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CE marking vs UKCA in 2026

Last reviewed: August 2026 · Legal status verified against EUR-Lex.

UKCA — "UK Conformity Assessed" — is the conformity mark Great Britain created after leaving the European Union. It was designed as a domestic replacement for CE marking, applying essentially the same technical requirements through legislation retained from EU law. In practice, the replacement never happened. After a series of postponed deadlines, the United Kingdom now recognises CE marking indefinitely in Great Britain for the product categories covered by 21 product regulations, and UKCA survives as an optional alternative for those categories rather than a requirement. A smaller set of sectors — medical devices, construction products, rail, marine equipment, and transportable pressure equipment among them — follows separate UK rules.

This page sets out how the two marks relate in 2026, which sectors sit outside the recognition arrangement, and how Northern Ireland differs from Great Britain. For what CE marking itself signifies, see what is CE marking?

From Brexit to indefinite recognition

The UK left the EU on 31 January 2020 and remained inside the single market until the end of the transition period on 31 December 2020. From 1 January 2021, Great Britain (England, Wales, and Scotland) operated its own product compliance regime based on EU law as retained at exit, with UKCA as its conformity mark and "approved bodies" taking the role of EU Notified Bodies.

CE marking was originally to be accepted in Great Britain only for a short transitional period. That period was extended repeatedly:

DateEvent
1 January 2021UKCA marking becomes available; CE marking continues to be accepted in Great Britain on a transitional basis.
2021–2022The original end-of-2021 deadline for mandatory UKCA is extended, first to the end of 2022, then to the end of 2024.
August 2023The UK Government announces that CE marking will continue to be recognised indefinitely for most product categories overseen by the Department for Business and Trade.
2024The Product Safety and Metrology etc. (Amendment) Regulations 2024 (SI 2024/1266) give legislative effect to continued recognition of CE marking and EU conformity assessment across a broad set of product regulations.
2025The Product Regulation and Metrology Act 2025 and associated regulations place recognition on a durable statutory footing; the UK recognises CE marking indefinitely in Great Britain for 21 product regulations.

The practical result: for the great majority of CE-marked products — machinery, electrical and electronic equipment, toys, PPE, pressure equipment, and the other categories listed below — a product that lawfully carries CE marking can be placed on the market in Great Britain without any UKCA marking, indefinitely.

The 21 product regulations covered by CE recognition

Continued CE recognition in Great Britain applies to products within the scope of 21 GB product regulations, which broadly mirror the EU harmonisation acts. The categories include:

The exact list is defined in the UK legislation and its schedules; where a product sits at the edge of a category, the applicable GB regulation — not this summary — is decisive. The gov.uk guidance "Placing manufactured goods on the market in Great Britain" maintains the current allocation.

Recognition covers conformity assessment, not just the mark. Where CE recognition applies, Great Britain accepts conformity assessment carried out under the EU rules — including certificates issued by EU Notified Bodies. A manufacturer does not need to repeat testing with a UK approved body to sell a CE-marked product in Great Britain in these categories.

UKCA in 2026: a valid, optional alternative

UKCA marking has not been abolished. For the categories covered by CE recognition, a manufacturer may choose to affix UKCA instead of, or alongside, CE marking for the GB market. Reasons some manufacturers keep UKCA include existing certification with UK approved bodies, retail customer requirements, or a wish to hedge against future divergence. But there is no regulatory obligation to use it in those categories, and no announced date on which CE recognition ends.

Where UKCA is used, the GB rules broadly track the familiar CE mechanics: the mark is affixed by the manufacturer, a UK declaration of conformity is drawn up (analogous to the EU Declaration of Conformity), "designated standards" give a presumption of conformity in the way harmonised standards do in the EU, and third-party assessment, where a module requires it, is performed by a UK approved body whose number accompanies the mark.

Sectors following separate UK regimes

Indefinite CE recognition is not universal. Several sectors are regulated by departments other than the Department for Business and Trade or under distinct legal frameworks, and follow their own rules:

Medical devices

Medical devices in Great Britain are regulated under the Medical Devices Regulations 2002 (UK MDR 2002), as amended, overseen by the MHRA — not under the EU Medical Devices Regulation (EU) 2017/745. CE-marked devices are accepted in Great Britain under transitional arrangements with staged end dates (running to 2028–2030 depending on the device's certification basis), while the MHRA implements a reform roadmap for a future GB regime, including new post-market surveillance rules and planned international reliance routes. Manufacturers must register devices with the MHRA, and non-UK manufacturers need a UK Responsible Person. Check current MHRA guidance before relying on any date.

Construction products

Construction products follow a separate GB framework based on the retained Construction Products Regulation, at a time when the EU regime is itself migrating to Construction Products Regulation (EU) 2024/3110. The treatment of CE marking for construction products in Great Britain has its own rules and timelines, and reform is under way following the Grenfell Inquiry; verify the current position on gov.uk before placing construction products on the GB market.

Rail, marine equipment, and transportable pressure equipment

Other exceptions

Certain further categories — for example cableways and some ecodesign and energy labelling requirements — sit outside the 21-regulation arrangement or follow modified rules. Products outside any harmonisation act altogether are governed in GB by general product safety law (the General Product Safety Regulations 2005, which GB retained), while the EU applies the General Product Safety Regulation (EU) 2023/988, applicable since 13 December 2024. The two general-safety regimes have already diverged in substance.

Northern Ireland: EU rules under the Windsor Framework

Northern Ireland applies EU product rules under the Windsor Framework. Products placed on the market in Northern Ireland must comply with the applicable EU harmonisation legislation and carry CE marking where the EU acts require it — UKCA alone is not valid there.

Where mandatory third-party conformity assessment is carried out by a UK body rather than an EU Notified Body, the product carries the UKNI marking alongside the CE marking. Two consequences follow:

Qualifying Northern Ireland goods benefit from unfettered access to the rest of the UK market, so a CE-marked (or CE + UKNI) product lawfully on the market in Northern Ireland can generally also circulate in Great Britain.

Divergence: the risk to watch

CE recognition in Great Britain means GB currently accepts compliance with the EU requirements — but the two statute books are no longer mechanically linked, and they are drifting apart:

The Product Regulation and Metrology Act 2025 gives UK ministers powers to recognise (or decline to recognise) updated EU requirements by regulation, so the scope of recognition can track — or stop tracking — EU changes over time. See 2025–2026 changes for the moving parts on the EU side.

Practical guidance for manufacturers selling in both markets

  1. Classify your product first. Establish which EU acts apply (does my product need CE marking?) and whether the corresponding GB regulation is one of the 21 covered by CE recognition.
  2. If it is covered: complete the CE marking process once. CE marking then serves the EU, the EEA, and Great Britain. UKCA is optional; dual marking is permitted if you want it.
  3. If it is not covered (medical devices, construction products, rail, marine, transportable pressure equipment): plan two compliance tracks with separate documentation, registration, and possibly separate third-party assessment.
  4. Mind the operator roles. An EU-established manufacturer selling into GB will typically have a UK importer whose details appear on the product or accompanying documents; a UK manufacturer selling into the EU needs an EU-established economic operator under Article 4 of Regulation (EU) 2019/1020 for many categories (see importing from non-EU manufacturers and authorised representative).
  5. For Northern Ireland: follow EU rules; use an EU Notified Body if you want a single assessment valid EU-wide, since CE + UKNI is NI-only.
  6. Monitor divergence. Where an EU act is replaced (machinery in 2027 being the clearest case), confirm how GB recognition treats the new EU requirements before relying on a single technical file for both markets.

Sources

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