There has been a lot of confusion about the future status of CE marking in the United Kingdom since Brexit. In its place, products were supposed to be marked with the UKCA symbol.
However, the UK has since changed course and decided to accept CE marking for certain product types. This can simplify the product compliance process, as the implication is that a CE marked product could be sold in both the UK and the EU.
In this guide, we explain which products can be CE marked in the UK, and how CE marking differs from UKCA marking.
Content Overview
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What is the purpose of CE marking?
The CE marking communicates that a product complies with all the CE marking directives and regulations that are relevant to the product. This means that the product has complied with the relevant testing, labelling, documentation, and other requirements contained in the applicable regulations.
Note that one or more CE marking regulations may apply to a product. For example, all the following directives could apply to the same electronic product:
- RoHS Directive
- Low Voltage Directive
- EMC Directive
- Radio Equipment Directive
The UK has national regulations that are based on EU directives, even after Brexit.
Is CE marking accepted in the UK?
Post Brexit, the UK introduced its certification mark (i.e. UKCA marking). The UKCA marking indicates that a product which bears the mark complies with UK product safety regulations.
However, the UK government continues to recognise certain CE marking regulations and directives. Recently, the UK government introduced the Product Safety and Metrology etc. (Amendment) Regulations 2024, which provide businesses with the option to go for the CE marking or UKCA marking route in order to have their products sold in the UK market.
Before the new legislation was set, there were expiry dates for the recognition of CE marking for certain products. However, the new legislation revokes the previous expiry dates for several CE marking regulations and does not introduce any new expiry dates.
In practice, this means that the CE Marking for certain products is accepted indefinitely. For example, the Toys (Safety) Regulations 2011 now indefinitely accepts toys sold in the UK with only CE marking.
For which products is CE marking accepted in the UK?
There are still many CE-marked products that are accepted in the UK. Here are some examples:
- Electronics
- Toys
- Personal protective equipment
- Machinery
- Gas appliances
The Product Safety and Metrology etc. (Amendment) Regulations 2024 lists regulations that allow the use of CE marking indefinitely. Here we provide these regulations and their product scope.
| Regulation | Scope | |
| The Noise Emission in the Environment by Equipment for Use Outdoors Regulations 2001 | This regulation applies to outdoor machinery typically used on construction sites or in large parks and gardens | |
| The Supply of Machinery (Safety) Regulations 2008 | This regulation applies to:
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| The Ecodesign for Energy-Related Products Regulations 2010 | This regulation applies to energy-related products. | |
| Toys (Safety) Regulations 2011 | This regulation applies to products for use in play by children under 14 years old. | |
| The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 | This regulation applies to electrical and electronic products. | |
| The Explosives Regulations 2014 | This regulation applies to explosives. | |
| The Pyrotechnic Articles (Safety) Regulations 2015 | This regulation applies to articles containing explosive substances or an explosive mixture of substances. | |
| The Electromagnetic Compatibility Regulations 2016 | This regulation applies to electrical and electronic equipment. | |
| The Simple Pressure Vessels (Safety) Regulations 2016 | This regulation applies to simple pressure vessels. | |
| The Lifts Regulations 2016 | This regulation applies to lifts permanently serving buildings and constructions | |
| The Electrical Equipment (Safety) Regulations 2016 | This regulation applies to electrical equipment designed or adapted for use between:
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| The Pressure Equipment (Safety) Regulations 2016 | This regulation applies to pressure equipment and assemblies with a maximum allowable pressure PS greater than 0.5 bar.
Pressure equipment refers to:
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| The Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres Regulations 2016 | This regulation applies to equipment and protective systems intended for use in potentially explosive atmospheres. | |
| The Non-automatic Weighing Instruments Regulations 2016 | This regulation applies to weighing instruments.
These are instruments used to determine the mass of a body and other mass-related magnitudes, quantities, parameters and characteristics. Additionally, the instruments require an operator to function. |
|
| The Measuring Instruments Regulations 2016 | This regulation applies to measuring instruments. | |
| The Recreational Craft Regulations 2017 | This regulation applies to:
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| The Radio Equipment Regulations 2017 | This regulation applies to radio equipment. | |
| The Personal Protective Equipment (Enforcement) Regulations 2018 and Regulation (EU) 2016/425 | This regulation applies to products to be worn or held by a person.
Such products are designed to protect the user against one or more risks to that person’s health or safety. |
|
| The Gas Appliances (Enforcement) and Miscellaneous Amendments Regulations 2018 and Regulation (EU) 2016/426 | This regulation applies to:
a. Appliances burning gaseous fuels and fittings that regulate, control, or are safety devices b. Sub-assemblies intended to be incorporated into appliances or assembled to become appliances |
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For which products is CE marking not accepted in the UK?
Not all EU regulations requiring CE marking are assimilated into UK legislation. This means that there are some products for which CE marking is, or will be, required in the EU but has yet to be accepted in the UK.
This is especially the case for some of the recent CE marking regulations that were recently introduced in the EU. Here are some examples of products for which CE marking is not accepted in the UK:
a. Batteries covered by the (EU) Battery Regulation
b. Products covered by the (EU) Ecodesign for Sustainable Products Regulation (e.g. textile products)
c. Products covered by the (EU) Artificial Intelligence Act
Additionally, the Product Safety and Metrology etc. (Amendment) Regulations 2024 did not mention all UK regulations that mandate the use of CE marking. This means that there exist products for which the UK recognises CE marking only until a certain date.
Here are some examples of such regulations:
a. The Medical Devices Regulations 2002
b. The Construction Products Regulation
What other products cannot be CE-marked in the UK?
