Please pay attention to exporting such products! The UK will open the UKCA certification mark to replace the CE mark!

Toys, aerosols, personal protective equipment, machinery, low-voltage electrical equipment… are all on the list.
On September 1, 2020, the British government officially announced that the United Kingdom has left the European Union. On January 1, 2021, it will officially start to use the United Kingdom Conformity Assessment (UKCA) certification mark. At the end of this year, the transition period for the use of the product mark after Brexit will end.
Therefore, most products currently under the control of the CE mark must be affixed with the UKCA mark if they are to be exported to the UK market (England, Wales and Scotland) in the future. UKCA will serve as a mandatory entry mark for products in the UK market. All related products must comply with the British national standard beginning with “BS”.
After the UKCA mark is implemented, the export of products that only required CE certification to the EU and the UK will require CE and UKCA certification respectively, which may have a significant impact on the cost of the company’s products and requires great attention.
There are still some questions for many foreign traders of UKCA. Today we will sort out these questions and hope it will be helpful to you.
1. When will the mandatory use of the UKCA mark begin?
After January 1, 2021, products that meet all the following conditions need to immediately use the new UKCA mark.
Products manufactured for the British market;
The law requires the use of the UKCA logo;
Products requiring mandatory third-party conformity assessment;
The product has been assessed by the British Conformity Assessment Agency.
Before January 1, 2021, the conformity assessment documents have not been transferred from the UK institution to the EU recognized institution (if the transfer is successful, it will be regarded as equivalent to the CE certification, and the CE mark can be used to continue to sell in the UK market instead of UKCA. Logo).
Supplement · New UKCA mark exemption
These regulations do not apply to existing inventory, for example, if the product has been fully produced and is ready to be placed on the market before January 1, 2021. In this case, even if it is a certificate of conformity issued by a British institution, products with the CE mark can still be sold in the UK.
From January 1, 2022, the United Kingdom will not recognize the CE mark. However, as long as the product also has the UKCA mark and complies with the relevant British rules, products with the CE mark can still be sold in the UK. There are separate applicable rules for medical equipment.
Important reminder:
In order to allow companies time to adapt to the new requirements, in most cases, the CE mark can still be used until January 1, 2022. The CE mark is only valid in areas where the current UK and EU rules are still consistent. If the European Union changes its rules and the product CE marking meets the new EU rules, the product will not be able to use the CE marking to be sold in the UK, even before December 31, 2021.

2. What products need to use the new UKCA mark?

Mainly used for products sold in the UK. The UKCA mark will apply to most goods currently using the CE mark. The UK encourages companies to prepare to use the UKCA logo as soon as possible before this date.

The following are the specific product areas covered by the UKCA mark:

  • Toy safety 

  • Recreational craft and personal watercraft 

  • Simple pressure vessels 

  • Electromagnetic compatibility 

  • Non-automatic weighing instruments 

  • Measuring instruments 

  • Lifts 


  • Radio equipment 

  • Pressure equipment 

  • Personal protective equipment

  • Gas appliances 

  • Machinery 

  • Outdoor noise 

  • Ecodesign 

  • Aerosols 

  • Low voltage electrical equipment 

  • Restriction of hazardous substances 

Products covered by the UKCA mark but with some special rules:

  • medical devices 

  • rail interoperability 

  • construction products 

  • civil explosives 

3. How to use the UKCA logo? How to place it?

In most cases, the UKCA logo must be used on the product itself or on the packaging. In some cases, it may be placed on manuals or other supporting documents. This will vary according to the specific regulations that apply to the product.

General applicable rules:

a. The UKCA logo can only be placed on the product by the manufacturer or authorized representative (as permitted by relevant laws and regulations);

b. When the UKCA mark is affixed, the manufacturer or authorized representative shall be fully responsible for the product’s compliance with the requirements of relevant laws;

c. Only the UKCA logo can be used to show that the product complies with relevant British laws;

d. The manufacturer or authorized representative must not place any mark or logo on the product that may misunderstand the meaning or form of the UKCA mark;

e. No other marks that affect the visibility, legibility or meaning of the UKCA mark shall be attached to the product;

f. Unless required by law, the UKCA logo cannot be used on products.

UKCA mark specifications:

The letters in the UKCA logo must be scaled in proportion to the official logo.

The height of the UKCA mark is at least 5mm, unless relevant laws provide for a different minimum size.

The UKCA logo must be clearly visible (it must be permanently attached to the product from January 1, 2023).

For general products covered by the UKCA mark, the following transitional measures apply:

Before January 1, 2023, for most goods (except those subject to special rules), you can choose to stick the UKCA mark on the label with the product or accompanying documents.

The operator (whether it is a manufacturer, importer or distributor) should take reasonable measures to ensure that the UKCA mark remains effective.

