CE marking vs UKCA in 2026

Last reviewed: October 2026 · Sources listed at the end of this page.

UKCA — "UK Conformity Assessed" — is the conformity mark Great Britain created after leaving the European Union. It was designed as a domestic replacement for CE marking, applying essentially the same technical requirements through legislation retained from EU law. In practice, the replacement never happened. After a series of postponed deadlines, Great Britain now recognises current EU requirements, including CE marking, with no end date for products under 21 product regulations, and UKCA survives as an optional alternative for those categories rather than a requirement. Other sectors follow their own rules. Some of them still accept CE marking on separate terms (construction products, medical devices, cableways); others do not use it at all (marine equipment, transportable pressure equipment, drones).

This page sets out how the two marks relate in 2026, which sectors sit outside the recognition arrangement, and how Northern Ireland differs from Great Britain. For what CE marking itself signifies, see what is CE marking?

From Brexit to indefinite recognition

The UK left the EU on 31 January 2020 and remained inside the single market until the end of the transition period on 31 December 2020. From 1 January 2021, Great Britain (England, Wales, and Scotland) operated its own product compliance regime based on EU law as retained at exit, with UKCA as its conformity mark and "approved bodies" taking the role of EU Notified Bodies.

CE marking was originally to be accepted in Great Britain only for a short transitional period. That period was extended repeatedly:

The practical result: for the great majority of CE-marked products — machinery, electrical and electronic equipment, toys, PPE, pressure equipment, and the other categories listed below — a product that lawfully carries CE marking can be placed on the market in Great Britain without any UKCA marking, and no end date has been set.

The 21 product regulations covered by CE recognition

Continued CE recognition in Great Britain applies to products within the scope of 21 GB product regulations, which broadly mirror the EU harmonisation acts. The categories include:

• machinery (GB: Supply of Machinery (Safety) Regulations 2008, as amended by SI 2026/867 from 20 January 2027; EU: Machinery Regulation (EU) 2023/1230 from the same date);
• electrical equipment within the Low Voltage Directive scope;
• electromagnetic compatibility (EMC Directive 2014/30/EU);
• radio equipment (Radio Equipment Directive 2014/53/EU);
• toys (toy safety);
• personal protective equipment (PPE Regulation (EU) 2016/425);
• gas appliances, lifts, pressure equipment, simple pressure vessels, and equipment for explosive atmospheres (ATEX);
• restriction of hazardous substances (RoHS), recreational craft, pyrotechnic articles, explosives, outdoor noise, ecodesign for energy-related products, measuring instruments, and non-automatic weighing instruments;
• aerosol dispensers and measuring container bottles, where the recognised EU mark is the reversed epsilon rather than CE.

The list above follows the gov.uk guidance "Placing manufactured goods on the market in Great Britain", last updated in May 2024. The government's March 2026 document "Product regulations by sector" is the newer overview, sector by sector. Where a product sits at the edge of a category, the applicable GB regulation, not this summary, is decisive.

UKCA in 2026: a valid, optional alternative

UKCA marking has not been abolished. For the categories covered by CE recognition, a manufacturer may choose to affix UKCA instead of, or alongside, CE marking for the GB market. Reasons some manufacturers keep UKCA include existing certification with UK approved bodies, retail customer requirements, or a wish to hedge against future divergence. But there is no regulatory obligation to use it in those categories, and we found no announced date on which CE recognition ends. Current guidance also allows a UKCA marking to go on a label or accompanying document until 11pm on 31 December 2027.

Where UKCA is used, the GB rules broadly track the familiar CE mechanics: the mark is affixed by the manufacturer, a UK declaration of conformity is drawn up (analogous to the EU Declaration of Conformity), "designated standards" give a presumption of conformity in the way harmonised standards do in the EU, and third-party assessment, where a module requires it, is performed by a UK approved body whose number accompanies the mark.

Sectors following separate UK regimes

The 21-regulation arrangement is not universal. The table summarises the other main sectors, using the government's March 2026 overview, updated for later decisions.

