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The CE marking can still be used provided the conformity assessment has been carried out by the UK notified body and the CE marking has been affixed to the fully manufactured goods before 1 January 2021. For importers, the transitional period for the UKCA marking (most recently 31 December 2024) has been extended indefinitely.

For the physical affixing of the new UKCA marking, the same rules apply as for the affixing of the CE marking, with the exception that, for the time being, the UKCA marking can be affixed on a label attached to the machinery or in a folder accompanying the machinery instead of being affixed to the machinery itself (even if it is otherwise possible to affix it to the machinery itself).

The UKCA marking indicates that a product placed on the UK market fulfils the conformity requirements of the market. The conformity assessment procedure and the underlying technical requirements (EN standards) that must be followed to demonstrate conformity are essentially the same as for CE labelling.

The new UKCA marking has been in use in the UK since 1 January 2021. The CE marking will continue to be recognised for many products in the UK during the transition phase. After the transition phase, only products with the UKCA marking will be authorised for certain product groups. In addition, both the CE and UKCA markings can be affixed to a product provided it fulfils all EU and UK requirements.

so that they can continue to function properly after the UK's withdrawal from the EU. Therefore, the "Product Safety and Metrology etc. ( Amendment etc.) (EU Exit) Regulations 2019" will address any shortcomings caused by the UK's withdrawal from the EU (e.g. references to EU institutions) and also provide specific provisions for the UK market.

The Supply of Machinery (Safety) Regulations 1995 were replaced by the 2008 Regulations, which were revised by the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 and now only apply to the UK market. As a result, there is only one set of UK Regulations from 2008, but some provisions apply in a different way in Northern Ireland for as long as the Northern Ireland Protocol is in force.

References to the CE mark in the current UK regulations have been replaced by references to the UKCA mark. The position of notified bodies is replaced by the role of UK approved bodies and references to European harmonised standards are replaced by references to UK notified standards.

Manufacturers need to be mindful that when complying with UK regulations, they need to think about the relevant UK/national regulations that apply to their products. Although these regulations have always existed, until recently it was common practice to refer to directives. From 1 January 2021, it will be necessary for UKCA to add a reference to the applicable UK legislation, e.g. on the Declarations of Conformity. For example, the Supply of Machinery (Safety) Regulations 2008 (SI2008/1597) is the UK implementation of the Machinery Directive.

After the end of the transition period, all harmonised standards that give rise to a presumption of conformity with EU law will be referred to as notified standards.

Many of the differences between the two systems are of an administrative nature and reflect the fact that UKCA is only applicable in the United Kingdom and the information only needs to be provided in English. Some questions, such as where to keep the technical information and which language to use, are simplified.

The scope of the products covered, the technical requirements (basic requirements, standards) and the conformity assessment procedures are similar in many respects. If your product is sold in both the EU and the UK, the technical documentation required to prove conformity will be the same. A separate declaration of conformity is required for the markets of the United Kingdom and the European Union/Northern Ireland. Although the type of information required is the same for both markets, there are certain designations and other changes that must be included in the documents. This applies in particular to legislation and standards.