UKCA marking for overseas sellers: UKCA or CE in Great Britain

Great Britain accepts the CE marking, alongside or in place of the UKCA marking, for most product regimes (Department for Business and Trade, DBT). A CE-marked toy, radio device or electrical product needs no second mark to be sold in England, Scotland or Wales. Northern Ireland takes CE, or CE and UKNI. This page covers only what the UK adds to the EU CE rule, and it applies only to a product whose product regulation asks for a conformity mark: DBT says not all products must bear one. The rest of the UK rules for a seller are on the United Kingdom overview.

Which mark each part of the UK takes

The product regulation your product falls under decides the mark. DBT’s marking table lists it for each regime:

What stands behind the first row and the dates:

• The 2024 regulations. The Product Safety and Metrology etc. (Amendment) Regulations 2024 (SI 2024/696) came into force on 1 October 2024. They amend 20 sets of product regulations and one provision of a 21st, the measuring container bottles regulations. In each they revoke the provision that set an expiry for meeting the Great Britain rules by complying with the corresponding EU law (explanatory note). Before them that provision was set to expire after four years (SI 2022/1393, reg. 2 and Schedule 1). They put no new expiry date in its place.
• Medical devices. The only regime in the table with end dates written into its regulations. Regulations 19B and 30A of the Medical Devices Regulations 2002, for devices under Directives 93/42/EEC and 90/385/EEC, cease at 23:59 on 30 June 2028. Regulations 19C, 44ZA and 44ZB, for Regulation (EU) 2017/745Regulation (EU) 2017/745, Medical Devices Regulation (consolidated text of 19 July 2026)The whole regulationClick opens the law on the EU Publications Office., Directive 98/79/EC and Regulation (EU) 2017/746Regulation (EU) 2017/746, In Vitro Diagnostic Medical Devices Regulation (consolidated text of 10 January 2025)The whole regulationClick opens the law on the EU Publications Office., cease at 23:59 on 30 June 2030. A consultation on indefinite recognition of CE-marked devices opened on 16 February 2026 (DBT).
• Construction products. The Construction Products (Amendment) Regulations 2025 (SI 2025/1172), in force 8 January 2026, let a CE-marked product meet the Great Britain rules by complying with Regulation (EU) No 305/2011Regulation (EU) No 305/2011, Construction Products Regulation (the 2011 Regulation)The whole regulationClick opens the law on the EU Publications Office. or Regulation (EU) 2024/3110Regulation (EU) 2024/3110, Construction Products RegulationThe whole regulationClick opens the law on the EU Publications Office.. DBT says the government has committed to keep recognising CE for these products, subject to reform, with any change given a minimum two-year transition.
• Outdoor noise. The 2025 amendment regulations (SI 2025/1073), in force 13 April 2026, update the noise measuring methods and drop the duty to send a copy of the declaration of conformity to the Secretary of State; DBT says they continue CE recognition for these products.
• Machinery. The Supply of Machinery (Safety) (Amendment etc.) and the EU Machinery Regulation (Enforcement etc. in Northern Ireland) Regulations 2026 (SI 2026/867), made on 22 July 2026, come into force on 20 January 2027. In Great Britain they replace regulation 12A of the Supply of Machinery (Safety) Regulations 2008, so that machinery meeting Regulation (EU) 2023/1230Regulation (EU) 2023/1230, Machinery Regulation (consolidated text of 27 July 2026)The whole regulationClick opens the law on the EU Publications Office. is treated as meeting the Great Britain rules, with the technical documentation and the EU declaration of conformity in English and the CE marking affixed. In Northern Ireland the Machinery Regulation applies directly, and the UKNI indication goes next to the CE marking where a UK notified body did a conformity assessment procedure under Article 25Regulation (EU) 2023/1230, Machinery Regulation (consolidated text of 27 July 2026)The whole regulationClick opens the law on the EU Publications Office. (reg. 5). The EU rules are in the Machinery Regulation guide.

