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[BREXIT UPDATE: 17-Apr-2024]

The UK Product Safety and Metrology Regulations have been formally amended (Amendment 2024).  The update modifies UK law to formally repeal the withdrawal date for permitting CE marked products on the UK market, as announced last August.  CE marking may be used indefinitely for the placement of products on the UK market.

Additionally, the updated Statutory Instrument allow use of the UKCA marking on products that have undergone successful evaluation to European Regulations and Directives.  Previously, to use the UKCA marking, products had to be evaluated to applicable UK Regulations.

At some point in the future a UK Regulation may diverge significantly form an EU counterpart such that to use the UKCA marking, it will mandatory to apply the UK Regulation (for example machinery safety), and yet other Regulations (for example EMC) may remain the same as EU Directives.  In such a circumstance the UK legislation will allow a mix of UK and EU conformity to be used for the application of a UKCA marking.  

Explanatory guidance can be found here.

[BREXIT UPDATE: 01-Aug-2023]
The UK requirements for implementing the UKCA marking detailed in Supply of Machinery (Safety) Regulations 2008: Great Britain  have been updated.  On August 1, 2023 the UK Government announced self-certifying machine builders may continue to use the CE marking on their machines placed on the UK market indefinitely.

This replaces the deadline for UKCA marking that was previously extended to December 31, 2024.

Manufacturers may now choose to indicated compliance of their products using either the UKCA marking or the CE marking when placing those products on the UK market (Northern Ireland requires the CE marking ONLY for most machines – see note below).

Note: The United Kingdom consists of England, Scotland, Wales, and Northern Ireland. Due to the unique historic relationship between Northern Ireland (part of the UK) and the Republic of Ireland (an independent country which remains a member of the EU and has the only land border between the UK and the EU), there will a separate set of requirements for goods placed on the market in Northern Ireland. The CE mark will continue to be required on machinery shipped to Northern Ireland unless the details of the Protocol on Ireland/Northern Ireland as modified by the Windsor Agreement are modified in the interim.

[UPDATE: 17-Nov-2022]

The UK requirements for implementing the UKCA marking detailed in Supply of Machinery (Safety) Regulations 2008: Great Britain have been updated, and now allow self-certifying machine builders to continue to use the CE marking on their machines placed on the UK market through to December 31, 2024. 

This is a TWO year extension to the previous extended date of December 31, 2022.

Note: The United Kingdom consists of England, Scotland, Wales, and Northern Ireland.  Due to the unique historic relationship between Northern Ireland (part of the UK) and the Republic of Ireland (an independent country which remains a member of the EU) as well as the fact that this is the only land border the UK has with the EU, there will a separate set of requirements for goods sold into Northern Ireland.  The CE mark will continue to be required on machinery shipped to Northern Ireland now and after December 31 2024 unless the details of the Ireland/Northern Ireland Protocol are modified in the interim.

[UPDATE: 24-Aug-2021]
Today the UK Government announced manufacturers can continue to use the CE marking for goods placed on the market in Great Britain until 1 January 2023. The UKCA marking must be used for placing goods on the market in Great Britain from 1 January 2023. The UKCA marking can be used now and they are encouraging businesses to start using the UKCA marking as soon as possible.

[UPDATE: 24-Dec-2020]
A bilateral trade deal has been agreed between the EU and the United Kingdom.  Details are now being published, and implications for machine builders shipping equipment to the United Kingdom will be posted here as soon as they are available.  Machine builders shipping to the EU will not be affected by this trade deal.

On January 31  2020 at 18:00 EST the United Kingdom of Great Britain and Northern Ireland (UK) formally withdrew from the European Union (EU).

However, provisions of the the European Union (Withdrawal Agreement) Bill are such that the UK remain bound to the ,now, 27 member bloc for the remainder of 2020, which will be considered a transition period where all trade will continue as normal.

During this time, business will be conducted as before, and CE conformity requirements will remain unchanged.  This period will then be used for negotiations between the UK and the EU for a complete withdrawal and an end to transition period on 1st January 2021.

The Bill prohibits any extension to the transition period and so, January 1 2021, the UK separate from the European Union in one of two ways:

• Separating without a trade agreement
• Separating with a trade agreement

Separating with a trade deal is generally considered by industry as the best option that will allow easier movement of goods and services between the UK and the remaining 27 members of the EU.

As of December 22, 2020 trade deal negotiations are still ongoing.

So what does this mean for Machine Builders outside the EU/UK?

Business as normal will continue throughout 2020.

Many businesses currently use European harmonised standards to provide a presumption of conformity with the relevant EU laws. Immediately after the end of the transition period, the essential legal requirements that businesses must meet will be the same as they are now. All harmonised standards that give a presumption of conformity to EU law at the end of the transition period will become ‘designated standards’ by the references being published on GOV.UK. Businesses will be able to use designated standards to provide presumption of conformity with GB law.

Harmonised standards will remain the relevant standards for placing goods on the Northern Ireland market where EU rules will continue to apply.

Machine Builders may continue to apply European requirements necessary to CE mark their machines, and then place them on the market in the European Union and the United Kingdom.  If your machine is expected to enter the United Kingdom after December 31, 2020 then we will prepare for both possible requirements.  The only burden on you as the machine builder will be the possible requirement to apply the UKCA marking rather than (or in addition to) the CE marking on your machine.

UPDATE: The UK requirements for implementing the UKCA marking detailed in Supply of Machinery (Safety) Regulations 2008 (Guidance) have been updated, and now allow self-certifying machine builders to continue to use the CE marking on their machines through to December 31, 2022.

Note: The United Kingdom consists of England, Scotland, Wales, and Northern Ireland.  Due to the unique historic relationship between Northern Ireland (part of the UK) and the Republic of Ireland (an independent country which remains a member of the EU) as well as the fact that this is the only land border the UK has with the EU, there will a separate set of requirements for goods sold into Northern Ireland.  The CE mark will continue to be accepted on machinery shipped to Northern Ireland after December 31 2020