What Is UKCA Marking?
UKCA — UK Conformity Assessed — is the United Kingdom's product conformity marking introduced after Brexit to replace the EU's CE mark for products placed on the Great Britain market (England, Wales, and Scotland). UKCA is the manufacturer's self-declaration (or, for higher-risk products, a UK Approved Body's verified confirmation) that the product meets the applicable UK regulations. The technical requirements are nearly identical to the EU directives — UKCA uses UK-adopted designated standards (the BS EN versions of the same harmonized standards) — but the documentation, the responsible person, and the mark itself must be UK-specific. Northern Ireland is treated separately under the Windsor Framework and continues to accept CE marking. UKCA is enforced by UK Trading Standards and the Health and Safety Executive at the border and through post-market surveillance.
UKCA vs CE: Key Differences for GB Market
UKCA was designed to mirror CE, but Brexit created several practical differences that importers must handle. Below is the comparison buyers use to scope GB market access.
| Dimension | UKCA | CE |
|---|---|---|
| Market | Great Britain (England, Wales, Scotland) | EU 27 + EEA (Norway, Iceland, Liechtenstein) |
| Responsible Party | UK Responsible Person (UK-based, mandatory for most products) | EU importer / Manufacturer (in EU) |
| Standards | UK designated standards (BS EN versions) | EU harmonized standards (EN versions) |
| Declaration | UK Declaration of Conformity | EU Declaration of Conformity |
| Conformity Body | UK Approved Body (UKAB) | EU Notified Body (NB) |
| Accepted for GB? | Yes | No — CE alone not accepted for new GB products |
| Accepted for EU? | No | Yes |
| Mark size | ≥ 5 mm | ≥ 5 mm |
| Northern Ireland | Not required (CE/UKNI used) | Accepted |
If you sell to both the EU and GB, you need both marks on the product, with the UK RP details for GB and the EU importer details for the EU. A single test report against the common EN standard can usually support both DoCs.
UKCA Product Categories
UKCA applies to the same product families that previously required CE. The main categories relevant to China-sourced consumer goods are:
| Category | UK Regulation | Key Standard | Self-Declare or Approved Body? |
|---|---|---|---|
| Electronics (LVD) | Electrical Equipment (Safety) Regs 2016 | BS EN 62368-1 / BS EN 60335 | Self-declare |
| EMC | Electromagnetic Compatibility Regs 2016 | BS EN 55032 / BS EN 55014 | Self-declare |
| Wireless / Radio (RED) | Radio Equipment Regs 2017 | BS EN 300 328 / BS EN 301 489 | Self-declare (most) |
| Toys | Toys (Safety) Regs 2011 | BS EN 71 series + BS EN 62115 | Self-declare |
| Machinery | Supply of Machinery (Safety) Regs 2008 | BS EN ISO 12100 | Self-declare (most) |
| PPE | Personal Protective Equipment (Enforcement) Regs 2018 | BS EN 149, BS EN 397, etc. | Approved Body for Cat III |
| Medical devices | Medical Devices Regs 2002 (UK MDR) | BS EN ISO 13485 | Approved Body for Class IIa+ |
| Construction products | Construction Products Regs 2011 | BS EN product standards | Approved Body for some |
RoHS compliance is enforced separately under UK RoHS and is bundled with UKCA for electronics.
UK Responsible Person (UK RP) — What You Need
The UK RP is the single biggest Brexit-era addition. Rules:
- The UK RP must be based in the UK (individual or company) — a Chinese or EU address does not qualify.
- The UK RP's name and address must appear on the product, its packaging, or the accompanying documentation (user manual).
- The UK RP holds the technical documentation and UK DoC and is the contact for UK market-surveillance authorities (Trading Standards, HSE, MHRA).
- If you don't have a UK entity, appoint a third-party UK RP service — typical fees are £200–£500/year per product family.
- Failure to name a UK RP is one of the most common reasons UK Border Force detains shipments.
How to Get UKCA from China (Step by Step)
- Classify the product and confirm the applicable UK regulations and designated standards. For electronics, this is usually LVD + EMC + (RED if wireless) + UK RoHS.
- Appoint a UK Responsible Person before testing begins — the RP's name goes on the DoC and label.
- Test at a UKAS-accredited lab (or a lab whose results are accepted by UKAS). In China, SGS, Intertek, TUV, and BSI's China partners can issue UKCA-acceptable reports. The test must reference the UK-adopted standard (e.g. BS EN 62368-1, not just EN 62368-1).
- Compile the technical file — product photos, schematics, BOM, test reports, risk assessment, English user manual, label artwork.
- Sign the UK DoC — the manufacturer (or UK RP) signs the UK Declaration of Conformity listing every UK regulation and designated standard applied.
- Affix the UKCA mark — at least 5 mm, with the UK RP's name/address. If the product is too small, mark the packaging and put RP info in the manual.
Timeline: 3–8 weeks for self-declared products; 6–16 weeks if a UK Approved Body is involved.
Worked Example: UKCA for an Electronic Toy
A buyer sources an electronic plush toy with sound and LED from a Yangzhou factory for the UK (Great Britain) market. The toy has a 3xAAA battery compartment, a speaker, and a PCB with a Bluetooth module.
