The UKCA Marking – Access the UK Market

The UKCA (United Kingdom Conformity Assessed) marking is a product marking dedicated to products placed on the Britain markets (i.e., in England, Scotland, and Wales). The UKCA marking covers the following products:

  • Aerosols
  • Ecodesign
  • Equipment for outdoor use
  • Equipment for potentially explosive atmospheres (UKEX)
  • Electromagnetic compatibility
  • Gas appliances
  • Lifts
  • Low voltage electrical equipment
  • Machinery
  • Measuring container bottles
  • Measuring instruments
  • Non-automatic weighing instruments
  • Personal Protective Equipment (PPE)
  • Pressure equipment
  • Pyrotechnics
  • Radio equipment
  • Recreational craft and personal watercraft
  • Simple pressure vessels
  • Toys

For each of these products, specific legislations are applied to which the manufacturers must comply. Apart from these products, some other products will get UKCA marking only if they abide by some special rules. These products are:

  • Cableways
  • Construction products
  • Civil explosives
  • Energy using products
  • Hazardous substances
  • Marine equipment
  • Medical devices
  • Rail interoperability, and
  • Transportable pressure equipment

Which Products Use the UKCA Marking?

As mentioned before, the UKCA marking is placed on the products that ought to be sold in the marketplaces of Great Britain. This UKCA marking applies to

  • Most of the products that used CE marking previously, when the UK was a part of the EU, and
  • Aerosol products that required the reverse epsilon marking previously

How can Manufacturers Obtain the UKCA Marking?

In this regard, manufacturers must comply with the Technical Requirements, otherwise known as the “essential requirements,” to obtain the UKCA marking for their products. Another way manufacturers can conform to these requirements is by using the designated standards. The UK introduced these designated standards to replace the EU harmonized standards.

Any manufacturer following these designated standards can claim a presumption of conformity with the corresponding technical requirements applicable to their products.

By fulfilling these requirements, manufacturers can use UKCA marking. However, some relaxation allows businesses and manufacturers to use the CE mark until 11:00 PM, December 2022.

What are the Regions where these UKCA-Marked Products cannot be Sold?

Currently, there are two regions where UKCA-marked products cannot be sold. These are:

  • Northern Ireland, and
  • The European Union

Manufacturers must obtain the CE mark to sell their products in the EU, as UKCA marking is not applicable under the EU’s jurisdiction.

What are the Accepted Markings for Each Relevant Market?

The accepted markings for each relevant marking can be seen in the table below.

Accepted Markings for the UK Markets

Product TypeAccepted Markings (or their combination)
Products being placed on the UK markets until 11:00 PM, December 2022CE or UKCA
Products being placed on the UK markets from 11:00 PM, 31 December 2022, and onwardsUKCA only
Accepted Marking in UK

Accepted Markings for the Northern Ireland Products Being Placed on UK Markets

Product TypeAccepted Markings (or their combination)
Qualified Northern Ireland products are being placed on the UK marketsCE, or CE and UKNI
Accepted Marking in UK

In conditions where a qualified Northern Ireland product is to be placed on the UK markets, whether or not the UKNI marking will be placed along with the CE marking depends upon the nature of the said products. Also, the placement of the relevant conformity assessment body will be considered in this regard.

Using the UKCA Marking

Any product being covered by the UKCA regime must start using the UKCA marking from 11:00 PM, 31 December 2022. However, some exemptions are as under:

  • Those manufacturers who had obtained the CE marking for their products before 11:00 PM, 31 December 2022, will not be required to remark or recertify them against the UKCA requirements. Such products are allowed to circulate on the UK’s market until they make their way to end consumers.
  • Those products that were CE marked went through the conformity assessment and got a certification from a UK-based conformity assessment body before 11:00 PM, 31 December 2020
  • There is no need to retest re-marking an existing imported product manufactured, CE-marked, and imported not the UK according to a contract by 11:00 PM, 31 December 2022

Here, it should be noted that these exemptions do not apply to the following products since different rules bind them:

  • Cableways
  • Construction products
  • Marine equipment
  • Medical devices
  • Rail products
  • Transportable pressure equipment, and
  • Unmanned aircrafts

Those manufacturers willing to place their products on the UK markets must note that the C E marking may not be valid after 11:00 PM, 31 December 2022, and they must use the UKCA marking in its replacement. It is projected that the UK government will introduce legislation that will enable the UKCA marking to be placed on

  • A label placed on a product, or
  • A document accompanying the product

This UKCA label placement shall be valid until after 11:00 PM, 31 December 2025.

