CE Marking vs UKCA Marking: what exporters need to know after Brexit
Since the UK’s departure from the European Union, product compliance for exporters has become more complex. One of the most important changes affects how manufacturers demonstrate conformity with safety and performance regulations: CE marking is no longer the only route. Enter UKCA marking — the UK’s product safety system.
If you’re an exporter selling goods in both the EU and the UK, here’s what you need to know about CE vs UKCA marking.
What is CE marking?
CE marking (Conformité Européenne) indicates that a product complies with applicable EU legislation and can be sold freely within the European Economic Area (EEA). It applies to a wide range of products — from electronics to machinery and toys — and shows that a manufacturer has met essential health, safety, and environmental requirements.
What is UKCA marking?
UKCA (UK Conformity Assessed) marking is the UK’s own version of the CE mark. It applies to most goods that previously required CE marking — but only in England, Wales, and Scotland. Northern Ireland still follows EU rules and accepts CE marking under the Northern Ireland Protocol.
UKCA is required for products placed on the Great Britain market (GB) and demonstrates conformity with UK legislation. While based on similar principles as CE, the UKCA process is legally separate.
CE vs UKCA: key differences for exporters
|
Aspect |
CE Marking |
UKCA Marking |
| Applies in | EU + EEA | Great Britain (England, Scotland, Wales) |
| Accepted in Northern Ireland? | ✅ Yes | ❌ No |
| Accepted in EU? | ✅ Yes | ❌ No |
| Requires EU-based representative? | ✅ Yes (for many products) | ❌ No, but UK-based rep may be needed |
| Standards and procedures | EU regulations and harmonised standards | UK regulations and designated standards |
| Notified Bodies | Must be EU Notified Bodies | Must be UK Approved Bodies |
Transition period and deadlines
Since Brexit, there have been several extensions and grace periods. Currently, Great Britain has indefinitely extended its recognition of the CE marking for most regulated product categories, meaning there is currently no fixed end date for acceptance of CE-marked products
For certain product categories, such as construction products, the UKCA marking will become the only accepted mark in Great Britain after specific deadlines (for example, construction products will require UKCA marking after 30 June 2025, unless further transitional arrangements are announced)
Final thoughts: act now to stay compliant
Regulatory divergence between the EU and UK is increasing, and non-compliance can lead to border delays, enforcement actions, or even product recalls.
Whether you’re new to CE/UKCA marking or need help navigating the post-Brexit regulatory maze, 24hour-AR can support you as your EU Authorised Representative or UK Responsible Person. We help businesses around the world meet their obligations efficiently and affordably.
Contact us to make compliance simple and ensure your products stay on the market.
Author Ferry Vermeulen is the Co-Founder of 24hour-AR, a company dedicated to providing authorised representative services as well as CE marking services. With a background in industrial design engineering, Ferry specialises in facilitating swift compliance with EU regulations, enabling manufacturers to enter markets seamlessly.
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