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This guidance is about placing manufactured goods on the market in Great Britain (GB). Great Britain is England, Wales and Scotland.
There’s different guidance if you’re:
If you placed goods on the UK market (or in an EU or EEA state) before 1 January 2021, you do not need to do anything for these individual goods.
EEA states include any country in the EU, Norway, Iceland and Liechtenstein.
They can continue to circulate on either market until they reach their end user and do not need to comply with the changes that took effect from 1 January 2021. This guidance explains what you need to do for any goods you’re placing on the GB market after 1 January 2021.
A fully manufactured good is ‘placed on the market’ when a written or verbal agreement (or offer of an agreement) to transfer ownership or possession or other property rights in the product is exchanged.
‘Placing a good on the market’ means each individual good, not a type of good. It does not require the physical transfer of the good.
You can usually provide proof of placing on the market on the basis of any relevant document ordinarily used in business transactions, including:
The relevant economic operator (whether manufacturer, importer or distributor) bears the burden of proof for demonstrating that the good was placed on the market before 1 January 2021.
All goods which previously required the CE marking will not need to use the UKCA marking until 1 January 2023
Businesses are encouraged to be ready for full implementation of the new UK regime as soon as possible. However, to allow businesses time to adjust, CE marked goods in scope of this guidance that meet EU requirements (where these match UK requirements) can continue to be placed on the GB market until 1 January 2023 where EU and UK requirements remain the same. This includes goods which have been assessed by an EU recognised notified body.
The UKCA mark must be used for placing goods on the GB market from 1 January 2023.
You will still need to take action to ensure you comply with new importer responsibilities if you are placing a product on the GB market from the EU market.
What you need to do depends on the type of goods you’re placing on the GB market.
Most of this page covers goods subject to the UKCA marking.
There are different rules for:
Check the sector specific legislation that applies to your goods. You can speak to your solicitor or trade association if you are unsure which regulatory framework applies to your goods.
You must follow different rules if you’re placing the following goods on the GB market:
You must make sure that your goods meet UK rules. You’ll need to do this even if they were previously sold in an EU country.
Check the UK product safety rules to find out what you need to do.
There are also special rules if you’re placing the following goods on the GB market:
You need to use a conformity marking if you’re placing certain goods on the UK market. Before 1 January 2021 you could do this using the CE marking or other appropriate marking (such as the wheel marking or Pi marking). The UKCA marking is the conformity assessment marking for Great Britain for most goods previously subject to CE marking.
Goods that are lawfully CE marked will be accepted in the UK until 1 January 2023 for certain goods. You must be ready to use the UKCA marking from 1 January 2023 at the latest, although you should look to use the UKCA marking as soon as possible.
If you’re a Northern Ireland business, you can place qualifying Northern Ireland goods on the GB market with an EU conformity assessment marking, such as the CE marking.
The table below illustrates the accepted markings on each relevant market.
|Type of good (see list of product areas at the end of this guidance)||Accepted markings or combination of markings|
|Placing goods on the market in Great Britain||Manufactured goods being placed on the GB market until the end of 2022||UKCA or CE|
|Manufactured goods placed on the GB market from 1 January 2023||UKCA|
|Placing qualifying Northern Ireland goods on the market in Great Britain (unfettered access)||Qualifying Northern Ireland goods being placed on the GB market under unfettered access||CE or CE and UKNI|
You only need to use the new UKCA marking before 1 January 2023 if all of the following apply. Your product:
This does not apply to existing stock. For example, if your good was fully manufactured, CE marked and ready to place on the market before 1 January 2021, you do not need to use the UKCA marking even if the certification was carried out by a UK-based body. These goods will only be able to be placed on the GB market and only until 1 January 2023. From 1 January 2023, you will need to use the UKCA marking.
These products are not allowed to be placed on the EEA market. For goods where mandatory assessment has been done by a UK body, the CE marking must be followed by the UKNI marking for goods being placed on the NI market.
Contact your solicitor or trade association for advice on whether your good will be affected.
Where mandatory third-party conformity assessment was required for CE marked goods, it is also required for UKCA marked goods.
This conformity assessment needs to be carried out by a UK-recognised conformity assessment body in order to be marked with the UKCA marking. The type of conformity assessment procedures are the same that were required for the CE marking.
The UK Market Conformity Assessment Bodies (UKMCAB) database lists all bodies which can provide conformity assessment for the UK market.
Where self-declaration of conformity is permitted for CE marking this is also the case for UKCA marking.
You will be able to use the CE marking until 1 January 2023 if any of the following apply:
You can only place CE marked goods that meet EU requirements on the market in Great Britain while UK and EU requirements are the same. This is currently the case and there are no UK plans to diverge at this time.
Nonetheless you are encouraged to be ready as soon as possible, and by 1 January 2023 at the latest. If the EU changes their rules and you CE mark your goods based on new EU rules which are different from the requirements in the UK, you will no longer be able to use the CE marking in the UK. This will be the case even if the change happens before 1 January 2023.
