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Brexit and CE Marking/UKCA Marking update

The United Kingdom is currently in a Brexit transition period until 31 December 2020 and a new regulatory regime will apply from 1 January 2021. What will this mean for your products?

Possible certification alternatives from 1 January 2021:

Mutual Recognition (MRA) EU/UK

A Mutual Recognition Agreement (MRA) of some form might be reached by the EU and the UK government whereby certification issued by both UK and EU Notified Bodies (NBs) continue to be recognized in the UK and the EU.


CE marking and UKCA marking

The EU’s CE mark will be required for products to be sold in the EU and the UK will introduce the “UKCA” mark for products to be sold in the UK.

If an MRA cannot be agreed:

  • Current EU legislation for CE marking (including that for construction products) will be adopted as UK legislation
  • All current harmonized standards will be adopted as UK Designated Standards
  • EU Notified Bodies’ CE marking certificates will continue to be recognised by the UK until 1 January 2022
  • A “UKCA” mark will be introduced for products to be sold in the UK domestic market and will exist alongside the CE mark as the UK’s equivalent, until 1 January 2022
  • Current UK NBs will automatically become Recognised Approved Bodies (RABs) and will continue to conduct ‘Third Party Conformity Assessment’ as they do now to enable certification to the UKCA mark
  • The EU has stated that after 31 December 2020 it will not recognize CE mark certificates issued by UK NBs

Further UK government information on the UKCA mark for CPR can be found here.

What does this mean for me?

  1. As the EU has stated that after 31 December 2020 it will no longer recognize CE marking certificates issued by UK NBs, if you wish to continue to sell your CE marked products in the EU after 31 December 2020 you will need a CE certificate issued by an EU-27 NB.
  2. If UKCA marking is introduced, the UK government has stated it will accept both certificates from EU-27 NBs for CE marking and certificates from UK NBs issued before 31 December 2020, (providing they have not expired) as being valid for sales on the UK market, until 1 January 2022.
  3. It is likely that you will be required to UKCA mark products for sale in the UK (instead of CE marking them) from 1 January 2021. The caveat in paragraph two above, is to give time for the new certificates to be issued.