Approximately one-half of all manufactured goods are subject to legally binding standards, in order to ensure the health and safety of users and to protect the environment. In the European Union, the familiar "CE" mark is used in most cases.
Contents
IntroductionWho is responsible for CE marking?
What standards apply in Great Britain?
What is the UKCA mark?
What standards apply in Northern Ireland?
Businesses in Ireland
Businesses in Northern Ireland
Summary table of accepted markings for different markets
Further information
Introduction
Approximately one-half of all manufactured goods are subject to legally binding standards, in order to ensure the health and safety of users and to protect the environment. In the European Union, the familiar Conformitè Europëenne or CE mark is used in most cases, to show that the goods conform to the standard. In some cases, other marks such as a wheel or the Pi sign mark are used for this purpose.
Some types of products are subject to legally binding standards in the EU, but CE marking is not required. They include chemicals, pharmaceuticals, cosmetics, and foodstuffs. Other detailed requirements apply in these cases.
Goods conforming to the EU standards, certified in most cases by the CE mark, may be distributed and sold anywhere within the European Union. They may also be sold in Northern Ireland.
The CE Mark
Who is responsible for CE marking?
The CE mark is part of a system designed to ensure product safety, which places obligations on producers, importers, distributors and retailers. Broadly similar rules apply, but they differ in their detail, depending on the type of product involved. In many cases, the manufacturer may self-certify compliance, while in other cases, an independent conformity assessment body is involved.
Producers must manufacture the goods in accordance with the relevant standards and comply with the required procedures to prove that this has been done. Importers, distributors and retailers must ensure that the goods have been manufactured in conformity with the standards, are CE marked and that where required, the declaration of conformity, technical assessment paperwork and the manufacturer’s contact details accompany the goods.
All businesses within the supply chain have ongoing obligations in relation to safety, record-keeping, monitoring, user complaints and product recall. They must cooperate with the national authorities that administer the product safety rules.
What standards apply in Great Britain?
Since 1st January 2021, Great Britain has been outside the EU system of product safety assurance. The UK has carried over almost all EU rules on product safety into UK law and has established an almost identical system of conformity assessment and post-sale monitoring.
Most of the EU rules and standards have been replaced in Great Britain with almost identical UK rules and standards.
In the same way as with the EU rules, there are different UK rules and requirements for the various category of products covered. At present, broadly similar requirements continue to apply in GB. There are some minor variations between the UK and EU rules and there may be greater divergence over time.
What is the UKCA mark?
In Great Britain, the new UKCA mark has begun to replace the CE mark. The UKCA mark is the conformity assessment marking for goods placed on the market in Great Britain.
The UKCA marking can be used now. However, to provide businesses with flexibility, the government will bring forward legislation that would continue to allow recognition of the CE marking and the reversed epsilon marking for most goods that are being placed on the market, or put into service before 11pm on 31 December 2024. You should check the sector specific set of regulations that apply to your product.
There are some cases where UKCA marking is required before December 2024. This includes cases where the EU and the UK rules have diverged. It also includes cases where the product is of a type for which an independent conformity assessment is required, and a UK conformity assessment body is used. For some products, you must comply with more than one set of regulations. Read more about which regulations apply to your products and how to comply with them in the GOV.UK industry guidance.
The UK authorities permit the UKCA mark and the CE mark to be placed on the same product if they do not impede each other. In most cases, the standards to which the mark certifies the goods to conform will be the same or very similar in GB and the EU.
The UKCA Mark
- GOV.UK has guidance on placing manufactured goods on the market in GB and on using the UKCA marking.
What standards apply in Northern Ireland?
Under the Northern Ireland Protocol, the EU rules on product safety and conformity assessment marking continue to apply in Northern Ireland. This facilitates the sale and free movement of goods throughout the European Union. The UKCA mark does not apply to goods placed on the market in Northern Ireland.
- GOV.UK has guidance about placing manufactured goods on the market in Northern Ireland.
Under the Northern Ireland Protocol's guarantee of unfettered access and the UK Internal Market Act, NI businesses may place CE marked goods on the GB market regardless of whether the EU and UK requirements on product standards and safety diverge in the future. Provided they are not EU goods seeking to circumvent the GB system of UKCA marking and product safety, qualifying NI goods may be placed on the GB market without the UKCA marking.
The UKNI or UK (NI) designation is used as an abbreviation for markings and labelling in a relatively small number of cases, where EU law requires the state of origin to be identified.
Where the particular type of product requires a mandatory third-party conformity assessment and a UK body is used to carry out this assessment, the CE marking must be accompanied by the UKNI or UK(NI) mark, when the goods are placed on the market in Northern Ireland. When placed on the EU market, the CE mark must appear without the UKNI indication. Those goods must be manufactured to EU rules and cannot be assessed by a body based in the UK.
- GOV.UK has guidance on UKNI Mark.
- Further information on the UKNI Mark is available from NI Business Info.
Individual goods which have been placed on the market prior to 1 January 2021, whether in the EU EEA (EU plus Norway Iceland and Liechtenstein) or in the UK, can continue to circulate until they reach the end user.
Businesses in Ireland
Businesses in Ireland may market and sell goods complying with the EU rules on product standards and safety (which are part of Irish law), with the CE conformity assessment mark, where required for that type of product, in Ireland, any other EU state and in Northern Ireland. No export or import customs requirements apply.
Businesses in Ireland which import goods from Great Britain for resale or use in Ireland must ensure that they comply with EU rules on product standards and safety and have the CE conformity assessment mark, where required. As the first importer into the European Union, they must ensure that the manufacturer has complied with the EU rules applicable to the type of goods concerned.