Recognition runs regime by regime, against the EU law as the Great Britain regulation names it. It does not extend by itself to new EU laws: each new EU law needs its own instrument. For energy-related products that instrument is the Ecodesign for Energy-Related Products and Energy Information (Amendment) Regulations 2026 (SI 2026/750), made on 3 July 2026 and in force on 27 July 2026. Regulation 4 amends regulation 20B of the Ecodesign for Energy-Related Products Regulations 2010, so that a manufacturer or importer can meet it by complying with Regulation (EU) 2024/1781Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationThe whole regulationClick opens the law on the EU Publications Office., the Ecodesign for Sustainable Products Regulation, with the EC declaration of conformity translated into English. The Product Regulation and Metrology Act 2025, in force from 21 July 2025, lets the Secretary of State set product requirements, marking and rules for sales through online marketplaces by regulations, and the 2025 noise regulations and SI 2026/750 are made under it.

The EU does not recognise UKCA. A product you also sell in the EU keeps its CE marking there (OPSS).

When you still use UKCA

• You choose it, or a UK body certified the product. The UKCA marking goes on after the UK route, or after Fast-Track UKCA: you meet the recognised EU requirements and the conformity assessment procedures, using an EU conformity assessment body where one is needed, and apply UKCA (DBT). A certificate from a UK Approved Body supports UKCA only.
• Both marks on one product. A product can carry UKCA and CE together, as long as it complies with the relevant requirements and the markings can be clearly seen (DBT).
• Where UKCA goes. On the product or its data plate. In most sectors it may go on a label affixed to the product, or on a document accompanying it, until 11pm on 31 December 2027 (DBT); for electrical equipment the regulation says “seven years beginning with IP completion day” (reg. 39(1A)). After that, regulation 39(1) applies: the product or its data plate, and the packaging and accompanying documents where that is not possible or not warranted (reg. 39(2)). Cableways, construction products, marine equipment, medical devices, rail products, transportable pressure equipment and uncrewed aircraft systems have their own rules.

UK Approved Bodies and where to find one

Many regimes let the manufacturer self-declare. Where a regulation requires third-party assessment, the body depends on the mark:

UK and EU bodies can also sit in a third country under a mutual recognition agreement, and OPSS says a body outside the UK can be approved where such an agreement exists with the UK. Every UK body is listed in the UKMCAB database: 198 bodies on 5 October 2026, filterable by body type, including “Approved body”, “NI Notified body”, “Overseas body” and “UK body designated under MRA” (Australia, Canada, Japan, New Zealand, the USA), and by legislative area.

The UK declaration of conformity

For the UKCA route you draw up a UK declaration of conformity. The legislation it names can be UK legislation or recognised EU product regulations. The manufacturer, or an authorised representative as agreed, creates it, and DBT publishes a template (DBT, template updated 21 August 2026). What it must contain varies by regulation. For electrical equipment it must state that the principal elements of the safety objectives have been demonstrated and follow the model structure in Schedule 8 (reg. 38). The manufacturer keeps it with the technical documentation for 10 years from the day the equipment is placed on the market (reg. 7), and so does the importer (reg. 21).

On the CE route the document is the EU declaration of conformity, as in the EU guide. For electrical equipment the manufacturer then has the technical documentation and the EU declaration prepared in or translated into English (reg. 34A(2)(d), (g)).

