United Kingdom – Brexit
Trust UL to help you navigate market access through Brexit’s new requirements.
Brexit’s new rules and market access implications
Staying abreast of market entry requirements is more important than ever as the regulatory landscape in the U.K. and EU finally reached an agreement. Here’s what we know today:
Following the United Kingdom’s (U.K.) departure from the European Union (EU) on Jan. 31, 2020, the EU and U.K. jointly agreed on a transition period that will end ended on Dec. 31, 2020. During the transition, the U.K. maintained status-quo for businesses and consumers, which means that the EU still recognized U.K. notified bodies, and manufacturers could sell CE marked products into the U.K. market until Dec. 31, 2020.
On Dec. 24, 2020, the United Kingdom and the European Union have agreed a Trade and Cooperation Agreement. The U.K.-EU trade Agreement contains new rules for living, working and trading together and entered into force on Dec. 31, 2020.
The full Agreement is 1,246 pages and is available here.
The deal secures tariff-free access between EU and U.K. markets, but does not change the compliance process, so the UKCA and the conformity to the U.K. Legislations remain mandatory for placing goods on the market in Great Britain. The new rules apply from 11 p.m. Dec. 31, 2020.
The UKCA marking
UKCA marking implementation and transition
The UKCA marking will apply to most goods currently subject to the CE marking (products covered by the following Directives/Regulations, e.g., LVD, EMCD, GAR, Machinery, ATEX, RoHS and RED). The UKCA marking can be used from January 2021. However, to allow businesses time to comply with the new requirements, CE marking can still be used until Jan. 1, 2022, provided that the requirements for the EU and U.K. legislation will continue to be the same.
Starting Jan. 1, 2022, the U.K. Government will no longer recognize the CE marking for Great Britain market access. Products bearing both the CE marking and UKCA marking will be acceptable as long as they comply with the relevant U.K. rules. The UKCA marking will need to be used immediately after January 1, 2021, if the product is only marketed in Great Britain and is covered by legislation that requires the UKCA marking and mandatory third-party intervention of a UKCA Approved Body.
For Northern Ireland, the CE marking will continue to be the conformity assessment marking for most goods. Manufacturers may also need the UKNI marking if selecting U.K. Approved Bodies for approvals or certification. Harmonized goods carrying only the UKCA marking will not be allowed in the Northern Ireland market.
Trust UL to help you bring products to the U.K. and EU markets
We have the global reach and unmatched expertise to support your market access needs. We combine trusted testing and certification, global scope and localized knowledge with real-time market expertise to help you reach your target markets.
Goods and legislations covered by the UKCA marking
- Equipment for use outdoors
- Electromagnetic compatibility (EMC)
- Civil explosives*
- Construction products*
- Gas appliances
- Low voltage electrical equipment (LVD)
- Medical devices*
- Measuring instruments
- Non-automatic weighing instruments
- Outdoor noise
- Personal protective equipment (PPE)
- Pressure equipment
- Products used/installed in Hazardous Locations (ATEX)
- Radio equipment
- Rail (interoperability)*
- Recreational craft and personal watercraft
- Restriction of hazardous substances (RoHS)
- Simple pressure vessels
*Additional requirements apply for these product types
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