The UKCA marking will not be recognised on the EU or Northern Ireland markets. Products currently requiring a CE marking for sale in the EU will continue to need a CE mark (and meet the other EU rules).
Although you are encouraged to prepare to use the UKCA marking for the GB market as soon as possible, you do not need to change the conformity marking on your product if it is CE marked and if either of the following apply:
You may need to take additional action if your good needs third-party conformity assessment.
Check whether your UK approved body is taking steps that help you continue to export to the EU without needing to find an EU notified body.
If not, you may need to apply for a new certificate from an EU notified body if you also want to sell your product in the EU. Your approved body should provide another body of your choice with information relating to your conformity assessments in order to facilitate this.
Speak to your testing body or solicitor for advice on how conformity processes for your good will be affected.
If you’re a Northern Ireland business, you’ll still be able to place qualifying Northern Ireland goods on the GB market with an EU conformity assessment marking (such as the CE marking) after 31 December 2022 if any of the following apply:
You’ll still be able to do this even if there are changes between the EU rules that the Northern Ireland Protocol applies to and GB rules. This is part of the government’s commitment for Northern Ireland businesses to have unfettered access to the rest of the UK market.
Both the CE and UKCA mark can be placed on a product so long as neither impedes the visibility of the other and requirements of both the GB and EU legislation are met.
The essential requirements and standards that can be used to demonstrate conformity with them for UKCA marked goods have not changed. That means that if your good is currently made to the technical requirements necessary for CE marking then it will be made to the same technical requirements that exist for UKCA marking. However, the conformity assessment bodies that test them may need to be different.
Great Britain does not recognise authorised representatives and responsible persons based in the EU.
If you need to (or choose to) use an authorised representative or responsible person, they will need to be based in the UK for products being placed on the GB market.
You are responsible for:
You can delegate some of the duties to an authorised representative – you will need to check the specific regulations that apply to confirm what can and cannot be delegated.
You’ll need to confirm whether you or your supplier will act as an ‘importer’.
You’re an importer if you’re the first one bringing goods from outside the UK and placing them on the market in Great Britain. If someone has already placed a good on the UK market before you sell it in Great Britain you will remain a distributor and will not have any additional responsibilities.
As an importer, you’ll need to make sure that:
You must comply with the above for goods placed on the GB market regardless of whether they are CE or UKCA marked.
If you’re a Northern Ireland business selling goods on the GB market that have been supplied to you (as a distributor) from the EU market, you’ll become an importer under GB rules. You’ll need to make sure:
For more information and a list of guides on specific product safety and metrology regulations for businesses, see Product safety and metrology from 1 January 2021: Great Britain.
The table below lists the current EU legislation for specific goods, and the title of the corresponding UK legislation.
|EU legislation||UK legislation|
|Toy Safety – Directive 2009/48/EC||Toys (Safety) Regulations 2011|
|Recreational craft and personal watercraft – Directive 2013/53/EU||Recreational Craft Regulations 2017|
|Simple Pressure Vessels – Directive 2014/29/EU||Simple Pressure Vessels (Safety) Regulations 2016|
|Electromagnetic Compatibility – Directive 2014/30/EU||Electromagnetic Compatibility Regulations 2016|
|Low Voltage Directive 2014/35||Electrical Equipment (Safety) Regulations 2016|
|Non-automatic Weighing Instruments – Directive 2014/31/EU||Non-automatic Weighing Instruments Regulations 2016|
|Measuring Instruments – Directive 2014/32/EU||Measuring Instruments Regulations 2016|
|Lifts – Directive 2014/33/EU||Lifts Regulations 2016|
|ATEX – Directive 2014/34/EU||Equipment and Protective Systems Intended for use in Potentially Explosive Atmospheres Regulations 2016|
|Radio equipment – Directive 2014/53/EU||Radio Equipment Regulations 2017|
|Pressure equipment – Directive 2014/68/EU||Pressure Equipment (Safety) Regulations 2016|
|Personal protective equipment – Regulation (EU) 2016/425||Regulation 2016/425 on personal protective equipment as brought into UK law and amended|
|Gas appliances – Regulation (EU) 2016/426||Regulation 2016/426 on gas appliances as brought into UK law and amended|
|Machinery Directive 2006/42/EC||Supply of Machinery (Safety) Regulations 2008|
|Outdoor Noise Directive 2000/14/EC||Noise Emission in the Environment by Equipment for use Outdoors Regulations 2001|
|Ecodesign Directive 2009/125/EC||The Ecodesign for Energy-Related Products Regulations 2010|
|Energy Labelling Regulation (EU) 2017/1369||Energy Labelling Regulation (EU) 2017/1369 (as retained in UK law and amended)|
|Restriction of the Use of certain Hazardous Substances in Electrical and Electronic Equipment (RoHS) – Directive 2002/95/EC||The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012|
|Directive 2013/29/EU – Pyrotechnic Articles||The Pyrotechnic Articles (Safety) Regulations 2015|