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 marking is required for products previously covered by CE marking directives when placed on the Great Britain market. This includes:

• 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

Products that are CE-marked for the EU market must obtain a separate UKCA assessment for Great Britain unless transitional arrangements still apply. Check the current transitional period status on: gov.uk/guidance/using-the-ukca-marking. UKCA transitional periods have been extended multiple times — always check the current deadline before exporting.

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. Polish manufacturers exporting machinery to the UK must either: (a) appoint a UK-established authorised representative who holds the technical file in the UK, or (b) ensure a UK importer takes on this responsibility.

UKEX marking for ATEX equipment (explosive atmospheres)

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'). Equipment must carry the UKEX mark instead of (or in addition to) the ATEX Ex mark. Certification must be by a UK Approved Body for explosive atmospheres equipment. This is a significant compliance requirement — Polish manufacturers must ensure their UK ATEX distribution partner holds the relevant UK certification or obtain it through a UKAS-accredited body. 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: from £45 to £120. 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: from £45 to £150. Prices quoted are indicative ranges — exact quote after document review. GMR for cross-channel machinery haulage: from £15 to £30. T1 transit if required: from £200 to £500.

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)
• UKCA Declaration of Conformity (or documentation confirming UKCA marking exemption status)
• Technical file reference (held by manufacturer or UK-authorised representative)
• For ATEX/UKEX equipment: UK Approved Body certificate
• 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 UKCA marking (not CE) and, for ATEX equipment, UKEX certification under SI 2016/1107. The conformity assessment requires involvement of a UKAS-accredited UK Approved Body for higher-risk equipment. Customs: export declaration EX-A from £45 to £120; UK import clearance from £45 to £150; GMR from £15 to £30; T1 transit if required from £200 to £500. 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?

Not without additional compliance steps. The CE mark is not valid for the Great Britain market (England, Scotland, Wales). You need UKCA marking, which requires a separate UK conformity assessment. Check the current transitional arrangement deadline on gov.uk — it has been extended multiple times.

What is the UKEX mark and when is it required?

UKEX is the UK equivalent of the ATEX mark for equipment used in potentially explosive atmospheres (chemical plants, mines, flour mills, grain silos, etc.). It is required under SI 2016/1107 for the Great Britain market. Assessment must be by a UKAS-accredited UK Approved Body.

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

Export declaration (EX-A) from Poland: from £45 to £120. UK import clearance: from £45 to £150. GMR for road transport: from £15 to £30. T1 transit if required: from £200 to £500. 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 (UKEX) — legislation.gov.uk
• UKAS — UK Accreditation Service (Approved Bodies) — UKAS