UKCA scope: Toys Safety Regs 2011 (BS EN 71-1/-2/-3 + BS EN 62115 electric toy safety) + EMC Regs 2016 + UK RoHS + Radio Equipment Regs 2017 (Bluetooth).
- Lab: SGS Shanghai (UKAS-accepted) — test 3 samples
- Tests: BS EN 71-1 (mechanical), BS EN 71-2 (flammability), BS EN 71-3 (migration), BS EN 62115 (electric toy safety), EMC BS EN 55014, UK RoHS screen
- Lab testing: 4 weeks, $1,800
- UK RP: third-party service — £350/year
- UK DoC drafting: $150
- UKCA mark: silk-screen 6 mm UKCA logo + UK RP name/address on the bottom label
- Total cost: ~$2,400 · Total timeline: 6 weeks
The same test report is reused to issue an EU CE DoC (EN versions of the same standards), so the product can sell in both GB and the EU with one test cycle. The buyer ships 3,000 units via sea freight to Felixstowe.
UKCA Label Requirements & Transitional Period
- UKCA mark must be at least 5 mm tall, in proportion, and clearly legible. It must be permanently affixed to the product; if that's not possible (small product), it goes on the packaging.
- UK RP name and address must appear on the product, packaging, or accompanying document.
- CE mark is no longer accepted alone on the GB market for new products. Products can carry both UKCA and CE if sold in both markets.
- Northern Ireland accepts CE (and UKNI for products needing third-party assessment) — UKCA is not required for NI.
How Yeatru Handles UKCA Compliance
Yeatru manages UKCA for UK-bound products out of Yiwu and Shenzhen, working with UK-based RP partners and UKAS-accepted labs in China. Our service includes:
- UK regulation classification and designated-standard mapping
- UK Responsible Person referral (third-party UK RP service, £200–£500/year)
- Lab testing coordination at UKAS-accepted labs (SGS, Intertek, TUV, BSI China)
- UK DoC drafting and technical file compilation
- UKCA label artwork review and on-product verification during pre-shipment QC
- Bundling with CE and UK RoHS so one test cycle covers GB + EU
For UK-specific sourcing strategy, see our UK sourcing guide. Compare UKCA against CE, FCC, and FDA in our product certifications overview.
Frequently Asked Questions
1. What is UKCA marking?
UKCA (UK Conformity Assessed) marking is the UK's post-Brexit conformity marking that replaced CE marking for products placed on the Great Britain (England, Wales, Scotland) market. It is the manufacturer's declaration that the product meets the applicable UK regulations. Northern Ireland continues to accept CE marking (and UKNI marking) under the Windsor Framework.
2. What is the difference between UKCA and CE?
CE is valid for the EU and EEA; UKCA is valid for Great Britain. CE marking is no longer sufficient for the GB market — products must carry UKCA and have a UK Responsible Person. UKCA uses UK-adopted designated standards (BS EN versions) instead of EU harmonized standards, and a UK DoC instead of an EU DoC. The technical requirements are nearly identical, but the documentation and responsible party must be UK-specific.
3. Do I need a UK Responsible Person?
Yes, for most products placed on the GB market. The UK Responsible Person (UK RP) must be based in the UK and hold the technical documentation and UK DoC. Their name and address must appear on the product or packaging. If you are an importer without a UK entity, you can appoint a third-party UK RP service (typically £200–£500/year per product family).
4. Is CE marking still valid in the UK?
No for Great Britain. CE marking alone is no longer accepted for new products placed on the GB market; UKCA is required. The CE-to-UKCA transition ended — products must now carry UKCA. Northern Ireland still accepts CE (and UKNI) under the Windsor Framework. If you sell to both GB and the EU, you need both marks.
5. Does UKCA apply to Northern Ireland?
No. Under the Windsor Framework, Northern Ireland follows EU rules for goods and accepts CE marking (and UKNI marking for products requiring third-party conformity assessment). UKCA is not required for NI. If your product is sold in both GB and NI, use UKCA for GB and CE for NI; products can carry both marks.
6. How much does UKCA certification cost from China?
For self-declared products (most electronics, toys, simple machinery), UKCA lab testing costs $300–$2,000 depending on the product, plus UK RP fees of £200–500/year, plus DoC drafting ($50–$200). Total typical cost: $500–$2,500. For products requiring a UK Approved Body (higher-risk PPE, medical devices, lifts), costs rise to $3,000–$15,000. Timeline is 3–8 weeks.
Conclusion
UKCA is the post-Brexit key to the Great Britain market: same technical standards as CE, but with a UK Responsible Person, a UK DoC, and the UKCA mark (≥5 mm). For most China-sourced products it costs $500–$2,500 and takes 3–8 weeks — and the test report can usually be reused for the EU CE DoC, so you cover both markets in one cycle. The two things that get shipments detained at Felixstowe are a missing UK RP address and a product carrying only CE. Appoint the UK RP before testing, verify the lab is UKAS-accepted, and print both marks if you sell in GB and the EU. Ask Yeatru for a UKCA scope assessment and UK RP referral — we'll map your product to the right UK regulations before you place the order.
