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United Kingdom - Brexit

Big Ben and Westminster Bridge in the sunset

December 2, 2020

On Jan. 31, 2020, the U.K. officially left the European Union (EU). The EU and U.K. have, however, jointly agreed on a transition period which will last until Dec. 31, 2020 (it shall not be extended further) and maintains complete status-quo for businesses, citizens and consumers.

The EU and U.K. are negotiating an “ambitious and fair partnership for the future,” i.e. a free trade agreement. The negotiations between the UK Government and the EU have been extensive with more than 10 rounds of official discussions, and it is fair to say that these discussions have been tough going with each making little ground on the substance.


From Jan. 1, 2021, the UKCA mark will replace the CE mark for goods entering the Great Britain market, however, the CE marking will still be accepted until Dec. 31, 2021.

From Jan. 1, 2022, the CE marking will not be recognized in Great Britain for areas covered UKCA marking.

The UKCA marking alone cannot be used for goods placed on the Northern Ireland market, which require the CE marking or UK(NI) marking  and on EU market.

By affixing the UKCA mark, the manufacturer declares under his sole responsibility that the product conforms to all applicable UK legislative requirements, and that appropriate conformity assessment procedures have been successfully completed.

For updates on this topic connect to the UL web page: Brexit’s status and market access implications.

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