UKCA Marking 2026 – Complete Guide for Polish Exporters

What is UKCA — UK Conformity Assessed

UKCA (UK Conformity Assessed) is the UK system for conformity assessment and marking of products placed on the British market — the exact equivalent of the European CE mark, but based on UK legislation and requiring certification by UK notified bodies (UK Approved Bodies).

The UKCA system was created as a result of Brexit. When the UK left the EU, the old EU regulations ceased to apply, and the UK transposed them into its own law (UK retained law). The technical requirements are practically identical to EU directives, but the conformity assessment procedure and certifying bodies are different.

Important: UKCA applies to the Great Britain (GB) market — England, Scotland and Wales. Northern Ireland is covered by the Windsor Framework and continues to accept CE marking.

Which products require UKCA

UKCA is required for products that before Brexit required the CE mark. Here are the main categories:

Products that do NOT require UKCA include, for example: food, medicines, motor vehicles (which have their own systems), and unregulated products without safety risks (simple goods).

When UKCA became mandatory — 2025/2026 timeline

The UKCA implementation schedule was postponed several times by the UK Government. Status as of 2026:

• 1 January 2021 — UKCA introduced, CE still accepted on a transitional basis
• 31 December 2024 — end of the transitional period for most categories. From 2025 new products must have UKCA
• 2026 — full implementation for all categories, including pressure equipment and construction products

Note: The UK Government has postponed transitional periods several times. Always verify the current status for your specific product category on GOV.UK or contact a UK Approved Body.

UKCA vs CE — key differences for Polish exporters

UK Approved Body — where to obtain UKCA certification

A UK Approved Body is an organisation authorised by the UK Government (OPSS — Office for Product Safety and Standards) to carry out conformity assessment for specific product categories. The list of UK Approved Bodies is available on GOV.UK and includes several dozen organisations.

Many European Notified Bodies (TÜV, SGS, Intertek, Bureau Veritas) have separate UK Approved Body divisions — which makes certification easier for Polish companies already working with these organisations.

UKCA certification costs vary significantly by category:

• Simple electrical products (LVD, self-declaration): from £500 (laboratory costs + documentation)
• Class II machinery: from £1,000 to £3,000
• PPE category III: from £2,000 to £5,000
• Radio equipment (RED): from £1,500 to £4,000

Quoted ranges are indicative — exact pricing after documents are submitted.

Can a product hold both CE and UKCA at the same time?

Yes — you can have the same product certified under both CE (EU market) and UKCA (UK market). Many Polish exporters run two parallel conformity assessment procedures. Key rules:

• Products sold in GB must not bear the CE mark (from 2025) — this carries a penalty and market withdrawal
• Northern Ireland: products may bear both CE and UKCA (Windsor Framework protocol)
• Technical documentation (Technical File) must be available to UK Market Surveillance Authorities for 10 years

FAQ — frequently asked questions about UKCA

Is my CE-marked product still legal on the UK market?

It depends on the date of manufacture and product category. Generally: products manufactured and certified before the end of 2024 could benefit from transitional CE recognition. New products from 2025 must have UKCA for the GB market. However, the timelines differ by category — always check the current requirements for your product on GOV.UK.

Can a Polish company carry out UKCA conformity assessment itself?

For some product categories (e.g. low voltage — LVD) the manufacturer can carry out self-declaration conformity assessment without an external certifying body, if the harmonised standards requirements are met. For higher-risk products (PPE category III, machinery class II+) a UK Approved Body is required.

What happens if I send a product without UKCA to the UK?

Goods may be held at UK customs clearance and referred for inspection by OPSS or MSA. Consequences: sales ban, mandatory market recall, financial penalty up to £10,000 per violation. For products posing serious risk — seizure of goods and entry on the dangerous products register.

Current rules — as of 2026

UKCA timelines have been updated several times by the UK Government. Always verify the current status for your product category on GOV.UK (OPSS). The information in this article reflects the legal position as of April 2026.

Official sources

• GOV.UK: Using the UKCA marking — OPSS, 2026
• GOV.UK: UK Approved Bodies list — OPSS, 2026
• GOV.UK: CE marking guidance for the UK — OPSS, 2026