UKCA vs CE: International Compliance
Everything you need to know about these two product markings
Certification Experts will be your full-service compliance partner and guide you through the complete UKCA or CE marking process. With over 25 years of experience, our team will help you to obtain access to the market.
Let our dedicated team of experts handle the compliance process for your products
You might be familiar with CE marking: the safety mark affixed to your product that confirms that your product is in compliance with all relevant European safety requirements and legislations. This mark was applicable for all products sold within the EU which used to include England, but because of Brexit, it is no longer valid for products that are to be sold on the UK market. This is why UKCA marking was developed. But two markings: what does that mean for you? If you are a producer who wants to sell on either, or maybe both markets, we will explain everything you need to know about UKCA and CE marking.
Why do I need a marking for my product?
By affixing a marking to a product, the manufacturer declares that their product meets all the legal, safety, health and environmental protection requirements for that specific marking, ensuring that it then can be sold on the corresponding market. CE/UKCA marking thus confirms that your product is in compliance with the European/UK harmonised legislation. However, obtaining these markings is a time-consuming process that requires a specific know-how and test facilities that you as a manufacturer might not have. The certification procedure is dependent on the product group, which means that you will need to classify your product first in order to follow the right certification procedure. Click on UKCA and CE marking for more information on all the different aspects and steps of the processes.
Generally, because this can be such a complex process, a third-party such as Certification Experts is chosen by the manufacturer to obtain the CE/UKCA certification for them. Certification Experts can:
- Classify your product
- Determine which legislations and requirements are applicable to your product
- Carry out the CE or UKCA process for you
Additionally, you may need an (UK/EU) Authorised Representative to act as a liaison between you and the competent national authorities, if you are located outside of the UK/EU, and you want to bring your product onto those markets. Certification Experts can become your AR and take care of this aspect too.
What is the difference between CE and UKCA?
The difference between CE and UKCA marking currently comes down to mere terminology and national differences of involved parties (e.g. the role of an Authorised Representative). Because UKCA marking was developed to replace CE marking, it aims to fulfil the same purpose. The main difference between CE and UKCA marking is that the UKCA mark is specific to the legislative requirements of the UK product market (England, Scotland and Wales), and the CE mark to those of the EU. The process of getting your product UKCA marked is also essentially the same as it is for CE marking.
The technical (or, essential) requirements your product must meet to obtain the UKCA marking are dependent on the specific legislations of the product group it falls under. If your product falls within the applicable UKCA regulations (also known as Statutory Instruments), it needs to be marked correctly from the 31st of December 2024 on forward (due to a recent extension)– the European CE mark will no longer be valid on the UK market by then anymore.
It is important to note however, that after this date, the requirements of UKCA and CE marking are likely to start to differentiate. As the UK and EU market develop separately, so will the legislations. Therefore, it is wise to involve a third party such as Certification Experts, who can help you prepare for the UKCA vs CE marking legislations. Our experts will help you obtain CE/UKCA certification and will discuss the possibilities of CE and UKCA dual marking.
UKCA and CE dual marking with Certification Experts
The UKCA marking can already be used now but must replace CE marking for alle products that are to be traded on the UK market before 11pm on 31 December 2024. The CE marking will not be recognised on the UK market form this point forward, and neither will UKCA marking be recognised on the EU market. If you thus want to trade your product on both markets, you will need UKCA CE dual marking. UKCA and CE dual marking refers to a product that carries both marks: it is not possible to obtain the markings as a collective marking or such. However, because the process of the markings is currently essentially the same, it is possible to start both processes right now. This requires sufficient expertise on both the EU and the UK legislation, and must be carried out in applicable testing facilities, both of which manufacturers often lack.
With Certification Experts as your Fullservice Compliance Partner, we can take this UKCA CE dual marking process off your hands and ensure that your products will be marked quickly and efficiently. Our team has years of international experience and guide you from start to finish. Your product will be ready to enter the market with our proven 5-step plan.
1 Identify: the legal framework for your products
2 Determine: the route to compliance
3 Execute: the conformity assessment procedures
4 Affix: UKCA and CE marking and sign the documentation (DoC)
5 Ship: your product worry-free to the UK&EU market
Want us to get your products ready for the EU & UK market?
Want us to get your products ready for the EU & UK market?
