Brexit and UKCA mark

Brexit effect on CE/UKCA marking

Last edit: 01/09/2023

Starting from 1 January 2021, United Kingdom is officially outside of the European Union; the UKCA mark is introduced, with the intention of replacing the CE mark on the territory of Great Britain (England, Wales and Scotland).

The table below clarifies some of the terms used in this article.

As we will illustrate below, several factors hindered the initial intent of the British government to completely replace CE marking with UKCA marking, causing first postponements and then a final rejection of the proposal. On August 1, 2023, the government of Great Britain announced that CE marking will retain its validity on British territory; it will no longer be necessary to UKCA mark machinery in order to import it into England, Wales, and Scotland.



In the United Kingdom, the “Supply of Machinery (Safety) Regulations 2008” implemented Directive 2006/42/EC, regulating legislation on machinery safety. In preparation for Brexit, the Regulation was modified by the “Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019”, which fixed any deficiencies coming from the UK separation from the EU, such as:
•    Replacement of the reference to EU institution.
•    Obligation to use English language for documentation, including technical file and user instruction.
•    Introduction of the UKCA mark and its declaration of compliance.

Ensuring of the essential health and safety requirements is guaranteed by complying with the “Designated Standards”. Those standards are and will be developed by the same UK colleagues belonging to the BSI that have been participating for the last years in the development of IEC / CENELEC or ISO / CEN standards and they will continue contributing to the same committees in the future. That means, we should expect that as soon as the list of Harmonised Standards are published in the European Official Journal, they will be published by the UK as “Designated Standards for UK”. The list published right now (Jan 2021) on the site lists all harmonised EN standards. Consequently, manufacturers shall follow similar procedures for both CE and UKCA marking.

European Directive 2006/42/EC explains the procedure machinery manufacturers have to follow in order to place their products on the market:
1.    Ensure the applicable essential health and safety requirements.
2.    Ensure that the technical file il compiled and made available in accordance with the requirements of Annex VII.
3.    Provide information necessary to operate it safely, such as instructions.
4.    Follow the conformity assessment procedures prescribed by Article 12.
5.    Draw up the CE declaration of conformity.
6.    Affix the CE marking on the machinery.

According to The Supply of Machinery Regulation (Section 7.2), this same procedure is applied for UKCA marking.


The UKCA remains a self-certification for products covered by the Supply of Machinery (Safety) Regulation 2008 where the application of Designated Standards ensures compliance with safety standards. As anticipated, after the initial intention to abolish the validity of the CE mark on its territory, the UK has granted several extensions of the transition period between the two marks. With the aim of facilitating the transition of goods to its borders, the obligation of the UKCA marking was finally abolished altogether, the CE marking will continue to be valid for exporting machinery to the UK territory even after 31 December 2024 (the date that was supposed to be the deadline for the use of the CE marking). The UKCA marking effectively becomes unnecessary for EU manufacturers, who will be able to follow the normal marking procedures for exporting their products to the UK.

In order not to hinder the movement of goods, Northern Ireland is subject to a special legislation.
1.    Goods on the Northern Ireland market: they need to bear the CE marking, to which the UKNI marking can be accompanied if the certification is made by third-party bodies UK-located (case of non-self-certification); if the third-party body of certification is in European territory only the CE marking is placed. NB: the CE marking must always be present.
2.    Northern Ireland goods sold in the United Kingdom (unfettered access): if the products are qualified for the unfettered access, they require the CE mark, accompanied by the UKNI mark if the declaration of conformity is certified by a third-party body located in the United Kingdom. Most of the products manufactured in Northern Ireland and products manufactured in the European Union with motivated passage to Northern Ireland are enlisted for the unfettered access (the UK Government aims to limit the qualifying products to goods produced in Northern Ireland only by the end of 2021).


The UK Declaration of Conformity replaces the CE Declaration of Conformity for products bearing the new UKCA mark. The declaration certifies compliance with the specific legislation of the product in question, its structure is similar to the structure used so far for the CE declaration:
1.    Name and business address of the manufacturer.
2.    Serial number of the machine type.
3.    Reference to the relevant legislation and regulations; in this case references to European regulations are replaced with references to UK regulations, and the transition from Harmonised Standards to Designated Standards takes place.
4.    Additional information, if necessary.
5.    Date of declaration and signature of the manufacturer or delegate.