Starting from January 1, 2021, the UK is no longer a part of the EU. The meaning of that is that the UK introduced new national rules for market access. However, the UK essential requirements and the conformity assessment procedures as well as standards in most cases are the same as for the EU conformity process. The key differences within the conformity procedure is in the national UK conformity assessed marking (UKCA).
The new UKCA marking became effective from January 1, 2021. However, the UK government gave a grace period to allow manufacturers of electrical products to prepare for the new requirements. Within this period, it is possible to put the product to the UK market using the CE marking in most cases but the period will end on January 1, 2022.
UKCA marking is valid only in England, Scotland, and Wales. The marking cannot be used on the Northern Ireland market at all, instead the CE mark or UK (NI) mark is used there. It is possible to use the UKCA mark when the product was assessed by a UK conformity assessment body against the UK legislation. If a UK conformity assessment body carries out the conformity assessment procedure aimed to put products to the Northern Ireland market, the body must use the UK (NI) mark instead of the UKCA mark.
It is allowed to have both CE and UKCA marks on the product as one of them shows that the product meets the EU requirements and the other proves the compliance of UK requirements. Until January 1, 2023, for most goods it is possible to put the UKCA marking either on a label affixed to the product or on an accompanying document. From January 1, 2023, the UKCA marking must, in most cases, be affixed directly to the product.
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