Please note that the information provided in this article does NOT constitute legal or other professional advice.
As the United Kingdom (UK) government introduced the UK Conformity Assessed (UKCA) marking after it left the European Union (EU), merchants selling to Great Britain are required to comply with the UKCA marking regulation for applicable Great Britain-bound products.
Note that the UK Government has extended the deadline for applying UKCA markings to December 31, 2024. As a result, merchants can continue to use the CE marking for products placed on the Great Britain market (i.e., England, Wales, and Scotland) until December 31, 2024, 11:00 PM, UTC, when the UKCA marking shifts from voluntary to mandatory. Please visit the UK government's official website to stay current.
To help merchants better understand the UKCA marking regulation, this article walks merchants through some commonly asked questions about the UKCA marking.
1. What is the UKCA marking?
The UKCA marking is a product marking used on consumer products that are placed on the market in Great Britain (i.e., England, Wales, and Scotland). The marking indicates that the product conforms to all legislation applicable to the product in Great Britain.
Most products that are currently covered under EU regulations and directives for CE marking fall under the scope of UKCA marking. However, some products covered by the UKCA marking will still be subject to additional special rules. See a list of UKCA marking-required product categories and the corresponding product rules.
The UKCA marking came into effect on January 1, 2021, so it can be used from now onwards (alongside the existing EU CE marking regulation). Starting December 31, 2024, 11:00 PM UTC, the UKCA marking must be used for regulated products placed (e.g., offered for sale, imported, and/or sold) on the Great Britain market for/to customers in Great Britain. After that time the CE mark will no longer be recognized in Great Britain. This requirement includes consumer products that are made available online and “targeted” at Great Britain consumers. "Targeting" will generally be considered to take place when customers are able to purchase the product in their local currency (GBP), and can have the product delivered to their local address.
The table below shows the accepted markings for placing goods on the market in Great Britain:
Accepted markings or combination of markings for sales into Great Britain
Until December 31, 2024, 11:00 PM UTC
UKCA and/or CE markings
After December 31, 2024, 11:00 PM UTC
UKCA marking only
See here for further information on what constitutes “placed on the GB market”.
Note that the UKCA marking cannot be used for products placed on the Northern Ireland market. Please continue reading to learn more about how Northern Ireland-bound products are treated.
2. How are products placed on the market in Northern Ireland treated?
While Northern Ireland continues to remain part of the UK, products placed on the Northern Ireland market are excluded from the UKCA marking regulation. In Northern Ireland, EU conformity markings can continue to be used to indicate that the product complies with EU rules. Therefore, the CE marking can continue to be used for most manufactured consumer goods sold/shipped to Northern Ireland customers, with some exceptions for specific products.
However, if merchants are using a UK Assessment Body to carry out mandatory third-party conformity assessment for Northern Ireland-bound products, then they need to apply a UKNI marking. The UKNI marking is a conformity marking for consumer products placed on the market in Northern Ireland indicating that products have undergone mandatory third-party conformity assessment by an Assessment Body based in the UK.
Note that the UKNI marking cannot be used on its own. It always accompanies an EU conformity marking (the CE marking). Also, products with both the CE and UKNI marking cannot be placed on the market in the EU. If products need to have access to both the UK and EU, they should carry both the CE and UKCA markings, but not the UKNI marking. Please see the UK government’s guidance on placing manufactured goods on the market in Northern Ireland for more information.
3. What happens with existing CE-marked products after the UKCA marking goes into effect?
For existing imported stock of products that are manufactured, CE-marked, and imported under contract into the UK before December 31, 2024, 11:00 PM, UTC, merchants do not need to re-test and re-mark them under the new UKCA regulations.
Additionally, existing CE marking certificates for products that have already been conformity assessed through December 31, 2024, will also be able to be used as the basis of UKCA marking until their expiry, or until December 31, 2027, whichever is sooner.
4. How can I prepare for the UKCA marking regulation?
For merchants who sell products to customers in Great Britain, please make sure all Great Britain-bound products comply with the UKCA marking regulation before December 31, 2024, 11:00 PM, UTC. Otherwise, those product listings could be removed without prior notice.
To prepare for the UKCA marking regulation, merchants are encouraged to do the following:
- Check whether their products require the UKCA marking. (Once again, the UKCA marking applies to most goods previously subject to the CE marking.)
- Check with the manufacturer (for products that require the UKCA marking) on the following:
- Products are properly assessed for conformity with applicable legal requirements.
- Technical file/documentation is correctly provided and managed. (For example, please ensure that the UK Declaration of Conformity is drawn up for the product. See “What is the UK Declaration of Conformity?” below for details.)
- Products are clearly affixed with the UKCA marking. (See “How to affix the UKCA marking?” below for details.)
- Upload images of all applicable conformity markings (CE, UKCA, and/or UKNI marking) for relevant products on Wish product listing pages. (See “How to upload applicable conformity markings for requisite products?” below for details.)
See the UK government’s site for details on conformity assessment and maintaining proper documentation.
NOTE: At the time of publication, December 22, 2022, technical standards applied in relation to CE-marked goods are exactly the same as those required for the UKCA marking. This means that the conformity assessment processes applicable to CE-marked goods are the same for UKCA-marked goods, apart from the marking applied, and the accompanying Declaration of Conformity. (Once again, existing CE-marked products may not need to be remarked or recertified to UKCA requirements and existing CE marking certificates may also be able to use after December 31, 2024. Please see “What happens with existing CE-marked products after the UKCA marking goes into effect?” above for details.)
