21 November 2022

UKCA - Latest Update

The UK Government intends to introduce legislation to extend the recognition of CE marking for most goods being placed on the GB market until the 31 December 2024 (previously 31 December 2022). This will provide businesses placing goods on the GB market with flexibility to use the UKCA or CE marking until 31 December 2024.

Reducing labelling costs by continuing to allow businesses to affix the UKCA marking and to include importer information for products from EEA countries (and in some cases, Switzerland) on an accompanying document or a label until 31 December 2027 (previously 31 December 2025).

Reducing re-testing costs for UKCA certification by allowing conformity assessment activities for CE marking undertaken by 31 December 2024 (previously 31 December 2022) to be used by manufacturers as the basis for UKCA marking until the expiry of the certificate or until 31 December 2027, whichever is sooner.

This measure applies across all module types for the following regulations:

  • Noise Emission in the Environment by Equipment for Outdoor Use Regulations 2001
  • Supply of Machinery (Safety) Regulations 2008
  • Ecodesign for Energy-Related Products Regulations 2010
  • Toys (Safety) Regulations 2011
  • Explosives Regulations 2014
  • Pyrotechnic Articles (Safety) Regulations 2015
  • Electromagnetic Compatibility Regulations 2016
  • Simple Pressure Vessels (Safety) Regulations 2016
  • Lifts Regulations 2016
  • Pressure Equipment (Safety) Regulations 2016
  • Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres Regulations 2016
  • Non-automatic Weighing Instruments Regulations 2016
  • Measuring Instruments Regulations 2016
  • Recreational Craft Regulations 2017
  • Radio Equipment Regulations 2017
  • Regulation 2016/425 on personal protective equipment as it applies in GB
  • Regulation 2016/426 on gas appliances as it applies in GB

Guidance issued by UK Government in relation to placing construction products on the GB market was issued on 1 September 2020 and updated on 20 June 2022. The guidance can be found at this location: https://www.gov.uk/guidance/construction-products-regulation-in-great-britain . Communications regarding extensions to the deadlines for the ending of recognition of CE marking announced on 20 June 2022 and 14 November 2022 state that different rules apply to products under CPR and so those changes to deadlines do not affect products falling under CPR.  The Government guidance document for CPR states “Our intention is to end recognition of the CE mark in GB by 1 January 2023. Current rules will remain in place until legislation is laid to end recognition of the CE mark.” At this moment in time no such legislation exists, and no announcement has been made as to when it is expected. As such, CE marking currently continues to be accepted for placing construction products on the GB market.

As an additional point of clarification, this Government CPR guidance continues to state that “for products subject to AVCP System 3 testing, the UK mark may be affixed on the basis of testing conducted by an EU recognised notified body for the purpose of CE marking where this testing was done before 31 December 2022.” Therefore, the change in date to 2024 announced for other sectors does not currently apply to construction products.

It should be noted that this information reflects the current situation as of 14 November 2022.
Notes on Full Changes
Significant changes announced by UK Government in relation to UKCA requirements
announced on 20 June 2022, and updated on 14 November 2022 included the following:
1. Completed conformity assessment activities carried out under EU requirements
(including existing testing, certification, and contractual arrangements relating to the
quality control or auditing of existing certificates) undertaken by non-UK conformity
assessment bodies (accredited by their national accreditation body) for CE certification
by 11pm 31st December 2024 can be used by manufacturers to declare existing product
types as compliant with UKCA. Products must still bear UKCA marking and will need to
undergo future conformity assessment with a UK Approved Body at either the expiry
date of the CE certificate or 31 December 2027, whichever is sooner.
This will allow manufacturers to apply the UKCA mark without the need for any UK
Approved Body involvement and continue to place their goods on the market, based on
their existing CE type examination completed by 31st December 2024, for the lifetime of
the CE certificate issued, or until 31 December 2027 (whichever is sooner).
Where manufacturers are using existing CE certification completed by 11pm 31st
December 2024 as the basis to demonstrate compliance with UKCA for their products,
UK Government recommends that they include in the UK Declaration of Conformity the
list of relevant UK designated standards and equivalent EU harmonised standards that
apply to their product, as well as details of the EU CAB (or CAB recognised under
an EU Mutual Recognition Agreement) which carried out the conformity assessment
If conformity assessment procedures have not been completed and a
supporting CE certificate issued by 11pm 31st December 2024, these products are
considered ‘new’ products. This also includes where goods are subject to important
changes, overhauling its original performance, purpose, or type requiring new
certification. Any ‘new’ good must comply with GB regulatory requirements, including the
requirement for conformity assessment by a UK Approved Body from 11pm 31st
December 2024.
2. There is no need to re-test existing imported stock, as these products will be considered
already placed on the market in Great Britain. This will prevent the costly and
unnecessary re-labelling of existing stock for businesses. It will allow CE marked
products that are manufactured and imported into the UK by 31st December 2024 to be
sold, without the need to meet UKCA requirements. This will remove the current need for
retesting and recertification for products that are imported whilst the UK recognised CE
3. Spare parts that repair, replace, or maintain goods already on the GB market can meet
the same requirements that were in place at the time the original product or system was
placed on the GB market. This will allow products and goods requiring spare parts to
continue to be maintained and help to address concerns about the availability of spare
parts and ensure businesses and organisations avoid disruption to their operations.
4. Businesses will be allowed to affix the UKCA marking, and to include importer
information for products from EEA countries (and in some cases Switzerland), on an
accompanying document or label until 31 December 2027. This will allow business to
adjust their product design to accommodate marking changes at a more convenient and
cost-effective time.
5. In relation to construction products, the following change has also been announced. For
products subject to AVCP System 3 testing, the UKCA mark may be affixed based on
testing conducted by an EU recognised notified body for the purpose of CE marking
where this testing was done before 31 December 2022.
For your convenience, the relevant UK Government documents can be accessed using these