Certification Experts offers the following services
Click on the service blocks below to see what our experts can do to help you
CE Marking
The CE mark serves as proof that a product complies with European product regulations. It’s a mandatory requirement for manufacturers whose products fall under applicable CE directives and regulations before they can enter the European market. Additionally, other parties like importers, distributors, and authorized representatives have their roles in ensuring that products bear the CE mark. Obtaining CE marking can be a complex and time-consuming endeavor. It involves understanding regulatory requirements, accessing the necessary testing facilities, and managing time effectively. Our team of CE mark consultants is here to support you throughout this process. We’ll guide you, conduct the required testing, and simplify the path to obtaining CE marking for your products. As your dedicated compliance partner, we aim to streamline this often intricate procedure.
- Conformity Assessement procedure
- Technical File
- Risk Assessment
- Inspection/Safety Assessment
- Testing
- Declaration of Conformity
- Authorised Representation
UK Compliance (UKCA)
UKCA compliance services are essential due to the UK’s departure from the EU. After Brexit, products entering the UK market must adhere to the UKCA marking standards to demonstrate compliance with local safety and performance regulations. These services ensure that businesses can continue selling products in the UK, maintain consumer trust, and navigate the updated regulatory environment effectively. Certifications Experts will help you enter the UK market with your products. We offer complete compliance guidance and expert services in order to ensure your product is compliant with the UKCA marking legislation.
- Consultancy and advice on problem solving
- Stipulate route to compliance
- Determine the applicable standards, directives and regulations
- Guiding the conformity assessment procedure
- Perform product testing
- On-site inspections
- Design review
- Support with technical documentation
- Perform risk assessment
- UKCA Declaration of Compliance
- UK Authorised Representation (UKAR)/ UK Responsible Person (UKRP)
Declaration of Conformity UK (UK DoC): your globally trusted partner
A UKCA Declaration of Conformity is an official document in which the manufacturer declares that their product is in compliance with the essential requirements of the applicable UKCA Statutory Instruments. This document is mandatory as it is necessary to be able to acquire UKCA marking. Certification Experts has both the knowledge and international experience to help you draw up a suitable UKCA Declaration of Conformity for your product, thereby ensuring that your product is safe and will be able to enter the market.
- Determine specific declaration of conformity requirements
- Determine applicable UKCA Statutory Instruments
- Collect all necessary product information
- Draw up the UKCA Declaration of Conformity
Authorised Representation
AR Experts (part of Certification Experts) can act as an authorised representative on behalf of your organisation and ensures that the products being sold on the EU and/or UK market comply with the applicable product compliance legislations. This concerns products that are sold either directly, via e-commerce (online), or through a fulfilment service provider.
We operate in various sectors, such as Machinery, Electronics, Medical Devices, Consumer Product, Toys, Personal Protective Equipment, Boats and more.
- EU Authorised Representative
- UK Authorised Representative
- EC Rep (Medical Devices)
- UK Repsonsible Person (UKRP)
- Responsible Person (RP) GDP
- Person Responsible for Regulatory Compliance (PRRC)
Declaration of Conformity UK (UK DoC): your globally trusted partner
A UKCA Declaration of Conformity is an official document in which the manufacturer declares that their product is in compliance with the essential requirements of the applicable UKCA Statutory Instruments. This document is mandatory as it is necessary to be able to acquire UKCA marking. Certification Experts has both the knowledge and international experience to help you draw up a suitable UKCA Declaration of Conformity for your product, thereby ensuring that your product is safe and will be able to enter the market.- Determine specific declaration of conformity requirements
- Determine applicable UKCA Statutory Instruments
- Collect all necessary product information
- Draw up the UKCA Declaration of Conformity
All the answers you might need!
Yes, you can. If you want to trade your product on both markets, you will even have to get both UKCA and CE marking for it. With Certification Experts as your Fullservice Compliance Partner, we can take this UKCA CE dual marking process off your hands and ensure that your products will be marked quickly and efficiently. Our team has years of international experience and guide you from start to finish.
This depends on your product. For each product group, the process can look different. With our expertise, we are able to speed up the process of getting your product marked.
Due to a recent extension, the CE mark is still valid in the UK until 11pm on 31 December 2024. After this date, all CE marking must have been replaced or must be complemented with UKCA marking for all products intended to be traded on the UK market.
The UKCA mark was developed to replace CE marking for the UK market because CE marking was no longer valid on the UK market as a result of Brexit. It is thus not the same but has the same aim. UKCA marking is specific to the UK legislations on product safety and CE marking is specific to those of the EU.
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