The UK has officially left the EU, and a lot of things have changed because of it. Many regulations we have known and followed for years were from the EU, and now that we are no longer a part of it, we are developing our own legislation. One significant change for products sold in the UK and beyond is the use of CE marks on products. It is essential that manufacturers, developers, and product designers understand these labelling changes and know what to expect with the new UKCA mark.

What Is CE Marking?

The CE mark is visible on a vast range of products. Electrical equipment, medical devices, toys, PPE, and more are required to show the CE mark if they are trading in Europe. It is a mandatory requirement for products sold in the EU which are subject to health and safety guidelines. The EU directives, regulations and standards have set many health and safety requirements for all kinds of products. Having the CE mark on these products signifies that they conform to all relevant regulations.

Manufacturing products that require a CE mark means that you are responsible for identifying the regulations you need to conform to, completing an assessment, maintaining a technical file, creating a declaration of conformity (DoC), and displaying the CE mark on the product in the appropriate format. Failing to conform with health and safety regulations and showcasing the CE mark can result in product recalls, hefty fines or imprisonment.


How Is CE Marking Changing in the UK?

As the UK left the EU, the rule around CE marking in the country changed. From 1st January 2021, the UK introduced the new UKCA mark, which stands for UK Conformity Assessment. This is required for products being sold in England, Wales and Scotland, and is similar to CE marking, but there are some differences which manufacturers must be aware of. Products which are sold in Northern Ireland are not subject to the UKCA mark but instead a new UK(NI) mark.

Businesses have been given a transition period to adjust to these new regulations. The rollout of the UKCA mark is:

  • From 1st January 2021: At the beginning of this year, we officially left the EU, but most products can continue to use the CE mark in the UK. This is the case for products that were manufactured before 31st December or have been assessed by an EU-Recognised Notification Body. New products and those which do not need third party assessment must immediately follow the new UKCA mark guidelines.
  • From 1st January 2022: Next year, CE marking will no longer be recognised in the UK. Products must be UKCA marked from this date, but it is possible to temporarily fix the marking to products using labels or by placing it in accompanying documentation.
  • From 1st January 2023: All products must have UKCA marking affixed directly during the manufacturing process.

What Products Need A UKCA Mark?

Many products sold in the UK after the end of 2021 will need to display a UKCA mark. This new labelling system covers most products that the old CE mark covered. Products which need UKCA marking include low voltage electrical equipment, machinery, toy, radio equipment, gas appliances, ecodesign and more. Aerosol products are also now covered by UKCA marking, although these were not under the CE mark. For a full list of products that require UKCA marking, check the government guidance.

What About Products for Sale in The EU?

Just because the CE mark regulations are changing here in the UK does not mean that they are changing everywhere. The EU will still be using CE marking in the same way as it did before, and any manufacturers who market their product in the EU will still need to conform to CE marking requirements. This means that many businesses who sell products in both the UK and the EU will need to provide both the UKCA mark and the CE mark. For most products, this shouldn’t pose too much of an issue, as the systems are very similar; however, it is essential that products are labelled correctly for both systems.

Another critical consideration is products that require a third-party conformity assessment. Some specific products must be assessed by a third party in order to display a CE or UKCA mark. These need to be assessed by an EU Notified Body, and from 2021 UK bodies are no longer recognised in the EU to complete this task. Similarly, UKCA requirements state that products will need to be assessed by a UK body. This could mean products are assessed twice by two separate bodies.

At 4D Products, many of the products we design go through stringent safety testing. We work in partnership with the best product testing houses to make sure we are working to the latest standards and procedures, regardless of where your new product is destined for sale.