Quick Manufacturer's Guide to UKCA Marking

Patrícia Gabriel / 05 July 2023

Product certification and conformity marks play a crucial role in ensuring safety, quality, and compliance with regulations in the global marketplace. In Europe, the CE mark has been widely recognised as a symbol of conformity, while the United Kingdom introduced the UKCA mark for Great Britain following its departure from the European Union. In recent times, both marks have undergone significant changes and updates. In this article, we will explore the latest developments, discuss the implications and introduce our fire stopping products that have now obtained the new UKCA mark.

The CE Mark

The CE mark, standing for Conformité Européene (European Conformity), has long been a prominent indicator of compliance with European Union (EU) regulations. It signifies that a product meets the essential health, safety, and environmental requirements outlined in relevant EU directives. However, with the UK's departure from the EU, the CE mark's applicability in the United Kingdom has undergone significant changes.

The UKCA Mark

The United Kingdom Conformity Assessed (UKCA) mark was introduced to replace the CE mark in Great Britain (England, Scotland, and Wales) after the end of the Brexit transition period on January 1, 2021. The UKCA mark ensures that products placed on the market in these regions comply with UK regulations. It covers most goods that previously required CE marking.


To achieve the UKCA Marking for non-harmonised products, the UK Technical Assessment (UKTA) is now mandatory. In a similar manner, the European Technical Assessment (ETA) is utilised to obtain the CE Marking in Europe and in the future, from the day the changes take place, it will no longer be recognised in the UK. Whilst UKCA Marking is mandatory, the UKTA route is voluntary, but it may be demanded in the future for specification purposes.

The UKTA’s can be issued by UK-based Technical Assessment Bodies and once obtained, products can then be affixed with UKCA Marking.

Key Changes and Updates

  1. Post-Brexit Transition Period: As mentioned, the Brexit transition period ended on January 1, 2021, marking the full implementation of the UKCA mark in Great Britain. However, it's important to note that Northern Ireland follows different rules due to the Northern Ireland Protocol, which aligns it with EU regulations, requiring the continued use of CE marking.
  2. Dual-Use of CE and UKCA Marks: Initially, the UKCA mark was supposed to be mandatory for most products from January 1, 2021, completely replacing the CE mark. However, recognising the challenges businesses faced due to the COVID-19 pandemic and difficulties in transitioning, the UK government has now allowed a two and half-year grace period. Until June 30th, 2025, products can be marked with either the CE mark or the UKCA mark to be placed on the market in Great Britain according to the legal obligations under UK Construction Product Regulations and / or the requirements of Approved Document 7. However, the UKCA mark alone is required for certain products, including those covered by specific UK legislation.
  3. New UKCA Marking Requirements: When using the UKCA mark, manufacturers must update their product labels, packaging, and accompanying documentation to reflect the new conformity assessment procedures. The UKCA mark must be affixed to the product or an accompanying label, and manufacturers must issue a UK Declaration of Conformity to demonstrate compliance with relevant UK regulations.
  4. Continued Recognition of CE Marking: The CE mark will continue to be recognized in the European Economic Area (EEA), which includes EU member states, as well as Iceland, Liechtenstein, and Norway. Therefore, manufacturers who meet EU requirements can use the CE mark for products intended for the EEA market, even if they have already obtained the UKCA mark.

Implications for Customers and Businesses

The changes and updates regarding CE and UKCA marks have important implications for both customers and businesses. Manufacturers exporting to the UK must ensure compliance with the UKCA mark requirements to access the Great Britain market. Similarly, companies exporting to the EU must continue to meet CE marking requirements for access to the EEA market.

For customers, the transition from CE to UKCA marks may cause some confusion initially, especially if products bear different markings depending on the intended market. It is crucial to understand that both marks serve the purpose of ensuring product safety and compliance with applicable regulations.

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