5. What is the UK Declaration of Conformity?
The UK Declaration of Conformity is a document that must be drawn up for all products lawfully bearing a UKCA marking. As with technical documentation, the UK Declaration of Conformity should be available to market surveillance authorities upon request.
The information required on the UK Declaration of Conformity is largely the same as what was required on an EU Declaration of Conformity. In the document, the manufacturer, or the authorized representative (where allowed for in the relevant legislation) should provide the following:
- The name and full business address of the manufacturer or of the authorized representative (if applicable).
- The product’s serial number, model, or type identification.
- A statement, stating the manufacturer takes full responsibility for the product’s compliance.
- The details of the approved body that carried out the conformity assessment procedure (if applicable).
- The relevant UK legislation and technical standards with which the product complies.
- The name and signature of the person authorized to sign on behalf of the manufacturer or their authorized representative.
- The date the declaration was issued.
- Supplementary information (if applicable).
6. How do I affix the UKCA marking?
The rules on affixing the UKCA marking are currently the same as for affixing the CE marking. In most cases, the UKCA marking should be affixed to the product itself or to the packaging. It may sometimes be placed on the manuals or on other accompanying documentation, which may be impacted by the specific regulations that apply to the product.
The UK government introduced legislation stating that until December 31, 2027, the UKCA marking can be placed on a label affixed or “stuck-on” to the product, or on a document accompanying the product. The UKCA marking and importer information of products from EEA countries and Switzerland can also be affixed on accompanying documents or labels until December 31, 2027. After December 31, 2027, a permanent UKCA marking will be mandatory. (Please visit the UK government's official website to stay current.)
Here are general rules for using the UKCA marking:
- The UKCA marking must be clearly visible and legible. Markings, signs, or inscriptions that may confuse the meaning or form of the UKCA marking to third parties or markings that affect the visibility, legibility, or meaning of the UKCA marking must not be placed on products.
- The UKCA marking must only be placed on a product by manufacturers or authorized representatives (where permitted in the relevant legislation), or if merchants are marketing the products, under their own brand, name, or trademark.
- The person affixing the UKCA marking takes full responsibility for the product’s conformity with the requirements of the relevant legislation.
- The UKCA marking must not be placed on products unless there is a specific requirement to do so in the legislation applicable to those products, e.g. E.g., a hairbrush will generally not be in scope of applicable legislation, and therefore should not carry the UKCA marking.
- A product may have additional markings and marks, as long as they:
- Fulfill a different function from that of the UKCA marking.
- Are not likely to cause confusion with the UKCA marking.
- Do not reduce the legibility and visibility of the UKCA marking.
Both the CE and UKCA marking can be placed on a product as long as neither prevents the other from being clearly seen and the requirements of applicable legislation in both Great Britain and EU are met.
When using the UKCA marking, please make sure that:
- The UKCA marking is at least 5 mm in height – unless a different minimum dimension is specified in the relevant legislation.
- When reducing or enlarging the size of the marking, the letters forming the UKCA marking are in proportion (see example below).
- The UKCA marking is easily visible, legible and indelible.
Note that the UKCA marking can take different forms (for example, the color does not have to be solid), so long as it remains visible, legible, and maintains the required proportions.
Download a marking:
7. How do I upload applicable conformity markings for requisite products?
Before uploading, please first check and make sure all applicable conformity markings (CE, UKCA, and/or UKNI marking) are affixed on the products and/or the packaging and/or any copy of the technical file/documentation. Then, merchants can take photos of the markings and upload the photos for the corresponding products as Extra Image(s) on Wish product listing pages. (Please visit “How do I add images to a product and its variations?” for details.)
Merchants only need to make sure that each product list has photos of applicable conformity markings. For products with variations, we strongly encourage merchants to choose a photo that works for all variations or upload a photo for each variation.
In addition, we recommend that merchants have all applicable conformity markings ready to upload at one time. Note that certain edits (Title, Description, Images, Size, Color, and GTIN) on existing listings will be subject to an updated review process before they are considered active on Wish. Additionally, editing a promoted product's images is strictly prohibited, as required by the Merchant Policy, "Product Promotion."
Starting January 1, 2025, if a product is found to be in violation of the requirement to carry the UKCA marking, including those lacking applicable conformity markings and/or images, the product could be removed from Wish.
8. What if I want to ship “spare parts” to UK customers after January 1, 2025, for goods placed on the market before January 1, 2025?
Spare parts are often used for repair, replacement, and maintenance operations. Therefore, spare parts can comply with the same requirements that were in place at the time the original products or systems they are intended to repair, update, upgrade, replace, or maintain, were placed on the market.
- For products that are repaired, refurbished, or exchanged without changing their original performance, purpose, or type, they are not considered ‘new’ products and therefore do not need to be recertified and remarked.
- If products have been subject to important changes, substantially changing their original performance, purpose, or type, they will be considered as ‘new’ products. Therefore, the modified products must comply with Great Britain's regulatory requirements, including the requirement for UKCA marking from December 31, 2025, 11:00 pm UTC.
See the UK government’s site for details on conformity assessment and maintaining proper documentation and guidance for spare parts.
9. Where can I find UKCA marking information?
Visit the UK government website for the following:
- UKCA marking use
- Conformity assessment and documentation requirements for the UKCA marking
- UK Market Conformity Assessment Bodies
- Product safety regulations for specific product types
- Roles and responsibilities for the UKCA marking
- Compliance with placing manufactured products on the market in Great Britain
- Compliance with placing manufactured products on the market in Northern Ireland