Since the UK left the EU on 2020-12-31, CE Marking machines heading for installation in the UK is in closing days. For the duration of 2021, machine builders can either CE Mark, or they can use the new UKCA Marking (UKNI for products going to Northern Ireland). The UKCA Marking applies in Wales, England and Scotland.
The UKCA marking applies to most goods previously subject to the CE marking. It also applies to aerosol products that previously required the ‘reverse epsilon’ marking.
The technical requirements (‘essential requirements’) you must meet – and the conformity assessment processes and standards that can be used to demonstrate conformity – are largely the same as they were for the CE marking.
The circumstances in which you can use self-declaration of conformity for UKCA marking are the same as for CE marking. Check the list of areas where self-declaration is permitted.
The UKCA marking came into effect on 2021-01-01. However, to allow businesses time to adjust to the new requirements, you will still be able to use the CE marking until 2022-01-01 in most cases.
In some cases, you need to apply the new UKCA marking to goods being sold in Great Britain immediately from 2021-01-01.
The CE marking is only valid in Great Britain for areas where GB and EU rules remain the same. If the EU changes its rules and you CE mark your product on the basis of those new rules you will not be able to use the CE marking to sell in Great Britain, even before 2021-12-31.
You only need to use the new UKCA marking before 2022-01-01 if all of the following apply. Your product:
- is for the market in Great Britain
- is covered by legislation which requires the UKCA marking
- requires mandatory third-party conformity assessment
- conformity assessment has been carried out by a UK conformity assessment body
This does not apply to existing stock, for example, if your good was fully manufactured, CE marked and ready to place on the market before 2021-01-01. In these cases, your good can still be sold in Great Britain with a CE marking even if covered by a certificate of conformity issued by a UK body before 2021-01-01.
The UKCA Mark cannot be used for products for sale in Northern Ireland. This is because the UK signed the Northern Ireland Protocol with the EU so that Northern Ireland can continue to be aligned with the EU in accordance with the Good Friday Agreement, and also with the UK.
The Northern Ireland Protocol came into force on 2021-01-01. For as long as it is in force, Northern Ireland will align with relevant EU rules relating to the placing on the market of manufactured goods.
Placing goods on the market in Northern Ireland
You need to use a conformity marking if you are placing certain goods on the market to show they meet the relevant rules.
In Northern Ireland, EU conformity markings continue to be used to show goods meet EU rules. For most manufactured goods, this is the CE marking, but there are some other markings for specific products.
If you are using a UK body to carry out mandatory third-party conformity assessment you also need to apply a UKNI marking.
You never apply the UKNI marking on its own — it always accompanies an EU conformity marking.
The UK Market Conformity Assessment Bodies (UKMCAB) database lists all bodies which can provide conformity assessment for the UK market.
Machinery is a new approach product, covered by at least the following legislation. Additional Directives/Regulations may apply.
|European Union||Northern Ireland|
|Electromagnetic Compatibility — Directive 2014/30/EU||Electromagnetic Compatibility Regulations 2016|
|Low Voltage Directive 2014/35||Electrical Equipment (Safety) Regulations 2016|
|Safety of Machinery 2006/42/EC||Supply of Machinery (Safety) Regulations 2008|
Using the UKNI Mark
You need to use the UKNI marking if all of the following apply:
- you are placing certain goods (mostly those goods subject to the CE marking) on the Northern Ireland market
- your goods require mandatory third-party conformity assessment
- you are planning to use a UK body to carry out those conformity assessments
You will not be able to use the UKNI marking if either of the following apply:
- you are placing goods on the market in the EU
- you are planning to use an EU body to carry out conformity assessments
If you are a manufacturer based in Northern Ireland (or the manufacturer’s authorised representative) and you currently mark your goods on the basis of a supplier’s declaration of conformity, you do not need to make any changes. Your goods continue to be valid on the UK and EU markets using the relevant conformity markings.
How to use the UKNI marking
Placing the UKNI marking
In most cases, you must apply the UKNI marking to the product itself or to the packaging. In some cases, it may be placed on the manuals or on other supporting documents. This will vary depending on the specific regulations that apply to the product.
The following general rules apply:
- the UKNI marking must only be placed on a product by you as the manufacturer or your authorised representative (where allowed for in the relevant legislation)
- when attaching the UKNI marking to accompany another conformity marking, you take full responsibility for your product’s conformity with the requirements of the relevant legislation
- you must not place any marking or sign that may misconstrue the meaning or form of the UKNI marking to third parties
- you must not attach other markings on the product which affect the visibility, legibility or meaning of the UKNI marking
- the UKNI marking cannot be placed on products unless there is a specific requirement to do so in the legislation
- the UKNI marking must accompany another conformity marking; it never appears on a product alone
Rules for using the UKNI marking
You must make sure that:
- if you reduce or enlarge the size of your marking the letters forming the UKNI marking must be in proportion to the version set out below
- the UKNI marking is at least 5mm in height – unless a different minimum dimension is specified in the relevant legislation
- the UKNI marking is easily visible, legible, and permanently attached