The goods must be exported from GB under the GB Customs Code and imported into the European Union in accordance with the EU Customs Code. Product conformity checks may be undertaken when goods arrive. The Customs Code may specify conformity documents required. Revenue may check the goods for conformity on a risk-assessed basis. They may also be checked at any later stage in the supply chain.
- GOV.UK guidance on placing manufactured goods on the eu market.
Businesses in Ireland which market and sell goods in Great Britain must ensure that they comply with the UK standards and rules on safety. Where the goods would require the CE mark in the EU, then in most cases, they will require the UKCA conformity mark when placed on the market in Great Britain. Until 31 December 2024, the CE conformity mark may be used in most cases. This will apply provided that the EU and UK requirements remain the same. There are some types of product which in certain circumstances will require the UKCA conformity mark before that date.
The UK government has extended the deadline by when businesses need to use the UKCA mark. For many products the CE marking and reversed epsilon marking may be used on the GB market until 31 December 2024 (rather than 31 December 2023 as was previously advised by government).
The labelling easement has also been extended until 31 December 2027 (previously 2025). The government intends to introduce legislation enabling the UKCA marking to be placed on a label affixed to the product (rather than affixed to the product itself) or on a document accompanying the product until 31 December 2027.
The legislation to implement these changes was laid before the Houses of Parliament on 14 November 2022 and is expected to come into force on 31 December 2022.
The goods must be exported from Ireland in accordance with the EU Customs Code and imported into Great Britain in accordance with the UK Customs Code. Product conformity checks may be undertaken when goods arrive at customs in GB. HMRC may check goods for conformity on a risk assessed basis. They may also be checked at any later stage in the supply chain.
- GOV.UK has guidance on placing manufactured goods on the market in GB
Businesses in Northern Ireland
Businesses in Northern Ireland may market and sell goods complying with the EU derived rules on product standards and safety (which remain part of NI law) with the CE conformity assessment mark where required for that type of goods, in Northern Ireland, Ireland or in any other EU state.
- NI Business Info has more guidance on CE Marking.
Businesses in Northern Ireland may market and sell goods in Northern Ireland which require a conformity assessment mark, with a CE mark alone or accompanied by the UKNI mark. The UKNI mark is required where the goods are subject to mandatory third-party independent conformity assessment and a UK body undertakes this assessment. The CE and UKNI marking must appear together. The CE marking alone must be used to place goods on the market in the EU.
The UKNI mark
- NI Business Info has more information on placing manufactured goods on the market in Northern Ireland.
The product rules for many types of goods permit EU manufacturers and manufacturers based in Northern Ireland, to mark their own goods with the CE mark by way of self-declaration. Where a third-party independent conformity assessment is required and has been undertaken by an EU recognised body, the CE mark may be applied. When the mandatory conformity assessment is undertaken by a UK conformity assessment body, the UKNI marking must be used alongside the CE marking.
- GOV.UK has guidance about placing manufactured goods on the market in Northern Ireland.
- NI Business Info has more information about products that need CE marking.
Businesses in Northern Ireland may market and sell goods in Great Britain which comply with Northern Ireland product standards and safety requirements, including the EU derived rules on product standards and safety, with the CE conformity assessment mark, where required. They do not need to apply the UKCA mark. The CE mark alone or accompanied by the UKNI mark is sufficient.
The unfettered access provisions in the Northern Ireland Protocol and the UK Internal Market Act apply. There are some very limited exceptions to the unfettered access provisions for hazardous goods and protected species subject to international conventions.
The goods must be qualifying Northern Ireland goods in order to benefit from the right to unfettered access to Great Britain. For example, goods starting their journey in Ireland would not qualify where they are moved through Northern Ireland for an avoidance purpose.
- GOV.UK has guidance about moving qualifying goods from Northern Ireland to the rest of the UK
- NI Business Info has more information about placing manufactured goods on the market in Great Britain.
Summary table of accepted markings for different markets
Your goods may require different markings for different markets. The table below, copied from GOV.UK guidance, illustrates the accepted markings on each market.
| Type of good (see list of product areas below) | Accepted marking or combination of markings* | |
| Placing goods on the market in Northern Ireland |
Manufactured goods being placed on the market in NI using an EU conformity assessment body | CE |
| Manufactured goods being placed on the market in NI using a UK-based body | CE and UKNI | |
| Placing goods on the market in Great Britain | Manufactured goods being placed on the GB market until the end of 2022 | UKCA or CE |
| Manufactured goods placed on the GB market from 1 Jan 2023 | UKCA | |
| Placing qualifying Northern Ireland goods on the market in Great Britain (unfettered access) | Qualifying Northern Ireland goods being placed on the GB market under unfettered access | CE or CE and UKNI |
| Placing goods on the EU market | Manufactured goods being placed on the EU market | CE |
*You may use combinations of the product markings listed in each box and your goods may be acceptable with more than one marking. For example, a product with both the CE and UKCA markings can be placed on the EU market. However, for the EU market the CE mark must appear without the UKNI indication as goods bearing the ‘CE and UKNI’ marking are not acceptable in the EU market. This means these goods must be manufactured to EU rules and cannot be assessed by a body based in the UK.
Note: Businesses should familiarise themselves with the particular requirements applicable to each of the types of products they sell, in the markets into which they sell.
Further information
- National Standards Authority of Ireland
Brexit impact on certification
- GOV.UK
UK Conformity Assessment guidance
Placing manufactured goods on the market in Northern Ireland
Placing manufactured goods on the market in Great Britain
- Other resources
Health and Safety Authority Q&A for Selling Goods on the EU Single Market
Your Europe guide to CE Marking
NI Business Info guide to products that need CE Marking
Article reviewed May 2023