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8 Tips for Navigating Post-Brexit Product Entry into the United Kingdom

March 30, 2021

The United Kingdom (UK) has officially left the European Union (EU)—and that makes a big difference about what you have to do to get your product into the UK. A new product marking called the UKCA is required for products sold in Great Britain. Importantly, however, your still need the traditional CE marking for selling your products in the EU. The following information, therefore, provides you with what you need to know regarding the new requirements:

  1.  The UKCA marking can be placed on the product, packaging or on an accompanying document. The transition period lasts until January 1, 2023.
  2.  Starting in 2023, the UKCA marking must be affixed in accordance with the requirements of the specific legislation. The information on product label for UKCA marked goods will mirror the current requirements for CE marked goods.
  3.  To ease the burden on businesses, the UKCA marking and UK importer’s address can be placed on an accompanying document until January 1, 2023.
  4.  The requirements for the manufacturer’s authorized representative will be the same as the current requirements for the EU authorized representative.
  5.  Authorized representatives for goods placed on the market in Great Britain from 1 January 2021 must be based in the UK, however for most goods sold, the use of authorized representatives is only voluntary.
  6.  No additional testing is needed for compliance to the United Kingdom. The standards are harmonized with the EU as shown in the Designated Standards.
  7.  The Reference Designated standards are categorized as “BS,” “EN,” “EN ISO,” or “EN IEC.” The “EN” prefix indicates that the standard has been adopted by a European standardizing body.
  8.  Generate a UK DoC (a document that declares the product is in conformity with the relevant statutory requirements applicable to the specific product) to the UK test standards.

Since the UK and EN tests standards are harmonized, the existing test report can be used to show presumption of conformity to the UK in most cases. If product is tested to non-harmonized standards, however, a UK Notified Body will be required.

In addition, please note that where the designated standard specified in the notice of publication is prefixed “EN,” it is acceptable to reference this version in technical documentation (or a version of the same standard with a national prefix). This is because European standards are adopted identically by the 34 national members of CEN and CENELEC.  For example: BS EN 71-1:2014+A1:2018, DIN EN 71-1:2014+A1:2018, or simply EN 71-1:2014+A1:2018 are all equally acceptable.

Finally, please note that the UKCA marking is for goods being placed on the market in Great Britain (England, Wales, and Scotland) and not used in Northern Ireland. To see the current UK legislation, you can click here for a list of the current UK legislation and the corresponding EU legislation.

If you want to speak directly to an expert in obtaining the UKCA marking, please contact us immediately.

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