A product should only be CE marked when the product is required to do so by a CE marking regulation or directive. Here are some examples of products that do not require CE marking in the UK (or the EU):
- Most textile products
- Most furniture products and their parts
- Some children’s products that are not considered as toys (e.g. strollers and cribs)
- Chemical substances and mixtures
- Pharmaceutical products
- Cosmetics
- Foodstuffs
- Food contact materials
The same logic would also apply to UKCA marking. If a product is not affected by UKCA marking regulations, it should not bear the conformity mark.
Is there an expiration date for the use of CE marking in the UK?
The UK government’s previous policy required setting an expiry date for the use of CE marking for many products. Under the policy, the expiry date was set for the 31st of December 2024. This meant that UKCA marking would become mandatory from 1 January 2025.
However, the Product Safety and Metrology etc. (Amendment) Regulations 2024 has revoked the previous expiry date for the recognition of CE marking for certain products. This means that for such products, CE marking is accepted indefinitely, until further notice.
EXPLANATORY MEMORANDUM TO THE PRODUCT SAFETY AND METROLOGY ETC. (AMENDMENT) REGULATIONS 2024, Page 4: This SI revokes the expiry provision, thereby removing the legislative end date for EU recognition in GB for the products in scope. This will enable businesses to continue to place goods with a CE or reversed epsilon marking on the GB market.
What is the difference between the CE marking and UKCA marking?
As the UK was once a part of the EU, there are similarities between pursuing the CE or UKCA marking path. However, there are differences between the two regimes and depending on which path you take, you must identify the right requirements to be able to use the conformity mark.
Additionally, the two regimes are likely to diverge further over time.
Requirements
In this table, we compare the requirements between CE marking and UKCA marking regulations.
| Overview | CE marking directives and regulations | UKCA regulations | |
| Compliance mark | CE marking | UKCA marking | |
| Declaration of Conformity | EU Declaration of Conformity
The declaration’s elements tend to be similar if not identical to its UK counterpart. However, the content of the declaration may be different. For example, most require a list of the relevant EU legislation and harmonised standards applied. |
UK Declaration of Conformity
See the comment in the left column. There may be differences in the required content of the declaration. For example, the declaration needs to contain relevant UK legislation and designated standards applied. |
|
| Traceability label information | Similar requirements, but there may be differences | Similar requirements, but there may be differences | |
| Technical file | Similar requirements, but there may be differences | Similar requirements, but there may be differences | |
| Test reports | Tested according to EU harmonised standards | Tested according to UK designated standards (even though in some cases they may refer to the same standard as per the EU) | |
| User instructions | Similar requirements, but there may be differences | Similar requirements, but there may be differences | |
| Language requirements | In languages required by member states the product is sold | Must be in English | |
| Notified body (when required) | Established in the EU and performs the conformity assessment | UK Approved body established in the UK performs the conformity assessment | |
| Authorised representative | Established in the EU | Established in the UK | |
Regulations
Here is a table that features the CE marking regulations and the corresponding UKCA regulations mentioned in the Product Safety and Metrology etc. (Amendment) Regulations 2024, for which CE marking is accepted indefinitely.
| CE marking directives and regulations | UKCA corresponding regulations | |
| Noise Emission in the Environment Directive | The Noise Emission in the Environment by Equipment for use Outdoors Regulations 2001 | |
| Machinery Directive
Note that the Machinery Regulation will replace the Directive. |
The Supply of Machinery (Safety) Regulations 2008 | |
| Ecodesign Directive | The Ecodesign for Energy-Related Products Regulations 2010 | |
| Toy Safety Directive | Toys (Safety) Regulations 2011 | |
| RoHS Directive | The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 | |
| Explosives for Civil Uses Directive | The Explosives Regulations 2014 | |
| Pyrotechnic Articles Directive | The Pyrotechnic Articles (Safety) Regulations 2015 | |
| Electromagnetic Compatibility Directive | The Electromagnetic Compatibility Regulations 2016 | |
| Simple Pressure Vessels Directive | The Simple Pressure Vessels (Safety) Regulations 2016 | |
| Lifts Directive | The Lifts Regulations 2016 | |
| Low Voltage Directive | The Electrical Equipment (Safety) Regulations 2016 | |
| Pressure Equipment Directive | The Pressure Equipment (Safety) Regulations 2016 | |
| Equipment for Explosive Atmospheres Directive | The Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres Regulations 2016 | |
| Non-Automatic Weighing Instruments Directive | The Non-automatic Weighing Instruments Regulations 2016 | |
| Measuring Instruments Directive | The Measuring Instruments Regulations 2016 | |
| Recreational Craft Directive | The Recreational Craft Regulations 2017 | |
| Radio Equipment Directive | The Radio Equipment Regulations 2017 | |
| Personal Protective Equipment Regulation | The Personal Protective Equipment (Enforcement) Regulations 2018 and Regulation (EU) 2016/425 | |
| Gas Appliances Regulation | The Gas Appliances (Enforcement) and Miscellaneous Amendments Regulations 2018 and Regulation (EU) 2016/426 | |
Can I affix both the CE and the UKCA markings on my product?
Both the CE and UKCA markings can be placed on a product so long as the applicable EU and UK regulations are both met.
Generally, when it comes to using compliance marks on a product that contains the UKCA marking, such marks must:
- Not cause confusion with the UKCA marking
- Fulfil a different function than the UKCA marking
- Not reduce the legibility and visibility of the UKCA marking
If my product is CE-marked, does that mean that UKCA marking is not required?
It depends on the regulations that apply. For example, the Toy (Safety) Regulations 2011 permits the CE marking of toys as an alternative to UKCA marking.
However, there may be situations where the UKCA marking is required. For example, the UK’s recognition of CE marking for medical devices has an expiry date. After the expiry date, UKCA marking becomes compulsory.