Medical devices

Medical devices in Great Britain are regulated under the Medical Devices Regulations 2002 (UK MDR 2002), as amended, overseen by the MHRA — not under the EU Medical Devices Regulation (EU) 2017/745. Under the Medical Devices (Amendment) (Great Britain) Regulations 2023, CE-marked devices are accepted in Great Britain until 30 June 2028 (or earlier certificate expiry) for devices under the MDD or AIMDD, and until 30 June 2030 for devices under the IVDD (or earlier certificate expiry), the EU MDR or the EU IVDR. On 21 October 2026, after a consultation that ran from 16 February to 10 April 2026, the government said it intends to legislate to recognise CE-marked devices certified under the EU MDR and IVDR indefinitely, and to align GB transitional arrangements for MDD devices with EU timelines. That is a stated intention: until the amending regulations are made, the statutory dates above still apply. Manufacturers must still appoint a UK Responsible Person where required, register devices with the MHRA, and meet GB post-market surveillance rules. Check current MHRA guidance before relying on any date.

Construction products

Construction products follow a separate GB framework based on the retained Construction Products Regulation, while the EU regime migrates to Construction Products Regulation (EU) 2024/3110. The government committed in September 2024 to keep recognising CE marking for construction products, subject to wider reform, with at least two years' transition before any later change. The Construction Products (Amendment) Regulations 2025 came into force in January 2026, and a reform white paper followed in February 2026. Designated standards are mandatory under the GB construction products rules, unlike most other sectors.

Rail, marine equipment, transportable pressure equipment, and cableways

• Rail: interoperability constituents carry no GB marking. They reach the market through a UK or EU declaration of conformity; EU declarations are accepted without further assessment where the EU and GB requirements are equivalent, and UK-specific cases may need more.
• Marine equipment: equipment within the scope of the Marine Equipment Directive 2014/90/EU in the EU follows a separate UK regime for UK-registered ships, with the Red Ensign mark. The EU wheelmark serves EU-registered ships.
• Transportable pressure equipment: Great Britain uses the rho mark, while Northern Ireland uses the EU pi mark under Directive 2010/35/EU.
• Cableways: CE marking remains usable alongside UKCA under 2019 amendments. The government notes that there is no UK-based body for this specialised market.

Products outside any harmonisation act

These are governed in GB by the General Product Safety Regulations 2005, while the EU applies the General Product Safety Regulation (EU) 2023/988, applicable since 13 December 2024. The two regimes have diverged. On 31 March 2026 the UK opened a consultation, closed on 23 June 2026, on replacing the 2005 Regulations under the 2025 Act, with new duties for online marketplaces and civil penalties. We found no government response as of 31 October 2026, so the 2005 Regulations remain the law.

Northern Ireland: EU rules under the Windsor Framework

Northern Ireland applies EU product rules under the Windsor Framework. Products placed on the market in Northern Ireland must comply with the applicable EU harmonisation legislation and carry CE marking where the EU acts require it — UKCA alone is not valid there.

Where mandatory third-party conformity assessment is carried out by a UK-based notified body rather than an EU Notified Body, the product carries the UKNI marking alongside the CE marking. Two consequences follow:

• UKNI is never used on its own — it always accompanies CE marking; and
• a product bearing CE + UKNI is valid for the Northern Ireland market but cannot be placed on the EU market, because the assessment was not performed by an EU Notified Body.

Qualifying Northern Ireland goods benefit from unfettered access to the rest of the UK market, so a qualifying product lawfully on the market in Northern Ireland can generally also circulate in Great Britain. From 20 January 2027, SI 2026/867 also applies the EU Machinery Regulation's enforcement rules in Northern Ireland.

Divergence: the risk to watch

CE recognition in Great Britain means GB currently accepts compliance with the EU requirements, but the two statute books are no longer mechanically linked, so recognition has to be renewed by UK legislation when EU law changes:

• The EU Machinery Regulation 2023/1230 applies from 20 January 2027, replacing Directive 2006/42/EC. Great Britain keeps the Supply of Machinery (Safety) Regulations 2008, but SI 2026/867 amends them so that machinery meeting the Regulation's requirements, with the technical documentation, conformity assessment, EU declaration, English-language instructions, and CE marking it specifies, can be placed on the GB market from that date.
• The EU has replaced its general product safety directive with GPSR 2023/988; GB has consulted on doing something similar but has not legislated.
• New EU instruments such as the Battery Regulation 2023/1542, the Digital Product Passport, and the AI Act have no automatic GB equivalent. A consultation on recognising CE marking under the EU ecodesign regulation for sustainable products closed on 20 January 2026.

