Since Brexit, "can I still use CE for the UK?" is a common question, and the answer is neither a plain yes nor no: the UK has its own mark, UKCA, while also making transitional arrangements to keep recognising CE. This article covers UKCA's scope, the four main regulations, responsible-party requirements, and the cybersecurity rules added in recent years.
What UKCA Is, and Where It Applies
UKCA (UK Conformity Assessed) is the product conformity mark created for Great Britain (England, Wales and Scotland) after Brexit, introduced from 2021. There is a geographic distinction: Northern Ireland still follows EU market rules and requires the CE mark (in some cases together with the UKNI mark). So the same product sold into the UK faces different requirements in Great Britain and Northern Ireland.
UKCA and CE: Not a Simple Substitution
The UK government has announced that for most applicable product categories it will continue to recognise the CE mark indefinitely in the Great Britain market, so sellers can choose CE or UKCA. This depends on the product regulation category, though, and policy may change — check the latest guidance from the UK government (OPSS, the Office for Product Safety and Standards) before shipping. Importantly, even when relying on CE, the UK's other requirements — a UK responsible person, address marking, UK plugs and so on — still apply; using CE does not satisfy them automatically.
Four Main UK Regulations for Electrical and Electronic Products
- Electrical Equipment (Safety) Regulations 2016: the UK counterpart of the EU LVD, covering electrical safety
- Electromagnetic Compatibility Regulations 2016: the counterpart of the EU EMC Directive
- Radio Equipment Regulations 2017: the counterpart of the EU RED, for products with Bluetooth, WiFi or other wireless functions
- RoHS Regulations 2012: the counterpart of EU RoHS, restricting hazardous substances in electrical and electronic equipment
The technical content of these regulations closely resembles the corresponding EU directives and uses "Designated Standards," which in practice mostly map one to one onto harmonised standards — for example, BS EN 62368-1 corresponds to EN 62368-1. Existing EN test reports can therefore usually serve as an important basis for the UKCA technical file, but confirm that the standard edition cited is on the UK designated list.
Responsible Party: UK Contact and Address Marking
UKCA (and UK market compliance when relying on CE) places particular emphasis on responsible parties:
- The manufacturer must issue a UK Declaration of Conformity and compile a technical file
- The product or packaging must show a UK contact address: where the manufacturer is outside the UK, the name and address of the UK importer must be shown (without a UK importer, an authorised representative generally needs to be appointed)
- The UKCA mark is generally required to be at least 5 mm high
Many sellers entering the UK for the first time have finished the technical testing but get stopped by platforms or customs for lacking a UK-based responsible party and address.
Two UK-Specific Points
- Plugs: the UK grid is 230V/50Hz, and consumer products with a mains cord are required to carry a three-pin plug conforming to BS 1363 with the specified fuse — not an EU or US plug
- PSTI cybersecurity rules: under the Product Security and Telecommunications Infrastructure (PSTI) regime, since 29 April 2024 consumer connectable products (smart home devices, wearables, connected toys and so on) must meet baseline security requirements: no universal default passwords, a published channel for reporting vulnerabilities, and a stated minimum period of security updates. Unlike traditional safety and EMC testing, this is mainly about product design and documentation
Is a Third-Party Body Required?
As in the EU, most products can be assessed by the manufacturer through internal production control and a declaration, without mandatory third-party certification; only a few high-risk categories require a UK Approved Body. In practice, though, Amazon UK and large retailers often ask for test reports from a third-party laboratory.
A Typical Scenario
A Bluetooth smart plug exported to the UK: electrical safety is assessed under BS EN 62368-1 or the relevant appliance standard; EMC and radio under the UK EMC and Radio Equipment Regulations; the plug must be changed to BS 1363; the product and packaging must show a UK importer address; and because it is connectable, PSTI default-password, vulnerability-disclosure and support-period requirements apply. Having only a CE test report leaves several of these items still to be completed.
Cost and Timeline Reference (for budget planning only, not a quote)
- Products with existing EN test reports: mainly checking standard editions and preparing the UK technical file and declaration, typically about 1-2 weeks
- Products needing fresh testing: EMC about 1-2 weeks, safety about 2-4 weeks, plus radio testing for wireless functions
- PSTI documentation review and product setting checks: typically about 1-2 weeks depending on complexity
Actual pricing depends on product category and how much existing test data can be reused.
Frequently Asked Questions
Q: My product has CE — must I switch to UKCA to sell in the UK? A: For most categories the UK currently continues to recognise CE, but a UK responsible party, address marking, plugs and other requirements still apply, and policy may change — check the latest OPSS guidance.
Q: Does Northern Ireland need UKCA? A: Northern Ireland follows EU rules and generally needs the CE mark; UKCA is not separately recognised there.
Q: If I only sell on Amazon UK, do I need a UK responsible party? A: For products sold to UK consumers, platforms and regulators look for a UK-based responsible party; confirm and prepare it before listing.
If your product is headed for the UK, send us its category, whether it is connected or has wireless functions, and any existing CE test reports — we'll help identify what needs adding and give you a test plan and cost/timeline estimate.