator's guidance for these products.

What to do next

If you're already compliant: Review your current approach. If CE marking meets your needs and you have valid EU conformity assessment, you can continue as you are. Consider whether dual marking provides useful flexibility.

If you're setting up compliance for a new product:

1. Identify which product regulation(s) apply to your product
2. Determine your conformity assessment route (self-declaration or Approved Body)
3. Compile technical documentation and complete testing
4. Draw up your UK Declaration of Conformity
5. Apply the UKCA marking according to the rules above
6. Keep all documentation for at least 10 years

If you're unsure: Contact OPSS for guidance on specific products, or consult a UK Approved Body who can advise on your conformity assessment options.