Frequently asked questions UKCA marking

What is the UKCA marking?
The UKCA marking (UKCA = "UK Conformity Assessed") is the British product marking which is required for certain products placed on the market in Great Britain (England, Wales and Scotland).

When will the UKCA marking come into force?
The UKCA marking came into force on 1 January 2021, although the CE marking will still be recognized in the UK until the end of 2024. However, from the beginning of 2025, only UKCA-marked products will be accepted in the Great Britain.

Which products are covered by the UKCA marking?
Most products currently covered by regulations and directives on CE marking will be covered by the UKCA mark.

What is an Approved Body?
An Approved Body is a body approved by the UK government that can provide UKCA services. BSI UK is an Approved Body.

What is a Notified Body?
A Notified Body is a body approved by the EU member state (and accepted by the European Commission and other member states) that can provide CE certification services. BSI the Netherlands is a Notified Body who can help you with both CE marking and UKCA marking.

How can companies prepare for the UKCA marking?
The steps you need to prepare for the UKCA marking depend on the current status of your company and your future market access requirements. If your product requires the services of a Notified Body for third party conformity assessment for CE marking, you will need to check whether they are also able to provide the UKCA marking.

Note: Only companies that are UKCA (UK Approved Body) approved for the UKCA marking can offer this service.

When is the right time?
Start as early as possible to secure UK market access, build resilience, protect your business and reduce the risk of losing market access because of the Brexit. You can start this now.

What does the UKCA marking cost?
This will depend on many factors – for example, the regulations that apply to your products, the number of products you make, and the number of manufacturing locations you operate. BSI is happy to provide no-obligation fee proposals for providing this service, so please contact us.

How long does it take to obtain certification?
Again, this will depend on many factors – for example, the regulations that apply to your products, the number of products you make, and the number of manufacturing locations you operate. It is better to start the process as soon as possible as there are very few Approved Bodies and they are likely to find it hard to meet the increased demand for UKCA services on the short-term and closer to the deadline.

How long is the UKCA marking valid?
The UKCA marking does not have any time limit – it is a declaration made at a point of time. Some certificates that are required for UKCA (as with CE Marking) may have time limits. For example, GAR type examination certificates are valid for a maximum of 10 years. This is the same under UK law.

Do I have to work with a UK Approved Body for UKCA marking services?
Yes, the UK regulations require the use of a UK Approved Body in place of the EU Notified Body that was used in the EU regulations.

Which Approved Body number will be below UKCA mark if the services are provided by BSI?
It will be "0086" for BSI UK.

Where can information about EU Notified Bodies and UK Approved Bodies be found?
Details of EU Notified Bodies may be found in the Europa Nando site, and the UK government intends to publish its own database of Approved Bodies as soon as possible.

UK Government information on UKCA can be found here.

Is there a Notified Body that can approve CE and UKCA marking?
Notified Bodies are appointed by the EU Member States and these only apply to CE Marking. Approved Bodies are appointed by the UK and these only apply to UKCA marking. So no single body can do this. However, some organizations may have operations in the EU and the UK, so they are able to support both regions. BSI is an Approved Body in the UK and also operates an EU Notified Body in the Netherlands.

For existing CE-certificates, is UKCA certification only granted after documentation testing?
In order to issue UKCA certification, BSI is required to make a technical decision, and this cannot be done without properly reviewing the evidence of compliance. BSI will review the evidence of conformity from your current Notified Body as well as CE documentation and if satisfactory to meet UKCA marking requirements will issue the UKCA certification. If not satisfactory, further evidence or testing may be required. For previously issued CE certificates from the BSI UK Notified Body (0086), we will be replacing them with a UKCA certificate where necessary to support your use of the UKCA Marking.

Do drawings have to be submitted with the test reports?
Yes – there needs to be a new UK technical file, so technical drawings are an essential part of this.

Does an electrical device with UKCA Mark have to have a UK plug?
Not necessarily – many products are battery powered and some are designed to be connected to fixed wiring. However, most consumer products would require a UK (BS 1363) plug to be fitted, and that was the case under CE marking too, so nothing has changed.

Does BSI also provide ATEX certification?
No, sorry, we do not provide this service.

Does BSI also offer services for the MID (Measuring Instruments Directive)?
Yes we do – for the UK version of it to support UKCA marking.

Will products that are only covered by the Low Voltage and EMC Directives have to carry the UKCA marking in the future when sold into the UK or will CE continue to be recognized in this case?
Yes, electrical equipment within the scope of regulations such as the LVD or EMC directives will be covered by the UKCA marking requirements, but they do not generally require the use of an Approved Body (as with CE marking). CE marking will continue to be accepted in the UK for these products until the end of 2022.

