If you manufacture outside the EU and sell into the UK or the EU, you can’t ignore the split between CE marking and UKCA marking anymore. Even though timelines and transition windows have been pushed, paused, and patched more than once, the practical takeaway hasn’t changed:
- The EU = CE marking (Notified Bodies, harmonised standards, EU DoC).
- Great Britain (England, Scotland, Wales) = UKCA marking (Approved Bodies, designated standards, UK DoC).
If you export from South Africa, Nigeria, Kenya, UAE, Saudi Arabia, Singapore, Malaysia, the UK, Germany, France, Spain, or any other non‑EU country, you now need to treat the UK and EU as two regulatory jurisdictions with subtle—but business‑critical—differences in technical documentation, labelling, representatives, and conformity assessment routes.
Let’s unpack what’s different, what you must change, what’s optional (for now), and how to keep both markets without doubling your workload.
Quick refresher: CE vs UKCA in one minute
- CE Marking: Required for most regulated products placed on the EU/EEA market. Conformity is shown against EU directives/regulations using harmonised EN standards. Third-party assessments are done by EU Notified Bodies. You issue an EU Declaration of Conformity (DoC).
- UKCA Marking: The UK’s post‑Brexit equivalent for Great Britain. Conformity is shown against UK law (retained EU law) using UK designated standards. Third-party assessments (when required) come from UK Approved Bodies. You issue a UK Declaration of Conformity.
- Northern Ireland: Still follows CE (and sometimes UKNI when a UK body is involved). Treat NI as EU‑aligned for most practical purposes.
Deadlines and recognition periods have changed several times. Always verify current sector-specific requirements (medical devices, construction products, PPE, radio equipment, etc.)—but don’t use that as an excuse to do nothing. The structure of the split is here to stay.
What non EU manufacturers must change (or at least prepare)
1) Technical files: separate, but 80% identical
Your technical documentation for the EU (CE) and GB (UKCA) will look very similar, but they need to reference different laws and standards:
- EU file: EU regulations/directives + harmonised standards + EU DoC.
- GB file: UK regulations (retained EU law) + UK designated standards + UK DoC.
Tip: Maintain a master technical file with jurisdiction-specific annexes. That way, you don’t multiply effort every time a regulation, standard, or test report changes.
2) Declarations of Conformity: two versions
You need two DoCs:
- EU Declaration of Conformity (naming EU laws, harmonised ENs, EU Notified Body if applicable, EU importer/authorised rep).
- UK Declaration of Conformity (naming UK laws, UK designated standards, UK Approved Body if applicable, UK importer/authorised rep).
3) Marking, labels, and addresses
Your labels, packaging, and manuals must:
- Show CE for EU markets, UKCA for GB (if/when required for your category).
- Include the correct importer address for each market (EU importer for CE, UK importer for UKCA).
- Reference the right legal entities (authorised representative, manufacturer, importer) for each jurisdiction.
If you’re exporting from South Africa or Singapore to both the EU and the UK, you cannot rely on a single legal representative to satisfy both—you need EU and UK coverage.
4) Bodies that sign your certificates differ
- EU: Notified Bodies (NBs).
- GB: Approved Bodies (ABs).
Certificates from an NB do not automatically transfer to an AB (and vice versa), unless there’s a specific scheme in your sector. If you relied on a UK NB before Brexit, you likely had to migrate your certificates to an EU NB to keep CE compliance. The reverse is also true for UKCA.
5) Standards are almost the same—until they aren’t
At the moment, UK designated standards are largely aligned to EN harmonised standards, but the references are different. Over time, divergence is possible (and in some verticals, already real). Your technical files and DoCs must cite the correct lists.
6) Authorised reps and importers: legally different roles in each region
- For the EU, you need an EU Authorised Representative (if you’re not EU-based) and an EU importer (the economic operator placing the product on the market).
- For Great Britain, you need a UK Authorised Representative (if you’re not UK-based) and a UK importer.
One address cannot legally satisfy both.
Real-world case study: A Kenyan electronics brand rescues its UK pipeline
Company: Mid-sized consumer electronics OEM headquartered in Kenya with contract manufacturing in Malaysia.
Markets: EU (Germany, France, Spain), UK, and UAE.
Problem: The company’s EU distributors started pushing for a CE‑compliant technical file refresh due to new EN standard updates. Meanwhile, UK retailers requested UKCA readiness evidence before onboarding new product lines. The firm had one EU Notified Body certificate (pre‑Brexit) and thought it was enough for both regions.
What went wrong
- Their EU DoC referenced valid EN standards, but they had no UK Declaration of Conformity.
- The UK importer address wasn’t on the label—potential customs rejection.
- They were still using the old EU NB certificate in UK bids—not recognised.
- Their manuals used a one-size-fits-all regulatory page. Procurement teams flagged it.
What changed with QCert360
- Rapid gap analysis across CE and UKCA requirements: technical file, labelling, importer/rep, standards reference.
