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UKCA Vs CE Marking: What’s the Difference?

20th May 2024

Product marking is crucial for retaining market access, adhering to local legal requirements and offering safety and quality assurances to customers.

UKCA Marking is the required product marking if you’re selling or supplying products, equipment or machinery to markets in Great Britain (GB), including England, Wales and Scotland.

CE Marking is the required product marking if you’re selling or supplying products, equipment or machinery in the European Economic Area (EEA).

While similar, UKCA and CE Marking regulations vary. You cannot use them interchangeably, and using the incorrect product marking can have severe consequences, including product fines, recalls and bans from market access.

In this article, we’ll outline the key differences between the UKCA and CE Marking regulations, which markets and products they apply to and how you adhere to them.

CE vs UKCA

To Which Markets and Products Do UKCA and CE Marking Apply?

UKCA (UK Conformity Assessed) Marking is currently the required product marking for products, equipment and machinery being supplied to GB markets only. It does not apply to Northern Ireland (NI) or EEA markets.

CE (Conformité Européenne) Marking, on the other hand, is the required product marking for products, equipment and machinery being supplied to EEA markets. It also does not apply to NI markets, but is currently still recognised for certain products being placed on GB markets. 

UKCA and CE Marking regulations currently cover the following product areas:

UKCA Marking

CE Marking

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

However, some products are covered by UKCA but have special rules. These include:

  • Medical devices
  • Rail interoperability
  • Construction products
  • Civil explosives
  • Marine equipment
  • Cableways
  • Energy using products
  • Transportable pressure equipment
  • Hazardous substances (RoHS)

See the GOV website here for further UKCA Marking guidance

  • Electromagnetic compatibility
  • Machinery 
  • Low-voltage electrical equipment
  • Active implantable medical devices
  • Appliances burning gaseous fuels
  • Cableway installations designed to carry persons
  • Eco-design of energy-related products
  • Equipment and protective systems intended for use in potentially explosive atmospheres
  • Explosives for civil uses
  • Hot-water boilers
  • Household refrigerators and freezers
  • In vitro diagnostic medical devices
  • Lifts
  • Measuring instruments
  • Medical devices
  • Noise emission in the environment
  • Non-automatic weighing instruments
  • Personal protective equipment
  • Pressure equipment
  • Pyrotechnics
  • Radio and telecommunications terminal equipment
  • Recreational craft
  • Safety of toys
  • Simple pressure vessels

The CE marking is not required for:


  • Chemicals
  • Pharmaceuticals
  • Cosmetics and foodstuffs

See the GOV website here for further CE Marking guidance.

 

Get a UKCA/CE Marking service you can trust. Learn more here.

EMF Testing

Recognition of CE Marking for GB Markets

UKCA Marking came into effect in January 2021 as a result of the United Kingdom leaving the European Union.

Its purpose was to replace CE marking as the required certification for products, equipment and machinery being placed on GB markets.

Initially, being placed on GB markets would require UKCA Marking by December 2024. However, to minimise the disruption to businesses, the Government intends to extend the recognition of CE Marking for specified products and equipment indefinitely.

This will apply to 21 regulations in total, including the 18 regulations owned by the Department of Business and Trade, alongside three additional regulations: ecodesign, civil explosives, and, in most circumstances, restriction of hazardous substances (in electrical equipment).

See the GOV website here for more information.

Which Legislations and Standards Apply to UKCA and CE Marking?

UKCA Marking is designed to align with UK legislation and standards, while CE Marking aligns with EU legislation and standards. 

Because UK standards were created to replace EU ones, they hold many similarities. For example, see our table below for a few specific UKCA regulations side-by-side with their CE counterparts:

UKCA Marking

CE Marking

UK Electromagnetic Compatibility Regulations

Electromagnetic Compatibility (EMC) Directive 

UK Supply of Machinery (Safety) Regulations

Machinery Directive 

UK Electrical Equipment (Safety) Regulations

Low Voltage Directive (LVD) 

 

Both the EU and the UK recognise similar standards and conformity assessment procedures to demonstrate compliance. 

However, the UK has the freedom to maintain alignment with EU standards or diverge from them over time.

We help you test for and comply with EMC, machinery and electrical regulations and directives. Learn more about our service here.

How Do You Comply with UKCA and CE Marking Regulations?

Both UKCA and CE Marking require a conformity assessment to demonstrate that specified requirements have been fulfilled. 

But while the processes for achieving UKCA and CE compliance are nearly identical, there are a few key differences to be aware of.

  • Adherence to regulations: While the assessment process might be the same, the rules and regulations will differ by market and by product. Be sure to check the regulations for your specific product mark and category to avoid fines for non-compliance.
  • Third-party bodies: Both UKCA and CE Marking allow you to either self-declare compliance or undergo a third-party assessment for higher-risk products. For UKCA Marking, you’ll need to consult a UK-approved body to perform this, while CE Marking requires an assessment from an EU-authorised notified body.
  • Documentation: For both UKCA and CE Marking, you’ll need to draft and maintain a technical file that demonstrates your product, equipment or machinery complies with the relevant regulatory compliance requirements. However, your documentation must reflect the appropriate marking and comply with the applicable regulations of the target market.

Discover all the steps involved in achieving UKCA or CE Marking compliance in our free guide here.

Get a UKCA/CE Marking Service You Can Trust

Since 1991, we’ve been helping manufacturers and importers test and evaluate equipment in cleanrooms, labs, and production facilities across the UK.

Our UKCA/CE Marking service covers every step of the compliance process, from assessing and testing high-technology equipment against specific regulations to providing a Declaration of Conformity.

Learn more about our Compliance Testing service here.

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