Which EU directives / regulations will be affected by UKCA?
All current EU CE Marking directives / regulations are being replaced with new UK regulations requiring the UKCA marking.

Please note, the introduction of UKCA for Medical Devices and IVDs is not covered in this document as timelines are different.

Are products or type labels allowed to carry both markings, i.e. CE and UKCA?
Yes, they are. As long as there is no confusion between the two marks.

Is the marking of the actual products compulsory or is it sufficient to put the marking on the documentation?
Marking of the product is compulsory. For a limited time, the UK will allow this to be a temporary means (a tie-on label for example).

Is it legally possible to add another page to the existing EU Declaration of Conformity, which would then confirm UK conformity?
There are no clear rules here, but it would be reasonable to add the UK declaration of conformity in this way, so long as there was no confusion between the EU and the UK declarations.

What is the name of the future British declaration of conformity?
It is called the UK declaration of conformity.

Does the declaration have to be signed by a UK company?
No, we believe the manufacturer can sign the declaration wherever they are based.

Do the test reports necessarily have to be in English or are test reports in other languages also accepted?
BSI generally requires reports to be in English, but we will normally accept translated reports so long as we have an official translation of the key parts. BSI can connect you with a provider of translation services should you require these.

Does the UKCA marking also require a UK importer address to be provided?
Yes, for a product that was manufactured outside of the UK. The regulation places duties on importers to ensure products are in compliance with the regulations and to mark their name and contact details on the product or its packaging/documentation.

Do products that are to be placed on the market in the UK have to be issued with a UKCA declaration of conformity? Does a UKCA label also have to be provided on the type label?
Yes, a UK declaration of conformity is required. The UKCA mark has to be marked on the product, but not necessarily on the type label.

Are any specific actions necessary from 1 January 2021 onwards? For example, a note on the delivery papers?
If you are CE marking your product then no actions are needed on 1 January 2021, as CE marking will continue to be recognized in Great Britain until the end of 2024. However, from the beginning of 2025 only products with UKCA marking will be accepted in Great Britain.

Are BS standards identical to the EN standards?
All EN standards should be identical – so "BS EN" standards are identical to, for example, "DIN EN" standards. "BS" standards are not likely to be identical to EN standards. Most standards used for product compliance in the UK will be EN standards.

Must only BS standards be listed on the UKCA or can EN standards also be listed?
You must list the actual standards you have used. We expect BS EN standards to be commonly used.

Do we as plant manufacturers have to make sure that products used carry the UKCA marking? Or is the entire product "approved"? It will be the case that our suppliers will only bear a UKCA mark on the deadline
Products are only required to carry the UKCA mark if they are being placed onto the UK market. In most cases, this will then apply to a finished product, and not the components within it. As a UK Approved Body, BSI would still need to check that component parts complied with expected safety standards.

Do products that are currently placed on the UK market need to be replaced?
No.

I have products which are due to be sold in the EU and in the UK, but not until January or February 2022 as we are still working on the certification process. Can I affix the CE marking to these and place them on the market in the UK?
It's important to note that the UK "transition period" ends at the end of 2020. The UK has chosen to continue to accept CE marked products until the end of 2022, so long as the EU and UK regulations remain unchanged and the certificate of conformity has been issued by an EU Notified Body. So new and modified products that are legally CE marked can be supplied in the UK until the end of 2022. From the beginning of 2023, products placed on the market in Great Britain must have the UKCA marking affixed.

What about products that receive a modification during the transitional period? Are they still covered by CE certification until the end of 2022, even if the modification is not completed until 2022?
Products that are legally CE marked can be supplied in the UK until the end of 2022. A product could still be modified in that time and the technical file updated.

We are committed to working with you to build a trusted partnership as you grow your business for the long-term. When you need to keep up-to-date and comply with the latest regulatory requirements BSI is ideally placed to support your market access needs. With 83 offices worldwide our global reach combined with our local presence means we are never far away and always on hand to work with you. What's more, our teams of trusted experts have an in-depth knowledge of standards and market access requirements that can enable you to successfully navigate the evolving regulatory landscape so your business remains resilient.

As the UK National Standards Body, a Notified Body for numerous EU Regulations / Directives, as well as our status as an Approved Body for UKCA marking, BSI is the logical choice for your product certification in a post Brexit landscape.

Start your preparation now to make sure your business is ready for UKCA marking. Contact us today:

Phone: +31 (0)20 346 0780
Email: sales.nl@bsigroup.com