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What does Brexit mean for CE Marking?

14th March 2019

Following the UK’s withdrawal agreement and departure from the European Union, the UKCA mark replaced the CE mark as the necessary certification for products and machinery sold in the UK. But if you are selling products to the European market, you will still require CE marking.

When should the CE mark be used?

CE marking and certification is required for products being supplied to, or sold in, the European market. These products include, but are not exclusive to, production tools, medical devices and equipment.

As part of the CE marking process, testing and assessments can be used to confirm your product adheres to the relevant European legislation.

When should a UKCA mark be used?

The UKCA mark covers many of the same goods as the CE mark. It applies to products, production tools and equipment sold on the market in the UK.

The UKCA mark is necessary in Great Britain (including England, Wales and Scotland), while goods placed on the market in Northern Ireland require CE marking or UKNI marking.

Find out about the CE marking services we carried out for VPS as they launched an innovative sustainable security product

Post-Brexit transition periods

There is a ‘post-Brexit transition period’ in place for CE marking in the UK, following the introduction of the UKCA mark on 1st January, 2021.

CE marking will continue to be valid in the UK up until 1st January, 2022. After that date, CE marking will cease to be valid in the UK.

Can products display both a CE and UKCA mark?

Products are able to carry both the CE and UKCA logos. This could apply to products being sold in both the UK and the EU.

There is expected to be no future restriction on products carrying both a CE mark and UKCA mark to represent conformance to both EU and UK product safety; so long as requirements for both marks have been properly met.

Correct application of standards

The CE marking process involves correctly applying standards in line with CE Directives and Regulations.

This process has not changed following Brexit. Harmonised standards will continue to be the template for CE marking conformity when supplying products to, or selling products on the European market.

In the UK, the government has published a list of designated standards to be applied when having products UKCA UK conformity assessed. It is these standards which will continue to be the foundation of product safety in the UK, and will be used as the basis for UKCA conformity.

In line with the extended transition period, the British Standards Institution’s (BSI) membership of CENELEC - the European Committee for Electrotechnical Standardization - is currently scheduled to run until the end of 2021. This implies that the UK’s adoption of European Standards will incorporate the same technical content as those used by CENELEC members for CE marking.

Following the end of this extended transition period, it is expected that the BSI’s CENELEC membership will continue. This means the BSI will be obliged to continue adopting and publishing all European Standards, and withdrawing any pre-existing British Standards that may be in conflict.

The key takeaway is that while the prefix of standards may change in the UK, the content of the standards is likely to remain the same.

Notified / approved bodies

A Notified Body can be involved in a number of parts of the CE marking process. Notified Bodies can take a lead role in ensuring quality control in production, testing the design of a product.

When an EU Notified Body has been involved in checking product conformity, their unique four digit Notified Body number must be displayed next to the CE logo affixed to the product.

Following Brexit and the introduction of the UKCA marking, in the UK the government has confirmed a number of UK Approved Bodies. These UK Approved Bodies are essentially a Notified Body for the UKCA marking process. They will retain their unique four-figure Notified Body number, and this must be displayed next to the UKCA mark when required.

In summary, a UK Approved Body will now be used for products that require third party involvement as part of the UKCA marking process.

Authorised representatives

From 16th July, 2021, onwards, products manufactured outside the EU can no longer be supplied to, or sold on the EU market without an authorised representative in the EU. This will follow the introduction of the new 2019/1020/EU regulation.

An authorised representative could be; the brand, manufacturer or importer. Among the regulations which will require an authorised representative are, the Machinery Directive, the Low Voltage Directive (LVD), and the Electromagnetic Compatibility (EMC) Directive.

There are some types of products - including medical devices, civil explosives and lifts – which the new rule does not apply to.

Key takeaways

  • CE marking will continue post Brexit. It will be required for many products, production tools and equipment sold on the market in the EU.
  • CE marking will continue to be accepted for many products, production tools and equipment sold on the market in the UK, until 1st January, 2022. From this date, only UKCA marking will be valid.
  • Product units that are already in the supply chain when new rules come into effect can retain the CE marking.
  • In general, the technical requirements of both CE marking and UKCA marking are the same.

Do you have any questions on CE marking? Speak to the IES team on +44 (0)1179 380 600 or use this contact form


<https://www.ies.co.uk/ce-guide>  Download our free CE Marking Guide <https://www.ies.co.uk/ce-guide>  Practical steps on how to get CE Compliance for your products and equipment  <https://www.ies.co.uk/ce-guide> Find Out More <https://www.ies.co.uk/ce-guide>