United Kingdom – Brexit

Brexit’s new rules and market access implications

Staying abreast of market entry requirements is more important – and challenging - than ever to maintain market access in the U.K. and EU. The EU-UK Trade and Cooperation Agreement requires significant changes in product conformity assessments and product marking. Leverage UL Solutions’ global regulatory expertise to help maintain continued market access.

The EU-UK Trade and Cooperation Agreement - key regulatory changes

Following the United Kingdom’s (U.K.) departure from the European Union (EU) on Jan. 31, 2020, the EU and U.K. jointly agreed on a transition period that ended on Dec. 31, 2020. During the transition, the U.K. maintained status-quo for businesses and consumers, which means that the EU still recognized U.K. Notified Bodies, and manufacturers could sell CE marked products into the U.K. market until Dec. 31, 2020.

On Dec. 24, 2020, the United Kingdom and the European Union have agreed to the Trade and Cooperation Agreement. The U.K.-EU trade Agreement contains new rules for living, working and trading together and entered into force on Dec. 31, 2020.

The full Agreement is 1,246 pages and is available here. 

The deal secures tariff-free access between EU and U.K. markets but does not change the compliance process, so the UK Conformity Assessed (UKCA) marking and conformity to the U.K. legislations remain mandatory for placing goods on the market in Great Britain. The new rules have been in application from 11 p.m. Dec. 31, 2020.

Recognizing the impact of the new UKCA marking on businesses, on Nov. 14, 2022 the Government has announced the extension of the deadline to Dec. 31, 2024 to apply UKCA marks for certain products to demonstrate compliance with product safety regulations, superseding the previously announced deadline of 1 January 2023. The CE marked goods in scope of this document that meet EU requirements can continue to be placed on the GB market until 1 January 2025 where EU and U.K. requirements remain the same. This includes goods which have been assessed by an EU recognized notified body.

The UKCA mark must be used for placing goods on the GB market from 1 January 2025.

The UKCA marking

The new UKCA marking declares that the product conforms to all applicable U.K. legislative requirements and that appropriate conformity assessment procedures have been successfully completed. Beginning Jan. 1, 2021, the UKCA marking replaced the CE marking as a requirement for goods entering the Great Britain market, including England, Scotland and Wales. The UKCA marking is required on products subject to the U.K. equivalent legislation to all of the EU directives/regulations that required CE marking, including the Radio Equipment, EMC and Low Voltage directives. Additionally, all U.K.-based EU Notified Bodies will also lose their status on Jan. 1, 2021. All EU Certificates issued by those bodies must be transferred to an EU 27 Notified Body by Dec. 31, 2020 to ensure continued validity. 

How UL Solutions can help you achieve business continuity in the U.K and EU

UL Solutions is prepared to support changes to product marking schemes for the U.K. and mainland Europe immediately.

We have established the following accredited Notified and Approved Bodies in the EU and U.K., allowing uninterrupted support for customers needing the UKCA mark and other global market access services.

UL EU Notified Body Services Capability

• Construction Products Regulation
• Marine Equipment Directive
• Personal Protective Equipment Regulation
• Machinery Directive
• EMC Directive
• Radio Equipment Directive
• ATEX Directive
• Measurement Instrument Directive
• Gas Appliance Regulation
• Pressure Equipment Directive
• Hot-Water Boilers Directive
• Toys Directive

UL U.K. Approved Body

• Construction Products Regulation*
• Marine Equipment Regulation
• Personal Protective Equipment Regulation
• Machinery Regulation
• Medical Devices Regulations 2002**
• EMC Regulations
• Radio Equipment Regulation
• ATEX Regulation
• Gas Appliance Regulation
• Pressure Equipment (Safety) Regulation 2016

* Approved Body for System 1+ and System 3 will be received in Q3/Q4 2021 for wire and cable (Product Area 31 – Power, control and communication cables).

** Limited scope currently, refer to MHRA website for details.

Our long-standing presence in and knowledge of the U.K. and EU markets helps you meet regulatory compliance as requirements change. Contact us for more information on how UL Solutions can ensure access of your products and services to Great Britain, Northern Ireland and the EU.