United Kingdom
United Kingdom compliance review and market access
The UK position is widely misreported. CE marking is accepted in Great Britain indefinitely for the main product regulations — UKCA remains valid but is not the only route. What an EU file does not cover is the GB economic operator, the PSTI security requirements, the plug, and the producer registrations.
What applies to your product
The starting point is never the mark — it is which regimes your product falls under, and what evidence each one accepts.
| Area | What applies | Practical effect |
|---|---|---|
| Conformity marking | UKCA or CE. The Product Safety and Metrology etc. (Amendment) Regulations 2024, in force since 1 October 2024, extended recognition of EU requirements — including CE — across 21 product regulations with no end date. | Manufacturers may choose either route for Great Britain. Sector regimes such as medical devices, construction products, marine, rail and transportable pressure equipment are carved out and must be checked separately. |
| Electrical safety | Electrical Equipment (Safety) Regulations 2016. | Designated standards published by the Office for Product Safety and Standards confer presumption of conformity for the UKCA route. These are usually the same BS EN texts as the EU harmonised standards, but the lists are maintained separately and can lag. |
| EMC and radio | Electromagnetic Compatibility Regulations 2016 and Radio Equipment Regulations 2017, with spectrum use governed by Ofcom's UK Interface Requirements. | UK interface requirements largely mirror European allocations but are not automatically identical — band, power and duty-cycle limits should be verified. |
| Product security | Product Security and Telecommunications Infrastructure Act 2022 and the Security Requirements for Relevant Connectable Products Regulations 2023, in force since 29 April 2024. | Applies to consumer connectable products regardless of protocol, and applies to CE-marked goods too. There is no UK equivalent of the EU's RED cybersecurity delegated regulation, and EU compliance does not discharge PSTI. |
| Plugs | Plugs and Sockets etc. (Safety) Regulations 1994. | Mains-powered domestic goods must be supplied with an approved BS 1363 fused plug or an approved conversion plug. A travel adaptor is not compliance. |
| Producer obligations | WEEE and battery producer registration, packaging extended producer responsibility, UK REACH and energy labelling. | Registration obligations that are separate from marking, and are frequently overlooked because they do not appear on the product. |
An EU representative does not cover Great Britain
Under each GB regulation, a non-UK manufacturer must have a GB-based economic operator — either an importer or an appointed authorised representative — whose name, registered trade name or trade mark, and contactable UK postal address appear on the product, or on the packaging or accompanying documents where the product is too small.
That party must verify that the correct conformity assessment was carried out and the technical documentation drawn up, hold a copy of the declaration of conformity and keep it available to market surveillance for ten years, ensure instructions and safety information are in English, and act on non-conformity by withdrawing or recalling and informing the authorities.
An EU authorised representative does not satisfy this. Enforcement sits with the Office for Product Safety and Standards and local Trading Standards.
What we provide
- Regulatory scoping and classification against the applicable GB regulations
- Gap analysis of an existing CE file against Great Britain requirements — what transfers and what does not
- Standards version checking against the current OPSS designated standards notices rather than the EU Official Journal lists
- Technical file compilation and UK Declaration of Conformity drafting where the UKCA route is used
- PSTI gap assessment against ETSI EN 303 645 and drafting of the statement of compliance
- Verification of spectrum use against the current Ofcom UK Interface Requirements
- GB authorised representative arrangements, and importer labelling review
- BS 1363 plug and cord set review
- WEEE, battery and packaging extended producer responsibility registrations
- Coordination of UK approved bodies where third-party assessment is required
Where these programmes usually stall
- Assuming CE alone is enough with no GB economic operator named on the product
- Treating an EU authorised representative as valid for Great Britain
- Missing PSTI entirely — it applies to CE-marked goods, and EU cybersecurity compliance does not discharge it
- Using EU harmonised standard lists instead of GB designated standards
- Shipping mains-powered domestic goods without an approved BS 1363 plug
- Confusing the 31 December 2027 labelling and importer-address easement with an end to CE acceptance — they are unrelated
- Applying UKCA to Northern Ireland-bound stock, where it has no validity
- Producer registrations for WEEE, batteries and packaging left unaddressed
Common questions
United Kingdom compliance — frequently asked questions
Is UKCA still required, or has CE been accepted permanently?
Both routes are available. Since 1 October 2024, the Product Safety and Metrology etc. (Amendment) Regulations 2024 have extended recognition of EU requirements, including CE marking, across 21 product regulations with no stated end date. UKCA has not been abolished — it remains a valid alternative. Because recognition rests on secondary legislation rather than a treaty, it could in principle be changed, and the government has indicated a minimum transition period if it were. Several sectors are carved out and must be checked individually.
What is the 31 December 2027 date I keep seeing?
It is an easement about where information may be placed, not about CE acceptance. Two allowances expire then: applying the UKCA marking to a label or accompanying document instead of the product itself, and giving importer details somewhere other than on the product for goods imported from the EEA. Conflating that with the end of CE recognition is the most common error in secondary commentary.
Does our EU cybersecurity work cover PSTI?
No. They are separate regimes with different scopes. PSTI requires no universal default passwords, a published vulnerability disclosure policy with a point of contact, and a published minimum security update support period, together with a statement of compliance supplied with the product. It applies to consumer connectable products regardless of wireless protocol, which makes it broader than the Radio Equipment Directive. Penalties are substantial.
What actually has to change if we already sell into the EU?
Usually four things: a GB-established economic operator named on the product with a UK address; a PSTI statement of compliance if the product is consumer connectable; an approved BS 1363 plug for mains-powered domestic goods; and UK producer registrations for WEEE, batteries and packaging. Your test reports, risk assessment and instructions generally carry across. If you use the UKCA route rather than CE, you also need a separate UK Declaration of Conformity citing the GB regulations and designated standards.
Want to learn more?
Speak to a Chartered Professional Engineer about your product, your target market and the approval pathway that actually applies to it.
Talk to an engineer
Planning a United Kingdom launch?
Send us the product and whatever test evidence you already hold. We will set out what transfers, what has to be added, and what the pathway costs — in writing.