The importer, the representative and English

• UK importer. An importer is a person established in the United Kingdom that places a product from outside the UK on the market, or a person established in Northern Ireland that places on the market a product supplied to it from an EEA state (Electrical Equipment (Safety) Regulations 2016, reg. 2). An EU address does not meet that definition. The duties sit with that UK business; regulation 2 does not make an overseas seller set one up.
• Importer’s name and address. The importer indicates on the product its name, registered trade name or trade mark, and a postal address at which it can be contacted, in a language easily understood by end users and the market surveillance authority; where that is impossible, on the packaging or in an accompanying document (reg. 18; the toy rule is similar, with one more case where the details go on the packaging: the importer would have to open the toy’s packaging to mark the toy, Toys (Safety) Regulations 2011, reg. 27). Until 11pm on 31 December 2027, an importer of products from an EEA state, or in some cases Switzerland, may put the details on the packaging or an accompanying document instead of the product (DBT).
• Authorised representative. Optional, and it must be established in the UK. It is appointed by written mandate; the mandate cannot cover designing and making the product to the safety objectives or drawing up the technical documentation; for the tasks it is given the representative takes on the manufacturer’s duties, and for electrical equipment the penalties for breaking them (reg. 14); under the radio rules it may be proceeded against as though it were the manufacturer (reg. 19); toys follow the same mandate model (reg. 25). DBT says a representative may be essential or voluntary depending on the regulation.
• English. Instructions and safety information must be in easily understandable English (reg. 9 for the manufacturer, reg. 19 for the importer).

Northern Ireland

• Marks. CE, or UKNI and CE. UKNI is never used on its own: it accompanies CE where a UK-based notified body did the third-party assessment (DBT). The marking table lists only CE, or UKNI and CE, for the regimes that take CE; UKCA is not on the Northern Ireland side.
• Northern Ireland products in Great Britain. Qualifying Northern Ireland products can be placed on the Great Britain market on their CE, or UKNI and CE, markings (DBT).
• English. Instructions for the Northern Ireland market must be in easily understandable English (DBT).
• Responsible operator. A separate rule on who answers for a product sold in Northern Ireland is on the United Kingdom overview.
• Crown dependencies and Overseas Territories. The UKCA and UKNI markings do not apply in Guernsey, Jersey, the Isle of Man or the British Overseas Territories (DBT).

Who enforces, and what a breach costs

Each product regulation names its own market surveillance authority. For electrical equipment it is the Health and Safety Executive for equipment used at work, and for equipment for private use, within its area, a weights and measures authority in Great Britain or a district council in Northern Ireland; the Secretary of State may enforce too (regs. 40 and 41). OPSS lists local authority Trading Standards in Great Britain and local authority Environmental Health in Northern Ireland for advice and support, and says its own enforcement staff investigate allegations that are national, novel or contentious in scope (OPSS).

The EU leaves penalties to each EU country. In the UK they are written into each regulation and are criminal offences:

It is a defence to show you took all reasonable steps and exercised all due diligence to avoid the offence (Electrical Equipment (Safety) Regulations 2016, reg. 52).

If you do nothing

Where the marking is missing or wrongly affixed, the declaration is missing or wrong, the technical documentation is missing or incomplete, or the type, batch or serial number, the manufacturer’s name and postal address or the instructions are absent, false or incomplete, the authority must require you to put it right within a reasonable period and cannot start proceedings or take other enforcement action before that period ends. If the non-compliance persists, it must take measures to restrict or prohibit the product, or have it withdrawn or recalled. None of that applies where the product presents a risk, and the procedure is written around the UK marking and the UK declaration: for a manufacturer on the CE route, regulation 34A(3)(d) disapplies regulation 48(1) (Electrical Equipment (Safety) Regulations 2016, regs. 48 and 34A). DBT says that if you fail to co-operate you must withdraw or recall the product, and you may be liable for a fine and imprisonment (DBT).

What you do from outside the UK

1. Find your product’s regulation in the table above. If it takes CE in Great Britain, your CE-marked product can be sold there with no second mark. You still keep the technical documentation and the EU declaration of conformity in English.
2. Add UKCA only if you choose the UK route or a UK Approved Body certified the product. Keep CE for the EU.
3. If third-party assessment is required, use an EU notified body for CE or a UK Approved Body for UKCA, and find either in the UKMCAB database or on NANDO.
4. For Great Britain, where a UK business imports your goods, it puts its name and postal address on the product, or on the packaging or an accompanying document where the rules above allow. A UK authorised representative is optional.
5. Write the instructions and safety information in English.
6. Keep the technical documentation and the declaration for the period the regulation sets, typically 10 years from the day each product is placed on the market.
7. For Northern Ireland, mark CE, and add UKNI only where a UK-based notified body did the assessment.