UKCA (UK Conformity Assessed) marking is Great Britain’s post-Brexit equivalent of CE marking, the mark showing a product meets the requirements of the relevant GB regulations. Its third-party assessor is the approved body, which plays the same role for UKCA that a notified body plays for CE. In structure it mirrors the EU system almost exactly, because the GB regulations were carried over from the EU directives at the point of departure.
The twist is what happened next. The UK government has repeatedly extended, and then made effectively indefinite, its acceptance of CE marking for most product areas placed on the GB market, so for the great majority of consumer and industrial goods UKCA is now voluntary rather than mandatory. Notable exceptions exist, with medical devices and construction products on their own separate timelines, and Northern Ireland follows EU rules under the Windsor Framework rather than UKCA. For functional safety equipment sold into Great Britain, the upshot at time of writing is that a valid CE mark is generally still accepted, so UKCA is something to be aware of rather than something most suppliers must act on.
Key Points
- UKCA marking is Great Britain’s post-Brexit conformity mark, with the approved body as the GB counterpart to the EU notified body.
- It mirrors the CE system because the GB regulations were inherited from the EU directives.
- The UK now accepts CE marking indefinitely for most product areas, making UKCA effectively voluntary for the majority of goods.
- Exceptions apply, such as medical devices and construction products, and Northern Ireland stays on EU rules under the Windsor Framework.
- UKCA, like CE, is about legal market access in Great Britain, not IEC 61508 functional safety certification; a component is SIL-certified to IEC 61508 separately by a certification body.
Example
A machinery safety component sold into Great Britain can still be placed on the market with a CE mark under the indefinite recognition policy, with UKCA marking and an approved body assessment available as an alternative route but not currently required for most product categories.
See Also: CE marking, notified body, conformity assessment
Cited Sources
- UK Government — Using the UKCA marking
- UK Government — Placing UKCA or CE marked products on the market in Great Britain
Deep dive: For a much more in-depth treatment, see Who Certifies Functional Safety Equipment, and Who Accepts It.