- Split & sync: One master tech file with EU/GB annexes—no double maintenance.
- Two Declarations produced (EU & UK), each referencing the proper legal instruments and standards lists.
- Importer/Authorised Rep alignment: New EU and UK economic operator details added to labels and manuals.
- Approved Body liaison: For the UK, QCert360 helped the company engage a UK Approved Body for applicable categories to replace reliance on the old NB certificate.
- Label & packaging templates: Cleanly separated CE and UKCA versions to avoid last-minute mistakes in production.
Outcome
- UK retailers onboarded all new SKUs after seeing UKCA documentation and correct labelling.
- EU sales continued uninterrupted with updated CE files and standards references.
- Customs clearance time in the UK dropped—no more compliance queries.
- The company’s export team now uses a single evidence pack for both markets when responding to tenders.
The “don’t get burned” checklist
If you manufacture in (or export from) South Africa, Kenya, Nigeria, UAE, Saudi Arabia, Singapore, Malaysia, the UK, Germany, France, Spain, or elsewhere, and sell into both the EU and Great Britain, make sure you can tick these:
- Two Declarations: EU DoC + UK DoC (right laws, right standards, right bodies).
- Tech file crosswalk: One master, two annexes.
- Correct economic operators: EU AR + importer; UK AR + importer.
- Marking cleanly separated: CE for EU, UKCA for GB (where required).
- Certificates valid for each region: NB ≠ AB.
- Labelling and manuals: Region-specific compliance sections.
- Northern Ireland plan: CE (and UKNI if a UK body is used) still matters there.
- Standard tracking: EN harmonised vs UK designated—cite correctly, track updates.
- Deadline monitoring: Sectoral rules shift—don’t assume last year’s grace period still applies.
How QCert360 helps you stay compliant (and fast)
Most companies spend months trying to decode CE vs UKCA and end up duplicating work—or worse, missing something small that kills a shipment or tender. QCert360 helps you separate what must be separate, and unify what can be unified, so you stay lean and legal.
What we do, practically:
- Rapid CE/UKCA gap analysis (technical files, standards, declarations, labels, importer/rep roles).
- Master tech file architecture with EU/GB annexes to avoid duplicate documentation.
- Draft/review EU & UK Declarations of Conformity and help map standards correctly.
- Label, packaging, and manual templates for both markets—ready for production.
- Liaison with EU Notified Bodies and UK Approved Bodies where third-party assessment is needed.
- Authorised Representative and importer structuring (EU and UK).
- Team training: what changed, what hasn’t, who signs what, and how to keep it updated.
- Ongoing standards and regulatory change monitoring—so you don’t get caught by another moving deadline.
If you’re exporting to the UK, EU, Middle East, or Africa and want to keep every door open with clean CE and UKCA compliance, we’ll get you there without multiplying the admin burden.
QCert360
Email: contact@qcert360.com
Phone: +91 7483870406
Ask us for a CE vs UKCA readiness scorecard—we’ll tell you exactly what to fix, what to reuse, and how fast you can be audit- and market-ready.
FAQ's
1. What is the main difference between UKCA and CE marking?
UKCA (UK Conformity Assessed) is the UK’s product marking post-Brexit, while CE remains valid in the EU and EEA. Each has different regulatory requirements and authorities.
2. Do I still need CE marking if I have UKCA certification?
Yes, if you want to sell in both the EU and UK. CE is mandatory in the EU, while UKCA is required in Great Britain.
3. When is UKCA marking mandatory for non-EU manufacturers?
UKCA became mandatory for most goods placed on the GB market from January 1, 2025. Non-EU manufacturers must comply if selling to England, Scotland, or Wales.
4. What product categories require UKCA marking?
UKCA covers most CE-marked goods like machinery, electronics, medical devices, toys, and PPE that are sold in the UK.
5. Can one technical file be used for both UKCA and CE compliance?
No. While similar, each scheme has its own regulations, documentation, and conformity assessment bodies. Dual files or adjusted versions are typically needed.
6. Are UK Notified Bodies and EU Notified Bodies the same?
No. After Brexit, UK Notified Bodies became UK Approved Bodies. Products tested by UK bodies are no longer valid for CE marking and vice versa.
7. Do labeling rules change between UKCA and CE?
Yes. UKCA requires the UK address of an importer or authorized representative, and the UKCA logo must be used separately from the CE mark.
8. Can both UKCA and CE marks appear on the same product?
Yes, as long as the product meets the requirements of both jurisdictions. Placement must follow the respective guidelines for visibility and legibility.
9. What happens if a non-EU company uses only CE marking for UK sales?
Post-2024, the UK will not accept CE marking alone. Products without UKCA compliance may be rejected at customs or fined.
10. How can QCert360 help with UKCA and CE marking compliance?
QCert360 guides manufacturers through documentation, conformity assessments, and labeling requirements for both UKCA and CE to ensure smooth market access.
