Approximately one-half of all manufactured goods are subject to legally binding standards, 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.
In the European Union, the familiar Conformitè Europëenne or CE mark is used in most cases, to show that the goods conform to legal standards. 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 for these 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.
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.
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 using CE or UKCA indefinitely (Exceptions Apply).
UKCA or CE
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.
Who is responsible for certifying compliance?
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 however, 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. It is important however for businesses to note that divergence in regulations may occur over time and it is vital that businesses engage regularly with their relevant industry standards authority to ensure full compliance with all requirements.
The specific requirements for different industries can be found at the following link: Placing manufactured products on the market - GOV.UK (www.gov.uk). For more information about requirements that apply in the EU businesses should use the following link: HSE: Guidance: Industries
What is the UKCA mark?
In 2021, the UK government introduced the UKCA mark. The UKCA mark is the conformity assessment marking for goods placed on the market in Great Britain. Initially when introduced it was intended that the UKCA mark would enable a phasing out of the use of the CE mark.
However, to help provide businesses with flexibility, the UK government has recently announced the extension of the validity of CE marking indefinitely. This means that after 31st December 2024 many businesses placing manufactured goods on the GB market will continue to be able to use either CE or UKCA marking on their products. A list of the products which will be eligible to continue to use CE marking can be found below.
The UKCA Mark
Which products can continue to use CE marking in Great Britain?
The UK government has recently announced that businesses involved in the following sectors will continue to be able to use CE Marking indefinitely:
- recreational craft and personal watercraft
- simple pressure vessels
- electromagnetic compatibility
- non-automatic weighing instruments
- measuring instruments
- measuring container bottles
- equipment for potentially explosive atmospheres (ATEX)
- radio equipment
- pressure equipment
- personal protective equipment (PPE)
- gas appliances
- equipment for use outdoors
- low voltage electrical equipment.
Are there any exceptions?
There are several exemptions for different types of products. Examples of products which are subject to different rules include but are not limited to:
- Medical devices
- Construction Products
- Unmanned aircraft
- Rail products.
For more information on the specific requirements for a product subject to different regulations businesses should consult with the appropriate industry regulator in GB and access the following link: Placing manufactured products on the market - GOV.UK.
If businesses are still unsure about how they are impacted by CE Marking or what regulations apply to them, please use the Chatbot function on the Cross Border Trade Hub where subject to eligibility you may be able to receive specialist consultancy advice from an approved InterTradeIreland service provider.
Can I use both the CE and UKCA mark?
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 which the mark certifies the goods conform to will be the same or very similar in GB and the EU
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: Placing manufactured goods on the market in Northern Ireland.
Following the UK government’s decision to extend indefinitely the validity of CE marking businesses in Northern Ireland who are trading with GB will be able to continue to display the CE mark on eligible products sold in GB .
What is the UKNI mark?
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 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.
The UKNI mark
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.
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.
Businesses in Ireland which market and sell goods in Great Britain
As with any other business selling to Great Britain businesses in Ireland within the approved sectors listed above will now continue to be able to use the CE mark indefinitely on their products in GB. For more information, please visit National Standards Authority of Ireland.
Labelling requirements when selling into GB
The UK government has recently announced its intention to bring forward legislation that will extend an easement of labelling rules regarding UKCA marking until December 2027.
This easement allows businesses to affix a conformity mark to either the product or a document which accompanies the product.
More information around the labelling easement can be found at the following link:
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.
National Standards Authority of Ireland
Do you need further assistance?
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Article prepared for the Cross-Border Trade Hub.
Article reviewed: October 2023