Exporting Industrial Machinery to the UK — UKCA Marking, ATEX/UKEX and Customs

UKCA Marking — What It Is and When It Is Required

The UKCA mark is the UK's post-Brexit product conformity marking system for the Great Britain market (England, Scotland, Wales).

What products require UKCA marking

UKCA is the GB marking for products previously covered by CE marking directives. For most of these regimes GB also recognises CE marking. They include:

• Machinery (Machinery Directive equivalent — UK Machinery Regulations 2008)
• Electrical equipment for use within specific voltage limits (Low Voltage Equipment — LVE)
• Electromagnetic compatibility (EMC)
• Pressure equipment (PED equivalent)
• Personal protective equipment (PPE)
• Lifts and other equipment regulated under former EU directives

A product that is CE-marked for the EU market and meets the EU requirements can be placed on the Great Britain market without a separate UKCA assessment — the UK recognises CE marking for these regulations under the Product Safety and Metrology etc. (Amendment) Regulations 2024. Medical devices, construction products and a few other sectors follow their own rules. Check the current guidance on: GOV.UK — Placing UKCA or CE marked products on the market in Great Britain.

How to obtain UKCA marking — conformity assessment

The conformity assessment process for UKCA mirrors the EU CE marking process. The manufacturer (or their UK-authorised representative) must: (1) carry out a conformity assessment against the applicable UK technical regulations; (2) compile a technical file; (3) declare conformity by issuing a UK Declaration of Conformity; (4) affix the UKCA mark to the product (and to the packaging if required). For products in higher-risk categories (where CE required a Notified Body), UKCA requires assessment by a UK Approved Body. The UK Approved Body is the UK equivalent of an EU Notified Body — it must be listed on the UKAS database. Where you use the CE route, an EU Notified Body assessment supports the CE marking; the Fast-Track UKCA route also lets you apply UKCA on the basis of EU conformity assessment. Whether a UK authorised representative is needed depends on the product regulation; when the goods are imported into GB, the UK importer must add its name and address.

ATEX equipment (explosive atmospheres) in Great Britain

Equipment intended for use in potentially explosive atmospheres — pumps, motors, compressors, sensors, lighting used in the chemical, petrochemical, mining, grain handling, flour milling, pharmaceutical and similar industries — previously required ATEX certification (EU Directive 2014/34/EU). For the Great Britain market, the ATEX directive equivalent is UK Statutory Instrument SI 2016/1107 (Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres Regulations 2016 — 'UK PSSR'). GB recognises CE marking for this equipment, including where an EU Notified Body carried out the assessment; the alternative is the UKCA marking, with a UK Approved Body where third-party assessment is required. "UKEX" is an industry shorthand, not a separate legal marking. This article reflects the legal position as of 2026-04-18. Contact a customs broker before taking any action.

Customs for Machinery Exports to the UK

Beyond product marking, exporting machinery involves standard customs procedures on both the Polish and UK sides.

Export customs from Poland (EX-A, PUESC)

Machinery exported from Poland to the UK requires an export customs declaration (EX-A) submitted in the Polish AES system through PUESC. The main HS codes for industrial machinery:

• HS Chapter 84 — Industrial and mechanical machinery, engines, pumps, compressors
• HS Chapter 85 — Electrical machinery, motors, generators, transformers

The export declaration includes the value of the machinery (CIF or FOB basis), the buyer's details, the HS code, and the transport details. An IE599 confirmation is generated when the goods leave EU territory — this is needed by the Polish exporter to claim VAT 0% on the export. Easy Clearance export service: see our pricing page. Prices quoted are indicative ranges — exact quote after document review.

UK import customs clearance (CDS, HMRC)

When machinery arrives in the UK, the UK importer (or their appointed customs broker) must lodge an import declaration in the UK CDS (Customs Declaration Service). The customs value is declared, import duty is calculated (typically 0% from EU under TCA if origin requirements are met for machinery — verify for the specific HS code), and UK import VAT at 20% is accounted for. If the UK importer is VAT-registered, VAT can be accounted for using PVA (Postponed VAT Accounting) — meaning no cash payment at the border. Easy Clearance UK import clearance: see our pricing page. Prices quoted are indicative ranges — exact quote after document review. GMR for cross-channel machinery haulage: see our pricing page. T1 transit if required: see our pricing page.

Documentation checklist for machinery exports to the UK

Required documents for a machinery export from Poland to the UK:

• Commercial invoice (value, description, HS code, Incoterms)
• Packing list (weight, dimensions, number of packages)
• CMR (consignment note for road transport)
• EU or UK Declaration of Conformity (matching the CE or UKCA marking used)
• Technical file reference (held by manufacturer or UK-authorised representative)
• For ATEX equipment: the EU Notified Body or UK Approved Body certificate, where third-party assessment is required
• Statement of EU origin on invoice (for TCA 0% duty preference)
• GMR (for road transport via RoRo ferry or Channel Tunnel)

Easy Clearance can advise on the specific documentation requirements for your machinery type and route.

What the current rules say

Exporting industrial machinery from Poland to England, Scotland or Wales requires CE or UKCA marking — GB recognises CE for machinery and for ATEX equipment under SI 2016/1107. Higher-risk equipment needs third-party assessment: by an EU Notified Body for CE, or a UK Approved Body for UKCA. Customs: export declaration EX-A, ; UK import clearance, ; GMR, T1 transit if required: see our pricing page. All prices are indicative ranges — exact quote after document review. This article reflects the legal position as of 2026-04-18.

FAQ — frequently asked questions

Can I sell CE-marked machinery in England and Scotland?

Yes, in most cases. Under the Product Safety and Metrology etc. (Amendment) Regulations 2024 Great Britain continues to recognise CE marking, alongside or instead of UKCA, for machinery covered by the Supply of Machinery (Safety) Regulations 2008. You can also use UKCA, including the Fast-Track UKCA route based on EU conformity assessment. Check GOV.UK guidance for your product, as a few sectors have their own rules.

Is there a separate UK mark for ATEX equipment ("UKEX")?

"UKEX" is an industry shorthand, not a legal marking. In Great Britain, equipment for potentially explosive atmospheres is regulated by the Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres Regulations 2016 (SI 2016/1107). GB recognises CE marking for this equipment, including where an EU Notified Body carried out the assessment; the alternative is UKCA, with a UK Approved Body where third-party assessment is required.

How much does customs clearance cost for machinery exports to the UK?

Export declaration (EX-A) from Poland: see our pricing page. UK import clearance: see our pricing page. GMR for road transport: see our pricing page. T1 transit if required: see our pricing page. Prices quoted are indicative ranges — exact quote after document review.

Do I need a UK authorised representative for UKCA?

If your product requires third-party (Approved Body) assessment for UKCA, you typically need to appoint a UK-established authorised representative to hold the technical file in the UK and to be the responsible party for conformity. Your UK importer can also take on this role. Contact a UK product compliance specialist for advice specific to your product category.

Official sources

• GOV.UK — UKCA marking guidance — GOV.UK
• SI 2016/1107 — ATEX equivalent UK regulations — legislation.gov.uk
• UKAS — UK Accreditation Service (Approved Bodies) — UKAS