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CE vs UKCA: what UK manufacturers need for the EU

UKCA is the UK's own conformity marking. The EU does not recognise it. UK manufacturers selling in the EU need CE marking under EU rules and an economic operator established in the EU.

UKCA not valid in the EU UK Approved Body ≠ Notified Body Northern Ireland follows EU rules EU operator required

Which mark where

MarketMarking
EU and EEACE marking only
Northern IrelandCE marking under EU rules (Windsor Framework); UKNI added where a UK body carried out mandatory third-party assessment
Great BritainUKCA, or CE marking, which the UK government continues to recognise for most product areas. Check GOV.UK for your sector.

What UK manufacturers need for the EU

Dual marking

A product can carry both UKCA and CE if it meets both sets of requirements. Many manufacturers now use CE alone for both Great Britain and the EU, where the UK recognition allows it.

Frequently asked questions

Is UKCA accepted in the EU?

No. Products placed on the EU market need CE marking under EU legislation.

Can a UK company be the EU authorised representative?

No. The authorised representative and the other economic operators required under Article 4 of Regulation (EU) 2019/1020 must be established in the EU.

Is my certificate from a UK Approved Body valid in the EU?

No. Where EU legislation requires a Notified Body, the certificate must come from a body notified under EU legislation and listed in NANDO.

Related guides

Note: This guide provides general information about EU product legislation, not legal advice. Check the current legal texts on EUR-Lex for your product. Last reviewed 5 October 2026.

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