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 The new UKCA (U.K. Conformity Assessed) marking declares that the product conforms to all applicable U.K. legislative requirements and that appropriate conformity assessment procedures have been successfully completed. Beginning Jan. 1, 2021, the UKCA marking will replace the CE marking as a requirement for goods entering the Great Britain market, including England, Scotland and Wales. The UKCA marking will be required on products subject to the U.K. equivalent legislation to all the EU Directives/Regulations that required CE marking, including the Radio Equipment, EMC and Low Voltage Directives. Additionally, all U.K.-based EU Notified Bodies will also lose their status on Jan. 1, 2021. All EU Certificates issued by those bodies must be transferred to an EU 27 Notified Body by Dec. 31, 2020 to ensure continued validity.


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.

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Goods and legislations covered by the UKCA marking

  • Aerosols
  • Ecodesign
  • Equipment for use outdoors
  • Electromagnetic compatibility (EMC)
  • Civil explosives*
  • Construction products*
  • Gas appliances
  • Lifts
  • Low voltage electrical equipment (LVD)
  • Machinery
  • 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
  • Toys

*Additional requirements apply for these product types

Contact us to get clear insights for your business.


On-demand webinar | Brexit – New Compliance Regulations

Gain insights about the new upcoming regulatory changes for UK market access – the UKCA (United Kingdom Conformity Assessed mark – which will come into effect on 1 January, 2021.

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Brexit FAQ

Gain answers to commonly asked questions about how the Brexit’s new requirements transition impact market access.

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