Products that require the UKCA mark cannot be provided without it (unless the CE mark is used before January 1, 2022)

From January 1, 2023, the UKCA logo must be printed directly on products in most cases, and manufacturers should incorporate this date into the product design process.

The transitional measures for the UKCA mark do not apply to products with special regulations such as construction products, medical equipment, interoperability equipment for railway systems, and transportable pressure equipment.

4. Will the UKCA mark be recognized in the EU?

Not possible. After the transition period, the UKCA mark will not be recognized in the EU market. Products that currently require CE marking will continue to require CE marking to be sold in the EU. In order to continue selling products in the EU, UK-based producers will need an authorized representative to do so.

5. Will the CE certification mark still be used after Brexit?

At present, the British government has not issued an official notice, but the British government promises to companies that there will be a consultation period and then a notice period before CE is completely eliminated.

Industry insiders say the timing of the transition period may depend on the Brexit negotiations in the coming months. It is recommended that any manufacturer that sells to the EU and the United Kingdom at least be prepared to add two quality marks to the product at the same time before the end of the year.

It is worth noting that chemicals, medicines, cosmetics and food do not have the CE mark, and the UKCA mark may not be needed in the future-these types of goods are covered by separate labeling requirements.

6. What is the impact on domestic export enterprises and how to deal with it?

With the official implementation of the British UKCA mark, products exported from China to the EU that require CE certification will require UKCA certification if they are exported to the UK, which will increase certification costs.

According to statistics in recent years, China’s main export products to the UK are mechanical and electrical products, furniture toys, textiles and raw materials. In addition, light metals and products, plastics, rubber and chemical products are also important commodities imported by the UK from China, including mechanical and electrical products and toys. It is the main scope of the UKCA logo.

Therefore, relevant product export enterprises need to focus on, obtain the relevant product certification requirements of the trading party in time, prepare certification materials in advance, and complete product certification as soon as possible to prevent unnecessary losses.

Important supplement · The impact of Brexit on export companies and freight forwarders and their response

There are less than two months before the official Brexit transition period ends. Exporters and freight forwarders will also face issues such as tariff changes, lengthy customs clearance procedures, and freight congestion. The Organization for Economic Cooperation and Development (OECD) research found that Brexit will cause freight transaction costs to increase up to 24% of the value of goods.

The possible effects of Brexit are as follows:

1. The EU custom tariff is no longer applicable

The regional integration of the European Union is in the nature of a customs union. It sets common tariffs externally and realizes trade liberalization internally. This means that member states transfer tariff-setting power to the European Union and cannot independently negotiate trade agreements with other countries outside the Union.

After Brexit, Sino-British trade and trade will operate in accordance with the rules of the World Trade Organization (WTO), and the UK will make certain adjustments to the Sino-British trade policy according to its own national conditions.

2. The customs clearance of goods entering and leaving the EU and the UK becomes complicated

Under the original EU unified customs system, goods entering and leaving the EU do not need to undergo repeated customs clearance and taxation procedures. After Brexit, there will be an independent customs operation system between the UK and the EU. The original EU unified HS system will inevitably have changes, and the customs clearance procedures for goods passing through both parties will be much more complicated than before.

3. The AEO mutual recognition between China Customs and the EU is affected

Even after Brexit, even if the UK postponed the AEO mutual recognition between the EU and China, the two countries still have to sign a separate mutual recognition agreement. This is the most ideal result. If the British Customs and the Chinese Customs have differences in the negotiations, the two parties will have to restart the negotiations, leading to the disappearance of the previous customs dividend.

4. The EORI number will become invalid in the EU

The EORI number is a necessary registration number for all economic activities in EU countries, especially for companies with import and export business, and is used to identify each import and export trade declared by a company, trader or individual. As long as the number is registered in the customs of the country where the company belongs, it will be used throughout the EU.

5. British ports will usher in massive delays

After Brexit, British truck drivers will be subject to the 1968 Vienna Convention on Road Traffic, and their transport capacity will be greatly reduced, leading to an increase in road transport prices.

How should exporters and freight forwarders respond?

1. Keep an eye on the latest news at any time, and adjust freight arrangements in time

2. Apply for EORI in EU countries as soon as possible

Many exporters used to have an EORI starting with GB to solve the entire European customs clearance problem. The EORI number of EU countries is universal and unique, but GB is not working now, and it is necessary to apply for EORI of EU countries as soon as possible.

For example, the German market is relatively large. It is recommended to apply for German EORI, which starts with DE. Of course, each company has its own focus and can choose which country to apply for.


Finally, foreign traders who have British customers are reminded to obtain relevant product certification requirements in time and complete product certification as soon as possible to prevent unnecessary losses.

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