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UKCA marking: how to ensure business continuity after BREXIT?

On 31 December 2020, the United Kingdom left the European Union, opening up a new political context on the free movement of goods and legislation. As of 1 January 2021, the UKCA (UK Conformity Assessed) marking came into force with the aim of replacing the CE marking for products destined for the UK market.This new marking will be required for products subject to UK legislation equivalent to all EU directives/regulations requiring CE marking. To allow companies to adapt to the new requirements, there is a transitional period where CE marking will be accepted until 1 January 2023.
Are you a European company and want to export your products to the UK? You should apply the new UKCA mark as soon as possible to continue your business with confidence.

Did you know ?

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If your product requires the services of a Notified Body for conformity assessment by a third party and if this service was performed by a UK Notified Body, your CE marking will no longer be valid.

To maintain the CE marking, you will have to work with a Notified Body registered in an EU Member State such as Apave.



What are the differences between UKCA marking and CE marking?


Currently, there are very few technical differences between these two types of marking.
The UKCA marking applies to articles that require CE marking.

  • It can only be affixed if products have been assessed by bodies approved by the UK authorities (UKAS).
  • Will not be recognised on the EU market
  • Manufacturers with self-certification CE can also do so for UKCA marking
  • Dual marking (CE and UKCA) is possible for products intended for 2 markets: EU and GB
  • UKCA marking cannot be used for the Northern Ireland market, which requires CE marking or UK-NI marking


What is the UKCA marking ?

logo UKCA

The UKCA marking is a new conformity marking requirement for products placed on the market in Great Britain (England, Wales and Scotland). It declares that the product complies with UK legislative requirements and that the appropriate conformity assessment procedures have been carried out* (source France UL.com). From 1 January 2023, to sell a product on the UK market, the UKCA marking will be mandatory and the only one recognised.


What is CE marking?

Logo CE

CE marking is an administrative marking by which the manufacturer or importer certifies compliance with European health, safety and environmental protection standards for products sold in the European Union. It is mandatory for products manufactured anywhere in the world that will be marketed in the EU.

Discover our CE marking offers


What are the challenges of UKCA marking?


  • Keeping your business in the UK market.
  • Being compliant with regulations.
  • Staying competitive by outperforming your competitors.

Companies exporting to the UK will have to apply the UKCA marking for products:

  • Intended for the UK market after 1 January 2023.
  • Regulated by legislation requiring the UKCA mark.
  • On which a third-party conformity assessment must be carried out in the UK.


Which products are affected by the UKCA marking?


  • Construction Products
  • Personal Protective Equipment
  • Gas appliances
  • Pressure equipment
  • Lifts
  • Nautical sector
  • Lifting equipment

Products subject to special rules

  • Medical equipment
  • Railway Interoperability
  • Construction products
  • Civil Explosives


How to obtain the UKCA marking ?


Companies must prepare for the end of recognition of the CE marking in the UK and affix the UK marking by contacting an 'approved body recognised in the UK'. Apave and its partners support you in the UKCA marking procedures.

Apave's support for UKCA marking

customer signing a contract
customer signing a contract

Apave and its partners support you in UKCA marking procedures. By turning to Apave, you benefit from:

A single point of contact to manage all your UKCA and/or CE requests.

Simplified administrative management with centralisation of contracts and full support from Apave teams.

Significant time savings: a single intervention to carry out the two necessary assessments.


Why choose Apave for UKCA marking?


  • A transversal competence
  • A proven test and trial structure
  • A single point of contact 





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