UKCA vs CE Marking Decision Tool
Post-Brexit routing for sellers shipping to GB, EU27 and Northern Ireland. Citations from gov.uk + EUR-Lex.
UKCA vs CE, at a glance
If you sell to Great Britain, you do not have to switch to UKCA for most products: CE marking is accepted in GB indefinitely. Northern Ireland follows the Windsor Framework (CE or UKNI), and the EU27 always requires CE.
Verified 2026-06-08: GB accepts the CE mark indefinitely for 21 product regulations — the 31 December 2024 deadline was removed by SI 2024/696 (in force 1 October 2024), extending the first tranche under SI 2023/1382. Seven sectors are excluded and stay UKCA-mandatory in GB: medical devices, construction products, marine equipment, rail products, cableways, transportable pressure equipment and unmanned aircraft systems.
| Marking | Where it applies |
|---|---|
| CE | Accepted in GB indefinitely (21 regs); mandatory in EU27 and (with Windsor Framework rules) NI |
| UKCA | Mandatory in GB only for the 7 carve-out sectors; never required for EU27 or NI |
| UKNI | NI route when a UK Approved Body does the assessment — but UKNI goods cannot be placed on the EU27 market |
The decision is not just price. UKNI-marked goods are blocked from the EU27 market, and retail consumer goods moving GB→NI may also need a NIRMS 'Not for EU' label (Phase 3, effective 1 July 2025). The wizard below applies all of these rules to your specific product and destination.
Sources: gov.uk — Using the UKCA marking · gov.uk — Product regulations by sector (UKCA/CE approaches) · SI 2024/696 — Product Safety and Metrology etc. (Amendment) Regulations 2024
Product category
Step 1 of 7Carve-out sectors — UKCA still mandatory in GB
Indefinite CE recognition in GB does NOT apply to these seven sectors. For each, the governing GB Statutory Instrument and the corresponding EU instrument are shown. All other listed sectors accept CE in GB indefinitely.
| Sector | GB instrument | EU instrument |
|---|---|---|
| Medical devices | Medical Devices Regulations 2002 (as amended); MHRA future regime phasing in (SI 2002/618) | Medical Devices Regulation (MDR) (Regulation (EU) 2017/745) |
| Construction products | Construction Products Regulations 2013 (SI 2013/1387) | Construction Products Regulation (Regulation (EU) No 305/2011) |
| Marine equipment | Merchant Shipping (Marine Equipment) Regulations 2016 (SI 2016/1025) | Marine Equipment Directive (Directive 2014/90/EU) |
| Rail interoperability products | Railways (Interoperability) Regulations 2011 (SI 2011/3066) | Railway Interoperability Directive (Directive (EU) 2016/797) |
| Cableway installations | Cableway Installations Regulations 2018 (SI 2018/816) | Cableway Installations Regulation (Regulation (EU) 2016/424) |
| Transportable pressure equipment | Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (SI 2009/1348) | Transportable Pressure Equipment Directive (Directive 2010/35/EU) |
| Unmanned aircraft systems | Air Navigation Order 2016 (UAS provisions) (SI 2016/765) | UAS Implementing Regulation (Regulation (EU) 2019/945) |
Medical devices are an exception within the exception: CE-marked medical devices remain acceptable on the GB market until 30 June 2028 (MDD/AIMDD) or 30 June 2030 (MDR/IVDR) under MHRA transitional arrangements.
The wizard covers 21 sectors in total. Sectors not listed above (electrical/LVD, EMC, radio, machinery, toys, PPE, pressure equipment, gas appliances, lifts, ATEX, measuring instruments, outdoor noise, ecodesign) accept CE in GB indefinitely.
How this tool decides
Each verdict is computed from a versioned rules dataset that maps your product category, destination market and manufacturer location onto the governing UK and EU conformity-assessment regime. Great Britain accepts CE marking indefinitely for 21 product regulations (the deadline was removed by the Product Safety and Metrology etc. (Amendment) Regulations 2024, SI 2024/696), the EU27 follows CE, and Northern Ireland follows the Windsor Framework — CE or UKNI depending on the goods and the NIRMS 'Not for EU' labelling rules. Seven sectors are carved out of indefinite CE recognition and remain UKCA-mandatory in GB. Outputs are indicative, not legal advice: confirm against the applicable Statutory Instruments and gov.uk guidance. The Product Regulation and Metrology Act 2025 grants the Secretary of State powers to amend marking rules by SI, so dates and recognition windows can change.
Frequently asked questions
Do I still have to switch to UKCA for the UK market in 2026?
For most products, no. CE marking is accepted in Great Britain indefinitely for 21 product regulations. The 31 December 2024 deadline was removed by the Product Safety and Metrology etc. (Amendment) Regulations 2024 (SI 2024/696, in force 1 October 2024). UKCA remains mandatory in GB only for seven carve-out sectors. Verified 2026-06-08 against gov.uk.
Which products are NOT covered by indefinite CE recognition in GB?
Seven sectors are excluded and stay UKCA-mandatory in GB: medical devices, construction products, marine equipment, rail products, cableways, transportable pressure equipment and unmanned aircraft systems. For everything else (electrical, machinery, toys, PPE, radio, etc.) CE is accepted in GB indefinitely.
What is the difference between UKCA, CE and UKNI?
CE is the EU conformity mark, also accepted in GB indefinitely for most sectors. UKCA is the Great Britain mark, mandatory only for the seven carve-out sectors. UKNI is a supplementary Northern Ireland mark used when a UK Approved Body carries out the conformity assessment for goods placed on the NI market under the Windsor Framework — but UKNI-marked goods cannot be sold in the EU27.
Do CE-marked medical devices still need UKCA in Great Britain?
Medical devices are excluded from indefinite CE recognition, but CE-marked devices are not blocked overnight. Under MHRA transitional arrangements, CE-marked devices remain acceptable on the GB market until 30 June 2028 (devices under the old MDD/AIMDD) or 30 June 2030 (devices under MDR/IVDR). A UK consultation on indefinite CE recognition for medical devices opened in February 2026. Check current MHRA guidance before deciding to UKCA-mark.
When does the NIRMS 'Not for EU' label apply?
Under Phase 3 of the Northern Ireland Retail Movement Scheme, effective 1 July 2025, individual retail consumer goods moving from Great Britain to Northern Ireland must be labelled 'Not for EU'. The wizard flags this when your destination includes NI, the goods are retail consumer goods, and the manufacturer is in GB or NI.
Can I sell UKNI-marked goods in the EU?
No. UKNI is a Northern-Ireland-only supplementary mark. Goods carrying UKNI cannot be placed on the EU27 market — for EU placement you need the CE mark via an EU Notified Body. If you sell to both NI and the EU27, the wizard recommends a CE-only route to preserve EU market access.
Which Statutory Instrument actually extended CE acceptance in GB?
The Product Safety and Metrology etc. (Amendment) Regulations 2024 (SI 2024/696) removed the 31 December 2024 cut-off and made CE acceptance indefinite for the relevant regulations; it built on the first-tranche SI 2023/1382 (1 August 2023). The Product Regulation and Metrology Act 2025 (Royal Assent 21 July 2025) gives ministers power to amend these rules by future SI.
How current is the rules data, and what happens when it goes stale?
The dataset was last verified on 2026-06-08 against gov.uk and EUR-Lex. Each sector row carries the governing GB SI and EU instrument with source links. If the data passes its 120-day freshness window the engine refuses to render a verdict and shows a stale-data banner instead — so you never get a silently out-of-date answer.