Operate after Brexit

Conformity assessment process and labelling

Conformity assessment process and product labelling

Goods will be subject to separate regulation in the UK and the EU. This means that businesses need to produce goods to two different requirements with separate markings for each product.

  • UKCA for the UK market (however please see below)
  • CE for the EU market

How will this affect businesses?

The UKCA (UK Conformity Assessed) marking is a new UK product conformity marking that will be used for most of those industrial goods being placed on the GB market (England, Scotland or Wales) which have, up until 31st December 2020, required the CE marking. Goods being placed on the Northern Irish market will require the CE mark. Where mandatory third party testing or certification is undertaken by a UK-based body, the goods may also require the UKNI marking for goods placed on the Northern Irish market.

Businesses placing goods on the EU market should continue to use the CE marking.

Manufacturers have been given a grace period to continue following the current rules for placing goods on the GB market, if they choose to.

However, all businesses are strongly encouraged to be ready for full implementation of the new UK regime as soon as realistically possible.  

For placing goods on the EU market you need to check if any changes are required. If you were previously exporting to the EU before 1 January 2021, you will not need to change your conformity assessment for exports to the EU if:

  • Any mandatory third-party conformity assessment was carried out by an EU-recognised notified body (whether based in the EU or in a country with which the EU has a mutual recognition agreement for certain products only)
  • The certificate of conformity previously held by a UK body has been transferred to an EU-recognised notified body

UK conformity assessment bodies cannot carry out mandatory conformity assessment for products being placed on the EU market and the UKCA mark will be not recognised on the EU market. Therefore, exporters to the EU need to ensure that any mandatory conformity assessment is carried out by an EU-recognised conformity assessment body.

It is important that you check whether your UK notified body has arrangements in place to help you get certification for the EU market. 

If needed:

  • Get your products assessed by an EU notified body
  • Arrange for information held by your existing notified body to be transferred to an EU notified body so they can issue you a new certificate

For further information on certificates and documentation, your legal responsibilities and how to appoint an authorised representative, please visit GOV.UK.

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