UKCA Certification to Replace CE Compliance in 2028

Starting from January 1, 2028, new products entering the markets of England, Wales, and Scotland will be fully required to bear the ukca (UK Conformity Assessed) marking, with the ce marking formally withdrawn. For Chinese export enterprises, completing compliance arrangements in advance can not only avoid the risk of unsold goods but also seize the first-mover advantage in the UK market.

UKCA to Take Effect in 2028

After Brexit, the UK has gradually withdrawn from the EU regulatory framework. Since its launch in 2021, the ukca certification has been in a transitional phase. Previously, enterprises could access the UK market with the ce marking (some high-risk products certified by EU Notified Bodies could postpone the switch), while Northern Ireland applied either the UKNI marking or the CE marking.

The 2028 new regulations mean the end of the transition period. Products newly entering mainland UK (England, Wales, Scotland) must complete UKCA certification and affix the marking correctly, as the CE marking will no longer be recognized.

Due to the Northern Ireland Protocol, Northern Ireland still follows EU Single Market rules. High-risk products require the UKNI marking or a compliant CE marking, which differs from the requirements in mainland UK. Enterprises must clearly distinguish their export destinations.

6 Core Questions for Enterprises Exporting to the UK

Can CE-marked goods exported before 2028 continue to be sold?

①　Goods cleared and entered the UK market (including inventory and on-shelf products) before January 1, 2028, can be sold until the end of their shelf life or service life.

②　Newly produced or imported products after 2028 must use the ukca marking.

③　It is recommended to calculate the certification timeline based on the product’s shelf life. For example, products with a 3-year shelf life should start UKCA certification no later than 2025-2026.

Core Differences Between UKCA Certification and CE certification

Do CE Self-Declared Products Need Recertification After 2028?

①　Low-risk products (e.g., ordinary toys, simple plastic products): No additional testing is required. Enterprises only need to switch the cited regulations in the declaration to UK regulations, sign the UKCA declaration, and affix the marking.

②　High-risk products (e.g., electrical equipment, machinery, medical devices): If the original CE certification relied on an EU Notified Body, recertification by a UK-recognized testing body is required to obtain UKCA certification.

Are the Requirements for Northern Ireland and England Markets Consistent?

①　They are completely different. Northern Ireland follows EU Single Market rules.

②　High-risk products require the UKNI marking or a compliant CE marking; low-risk products can generally use the CE marking directly.

③　Incorrectly using the UKCA marking for the Northern Ireland market may result in goods being seized.

Consequences of Misapplying or Omitting the UKCA Marking?

The marking must meet requirements for visibility, size, content compliance, and durability. Violations may lead to product removal, recall, or fines.

How Can SMEs Complete UKCA Certification at Low Cost?

①　Prioritize self-declaration for low-risk products to save testing fees.

②　Reuse qualified EU test reports to reduce duplicate testing costs.

③　Choose "one-stop" combined certification services covering testing, document sorting, and designation of UK Authorized Representatives.

④　The period 2025-2027 is a golden transition phase, offering more favorable costs and timelines for certification.

Long-Term Compliance: Dynamically Track UK Regulatory Changes

①　Monitor the official website of the UK Department for Business, Energy and Industrial Strategy (BEIS) or obtain policy updates through professional institutions.

②　Track revisions to UKCA-related harmonized standards and optimize production processes in a timely manner.

③　Integrate UKCA certification management into the enterprise’s quality system to achieve full-process compliance control.

Seize the Final Window to Stabilize Success in the UK Market

The full switch to UKCA in 2028 is an inevitable result of the UK’s regulatory independence. Chinese export enterprises need to proactively use the 2025-2027 transition period to complete compliance planning. Compliance is not only a prerequisite for market access but also a core competitiveness in global layout. Specific operations shall be based on the latest official documents of the UK government. For complex cases, it is advisable to consult professional certification institutions.