The Product Regulation and Metrology Act 2025 gives UK ministers powers to make product regulations, which is how recognition can follow, or stop following, EU changes over time. See 2025–2026 changes for the moving parts on the EU side.

Practical guidance for manufacturers selling in both markets

1. Classify your product first. Establish which EU acts apply (does my product need CE marking?) and whether the corresponding GB regulation is one of the 21 covered by CE recognition.
2. If it is covered: complete the CE marking process once. CE marking then serves the EU, the EEA, and Great Britain. UKCA is optional; dual marking is permitted if you want it.
3. If it is not covered: use the sector table above. CE can serve for construction products, cableways, and (with MHRA registration and a UK Responsible Person where needed) medical devices. Marine, transportable pressure equipment, and uncrewed aircraft need GB-specific marking, so plan a separate compliance track.
4. Mind the operator roles. An EU-established manufacturer selling into GB will typically have a UK importer. For goods imported from the EEA, and in some cases Switzerland, importer details may go in an accompanying document or on the packaging until 11pm on 31 December 2027; a UK manufacturer selling into the EU needs an EU-established economic operator under Article 4 of Regulation (EU) 2019/1020 for many categories (see importing from non-EU manufacturers and authorised representative).
5. For Northern Ireland: follow EU rules; use an EU Notified Body if you want a single assessment valid EU-wide, since CE + UKNI is NI-only.
6. Monitor divergence. Where an EU act is replaced, confirm how GB recognition treats the new EU requirements before relying on a single technical file for both markets. For machinery, SI 2026/867 answers that question from 20 January 2027.

Frequently asked questions

Is UKCA marking mandatory in 2026?

Not for products under the 21 GB regulations where CE recognition applies. A manufacturer may use CE, UKCA, or both. Sectors outside those regulations have their own rules, and some require GB-specific marking.

Can I sell a CE-marked product in Great Britain?

Usually yes. A product that lawfully carries CE marking under one of the 21 regulations can be sold in Great Britain without UKCA. You still need to meet GB duties such as importer identification.

Will CE-marked machinery still be accepted in GB after 20 January 2027?

Yes, on the conditions in SI 2026/867. From 20 January 2027, machinery meeting the EU Machinery Regulation can be placed on the GB market if it has the required technical documentation, conformity assessment, EU declaration, English instructions, and CE marking.

Are CE-marked medical devices recognised indefinitely in Great Britain?

Not yet in law. On 21 October 2026 the government said it intends to legislate for indefinite recognition of devices certified under the EU MDR and IVDR. Until then, the dates in the 2023 Regulations apply.

Does the 21 product regulations figure include every CE-marked product?

No. Medical devices, construction products, cableways, marine equipment, rail, transportable pressure equipment, and uncrewed aircraft are outside it, with their own arrangements.

Can a CE + UKNI product be sold in the EU?

No. UKNI means a UK-based notified body carried out the assessment for the Northern Ireland market. For the EU market, use an EU Notified Body.

Sources

• UK Government — Using the UKCA marking (gov.uk guidance).
• UK Government — Placing manufactured goods on the market in Great Britain (gov.uk guidance).
• UK Government — Using the UKNI marking (gov.uk guidance).
• UK Government — Product regulations by sector and current approaches to product marking (published 31 March 2026).
• UK Government — Government confirms indefinite recognition of CE marked medical devices, and the consultation outcome (21 October 2026).
• UK Government — Government response on machinery safety legislation (25 February 2026).
• The Supply of Machinery (Safety) (Amendment etc.) and the EU Machinery Regulation (Enforcement etc. in Northern Ireland) Regulations 2026 (SI 2026/867) — legislation.gov.uk.
• Cooley — UK product safety overhaul (secondary source on the 2026 consultation).
• The Product Safety and Metrology etc. (Amendment) Regulations 2024 (SI 2024/696) — legislation.gov.uk.
• Product Regulation and Metrology Act 2025 — legislation.gov.uk.
• Regulation (EC) No 765/2008 (general principles of CE marking, Article 30) — EUR-Lex.
• Regulation (EU) 2019/1020 on market surveillance and compliance of products — EUR-Lex.