Placing The UKCA Marking on the Products

In most cases, manufacturers will have to place the marking on their products or their packaging. The following entities will be responsible for the placement of the UKCA marking.

  • The manufacturer, or
  • Their authorized representative (as authorized by the legislation)

Manufacturers can also lace the marking on their products if they are marketing under their trademark or their name.

Dos and Don’ts of the UKCA Marking

When manufacturers place the UKCA marking on their products, they conform, taking complete responsibility for fulfilling the relevant requirements of the UK’s legislation. Therefore, while placing the UKCA marking on their products, they must keep the following dos and don’ts in their minds:

Dos of the UKCA Marking

  • The marking must be visible and legible
  • It should not be erased away during the washing
  • It can be placed on the manuals and supporting literature accompanying the product, but only if the regulations applying to that product allow it.

Don’ts of the UKCA Marking

  • They will not place any sign, inscription, or marking that will mislead others regarding the meaning or farming of the UKCA marking.
  • They will not place any marking leading to impaired visibility, legibility, and the meaning of the UKCA marking.
  • The marking cannot be placed on the products without correlating to any specific requirement in the legislation.

What are the Requirements Regarding Additional Markings?

Products can have additional markings (e.g., CE marking) if:

  • They can perform some other functions apart from the UKCA marking
  • They will not create any confusion with the UKCA marking, and
  • They do not know the marking’s visibility and legibility

Both CE and UKCA markings can be placed on the product simultaneously if they do not hamper each other’s visibility and fulfill the requirements of the EU and the UK.

Conditions regarding Accompanying Documents with the UKCA-Marked Products

As of now, there aren’t any rules concerning the form of the accompanying document and the duration for which it must be kept. This depends on specific circumstances, such as commercial transactions (i.e., B2B or B2C transactions). Those businesses supplying the product must verify that their supplied products have the UKCA marking on them.

What are the Specific Conditions Regarding Accompanying Documents?

The end consumers must receive the accompanying document with the product. However, there is no need to place the accompanying document with each product if it moves across the supply chain while being part of a whole batch.

Consider an example where a product batch is being moved from Supplier A to Supplier B. Here, Supplier A will not have to place an accompanying document with each product as long as the information accompanying the UKCA marking is applicable to all units of the batch. However, if Supplier B decides to distribute the products among separate distributors, he must place an accompanying document with each product batch. This rule will be applicable until the end consumer receives the product.

Rules Concerning the UKCA Image

The rules regarding the UKCA image are as follows;

  • The minimum dimensions for the marking are at least 5 mm in height unless otherwise specified in a relevant legislation
  • The marking must be clearly visible, legible and should not be erased
  • The marking can be in different forms. For example, it is not mandatory for the marking to have a solid color as long as it can maintain its visibility, legibility, and required proportions.
  • In case manufacturers want to increase or decrease the marking’s size, they must ensure that the letters of the marking are in the proportion as shown below:

Let’s Comply to Access the UK market Smoothly

Manufacturers must ensure that they oblige to these requirements before the 11:00 PM, 31 December 2022 deadline. This will enable them to enjoy a smoother business experience while avoiding any legal technicalities. Contact our experts for more information.

About the Author

Waqas Imam

S. M. Waqas Imam is associated with TS Quality as a Regional Partner. He is also an ambassador of Medical Device Community. He is an Industrial Engineer by qualification and served the manufacturing industry since 2011. He is also IRCA CQI Lead Auditor of ISO 9001 and other management system standards. He had served as Quality Assurance and Regulatory Affairs Manager in QSA Surgical Pvt. Ltd. and Ultimate Medical Products. He managed requirements of ISO 13485:2003, EU directives, CE marking and FDA. He also served as Expert Blog Writer for 13485Academy and wrote expert articles on various topics of ISO 13485:2016.