UKCAThe CE mark for Great Britain

The manufacturer or their authorised representative will be responsible for affixing the UKCA mark to the product. The process is analogous to that of CE conformity assessment, except that it applies to the UK market.

This simplifies some aspects, such as where the technical information must be kept, or which language applies. Other differences relate to the separation of UK Conformity Assessment Bodies from the EU Notified Body system as described below.

If your product is sold in both the EU and the UK, the technical documentation showing that it fulfils these requirements will also be the same.

regardless of their origin, with one exception: companies in Northern Ireland will be in a special position to supply products certified under EU (CE mark) or UK (UKCA mark) regulations to Great Britain.

and Metrology and (EU Exit) Regulations 2019, which run to 659 pages. These regulations amend most of the UK CE marking requirements for products placed on the UK market and require the UKCA mark. Where a directive requires CE marking and the UK regulations have already been established, the changes are limited to

• replacing the CE mark with the UKCA mark,
• restriction of applicability to products for the UK market,
• change of references to Notified Bodies in Approved Bodies,
• change of language references to English.
• In cases where an EU regulation on CE marking is amended and not a directive, more substantial changes were required, similar to the regulations implementing the directives.

UK regulations refer to them as 'named standards' and the lists of harmonised and named standards will initially be the same. It is unlikely that the BSI will withdraw the EN standards, but the list of UK notified standards is likely to vary slightly over time as UK authorities such as the HSE exert their influence over standards they do not like.

• From the end of the transition period, importers of products marketed in the UK must be established in the UK. Their product labelling obligation can be fulfilled by information on the documents accompanying the product for a period of 18 months.
• Authorised representatives already established in the EEA will continue to be recognised in the UK, but those established after 31 December 2020 must be established in the UK.
• Organisations based in the EU that import UK products for marketing in the EU will become an "importer" with increased responsibility for compliance. Currently, these organisations are classed as 'distributors' with responsibility for checking declarations, instructions and labelling. As importers, they must also check that the products have adequate technical documentation, which is a significant additional obligation, and they must put their name and address on the product.

to export to the EU single market. This regulation was enacted with the aim of better protecting the EU single market against non-compliant products and avoiding loopholes in the system of application of the law, particularly in view of the increasing number of products being offered for sale online to end consumers within the EU. It states that for manufacturers based outside the EU, the responsible economic operator established in the EU must be one of the following:

• an importer
• a representative appointed by the manufacturer
• a fulfillment service provider handling the product if neither of the above-mentioned exist