If you sell products in European markets, you must know something about CE certification in EEA. But the CE marking is no longer widely applicable to products sold in the UK market after Brexit, which is replaced by the new UKCA certificate.
This post today will tell you the differences between CE and UKCA marking, certification and requirements. You can know whether CE or UKCA marking is required for your products if you want to sell them in the UK.
What is UKCA marking?
The UK Conformity Assessment marking, also UKCA marking, refers to the new product mark required to affix on certain products sold in the UK in accordance with the new regulations of product certification.
After Brexit, the UK Government introduced the new UKCA declaration of conformity to replace CE certification and the UKCA marking will replace CE marking used for products sold in the UK market (covering England, Scotland and Wales) from 1st Jan 2022.
It means any product with CE marking sold in the UK in the past or at present will switch to using the UKCA marking as their certification marking in the future.
What is CE marking?
If you sell products in the European Economic Area (EEA) or some other countries, or where products are manufactured to EU standards, the products are required to make CE certification to meet requirements on high safety, health and environmental protection.
After being assessed, your products will be affixed a CE mark to be sold in these areas legally.
What's the relation between UKCA vs CE?
CE and UKCA Requirements
Though CE and UKCA marking are two different markings required for respective markets, product categories and scope, technical requirements (including basic requirements and standards) and procedures of conformity assessment they cover are the same.
For instance, if you sell products in both EU and UK markets, the required materials and documents for assessment to get the CE and UKCA markings are the same.
Based on the same assessment requirements, the process to assess and get certificated UKCA and CE marking is the same. So the following part will take the process of getting UKCA marking as an example for your reference:
- Ensure appropriate UK regulations and standards for your products
- Make self-verification of product conformity
- Requiring conformity assessment by the UK notification body or not
- Assessing product conformity
- Save required technical files
- Affix the UKCA marking on your products and issue UKCA DoC
The using regulations of UKCA marking are consistent with the current rules for use of the CE marking.
As for detailed using rules, you can check on the official website.
When is the UKCA marking applied?
The new UKCA certificate in the UK has come into effect since Jan 1st, 2021. But considering the pre-existing stock and adaption time of all businesses, the usage of the CE mark in the UK will extend until 31st Dec 2022 in most cases.
In other words, if your products are manufactured and placed on the market before 1st Jan 2021, you can still sell them in the UK with the CE marking, without changing it to the UKCA marking until 31st Dec 2022.
According to the UK government, it requires the products to meet the following two conditions to use UKCA marking from 1st Jan 2021 without a transitional period:
- Products required the compulsory conformity assessment by the third-party (also conformity assessment bodies established in the UK.
- Having the assessment certification by the UK Conformity Assessment body or notified body.
Also, the following special product categories have different UKCA marking rules for the transitional period for your reference:
But there is a special district in GB that still uses CE marking, which is Northern Ireland. The UK government has a special marking-UKNI marking for the products sold in the Northern Ireland market. The following part will explain it in detail.
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What is UKNI marking? Where is it used?
UKNI is a new conformity marking for products sold in the Northern Ireland market, representing the product passing the compulsory conformity assessment by a third party in the UK.
It cannot be used alone, but has to be used with CE marking for legal sales in Northern Ireland. It has the following three conditions:
- Products apply to CE marking from 1st Jan 2021.
- Products required the mandatory conformity assessment from the third party (approved by notified bodies).
- UK institutions have to conduct conformity assessments according to EU regulations.
FAQs about CE, UKCA
1. What you should pay attention to about CE and UKCA?
- The valid time of CE Marking of pre-existing stock products in Great Britain is before 1st Jan 2023.
- Valid area of UKCA marking in beGreat Britain covers England, Scotland and Wales, and in Northern Ireland, CE marking continues to be effective. So if you sell products in Northern Ireland, only UKCA marking on your products is not available.
2. What products need to get CE marking?
Generally, you should get CE marking for your products before sales, so this part lists certain product categories requiring CE marking for your reference:
- Most general products, from toys to electronic devices
- Medical devices,
- Personal protective equipment,
- Other different equipment
But CE marking is not mandatory required for certain items, like
- Textile products,
- Raw materials (e.g. minerals, coal)
3. What products need to get UKCA marking?
At present, the UKCA marking is suitable for most categories of products previously subject to the CE marking. If your products are required for UKCA marking, you can refer to the product categories needed for CE marking, and also check more required product categories on the UK gov. website.
4. Can you use both UKCA and CE duel marking on your products?
Of course, you can. It’s very common that products of the same seller are sold in many countries or districts. For example, if your products are sold in the EEA, it requires you to affix a CE marking on your products; while you sell the same products in GB (Great Britain), you should have the UKCA mark on your products. Also, there are many products affixed with different required marks on the market.
5. Is the UKCA mark accepted within the EU?
The UKCA mark is only available in the GB area. If your products are only affixed with the UKCA mark but no CE mark, they are not allowed to be sold in the EEA area. In other words, only the UK government recognizes the UKCA, while the EU does not recognize it.
We hope this post will help you know the differences between CE and UKCA better, and you are clear about what product certificates are required for your products. If you want to know more about product certifications, you can find other articles on our website:
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